Hi Donna
In my opinion you’re correct.
While the MRCA impairment rating of 80 points is the highest level of impairment and is treated as the MRCA equivalent of total and permanent incapacity for compensation purposes, this impairment score does not, on its own, provide eligibility for a pensioner rebate.
Eligibility arises only when they hold a Gold Card (TPI/EDA).
Hope this helps
Robert