WWDA Submission to the ‘Review of the Commonwealth Disability Strategy’ – Stage Two


The Commonwealth Disability Strategy (CDS) was introduced in 1994 to provide Australian Government Departments and agencies with a planning framework to ensure access to all federal programs, services and functions for people with a disability. The original strategy applied to the activities of all departments, agencies and authorities for ten years (1994-2004) and aimed to ‘enhance access opportunities for people with a disability to the programs, services and infrastructure of society’. The CDS was reviewed in 1995, 1997, and 1999. In 2004, the Australian Department of Family and Community Services (FaCS) contracted the Social Policy Research Centre to design an evaluation of the Commonwealth Disability Strategy (CDS). In 2005, FaCS contracted a Consultancy firm, Erebus International, to undertake the second stage of the Review – the evaluation of the Commonwealth Disability Strategy. This paper is WWDA’s Submission to the Evaluation of the Commonwealth Disability Strategy. WWDA’s response broadly follows the framework set out in the Erebus International guidelines for Interview with relevant Non-Agency Stakeholders (Peak Organisations) in the review process. Copyright WWDA September 2005.

In 2006, Erebus International released the final report from the ‘Review of the Commonwealth Disability Strategy’ – Stage Two: Erebus International Final Report of the Evaluation of the Commonwealth Disability Strategy (2006)


‘Maximising the employment of people with disabilities is a rational economic necessity of making the fullest use of the skills and abilities available in our and society’ (Ozkowski 2005).


When the Commonwealth Disability Strategy (CDS) was brought into being in 1994 in order to underpin the Disability Discrimination Act of 1992, people with disabilities were optimistic that it would be instrumental in increasing the social capital of a significantly disenfranchised sector of the population. The CDS had, and still has, the potential to optimise the equitable participation of people with disabilities in the workplace and in the wider community. As the above quote from the Acting Human Rights Commissioner indicates, our failure to utlilise the skills and abilities of people with disabilities means that we are diminished as a society.

Women With Disabilities Australia (WWDA) is pleased to give the following feedback to the Department of Family and Community Services in its current evaluation of the (CDS). This response broadly follows the framework set out in the Erebus International guidelines for Interview with relevant Non-Agency Stakeholders (Peak Organisations) in the review process.

1. In what ways have the lives of people with disabilities been enhanced by the Commonwealth Disability Strategy since 1999?

Without targetted research being undertaken, WWDA is unable to give an accurate response to this question. However, there are a number of indicators which could be used to gauge the degree to which the lives of women with disabilities may have been enhanced by the CDS over the past 5 years. WWDA believes that the most important indicator is levels of employment – given that the CDS’s objective is to enhance employment outcomes for people with disabilities. Participation in the labour market should result in tangible economic benefits [1]. Other benefits include the enhancement of self esteem; better quality of life; an increase in life choices and an ability to participate more fully in community life.

Unfortunately, employment data indicates that the situation for women with disabilities has not improved markedly over the past five years. In 2003, the labour force participation rate for women with disabilities was 46.9%, compared to 59.3% for men with disabilities. This is a greater than 12 percentage point difference. The unemployment rate for women with disabilities is about 8.6% and has improved little over the past 5 years, whereas that for men with disabilities has improved radically from 13.5% to 8.8%. The unemployment rate for the able-bodied population has improved from approximately 8% to approximately 5% over the same period (HREOC 2005; ABS 2004).

Moreover men with disabilities are far more likely to be in full time employment (21% compared to 9%), whilst the converse is true for part time employment (6% compared to 11%). Women with disabilities, whether employed part-time or full-time are likely to be in lower paid jobs (WWDA 2004a). In 2003 open funded employment services assisted more than 35,000 people with disabilities. Only 35% of those assisted were women (WWDA 2005).

The poor employment outcomes for women with disabilities are worse than appears at face value, because women with disabilities are now achieving education levels which are equal to those of men with disabilities. More than 71% of women with disabilities are now completing Year 10 or higher (compared to 68% of men with disabilities and 87% of able-bodied people). In tertiary education, 61% of the students with disabilities completing degrees in 2002 were women (WWDA 2004b).

Moreover, we know that the percentage of people with disabilities employed in Commonwealth Departments has decreased over the last decade. For example, we know that currently, people with a disability represent 3.6% of employees within the Australian Public Service (APS), down from 5.5% a decade ago. This decline occurs across all job classifications. WWDA acknowledges that the most recent percentage figure may not accurately represent the situation. Anecdotal evidence from women with disabilities indicates that in some areas of the APS there are relatively high levels of employment of people who obviously have disabilities, but do not categorise themselves as such. This could be an indicator that increased accommodation of diversity in the workplace, and increased job flexibility (whereby some work can be done from home, for example) make more favourable conditions for employees with disabilities.

This aspect of employment of people with disabilities warrants further investigation, because research conducted by the Australian Public Service Commission (APSC) shows that APS employees who identified as having a disability are significantly more dissatisfied with their job than people without a disability. Only 49% of people with a disability have a job satisfaction index of over five compared to 77% of people without a disability (APSC 2004).

Further research is needed to identify what factors contribute to the high levels of dissatisfaction. Discrimination continues to be a major barrier for many people with disabilities in gaining employment. They also face discrimination in the workplace. Their work can be undervalued; work allocated can be below their level of ability; they can be overlooked for promotions (especially those working in part time positions), and face being ostracised by colleagues who lack understanding of their disabilities. In recent years the majority of complaints under the DDA brought to HREOC are employment related (HREOC 2002), and the Productivity Commission’s Review of the DDA (Productivity Commission 2003) found that: ‘the number of complaints under the Disability Discrimination Act (1992) and participants’ views indicate that disability discrimination in employment remains a significant issue. Overall, the Act appears to have been least effective in reducing discrimination in employment’.

It would seem that the CDS has had minimal positive impact on employment outcomes for women with disabilities either in Commonwealth Government, or any other level of government, or in business or community organisations. In other indicators of social and personal wellbeing, the lives of women with disabilities have only been marginally enhanced by the CDS (WWDA 2004c).

RECOMMENDATION 1: Strengthen the CDS to introduce targetted programmes to encourage the employment of women with disabilities.


2. Can you provide specific details about the impact of the Strategy in improving:

 

(i) equity for people with a disability (opportunity to contribute to social, political, economic, and cultural life)

 

? Once again, without targetted research it is not possible for WWDA to give specific details about the impact of the CDS in improving equity for women with disabilities, in enhancing their ability to contribute to social, political, economic and cultural life. We do know that women with disabilities continue to be one of the most marginalised groups in society, and that their levels of income, from whatever source, are significantly less than those of their able-bodied counterparts, and significantly less that those of their disabled male counterparts. Forty-seven percent of women with disabilities are on some sort of pension, compared to 39% of men with disabilities, and just 20% of able bodied women. They are underrepresented in receiving business income compared to both these groups, and underrepresented in waged and salaried positions with only 32% receiving income in this way compared to 56% of their able bodied sisters and 38% of men with disabilities (ABS 2004). These statistics document the current situation for women with disabilities, although they may not be directly related to the CDS.

We know that living in poverty deprives anyone of the opportunity to participate in society and to contribute to social, political, economic and cultural life. The above statistics show that employment and income levels for women with disabilities have not improved over the last 5 years.

RECOMMENDATION 2: Strengthen the CDS so that strategies and incentives which address the employment inequities which exist for all people with disabilities can be supported. Targetted supports are needed to address the exacerbated inequities which exist for women with disabilities. Increased workforce participation rates at higher levels of income will enable greater whole-of-life equity for people with disabilities.

(ii)inclusion of people with a disability (availability of all mainstream Commonwealth programs, services and facilities)

Once again without targetted research it is not possible for WWDA to make specific comment on the availability of mainstream Commonwealth programs, services and facilities to women with disabilities. The fact that levels of employment of people with disabilities appear to be decreasing in real terms, indicates that the CDS is not improving the inclusion of people with disability in mainstream Commonwealth programs, services and facilities.

While disabled people constitute one-fifth of the population (3.9 million people), they are neither visible in the community, nor likely to hold high office in the public or private sectors. Discrimination and lack of support services mean that they are excluded from participation in many aspects of society. This indicates that the CDS needs to be strengthened and that more positive discrimination is needed to increase the level of inclusion in employment and in the wider community.

What is also of great concern is that there has been a decrease in the number of supported programs, services and facilities available for people with disabilities.

RECOMMENDATIONS 3: Increase levels of support for people with disabilities so that they can participate in mainstream programs, services and facilities.

(iii) participation for people with a disability (participation on an equal basis in decision making processes that affect their lives)?

Once again WWDA cannot comment on the degree to which the CDS is affecting the ability of women with disabilities to participate on an equal basis in decision making processes which affect their lives. WWDA has no quantitative data on the number of boards, advisory groups and reference committees are operating in Commonwealth Government Departments and Agencies, or information on the degree to which formation of these groups has resulted from CDS initiatives. It has no qualitative information on the effectiveness of these groups. The number of such groups, and the numbers of women with disabilities representative on them, would be a useful quantitative indicator of the effectiveness of the CDS [2].

WWDA receives frequent invitations to be represented on advisory groups, and is often unable to meet these requests because it has no means of building capacity to train and mentor its constituents to undertake representative and advocacy work. This is a necessary first step to enabling people with disabilities to participate. Participation ‘on an equal basis’ is only possible when support of the disempowered can be sustained in the long term. In general, WWDA knows that women with disabilities continue to be disenfranchised in many aspects of their lives.

In order for people with disabilities to participate ‘on an equal basis’, they must also be supported to have the capacity to be included on mainstream boards and consumer advisory groups.

RECOMMENDATION 4: Support disability organisations to build capacity so that they can increase levels of systemic advocacy and participate more fully in decision making processes which affect their lives.

(iv) access for people with a disability (access to information in appropriate formats about the programs and services they use)?

There is some evidence of greater awareness of the need to make information available in accessible formats to people with disabilities. An increasing number of the websites of Commonwealth Government departments and agencies conform to World Wide Web Consortium (W3C) standards. However, not many websites use the highest level of accessibility so that many are still difficult for people using screen reader programs (such as JAWS) to access. In addition many links and documents are only available in ‘PDF’ format, which is inaccessible to all but the latest versions of screen reader programs.

Printed information is less consistently available in formats and styles which are accessible to people with low vision, but advocacy through disability representation.

It is not possible to say whether these improvements have come about as a result of the CDS. There is ongoing urgent need for information accessibility requirements to be brought to the attention of those seeking to disseminate information.

RECOMMENDATION 5: Maintain/increase programs which raise awareness of the information access needs of people with disabilities.

(v) accountability for agency responsibilities in relation to people with a disability (for the provision of access to programs, facilities and services, including complaints handling procedures)?

Once again without targetted research having been undertaken, WWDA cannot comment on the impact of the CDS in this area.

RECOMMENDATION 6: Set up feedback mechanisms so that information about agency success in the provision of access to programmes, facilities and services, including complaints incidence and resolution rates are publicly available.


3. Are there other major achievements that have been made by Commonwealth government agencies since 1999 that provide outcomes for people with disabilities?

Without targetted research, WWDA is not able to give any information about achievements which have made by the CDS. There are some improvements in the consultative processes by which people with disabilities are involved on boards, advisory committees, and reference groups.


4. What barriers remain to be overcome?

When WWDA looks at the situation for women with disabilities and their low status in society as reflected in their over representation in the lowest socio economic strata, it is difficult to see any positive impact of the CDS on their lives. However, it would seem that the CDS has meant increased awareness of the situation for women with disabilities. It is possible that the CDS has prevented a worsening of the situation, and that it will take time for the strategies currently in place to have a measurable positive impact.

(i) Barriers to employment

In society women with disabilities face double discrimination because of their gender and because of their disabilities. This double discrimination has the affect of marginalising women in all aspects of their lives. In the area of employment, at face value the CDS has the capacity to reduce the barriers which affect access to work for women with disabilities. Disability Action Plans can name the barriers, and train the staff without there being any diminution in the effect of those barriers. The barriers to employment are documented in detail in the WWDA submission to the HREOC National Inquiry into Employment and Disability (WWDA 2004c). In summary these barriers include:

a. Lack of understanding of the complexity and nature of disability
The workplace is not structured to be able to offer employment to people whose disabilities may be episodic or fluctuating in nature. In addition, little account is taken of the additional time and energy which a person with disabilities must put in, just to be able to function at the level of their able bodied counterparts. For example, the lead time for a paraplegic to get ready for work may be 1.5 – 2 hours, compared to 30 minutes for an able bodied worker. Extra energy input is required for every action undertaken during the working day.

b. Negative social attitudes and discrimination including the employers’ and co-workers’ attitudes
Staff training and employer leadership are not sufficient to overcome entrenched social attitudes to people with disabilities. An employee with disabilities can feel isolated within a workplace by virtue of being the only one coping with the additional energy inputs outline above. This isolation can be exacerbated by passive isolation and by both overt and covert harassment. Women with disabilities are often given marginal jobs which are far below their capacity, and are denied opportunities to undertake higher duties or in-house training. These attitudes affect the retention rates of people with disabilities. Early resignation may result from the isolation experienced. In addition, employees with disabilities are at greater risk of retrenchment in situations of workplace restructure.

c. Poor job design and inflexible work arrangement
The need for flexible work conditions has been outlined above. In addition to this our current system rewards people who work full-time and penalises people who work part-time. It also penalises women with disabilities by removing income supports for which she may have been eligible whilst unemployed. The supports are removed well before her level of income is able to compensate for their lack. Thus a woman with disabilities can be monetarily worse off by being employed. People with disabilities face greater barriers to employment progression and promotion. This may result from being in part time employment, and/or lack of recognition of their abilities.

d. Lack of attendant care
The lack of this support service may preclude a woman with disabilities from seeking employment. Attendant care may be needed at home prior to and after work. It may also be needed during the course of the day. Attendant care is virtually non-existent in the workplace.

e. Inadequate transport
For many women with disabilities, taxis or private cars are the only means of getting to work. Even with subsidy, the cost of taxi transport may be greater than the income earned. In a city, taxi transport can be unreliable. In rural and regional areas, taxi transport may not even be available.

f. Inaccessible and unresponsive employment services
Women with disabilities are underrepresented in their access to both Job Network and (disability) Open Employment Services. The employment outcomes are correspondingly reduced. In addition, employment services tend to place women with disabilities in stereotypical roles, and to underestimate their employment capabilities.

g. Inaccessible built environment
The inaccessibility of the built environment can decrease the number of workplaces available, and increase the level of energy necessary to function in a particular workplace. It can mean the woman with disabilities has to depend on colleagues for ordinary activities such as refilling the photocopier paper stack or getting a cup of coffee.

h. Lack of access to training
Being on low income often prevents women with disabilities from participating in the very training programs which would enable them to be viable candidates for employment. Women with disabilities have also expressed their frustration at their lack of access to education and training programs, voicing a feeling of segregation from the education system (WWDA 2004). Cuts to disability programs, rising education fees and the lack of funds to meet the extra costs of travelling to and from school are making education and training less accessible to women with disabilities.

i. Restricted access to information and communication technologies.
Many women with disabilities are restricted in their access to information and communication technologies (ICT) due to cost, poor design and lack of connectivity of ICT equipment, lack of responsibility in addressing disability issues on the part of telecommunications service providers, and lack of appropriate information about telecommunications equipment and services (WWDA 1999, 2004).

j. Costs of Disability
Disability is linked to increased cost of living. There are additional costs of medication, medical supplies and visits to medical professionals; the costs of mobility aids; the costs of labour saving devices (a microwave oven can be an essential tool for someone unable to get hot dishes from an oven); the cost of house cleaning; the cost taxi transport for those unable to use public transport; and the cost of attendant care and support services. In addition to these barriers, women with disabilities have additional costs in terms of dollars and energy in finding adequate childcare, in maintaining their households, and meeting their domestic and parenting duties.

k. Personal limiting factors
Social conditioning means that women with disabilities often have lowered life expectations, lack self confidence, assertiveness and have low self esteem. Many have experienced abuse, violence and harassment particularly in the domestic sphere but also in places of work, recreation and the wider community. They are often not aware of their rights so that they are vulnerable to a range of exploitations. Alternatively their fear of losing their job may preclude them from taking any action. Lack of access to secure and appropriate accommodation restricts women with disabilities in their ability to look for and retain employment.

RECOMMENDATION 7: Strategies to address these barriers (which recognise their disproportionate impact on women with disabilities), need to be put in place and/or strengthened.

(ii) Barriers in Attitude

The CDS should have a role influencing the ability and desire of all organisations to increase the number of people with disabilities in employment; to increase the integration of those employed into the fabric of the workplace; to enhance the quality of interactions which employees have with their clients with disabilities; and to enhance the inclusion and integration of people with disabilities into society. The CDS has the potential to make positive progress in all these areas, but to date there is not tangible evidence that it is doing so.


5. Additional problems affecting women with disabilities

(i) Lack of portability of state funded programs

Disabled people who require support through funded programs (such as home help; personal care) can be severely restricted in terms of being able to move from State to State because funded programs may not be portable between the various States and Territories.

(ii) De-link Income and Disability Supports

Concessions and allowances linked to the DSP currently cease when total weekly income is approximately $960 per week (NATSEM 2005). This needs to be reviewed and adjusted upwards. Similarly, the same concessions and allowances should be available to people with disabilities on other income support allowances (such as the Newstart Allowance) and continued until comparable total income level is reached. Supports need to be reinstated immediately the income drops below the threshold. Disability supports need to be de-linked from Income supports.

(iii) Discriminations caused by the intersection of gender and disability

It is unlikely that the un/employment and labour force participation rates for women with disabilities will ever change unless there is explicit recognition of the impact of multiple discriminations caused by the intersection of gender and disability. Similarly, there has been virtually no improvement in the unemployment rate and/or labour participation rate of women with disabilities since 1997, in stark contrast to the improvements made for disabled men, non-disabled men and non-disabled women in the same period. The Disability Services Act allows for positive discrimination.

(iii) Research into appropriate education courses for people with disabilities

The number of people with disabilities undertaking Vocational and Educational Training has been decreasing. Programmes to address this decline are needed. Lack of education is a major impediment to achieving employment and through employment to achieving empowerment and participation in society. However, there is no longer a disparity in educational achievements between women with disabilities and men with disabilities. We know, for example, that 71% of women with disabilities are now completing Year 10 or higher in secondary education and their completion rates of post secondary education are now comparable to those of men with disabilities (WWDA 2004). Research is needed to investigate why educational achievement is not reflected in levels of employment for women with disabilities.

(iv) data collection and disaggregation

Underpinning the research is an ongoing need for data collection and disaggregation of this data so that the discrepancies between the situation for women with disabilities and men with disabilities can be identified and address. This disaggregation of data needs to be obligatory in the reporting all aspects of CDS achievements by Government Departments and agencies. The data needs to be publicly available. Research and programmes need to be put in place to address disparities revealed by the data.

RECOMMENDATION 8: Put strategies in place to address: the lack of portability of disability support programmes; the de-linking of disability supports from income supports; the double discrimination which affects women with disabilities; research into impediments to uptake of Vocation and Educational Training programmes; and reinstatement of the collection of disaggregated data in all areas affecting people with disabilities accompanied by appropriate remedial programmes to address disparities revealed.


6. What do you consider to be the future priorities and actions for improving outcomes for people with disability?

WWDA believes that the current actions required by the CDS are not delivering tangible improvements in the lives of women with disabilities. Although the CDS sets a framework for departments and agencies to improve the accessibility of their services and programs for people with disability, many efforts to do this are misdirected so that progress is limited.

When the CDS was evaluated in 1999 and re-released in 2000, with more clearly articulated goals of access, equity, participation, accountability and inclusion for people with disabilities, it did not incorporate sufficient performance indicators so that targets for improvement could be set and measured. The new performance-reporting framework with explicit links to the five main roles of the Australian Government, as policy maker, purchaser, regulator, service provider and employer, did not carry with it sufficient requirement for measuring or reporting on quantitative indicators.

The requirement for the development and application of Disability Action Plans was subsumed into general requirements for strategic plans and business plans. Unfortunately in some cases this has enabled the spirit of the CDS to be diluted to the point of tokenism.

A quick survey of the 2003-2004 Annual Reports for a number of Commonwealth Government departments showed that for some departments, their reporting against the 5 main government roles was reduced to little more than a single paragraph, and there was a paucity of strategies in place to address specific issues. Without quantitative performance indicators it is difficult for WWDA to assess the degree to which the CDS is having positive outcomes. It may be true that all departments and agencies are striving to fulfill their obligations under the CDS to improve all aspects of their interactions with people with disabilities. Annual Reports do not show whether or not this is the case.

There are notable exceptions, particularly in areas dealing with the health, employment and income of people with disabilities. The Department of Workplace Relations has put a raft of strategies in place under the CDS to address the employment and employability of people with disabilities. However, it is seems that positive outcomes in terms of increased percentages of people with disabilities in employment have not been achieved.

Similarly the Department of Health and Ageing has a number of programmes in place where it is engaging with a range of groups of people with disabilities. Likewise the Department of Family and Community Services has a registered Disability Action Plan and in its Annual Report gives quantitative details of activities against all key performance indicators.

However, despite all these strategies being put in place, there are only marginal positive employment outcomes for people with disabilities. The most important priority for women with disabilities is that of improving employment outcomes. The barriers to employment have been outlined in Section 4 and strategies to address those barriers outlined in Section 5.

(i) What will help or hinder the achievement of these priorities?

There is a need to continue to consult with people with disabilities through formation of boards, advisory committees and reference groups. This commitment carries with it the need to dedicate resources to training and capacity building for so that people with disabilities can make an effective contribution to such groups.

(ii) What are the alternatives to the current approach (Strategy) for achieving the outcomes intended?

It could be that many government departments and agencies regard the CDS as obligatory rather than empowering. The current approach has the potential to make a difference. However, the current approach needs to be augmented by demonstrations of leadership from the highest echelons of government. Increasing the percentage of people with disabilities employed in key departments (such as the Department of Prime Minister and Cabinet, the Department of Workplace Relations, the Department of Family and Community Services, and the Department of Health and Ageing) is essential. By showing example, other departments and agencies could copy strategies and incentives which were successful in recruiting and retaining staff with disabilities.

(iii) What is the best option for moving forward?

The barriers to equal employment opportunity for women with disabilities have been outlined elsewhere. Strategies need to be put in place to address these.

There is a continued need for disaggregation of data so that progress can be measured on a gender basis. There is a need for targetted research and targetted programs to address the imbalances which negatively affect women with disabilities in employment and levels of income. There is a need to address the unequal access to employment services for women with disabilities. There is a need to address the unequal access to supported accommodation and public housing for women with disabilities.

There is a continued need to engage with people with disabilities on boards, advisory committees and reference groups. Disability organisations need to be resourced and supported to train and empower their constituents to take up representative roles.

The HREOC needs to be resourced so that Disability Rights can be effectively promoted through that body, and complaints brought to it under the DDA adequately and expeditiously addressed.

The Commonwealth needs to ensure that legislation and standards developed in areas covered by the DDA, particularly in employment, transport, education, and access to premises, are effective in delivering equitable outcomes for people with disabilities. The ‘unjustifiable hardship’ clause in the DDA can lead to unjustifiable inequities for people with disabilities being perpetuated.

RECOMMENDATION 9: Strengthen the resourcing of the Disability Rights Section of HREOC.


7. Are there any other issues you wish to raise in relation to the Commonwealth Disability Strategy?

Despite the positive potential of the CDS, people with disabilities are not yet seeing many positive outcomes in their working and private lives. With the economy strong at present, the Australian Government has an opportunity to consolidate the gains that have been made for people with disabilities, and to dedicate additional resources to CDS initiatives to make further improvements.

WWDA would like to see Commonwealth support for systemic advocacy for women with disabilities. This will mean allocating resources to capacity building in organisations such as our own. It will also mean allocating resources to training women with disabilities to take up advocacy, leadership and representative roles in the workplace and in the community.

The CDS could also instigate an awards or rewards system which would recognise employer/employee with disabilities achievements. This would be separate to, or an adjunct to the current Prime Minister’s Employer of the Year Awards.

There is a need to consider the review in the CDS in the light of the Industrial Relations reforms and the Welfare-to-Work Reforms, both of which will have a disproportionate affect on women with disabilities (NATSEM 2005). Under the current regimes, women with disabilities have not fared well in being able to obtain paid employment. All the barriers to employment for women with disabilities already outlined in this submission will not be diminished or be specifically addressed under the Industrial Relations and Welfare-to-Work reforms. The current proposals will entrench the disparities which exist for women with disabilities, especially for new Disability Support Pension applicants who are put on Newstart Allowance, and all the accompanying negative effects of poverty will be exacerbated. Without pro-active strategies being put in place, the employability gap between women with disabilities and their male counterparts, along with their able-bodied counterparts will increase markedly.

The mantra of the disability movement: ‘Nothing about us without us’ is still largely ignored. The Government wishes industries to be self regulating. But where they operate in environments of strong competition and low profit margins, any activities which carry increased costs will be jettisoned. In such environments the CDS will be ineffective and people with disabilities are the losers. For example, meeting the needs of people with disabilities in access to the built environment, and in information and communication technologies, needs Commonwealth leadership and monetary support. The current structure of the CDS cannot bring about actions which would see people with disabilities involved in the inaugural stages of planning of policies, programs and services.


8. Conclusion & Summary of Recommendations

WWDA is disappointed that the degree of inclusion and participation in society, and the rates of employment of women with disabilities have improved only marginally since the instigation of the CDS. However, in 2005 there is a much wider awareness of the low status of women with disabilities in society. There are now many initiatives in place which seek to improve the status of women with disabilities. Some of these initiatives are directly attributable to the CDS. Without the CDS, there would be markedly fewer strategies in place to address the barriers facing people with disabilities. The current Industrial relations and Welfare-to-Work reforms have the potential to remove all gains made by people with disabilities under the CDS. WWDA therefore endorses the CDS and supports all measures which can be taken to strengthen its affects on improving the lives of people with disabilities and improving the overall fabric of Australian Society.

RECOMMENDATION 1: Strengthen the CDS to introduce targetted programmes to encourage the employment of women with disabilities.

RECOMMENDATION 2: Strengthen the CDS so that strategies and incentives which address the employment inequities which exist for all people with disabilities can be supported. Targetted supports are needed to address the exacerbated inequities which exist for women with disabilities. Increased workforce participation rates at higher levels of income will enable greater whole-of-life equity for people with disabilities.

RECOMMENDATIONS 3: Increase levels of support for people with disabilities so that they can participate in mainstream programs, services and facilities.

RECOMMENDATION 4: Support disability organisations to build capacity so that they can increase levels of systemic advocacy and participate more fully in decision making processes which affect their lives.

RECOMMENDATION 5: Maintain/increase programs which raise awareness of the information access needs of people with disabilities.

RECOMMENDATION 6: Set up feedback mechanisms so that information about agency success in the provision of access to programmes, facilities and services, including complaints incidence and resolution rates are publicly available.

RECOMMENDATION 7: Strategies to address these barriers (which recognise their disproportionate impact on women with disabilities), need to be put in place and/or strengthened.

RECOMMENDATION 8: Put strategies in place to address: the lack of portability of disability support programmes; the de-linking of disability supports from income supports; the double discrimination which affects women with disabilities; research into impediments to uptake of Vocation and Educational Training programmes; and reinstatement of the collection of disaggregated data in all areas affecting people with disabilities accompanied by appropriate remedial programmes to address disparities revealed.

RECOMMENDATION 9: Strengthen the resourcing of the Disability Rights Section of HREOC.


9. References

Australian Bureau of Statistics 2004 Disability, Ageing and Carers: Summary of Findings Australia, Cat.No: 4430.0 2003.

Australian Public Service Commission 2004 State of the Service Report 2002-2003; accessed online: http://www.apsc.gov.au/stateoftheservice/0203/index.html

Department of Education, Employment & Training 2002, Students 2002: Selected Higher Education Statistics, Australian Government 2002 accessed online at http://www.dest.gov.au/highered//statistics/students/02/students_table/students2002.pdf

Human Rights and Equal Opportunity Commission (HREOC) 2002 Annual Report 2001-02, Canberra.

Human Rights and Equal Opportunity Commission (HREOC) 2005 National Inquiry into Employment and Disability; Issues Paper 1: Employment and Disability – The Statistics; HREOC, Sydney.

National Centre for Social and Economic Modelling (NATSEM) 2005 The Distributional Impacts of the Welfare-to-Work Reforms on Australians with Disabilities

NSW Council of Social Services & Women’s Rights Action Network Australia (2004), Our Rights, Our Voices, (Report on) a forum for women and community groups working with women to discuss, explore and report on women’s rights in NSW, NCOSS 2004.

Productivity Commission (2003) Review of the Disability Discrimination Act (DDA) Draft Report, accessed online: http://www.pc.gov.au/inquiry/dda/draftreport/index.html

Ozdowski, S 2005 People with Disabilities and productive diversity in the Australian Public Service, presentation to Australian Public Service Commission, HREOC June 2005, accessed online at http://www.hreoc.gov.au/disability_rights/speeches/2005/aps.htm

WWDA 2004a Use of disaggregated data tables from Australian Bureau of Statistics Disability, Ageing and Carers: Summary of Findings Australia, Cat.No: 4430.0 2003 purchased from ABS

WWDA 2004b Use of disaggregated data tables from Department of Education, Science and Training (2002), Students 2002: Selected Higher Education Statistics, Australian Government 2002 purchased from DEST

WWDA 2004c Submission to the Social Policy Research Centre on the Discussion Paper ‘Designing the Evaluation of the Commonwealth Disability Strategy’

WWDA 2005, Submission to the HREOC National Inquiry into Employment and Disability, WWDA 2005


Endnotes

[1] Loss of income support payments and high effective marginal tax rates may mean that income levels for people with disabilities are actually lower when in paid employment.

[2] Qualitative information on the effectiveness of all such groups is also needed. Tokenistic consultation has a negative impact on both persons and processes.


Erebus International Final Report of the Evaluation of the Commonwealth Disability Strategy (2006)