National Inquiry on Employment and Disability
Interim Report:
7.
Interim Recommendations
7.2 Assess and address information needs
7.2.1 Develop a one-stop-information-shop and inquiry service
7.2.2 Map of government services
7.3 Assess and address the costs facing employers and people with disability
7.3.1 Research real costs to people with disability, employers and employment services
7.3.2 Streamline the system of subsidies, supports, incentives, concessions and income support
7.3.3 Introduce a 'cost of disability' allowance.
7.3.4 Introduce a 'cost of participation' allowance
7.3.5 Investigate extension of health concessions
7.3.6 Investigate increases to Mobility Allowance and extension of transport concessions
7.3.7 Improve the Workplace Modifications Scheme
7.3.8 Investigate the introduction of tax incentives
7.4 Assess and address the risks facing employers and people with disability
7.4.2 Ensure a comprehensive safety net for those on income support
7.4.3 Support and develop work trials
7.5 Assess and address recruitment and support needs
7.5.1 Improve transition to work schemes
7.5.2 Increase access to ongoing support
7.5.3 Develop guidelines for creating a flexible workplace
7.5.5 Investigate recruitment and support needs for people with mental illness
7.5.6 Increase access to attendant care packages and work based personal assistance
7.6 Encourage public and private sector leadership
7.6.1 Increase public sector employment
7.6.2 Develop a government procurement policy
7.6.3 Develop a reporting scheme for employers.
7.6.4 Create and promote awards for employer best practice.
7.6.5 Encourage employers to use recruitment agencies that have an inclusive process
7.6.6 Create an inter-sector leadership coalition.
7.1 Introduction
The preceding chapters of this report are a summary of the main issues raised in the submissions and consultations already conducted by the Inquiry. The issues have been grouped into themes as follows:
- The general information needs, costs and risks faced by employers (Chapter 2).
- The general information needs, costs and risks faced by people with disability (Chapter 3).
- The issues facing people with disability in getting ready for a job in the open workplace (Chapter 4).
- The issues facing employers and people with disability regarding recruitment in the open workplace (Chapter 5).
- The issues facing employers and people with disability regarding job retention (Chapter 6).
In considering the Interim Recommendations below, the Inquiry urges readers to keep in mind that the employment process involves a number of interdependent parties and elements. Improvements to any one aspect of the process in isolation is unlikely to result in much success. Unless the barriers for people with disability and employers are addressed in a holistic manner, there is a real chance of setting up all parties to fail.
For example, getting more people with disability into the workforce through improved access to information and better recruitment practices may not ensure a positive employment outcome without adequate supports for employees with disability, employers and work colleagues. And a failed employment situation in the case of employees with disability can have serious knock-on effects by perpetuating stigma and negative perceptions.
The Interim Recommendations in this chapter attempt to address the overarching elements amongst different parties throughout the employment process.
The Interim Recommendations have been organised in the following groups:
1. Assess and address information needs
2. Assess and address the costs facing employers and people with disability
3. Assess and address the risks facing employers and people with disability
4. Assess and address recruitment and support needs
5. Encourage public and private sector leadership
The Inquiry emphasises that these recommendations are guided by the content of the submissions and consultations; they do not intend to, and do not, cover the field. Further, these recommendations are interim recommendations only. The Inquiry remains open to comments and suggestions as to other measures needed to increase participation and employment of people with disability.
Chapter 8 selects some of these Interim Recommendations for further work by the Inquiry in its remaining months.
7.2 Assess and address information needs
There appears to be substantial confusion, misapprehension and fear in most parties involved with the participation and employment of people with disability in the workplace. Part of the problem lies in the absence of appropriate information. However the larger problem is that the information that is available is disconnected, difficult to find and often inaccessible to people with disability.
7.2.1 Develop a one-stop-information-shop and inquiry service
An overwhelmingly consistent theme of the submissions to, and consultations by, the Inquiry is that there needs to be a comprehensive one-stop-information-shop for all parties involved in the employment of people with disability.
It is not the first time that this idea has been suggested. This initiative was suggested in the 2003 Review of the Employer Incentives Strategy.[1] The 2005 Budget Papers also suggest the establishment of an information site that is based on the Job Accommodation Network (JAN) funded by the United States Department of Labor.[2]
However, the Budget Papers suggest that such a website should be focussed on the needs of employers. While the JAN website is primarily focussed on workplace modifications, the information collected by this Inquiry suggests the need for a broader approach.
In particular, a comprehensive information source should cater to the needs of the following groups of people:
- Large, medium and small employers considering the employment of people with disability
- Large, medium and small employers already hiring people with disability
- Work colleagues of people with disability
- People with disability who are considering entry into the open workplace
- People with disability who already participate in the open workplace
- Employment service providers
- Private recruitment agencies
- Carers of people with disability
- Government and non-government support services
- Community groups.
Submissions and consultations suggest that employers would be interested in a one-stop-information-shop that addresses at least the following topics:
1. The business case for hiring people with disabilities for large, medium and small businesses.
2. Potential costs incurred by a business when hiring people with different disability.
3. Government assistance available to employers with employees with disability (for example the Workplace Modification Scheme, Wage Support Subsidy, Supported Wage Scheme, Disabled New Apprentice Wage Support)
4. Lists of government-funded employment services that can help in the recruitment of employees.
5. Lists of private recruitment agencies that have disability-friendly policies.
6.Clear information on any legal implications of hiring people with disability.
7.Technical assistance regarding workplace accommodations.
8. Training assistance and sample curricula for managers and other staff regarding working with people with disability.
9. Guidelines regarding accessible training for employees with specific disabilities.
10. Guidelines regarding an open and inclusive recruitment and selection process.
11. Guidelines regarding the creation of a flexible workplace.
12. Guidelines on how to access or run mentoring programs for employees with disability.
13. Information about specific disabilities.
14. Information about, and access to, on-going support services for employees and managers of employees with disability.
15. Best practice workplace policies and case studies.
16. Information and promotion of employer award schemes.
17. Referrals to experts regarding support, training and retraining for people with specific disabilities.
18. Personalised inquiry service (with the option for confidentiality).
Submissions and consultations suggest that people with disability would be interested in a one-stop-information-shop that addresses at least the following topics:
1. The impact of potential wages on overall income for those receiving government support (for example the interaction between salary, loss of income support and taxation rates).
2. Transport costs, transport concessions and available subsidies (including Mobility Allowance).
3. Equipment costs and available subsidies (including the Workplace Modifications Scheme and other State-based subsidies).
4. Medical costs and potential loss of medical concessions.
5. Safety-net information in the event of an unsuccessful employment relationship.
6. Education and training options (both prior to and during employment), including associated costs and government assistance.
7. Lists of government-funded employment services, including agencies with specialist services in specific disabilities.
8. Lists of private recruitment agencies with disability-friendly policies.
9. Assistance available throughout the job-seeking and employment process.
10.Information about, and access to, on-going support services for employees with disability.
11. Personal assistance and care services available at home and in the workplace.
12. Guidelines on disclosure of disability to a potential or current employer (especially for those people with mental illness and HIV/AIDS).
13. Personalised inquiry service (with the option of confidentiality).
The submissions and consultations also make very clear that the information must be accessible - both in the sense that people with disability must be able to read and understand the information, and in the sense that it must be simple, cheap and comprehensive.
The existence of an expert personal inquiry service is also crucial to the success of an information service. This service should be able to answer questions specific to particular circumstances and refer inquirers to experts where needed.
Finally, the submissions emphasise that there is little use in an information service that nobody knows about. The one-stop-information-shop should therefore be actively promoted amongst the community sector, employment services, recruiting agencies and the business sector. One way to promote the service is to employ staff to visit workplaces with employees with disability and explain what information, advice and support is available to employers and employees.
Thus, while the Inquiry is of the view that the American JAN service provides a good starting point, many things have been raised in this Inquiry process that are not included in JAN. The Inquiry therefore recommends that the Department of Employment and Workplace Relations (DEWR) conduct further consultations and investigations regarding the ideal content, format of costing structure and therefore makes the following recommendation.
Interim Recommendation 1: One-stop-information-shop
The Inquiry recommends that:
(a) DEWR conduct multi-sector consultations on the ideal content, scope, format and cost of a one-stop-information-shop; and
(b) DEWR facilitate the launch of a site-in-progress, accompanied by an individualised inquiry service in early 2006.
7.2.2 Map of government services
From the outset of this Inquiry, it was apparent that there was a need for clearer information on the services offered by the Commonwealth government regarding employment of people with disability. Issues Paper 5 was the first step towards collecting information for these purposes.[3]The various responses to Issue Paper 5 made suggestions regarding the type of information that should still be collected, including:
- clearer information on the relationships between Commonwealth programs and agencies
- services provided by each State and Territory
- better information about the interaction of State, Territory and Commonwealth services and programs
- information about the outcomes of government programs
- presentation in an accessible, user-friendly and interactive format.[4]
The Inquiry is of the view that this information should be a priority for inclusion in a one-stop-information-shop. It is therefore important to ensure an ongoing process for data collection.
Interim Recommendation 2: Map government services
The Inquiry recommends ongoing Commonwealth, State and Territory interagency consultations with a view to developing up-to-date information regarding:
(a) the programs available to employers and people with disability;
(b) the relationships between various government agencies and programs; and
(c) the outcomes of those programs.
The Inquiry recommends that this information be part of the one-stop-information-shop (see Interim Recommendation 1).
7.3 Assess and address the costs facing employers and people with disability
Just as employers are concerned about the possible financial impact of employing a person with disability, so are people with disability concerned about the possible financial impact of entering the open workplace.
In both cases part of the concern can be addressed by clear and easily accessible information about the real, as opposed to the perceived, costs. Similarly, clear information about the government assistance available to offset various costs should remove at least some apprehension.
However, there are some actual costs on both sides and not all them are covered by State, Territory or Federal governments. Further, not all of the costs are known, and it is therefore difficult to resolve some of the uncertainties that exist.
The question is which of those actual and perceived costs have a real impact on the participation, employment and retention rates of people with disability and how they are best addressed.
The following Interim Recommendations attempt to address some of the cost-related concerns raised throughout this Report.
7.3.1 Research real costs to people with disability, employers and employment services
There has been much anecdotal discussion about the costs of participation for people with different disabilities and the inadequacy of income support, concessions and subsidies to cover those costs. Similarly there is debate about the inadequacy of funding for employment services to assist people with various disabilities to find a job. There is also discussion of the burden borne by employers who recruit employees with various disabilities.
However, to the Inquiry's knowledge there is little publicly available economic analysis of what those costs really are at the job-readiness, recruitment and retention stages of the employment relationship.
Further, there has been little analysis about the impact of the costs of disability on small business as opposed to larger employers.
It is the Inquiry's view that further research in this area would provide better guidance to all parties. In particular such research would assist the government in determining the appropriate amount of support and funding for all parties involved in the employment equation. It may also dispel some of the myths and fears about the costs involved in the employment process.
Interim Recommendation 3: Research into costs
The Inquiry recommends research into the economic cost of disability to:
(a) people with different disabilities participating in the open workplace;
(b) employment services assisting people with different disabilities; and
(c) large, medium and small employers of people with different disabilities.
7.3.2 Streamline the system of subsidies, supports, incentives, concessions and income support
Many submissions suggest that the Commonwealth-State-Territory division of support services and the multitude of supports and services 'hidden away' make it very difficult to determine what is available to people with disability and employers.
While a better information service might go some of the way towards addressing this problem, several submissions suggest developing a more holistic approach to the provision of assistance to employers and employees.[5]
In particular, submissions refer to the New Zealand government's Job Support program under which a grant of up to $NZ16,900 per year is able to fund support services in employment, including equipment.[6] Submissions also refer to the United Kingdom's 'Access to Work' system.[7] The Inquiry is also aware that Canada has developed a more integrated approach to the employment of people with disability.
ACE National Network suggests that a streamlined program could cover a range of possible interventions. All interventions should be properly funded and employers should directly receive funding for the intervention needs in the individual circumstances. The interventions noted by ACE include:
- communication support at job interviews or on-the-job support (e.g. interpreters, note-takers, mentors, support workers)
- special equipment or workplace adaptations
- assistance with travel costs
- skills or disability awareness training
- work-experience
- purchase of specific licenses or work clothing/boots
- work-based personal assistance
- Supported Wage Assessments.[8]
The 2005 Standing Committee Working for Australia Report also recommends a whole-of-government approach to assist the long-term unemployed (noting that it applies to all people on income support):
Recommendation 6: The Committee recommends that the Australian Government work with local, State and Territory governments, business, union and community organisations to invest in more holistic pilot projects which combine personal support, paid work experience, pre-vocational training, employment assistance, traineeships and post-placement support for the long term unemployed.[9]
In the context of employer incentives, the Commonwealth Productivity Commission recommended that the government:
-
... review the effectiveness of the various schemes it uses to subsidise
the costs to organisations of adjustments needed by people with disabilities.[10]
In January 2005, the Commonwealth government accepted this recommendation.[11]
Interim Recommendation 4: Streamline support and subsidies
The Inquiry recommends research into international approaches to encouraging the participation and employment of people with disability with a view to developing:
(a) a more streamlined and comprehensive program of support, assistance and incentives; and
(b) a whole-of-government approach.
Some submissions suggest that a case management model that ensures coordination of services and supports across all levels of government is essential to a successful employment experience for people with disability and employers.[12]
The submissions suggest that case management should be available from the final year of schooling until there are no longer ongoing support needs in a job. The purpose of this model would be to make one person responsible for coordination of services throughout an individual's employment experience and to provide a single contact for each person with disability and his or her carers and employers. .
Interim Recommendation 5: Case management model
-
The Inquiry recommends research into case management models for people
with disability throughout the job readiness, recruitment and retention
stages of the employment process, with a view to ensuring coordination
of all services and supports across all levels of government.
7.3.3 Introduce a 'cost of disability' allowance
Submissions addressing the costs of participation for people with disability consistently recommended the introduction of a 'cost of disability' allowance.
This type of allowance was also recommended in the 2000 Commonwealth Reference Group on Welfare Reform Report (the McClure Report) in the context of simplifying the income support structure. The McClure Report recommends one base payment for all income support recipients with additional payments for those with special disadvantages, including people with disability.
The Brotherhood of St Laurence recommends following the New Zealand system which creates a single benefit to be supplemented by a second tier disability allowance based on the costs of ill health or disability:
this is the approach being favoured by the New Zealand government which has accepted that such a single benefit and 'an integrated cost-based disability payment would eliminate the incentive for people with disabilities to distance themselves from the labour market in order to access a higher level of benefit'.[13]
The Deafness Forum suggests that any such system could be made fairer by ensuring that the 'additional costs of living due to disability' component has several tiers, to account for differing levels of disability and associated costs.[14] Some of the associated costs that might vary depending on disability include transport, health costs and personal care costs.
Submissions also argue that a cost of disability benefit should continue when a person has work and that it should be separated from pension or unemployment benefit entitlements:[15]
People should be entitled to certain benefits that are designed to compensate for the extra cost of disability. These benefits should not be related to the work status of people with disability and should be paid as long as there is evidence of additional costs.[16]
Interim Recommendation 6: Cost of disability allowance
The Inquiry recommends reconsideration of the McClure Report's recommendation regarding simplification of welfare payments and the introduction of a cost of disability allowance, which takes into account the varying needs of people with different disabilities.
7.3.4 Introduce a 'cost of participation' allowance
In addition to a 'cost of disability' allowance available to all people with disability, some submissions argue that there should be supplementary support for the extra costs incurred by those who seek to participate, or who are participating, in the open workforce. [17]
This type of payment was suggested as an incentive for participation in the McClure Report.
This type of allowance would be different to the more general lump sum Employment Entry Payment which is currently available to all people on income support when they commence employment to off-set start-up costs.
As with the cost of disability allowance, the extra costs on participation will vary depending on the type and severity of disability. For example, a person in a wheelchair may have disproportionately higher transport costs, and a person with mental illness might have disproportionately higher health costs when in employment.
Interim Recommendation 7: Cost of participation allowance
The Inquiry recommends reconsideration of the McClure Report's recommendation regarding simplification of welfare payments and the introduction of a cost of participation allowance, which takes into account the varying needs of people with different disabilities.
7.3.5 Investigate extension of health concessions
Many submissions suggest that the simultaneous loss of income support and health concessions has a devastating impact on people with disability who enter the workplace. This impact can affect the willingness of people with disability to seek employment. This is especially the case for people with certain disabilities whose health may be impacted by the pressures involved in working.
The 2005 Budget announcements state that people who lose the Disability Support Pension (and, from 1 July 2006 - Newstart Allowance) due to earnings will be entitled to health concessions for a further year. However the submissions suggest that higher health costs are an ongoing burden for many people with disability:
Health care cards for all disabled people would be of immense help as it costs more to be disabled than to be healthy and in many cases it costs even more for medicine to remain at work than to remain at home due to stress and physical challenges associated with work.[18]
For people with episodic illnesses, the one year extension of health concessions may be of little use. Further, people who do not move from income support to employment are not entitled to the concessions despite the fact that they may be on low incomes and have high health care costs due to their disability.
Some submissions suggest the introduction of a chronic illness card for people assessed as having a chronic manageable illness.[19] For people with hearing impairments, submissions propose permitting Medicare rebates for those who use audiologists rather than medical practitioners.[20] Deafness Forum Australia also recommends that eligibility for the Commonwealth government's hearing services program be broadened to include unemployed job seekers and employees on low income.[21]
Interim Recommendation 8: Health concessions
The Inquiry recommends further investigation into the need for extending eligibility for health care concessions for people with disability. The investigations should include a focus on:
(a) the cost of health care for people with different disabilities;
(b) the additional heath costs that may be incurred because of participation in the open workplace; and
(c) the impact of health care costs on participation in the open workplace.
7.3.6 Investigate increases to Mobility Allowance and extension of transport concessions
The submissions suggest that the impact of transport costs on people with certain disabilities can be a disincentive to participation in the workplace.
The Inquiry welcomes the increase in the amount of the Mobility Allowance announced in the May 2005 Budget. However, comments in submissions suggest that $100 per fortnight for people on income support will still be insufficient to cover the out-of-pocket expenses for people with disability who are forced to rely on taxis when travelling to and from work (or vocational/life-skills training).[22]
Interim Recommendation 9: Mobility AllowanceThe Inquiry recommends reconsidering the amount of the Mobility Allowance to take into account the cost of transport to and from the workplace for people with different disabilities. This should include consideration of access to the Mobility Allowance on an 'as needed' basis.
Eligibility for the Pensioner Concession Card has also been extended under the Budget so that a person can retain the card for a year after losing entitlement to the DSP. It is still unclear what will happen to people who lose entitlement to the Newstart Allowance after 1 July 2006.
While this means that transport concessions will also continue for another year, there is some concern that this is not long enough for people with disability on low incomes.
Interim Recommendation 10: Transport concessions
The Inquiry recommends further investigation into the need to extend eligibility for transport concessions for people with disability. The investigations should include a focus on:
(a) the cost of transport for people with different disabilities;
(b) the additional costs that may be incurred because of participation in the open workplace; and
(c) the impact of transport costs on participation in the open workplace.
7.3.7 Improve the Workplace Modifications Scheme
Employers argue that it can be costly to make the workplace accommodations necessary to employ people with certain disabilities. People with disability argue that this concern operates as a serious barrier to employment.
The Federal government's Workplace Modifications Scheme (WMS) is intended to address this concern and provide an incentive to employers to hire people with disability. However, submissions and consultations indicate that the WMS has little practical impact on employment decisions.
One reason for this is that many employers do not know that the scheme exists. Therefore promotion of, and clear information about, the availability of the scheme, the extent of assistance and the method of accessing that assistance will go some way to improving its impact.
However, submissions also suggest that a number of other changes should be made to the WMS to increase the incentive value of the scheme.
For example, several submissions from organisations representing people with hearing impairments suggest expansion of the Workplace Modification Scheme to include items such as interpreters, TTY equipment, hearing aids and other communication access devices needed for employment. [23]
Blind Citizens Australia also recommend that the Commonwealth government investigate ways of providing people who are blind and vision impaired with ready, affordable access to necessary technology and equipment.[24] Ability Technology suggest that an assistive technology policy, similar in scope to the Assistive Technology Act in the United States is needed.[25]
In summary, the suggestions are as follows:
1. increase the amount available under the scheme
2. provide access to all employers, not just those who employ someone through a Disability Open Employment Service
3. provide access to people with disability who are self-employed
4.broaden the range of modifications that the scheme will fund (for example include Auslan interpreter costs)
5. permit employees with disability to take any WMS funded equipment with them to a new job
6. simplify the administration of the scheme
7. look at international models for guidance on how to improve support for workplace modifications.
Many of these suggestions were made in the 2003 FaCS Review of the Employer Incentives Strategy.[26] The Productivity Commission also recommended that there be an assessment of 'the merits of portable access grants that could contribute to the costs of adjustments required for participation in employment and education.'[27]
Further, the 2005 Standing Committee Working for Australia Report made three recommendations regarding the WMS:
Recommendation 15: The Committee recommends that the Australian Government extend the eligibility criteria of the Workplace Modification Scheme to provide support for people with an assessed disability to enter the paid workforce where their capacity to work would be significantly improved by workplace modification.
Recommendation 16: The Committee recommends that the Australian Government conduct an awareness-raising program to promote the Workplace Modifications Scheme to employers and employment services providers.
Recommendation 18: The Committee recommends that the Australian Government extend eligibility for the Workplace Modification Scheme to part-time and casual positions.[28]
The Inquiry notes that the May 2005 Federal Budget announcement indicates both increased funding for this program and a review of eligibility criteria. The Inquiry welcomes these initiatives and recommends that DEWR consider the issues noted above in redesigning the scheme.
Interim Recommendation 11: Improve the Workplace Modifications Scheme (WMS)
The Inquiry recommends that any revised WMS include the following features:
(a) eligibility regarding any employee with disability, whether or not the person is referred by a government-funded employment service or working on a full-time, part-time or casual basis;
(b) expansion of the types of modifications covered by the scheme;
(c) portability of WMS-funded equipment;
(d) increased amounts available for modifications;
(e) simplified application process; and
(f) promotion of the scheme.
7.3.8 Investigate the introduction of tax incentives
A number of submissions to the Inquiry suggest that tax incentives for employers might encourage the employment of people with disability. In particular there was a suggestion regarding tax deductibility of workplace modifications. The 2005 Working for Australia Report also discusses the merits of income tax incentives for employers to hire people with disability.[29]
Models operating in the United States and the United Kingdom would be a good starting point for any further investigation.
Interim Recommendation 12: Employer tax incentives
The Inquiry recommends research into the structure and effectiveness of international models for tax incentives regarding employment of people with disability, with a view to determining the appropriateness of introducing such incentives in Australia.
7.4 Assess and address the risks facing employers and people with disability
Both employers and people with disability have concerns about what the work environment will be like and what will happen in the event that the employment relationship breaks down. In fact, some are of the view that the relationship will inevitably break down due to insufficient supports.
From the employer perspective the main concern appears to be the risk of liability under occupational health and safety laws, industrial relations laws and discrimination laws.
From the employee perspective, the main concern appears to be the risk of losing income supports and other concessions when moving to the open workplace.
The following are suggestions to address these concerns.
7.4.1 Clarify the protections and risks attached to occupational health and safety, industrial relations and discrimination laws
Employers express concern about the risks involved with the employment of people with disability. Some of these risks are perceived and some are real. It is important that there be clarification between the two types of risk.
The perceived risks can be partially alleviated by the provision of good information. Thus information that reduces the fear of organisational culture risks or litigation risks should be included in the one-stop-information-shop and promoted widely.
However genuine hurdles in the context of unfair dismissal laws, workers compensation laws, insurance, occupational health and safety regulations and disability discrimination laws may still exist.
Currently it is difficult to determine which risks are real and which are perceived. The Inquiry therefore recommends closer analysis of the practical impact of all these laws in the workplace.
Interim Recommendation 13: OHS, IR and disability laws
The Inquiry recommends gathering clear and practical information about the financial impact of, and legal risks created by:
(a) occupational health and safety laws;
(b) disability discrimination laws;
(c) industrial relations laws; and
(d) the interaction between those laws on employers who hire people with disability.
7.4.2 Ensure a comprehensive safety net for those on income support
Entering the workplace can be a difficult process for some people with disability and there is no guarantee of success, especially at the beginning. Many people with disability are afraid that if they lose income support and associated concessions because they have a job, and then the job does not work out, they may not be able to regain that income support.
[P]eople need to be empowered to do their best, to take calculated risks to move forward; services also need to provide support to them in their achievements. The DSP, or other reasonable income support, needs to remain in place to provide ongoing income support and health care extras to ensure people can participate to the best of their ability. Opportunities to access renewed income support if a person is unable to continue work for a time would provide security and increase the likelihood of them returning to the workforce.[30]
This was one of the most common concerns identified for people with disability in determining whether to enter the workforce.[31]
There needs to be some sort of 'safety net' that enables people to attempt to disengage from the DSP and take the risk of entering open employment, bearing in mind the episodic, chronic and sometimes swift onset of mental illness.[32]
Changes announced in the May 2005 Budget may go some way to alleviating this concern by providing that a person who loses the DSP because of their earnings or hours worked, will be entitled to return if they lose their job, for whatever reason and without reassessment, for up to two years. Further, people with disability who lose the DSP will retain access to the Pensioner Concession Card for 12 months and Telephone Allowance for 6 months.
However, from 1 July 2006 people with disability assessed as capable of working between 15 and 29 hours per week may in fact face an increase in the financial risk of entering the workplace.
For example, a person who is entitled to the Newstart Allowance from 1 July 2006, may not have the benefit of the longer term safety nets for assistance with expenses related to healthcare and travel. Further, due to fluctuations in symptoms and severity of some mental illnesses, a person who can work more than 15 hours a week when they are well, but who is not capable of sustaining these hours when they are unwell, may feel the new criteria jeopardises their eligibility for income support.
Further, the Inquiry heard that the 'whole package' of financial outgoings needs to be considered in order for people with disability to feel safe about entering the workplace and losing their current supports and allowances. Many people with disability, depending on the nature and severity of their disability, have significant health, transport, equipment and personal assistance costs that are not borne by people without disability.
Interim Recommendation 14: Safety net options
The Inquiry recommends ongoing consultation regarding the proposed safety net provisions in the 2005 Budget in order to:
(a) determine the financial impact of participation for people with disability over an extended period of time; and
(b) explore other options that might reduce the risk of returning to the open workplace for people with disability.
7.4.3 Support and develop work trials
Many employers are afraid of the unknowns that may arise in hiring people with disability. Several submissions suggest that a 'risk-free' opportunity to test an employment relationship with people with disability would be a great incentive to employers. Similarly, people with disability have expressed eagerness at getting 'a foot in the door.'
Work trials can take a variety of forms - long-term and short-term, paid and unpaid, supported and unsupported. For example, the Inquiry's Employer Consultation on 7 July 2005 suggested the creation of government-funded long-term work trials that remove risk, provide ongoing support and demonstrate the benefits of hiring people with disability.
Any work trial scheme would need to be carefully designed so that the employee could prove themselves to an employer on an equal footing with other employees. For example, there would be little point in having a work trial scheme that did not ensure that any appropriate workplace accommodations and supports were in place, as such an arrangement would be destined to fail.
Further, while such a scheme might relieve the employer of the financial liability for additional workers compensations premiums during a trial, that should not mean that the employee is not covered in the event of an accident.
The expansion of 'robust' government-supported work trials was recommended in the 2003 Review of the Employer Incentives Strategy.[33]
Interim Recommendation 15: Work trials
The Inquiry recommends the development of robust government-supported work trial schemes that benefit employers and people with disability.
7.5 Assess and address recruitment and support needs
7.5.1 Improve transition to work schemes
Chapter 4 sets out some of the concerns regarding supports available to youth and adults with disability in the secondary, tertiary and vocational education sectors. However the main emphasis of submissions that discuss what is needed to get people with disability 'job-ready', relates to the assistance and programs available to ensure transition from education and vocational training institutions into the workforce.
The Inquiry has already suggested that there be a more robust work trial scheme above. However the submissions contain more specific suggestions regarding transition from an educational environment to a workplace.
For example, the South Australian Government suggests linking training to employment opportunities. It also suggests that the allocation of an individual case-manager could help ensure a more successful transition from school to work.[34] Further, the South Australian Government suggests improvements to the training and employment support available to assist people with disability commence and complete traineeships. [35]
Parents and Professional Advocates suggest that transition planning to the tertiary sector and on to employment should begin as early as possible so that funding, support and modifications can be in place.[36] They also recommend that provision for 'workplace modifications' under the Disability New Apprentice Wage Scheme (DNAWS) include reimbursements for professional advice about what needs to be adjusted.[37] The availability of such support was seen as critical for employers of apprentices with intellectual disability.
The Brotherhood of St Laurence recommended the establishment of a 'Disability Access and Support' program to assist New Apprenticeship Centres or Group Training Companies who lack the expertise in assisting and supporting people with disability participating in VET through the New Apprenticeship scheme.[38]
Blind Citizens Australia recommend that the public sector take a more active role in providing traineeships and work experience programs, and by increasing work experience opportunities for students with disability.[39]
The 2005 Standing Committee Working for Australia Report recommends:
That Commonwealth, State and Territory agencies improve the transition assistance available from education to work or to further training through more coordinated work placement support and the links between workplace coordinators and disability employment services.[40]
One submission provides an example of the problems that arise when there is a lack of coordination:
For instance, a person with a mental illness may receive help from a Clubhouse, a specialised or generic open employment service, or from CRS Australia to prepare for work, and may need access to vacancies held by a Job Network agency when job searching. To retain employment, ongoing help may be needed from an Open Employment service. In addition, a TAFE College may be assisting with tailored vocational training to improve employment prospects, or as part of a traineeship package. These programs need coordinating.[41]
While there are several government funded apprenticeship and training schemes (eg New Apprenticeship Access Program (NAAP), School-based New Apprenticeships (SNAP), only one of them - the Disabled New Apprentice Wage Support (DNAWS) Scheme - ensures provision of the appropriate supports for people with disability. And the funds available under that scheme have been described as 'unrealistic to support apprentices with high support needs' or for apprentices who need extended time to complete their qualification.
Interim Recommendation 16: Transition to work schemes
The Inquiry recommends consideration of the following measures to improve transition to work schemes:
(a) ongoing consultation and cooperation between Commonwealth, State and Territory governments to ensure more coordinated work placement support;
(b) improvements to the Disability New Apprentice Wage Support (DNAWS) scheme, including increased funding;
(c) provision of appropriate supports for other work experience, traineeship and apprenticeship schemes (eg New Apprenticeship Access Program (NAAP) and School-based New Apprenticeships (SNAP)); and
(d) public sector leadership in recruiting people with disability into work experience, traineeships and apprenticeships.
7.5.2 Increase access to ongoing support
As Chapter 6 discusses, access to support throughout an employment relationship can be critical to its success.
The Inquiry found it quite difficult to determine exactly what ongoing support services are offered, to whom, by whom, for how long and of what quality. Given the importance of post-placement support for a successful employment outcome, this is of great concern.
In principle, the main Commonwealth government-funded post-placement support sources are the Disability Open Employment Services (DOES), Job Network (JN) members and CRS Australia (CRS).
Some submissions suggest that the quality and range of services provided by these agencies vary greatly between service providers. Submissions also indicate that the support services are insufficient to meet the ongoing needs of employers and employees with disability. Employment service providers suggest that the funding is inadequate to meet the spectrum of needs.
The 2005 Budget announced funding for additional places in Job Network, DOES and CRS Australia from 1 July 2006. However, it is still unclear whether the funding model and the amount of additional resources will be sufficient to ensure that those services can offer adequate support to people with disability and their employers.
Further, several submissions have raised concerns about the restrictions on when a person can access support from a government-funded service provider. In particular, people with mental illness or other episodic health conditions argue that it is extremely difficult to predict when support will be needed. They may therefore be unable to fit within the restricted time frames. Concerns were also raised more generally about what employers and employees with disability would do once the time limits expire. In particular, people with intellectual disability suggest that their needs will continue indefinitely.
There are also concerns about how people access on-the-job support when they find their job independently of a DOES or CRS provider. Some people may acquire a disability while in employment, some people may use a private recruitment agency and others may just answer a job advertisement.
None of these groups of people will have access to government-funded ongoing support through DOES or JN. It is unclear where they get the help they need and how they pay for it.
However, any person who is at risk of losing a job due to a disability may have access to support through the Jobs in Jeopardy Program. Several submissions suggest improved access to this program.
Interim Recommendation 17: Government-funded post-placement support
The Inquiry recommends a review of the post-placement support services offered by the Commonwealth government, including consideration of the following issues:
(a) funding levels for DOES, JN and CRS to provide on-the-job post-placement support;
(b) scope of services provided by DOES, JN and CRS;
(c) the appropriateness of time limitations on post-placement support; and
(d) access to the Jobs in Jeopardy Program.
Interim Recommendation 18: Other support services
The Inquiry recommends investigation into the following matters regarding people who obtain a job outside government-funded employment services, or who acquire a disability while on the job:
(a) where employees with disability and their employers currently access ongoing support services;
(b) who pays for those services;
(c) whether those services are sufficient; and
(d) any recommendations for improvements.
7.5.3 Develop guidelines for creating a flexible workplace
There are many aspects of day-to-day living that require some degree of flexibility in the working environment. In particular there is much discussion about creating family-friendly workplaces and workplaces that take account of the needs of the maturing workforce.[42] People with disability are amongst the groups of the population that would benefit from a flexible workplace. It may be therefore be helpful to develop guidelines for employers and provide model workplace policies.
The submissions to the Inquiry suggest a range of conditions that might be considered in developing a flexible workplace for all employees, and people with disability in particular. In creating guidelines it will be useful to take those suggestions together with the policies developed in the context of providing a family-friendly workplace.
For example, DEWR has developed Fact Sheets on creating a family-friendly workplace and a database of family-friendly agreement clauses on its website.[43] Many of those suggestions also apply to employment of people with disability.
Further, some companies may be willing to share their policies and provide examples of what has, and has not, worked.
Interim Recommendation 19: Flexible workplace
The Inquiry recommends the development of guidelines for creating a flexible workplace for employees with disability. It may be useful to coordinate such efforts with people designing family-friendly workplaces.
7.5.4 Conduct ongoing consultation regarding the impact of Budget changes to the employment services model
As discussed in Chapter 5 and in section 7.5.2 above, the 2005 Budget introduced a raft of reforms regarding government-funded employment services, some of which commenced on 10 May 2005 (the night the Budget was delivered), some on 1 July 2005 and some of which will commence on 1 July 2006. Predictably, some of the proposed reforms have been welcomed and others have been strongly criticised.
While it is too early to ascertain the true impact of the reforms, the Inquiry is concerned that some of the features may not in fact have the effect of providing better opportunities for people with disability to enter and remain in the workplace.
Submissions to the Inquiry suggest that further research into models of employment assistance would ensure that services better meet the needs of people with disability.
NESA urges a whole-of-government approach. [44] ACROD argues that:
- An authoritative independent analysis of the costs and benefits of employment programs to assist people with disabilities to find and retain employment would be in the interests of Government, taxpayers, service providers and job seekers.[45]
DEAC made similar suggestions:
- The Commonwealth research best practice models in providing employment assistance to people with a variety of disabilities and fund alternative employment assistance services.
- The Commonwealth invest substantial funds on research, demonstration projects and new employment assistance pilot programs with the aim of modeling new employment assistance services around specific disabilities i.e. ID, ABI, MS, psychiatric disability.[46]
A number of submissions commented on successful international programs into which there should be further research.[47] ACROD and Waghorn and Lloyd call for specific research into appropriate employment services for people with psychiatric disabilities.[48]
The Inquiry strongly recommends that DEWR augment its consultation with relevant parties in order to better understand the likely outcomes of the various measures proposed in the Budget regarding employment services. In particular, the Inquiry recommends a focus on:
- the impact of maintaining a cap on DOES places for those on the DSP
- mechanisms to ensure better cooperation between DOES and Job Network
- whether Job Network has sufficient expertise to assist people who access their services
- whether the Case Based Funding model is sufficiently funded to assist people with high support needs
- whether the recruitment and post-placement support provided by Job Network and DOES adequately caters to those with episodic needs (for example people with mental illness)
- the impact of the new employment services model on recruitment outcomes and long-term retention of people with varying disabilities.
Interim Recommendation 20: Employment services
The Inquiry recommends ongoing consultation and the collection and examination of data over the next 24 months regarding the impact of changes to employment services on people with disability, employers and employment service providers.
7.5.5 Investigate recruitment and support needs for people with mental illness
An overwhelming number of submissions highlighted the prevalence of mental illness in Australian society and the special needs of people with mental illness. In particular the submissions suggest that the episodic and often chronic nature of mental illness requires flexibility at all stages of the employment process. For instance, an assessment of work capabilities at a certain point in time may be an inaccurate indication of work capabilities at another point in time.
While the number of submissions discussing mental illness suggests that there should be a special focus on this area, the Inquiry emphasises that adjustments made in the context of mental illness has benefits for many other groups of people. For example, a workplace that has flexible working hours will benefit people with mental illness, and people with multiple sclerosis and HIV/AIDS. It will also benefit working parents who have episodic demands on their time.
Similarly a workplace that ensures access to a mental health hotline will not only benefit those with a chronic mental illness, it can also benefit other employees who go through a stressful period during their lives.
A submission by Waghorn and Lloyd makes detailed suggestions regarding an employment model for people with mental illness. SANE Australia has developed a 'blueprint' and guidelines regarding employment for people with mental illness.[49] Further, the Mental Health Council of Australia is currently conducting consultations on this issue in order to inform DEWR on the appropriate measures to take.
Interim Recommendation 21: Mental illness
The Inquiry recommends further investigation and implementation of measures that address the recruitment and support needs of people with mental illness, noting the general application of such measures.
7.5.6 Increase access to attendant care packages and work based personal assistance
The Inquiry heard that many people with disability were unable to seek employment due to the limited access to attendant or personal carers at home and in the workplace.
The problem of access to carers appears to be exacerbated by the separation between State and Commonwealth funding. For example, if assistance is required at home, the funding comes from a State or Territory government and if the assistance is required in the workplace, the funding is Federal.
Long wait lists exist in most States and Territories and there is insufficient funding available on a per capita basis. Further, the Work Based Personal Assistance scheme, which is Commonwealth funded workplace assistance, is restricted to people who have already commenced employment. The Equal Opportunity Commission Victoria recommended that access to 'Workplace Attendant Care Schemes' should be widened.[50]
Interim Recommendation 22: Home and work based personal assistance
The Inquiry recommends better coordination, increased funding and streamlined access to work and home based personal assistance to enable people with disability in full-time, part-time or casual employment, apprenticeships, traineeships and work experience programs access to the help they need to meet their employment or study obligations.
7.6 Encourage public and private sector leadership
7.6.1 Increase public sector employment
Many submissions to the Inquiry express concern about the fall in the Commonwealth public sector employment of people with disability and call for public sector leadership.
The 2005 Standing Committee Working for Australia Report also notes the decline in employment of people with disability in the Australian Public Service and recommends that:
[T]he Australian Government develop a consistent and standardised reporting system to:
Some submissions note various positive initiatives in State government which could be shared and promoted amongst the public and private sector.
- report on trend data for the number of people with a disability being employed by the Australian Public Service; and
- implement strategies to improve the participation of people with disabilities in the Australian Public Service.[51]
Interim Recommendation 23: Public sector leadership
The Inquiry recommends a national review of public sector employment of people with disability, including consideration of the following:
(a) collection of comprehensive statistics;
(b) reasons for which employment levels have fallen; and
(c) strategies to increase public sector employment of people with disability.
7.6.2 Develop a government procurement policy
Submissions, and discussions at forums convened by the Inquiry, note that it can be more difficult, and involve delay and expense, to make adjustments in work premises, facilities and equipment after the event. For example an existing employee may acquire a disability or a jobseeker may present a request for an adjustment.
As far as possible it is preferable if premises, equipment and facilities are designed to meet 'universal design' principles, to accommodate the widest possible range of human needs.
One submission makes several recommendations in the context of IT accessibility for people with vision impairments. One of those recommendations is that:
Government should be the leader and only implement IT systems which are accessible. Government could demonstrate leadership in this regard by introducing legislation which requires Government Departments, statutory bodies and Government enterprises to comply with "procurement" policy which requires all office equipment and software to be accessible.[52]
While it would be appropriate for the Commonwealth government to show leadership in this area there is no reason why other levels of government, and private sector organisations, should not also adopt accessible procurement policies. The United States and the Council of Europe provide good models for the development of a procurement policy.[53] In Canada, the Federal government maintains an Accessible Procurement Toolkit which is available to all.
In March 2005, the Australian Government Information Office (AGIMO) issued a Better Practice Checklist on assistive technology. This is a welcome development although it is restricted to information and communications technology and is not backed by specific mandatory legislative or policy requirements. It does not appear to have been extensively promoted within government or more generally.
Interim Recommendation 24: Government procurement policy
The Inquiry recommends further exploration into the feasibility and impact of mandatory accessible procurement policies for government agencies. To this end the Inquiry recommends research into international procurement policies and practices.
7.6.3 Develop a reporting scheme for employers
In addition to improving the quality of public sector employment statistics, some employers suggested that compulsory reporting for the private sector might prove to be a powerful incentive. Participants highlighted that such requirements already exist regarding the employment of women under the Equal Opportunity for Women in the Workplace Act 1999 (Cth). They suggest a similar model for the employment of people with disability.
Interim Recommendation 25: Reporting scheme for employers
The Inquiry recommends consideration of a mandatory reporting scheme regarding employment of people with disability.
7.6.4 Create and promote awards for employer best practice
Employer consultations and submissions to the Inquiry suggest that award schemes can be a significant incentive to private employers.[54] This initiative was also recommended in the 2003 Review of the Employer Incentives Strategy, which found that:
Recognition is important as it reinforces the employer's decision to hire a person with a disability. It provides tangible evidence of their achievements . Many of the larger businesses said gaining recognition enhances their reputation both as a good corporate citizen and an employer of choice.[55]
While such awards do already exist to some extent (for example the Prime Minister's Employer of the Year Awards), some employers suggest that they are not well known and therefore have little incentive value. Any new awards scheme should therefore be broadly promoted amongst the business and consumer communities.
An awards scheme could provide an opportunity for sharing information about best practice strategies. Nominees and winners could be requested to place their policies and case studies within the one-stop-information-shop. Furthermore the prize-giver could commit to broad publicity of their good practice and policy.
Interim Recommendation 26: Awards scheme for employers
The Inquiry recommends consideration of a widely promoted national scheme of awards for best practice in furthering employment opportunities for people with disability. Any awards scheme should require sharing of expertise with the business community.
7.6.5 Encourage employers to use recruitment agencies that have an inclusive process
As discussed in Chapter 5, ever-increasingly, the private and public sector use private recruitment agencies to hire staff. Some companies have a policy of using 'preferred recruitment agencies' which have the appropriate expertise and approach to ensure equality of opportunity for people with disability.[56] The more recruitment agencies that have such a expertise, the greater the opportunities for people with disability.
Interim Recommendation 27: Recruitment agencies
The Inquiry recommends that employers ensure that they use recruitment agencies that have policies and practices designed to encourage hiring of people with disability.
7.6.6 Create an inter-sector leadership coalition
The work of the Inquiry thus far demonstrates that strategies for increasing the employment opportunities of people with disability will require ongoing development.[57]
To this end, the Inquiry recommends that there should be a readily accessible representative group, from all sectors, which can engage in ongoing development of strategies regarding the employment of people with disability. This group should provide leadership to all sectors.
A useful set of principles has been articulated by National Diversity Think Tank in the context of an employer group:
To provide leadership in establishing an employer run entity to assist and encourage organisations to attract, retain and successfully integrate people with a disability into their organisations.
To assist organisations to develop pragmatic, tailored strategies & action plans to better attract, retain and integrate people with a disability into the workplace.
To provide a mentoring service, telephone help-line and information website, publications and guidance and support concerning issues including understanding and interpreting current legislation, all available from one source.
To facilitate an employer network for communication and knowledge sharing amongst member organisations, and establishing alliances with organisations which have successfully implemented effective practices.
To establish alliances with key partners and organisations who facilitate real outcomes related to the employment of people with a disability.
To heighten awareness of the benefits of attracting, recruiting and integrating people with a disability into an organisation as well as acknowledging how particular organisations have successfully achieved diversity.
To develop national and international benchmarks in conjunction with similar successful entities abroad.
To demonstrate high levels of innovation and social responsibility among Australian organisations.[58]
This provides a good starting point for creating a charter for an inter-sector coalition.
Interim Recommendation 28: Inter-sector coalition
The Inquiry recommends the creation of an inter-sector leadership coalition, including representatives from employers, disability groups, employment service providers and government agencies.
Back to contents page | Next chapterEndnotes: Chapter 7
[1] FACS, Employer Incentives Strategy Review, 2003, Action 3 - Provide targeted information, advice and support to employers about employing people with disabilities, p44.
[2] See FACS, Employer Incentives Strategy Review, 2003, Key Areas for Action, Action 2 and 3.
[3] See http://www.humanrights.gov.au/disability_rights/employment_inquiry/papers/issues5.htm
[4] See for example Submission 77B, RBS.RVIB.VAF Limited; Submission 80B, Blind Citizens Australia; Submission 113A, Australian Public Service Commission; Submission 72A, Scope Victoria; Submission 86A, Ai Group.
[5] See for example, Submission 131, Disability and Participation Alliance, p6; Submission 50, Deafness Forum Australia, p8.
[6] Submission 79, Australian Federation of Deaf Societies, p15; Submission 68, ACE National Network, p6; Submission 77, RBS.RVIB.VAF Limited, p3; Submission 114, ACROD, p5.
[7] See for example, Submission 68, ACE National Network, p8; Submission 79, Australian Federation of Deaf Societies, p15; Submission 100, Brotherhood of St Laurence, p9; Submission 25, Victorian Deaf Society, p3.
[8] Submission 68, ACE National Network, p8.
[9] Working for Australia Report, p130, 184. See also the submission from DEWR to the Standing Committee at p120.
[10] Productivity Commission, Review of the Disability Discrimination Act 1992, Report No 30, 30 April 2004, Vol 1, ppLIV-LV; pp426-428.
[11] For the full response of the Commonwealth Attorney-General to the Productivity Commission Report see http://www.ag.gov.au/PCDDA.
[12] See for example, Submission 49, Disability Council of NSW, p8.
[13] NZ Minister for Social Development 2005 as cited in Submission 100, Brotherhood of St Laurence, p11. See also Submission 114, ACROD, p5; Submission 68, ACE National Network, p6; Submission 17, Family Advocacy, p2.
[14] Submission 50, Deafness Forum Australia, p8.
[15] Submission 100, Brotherhood of St Laurence, p11.
[16] Submission 49, pp7-8. See also Submission 27, DEAC, p7.
[17] See for example, Submission 7, Name withheld, p4.
[18] Submission 23, Name withheld, p4.
[19] Submission 91, National Association of People Living with HIV/AIDS, p20; Submission 72, Scope Victoria, p8.
[20] Submission 50, Deafness Forum Australia, p7.
[21] Submission 50, Deafness Forum Australia, p9.
[22] Submission 114, ACROD.
[23] Submission 50; Submission 79; Submission 32, Australian Disability Training Advisory Council, p7.
[24] Submission 80, Blind Citizens Australia, p10.
[25] Submission 52, Ability Technology, p5.
[26] FACS, Employer Incentives Strategy Review, 2003, Action 9 - Improve the administration of the Workplace Modifications Scheme to make it easier to access, p50.
[27] Productivity Commission, Review of the Disability Discrimination Act 1992, Report No 30, 30 April 2004, Recommendation 15.1 pLV. See also Submission 68, ACE National Network, p9; Submission 32, Australian Disability Training Advisory Council.
[28] Working for Australia Report, p165-166.
[29] Working for Australia Report, p78-79.
[30] Submission 107, Uniting Care Australia, p5
[31] Submission 100, Brotherhood of St Laurence, p11; Submission 109, Waghorn and Llyod, p28, citing DEWR, Job Network Disability Support Pension Pilot: Interim Evaluation Report, Canberra, 2004. See also Submission 100, Brotherhood of St Laurence, p11; Submission 53, RANZCP, p2
[32] Submission 26, National Network Of Private Psychiatric Sector Consumers and Carers, p4.
[33] FACS, Employer Incentives Strategy Review, 2003, Action 6 - Develop a robust platform for work trials, p47.
[34] Submission 126, South Australian Government, p4-5.
[35] Submission 126, South Australian Government, p4.
[36] Submission 119, Parents and Professional Advocates, ACT, p2.
[37] Submission 119, Parents and Professional Advocates, ACT, p11.
[38] Submission 100, Brotherhood of St Laurence, p9.
[39] Submission 80, Blind Citizens Australia, p12. Similar recommendations are made in Submission 77, RBS.RVIB.VAF Limited, p2.
[40] House of Representatives Standing Committee on Employment, Workplace Relations and Workforce Participation, Working for Australia's Future: Increasing participation in the workforce, Recommendation 21, p172 (Working for Australia Report). See also Submission 86, AiGroup, p5.
[41] Submission 109, Waghorn and Llyod, p27-28.
[42] See for example, Working for Australia Report, p66-67, 134-7, 162.
[43] For the Fact Sheets see http://www.workplace.gov.au/workplace/Category/SchemesInitiatives/WorkFamily/Factsheets.htm. For the database see http://www.wagenet.gov.au/FFAC/Main/Default.aspx. See also the Working for Australia Report, p134-7.
[44] Submission 133, NESA, p12.
[45] Submission 114, ACROD, p2. See also Submission 23, Name withheld, p4; Submission 21, Disability Services Commission WA, p.2
[46] Submission 27, DEAC, p13.
[47] Submission 45, NSWCID: Sweden, Oklahoma, US. Submission 32, Australian Association of the Deaf: New Zealand and the US; Submission 58, Centre of Full Employment and Equity: US; Submission 77, RBS.RVIB.VAF Limited: Canada and New Zealand; Submission 100, Brotherhood of St Laurence: UK.
[48] Submission 114, ACROD, p3; Submission 109, Waghorn and Lloyd, p21-23.
[49] Submission 54, SANE, p2.
[50] Submission 118, EOCV, p15-16.
[51] Working for Australia Report, p172-3.
[52] Submission 77, RBS.RVIB.VAF Limited, p5. See also, Submission 44, Australians for Diversity Employment, p4; Submission 80, Blind Citizens Australia, p8; Submission 114, ACROD, p8.
[53] Re the USA see section 508 of the Rehabilitation Act 1973. European governments are now bound by a Council of Europe Directive on accessible procurement adopted in 2004.
[54] See for example: Submission 34, Manpower Services Australia, p7; submission 57, Queensland Department of Employment and Training, p1; Submission 67, Department of Consumer and Employment Protection, p7.
[55] FACS, Employer Incentives Strategy Review, 2003, Action 4. Identify mechanisms to recognise employers' performance and encourage ongoing improvement in employers' efforts to recruit people with disabilities, p45.
[56] Submission 65, IBM, p2; Submission 127, National Australia Bank, p2.
[57] See FACS, Employer Incentives Strategy Review, 2003, Key Area for Action 1.
[58] Submission 15, McCall (National Diversity Think Tank), pp29-30.



