NDIS Act Review and Participant Service Guarantee (Tune Review)
People with Disabilities (WA) Inc. (PWdWA) perovided this submission to the Australian Government – Department of Social Services (DSS) review into the operation of the National Disability Insurance Scheme Act 2013 (NDIS Act). People’s fair access to supports under the NDIS is an extremely important aspect of PWdWA’s advocacy work at both a systemic and individual level. Our submission is compiled on the experiences of people with disability, their families and carers. PWdWA is extremely concerned with the rising number of issues being considered by our advocates in relation to NDIS. The points raised in this submission are reflective of the hundreds of people we have assisted in advocacy on NDIS over the past year (300 in 2018-19).
This submission provides a number of recommendations that PWdWA strongly urges DSS to consider. These recommendations have been developed as a result of issues brought to our attention through our individual advocacy work and systemic NDIS work, including our NDIS Experience Survey. Consumers of Mental Health WA (COMHWA) have specifically provided input and recommendations to our responses to the Participant Service Guarantee. Our responses are also informed through PWDWA collaboration with Advocacy WA, Ethnic Disability Advocacy Centre, Explorability, Sussex Street Community Legal Service, Midlas and Your Say. Advocacy organisations are extremely concerned that the number and complexity of cases relating to NDIS is increasing, in part due to issue with the current legislation, and we are unable to currently meet the demand for advocacy on NDIS issues.
Inquiry into climate change and its impact on health and health systems
The WA Department of Health asked us to submit on the issue of climate change impacting people with disability. People with disabilities will likely be adversely impacted by climate change before other groups. As a demographic people with disabilities are more likely to have other health conditions, are more likely to be reliant on technology and require access to specialised equipment and resources to live the best life they can, and are less likely to be able to quickly respond without support to extreme situations of flood, heat, bushfire. As the impact of climate change is being felt it is people with disabilities who are being impacted first with temperature increases and energy supply having a major impact.
The Joint Parliamentary Standing Committee on the NDIS: The Inquiry into the NDIS.
PWdWA has provided a submission to the committee on the inquiry into the three areas of the NDIS;
- General Issues around implementation performance of the NDIS
- NDIS Planning
- Supported Independent Living (SIL)
PWdWA provides ongoing advocacy to individuals engaging with the NDIS processes at all levels. There is a rising number of issues being considered by the advocates in relation to NDIS. In 2018-2019 Financial Year, NDIS represented one third of all issues dealt with by PWdWA. This is outside of the specific funding received to assist people with NDIS Appeals. The requests for advocacy support on NDIS issues continues to grow.The points raised in this submission are reflective of the hundreds of people we have assisted in advocacy on NDIS over the past year (300 in 2018-19). Quotes and graphs are taken from our survey, which has over 300 respondents as of the first week of September 2019, and the focus groups we have attended and facilitated.
The impact of changes to service delivery models on the administration and running of Government programs: Senate Legal and Constitutional Affairs References Committee
This submission will focus on the following sections of the terms of reference:
C. the broader outsourcing of functions in the Human Services portfolio and at the National Disability Insurance Agency (NDIA), including:
ii. the impact of capped staffing numbers and the efficiency dividend at government departments/agencies, and
iv. the impact outsourcing has on service provision.
Accessibility of Offices of Members of Parliament in WA 2019
People With Disabilities (WA) Inc. (PWdWA) has recently conducted a project which sought to address the following question: how accessible (or inaccessible) are the offices of WA Members of Parliament (MPs)? In order to answer this, the Project Officer: created an accessibility checklist, and delivered training to volunteers on how to use the checklist, matched volunteers to their local MP office, coordinated the logistics of the reviews, and reviewed and analysed the final results. Ultimately, in light of ongoing concerns surrounding a lack of basic disability access, this project has determined that the offices of WA MPs are currently only accessible to people with disabilities to a limited extent.
Inquiry into Short Stay Accommodation Parliament of Western Australia
This submission is in response to an Inquiry by the Economics and Industry Standing Committee. Short stay accommodation is one of the range of holiday accommodation options now available to the general public. It’s form has changed with the digital disruption of models such as Airbnb and Stayz to include many more houses, units and apartments that are classified residential dwellings. Currently residential dwellings are not required to provide any form of universal disability access. Therefore, the vast majority (over 99%) of short stay accommodation that is advertised for the public is not able to be accessed by people with mobility disability, and not likely to be safe for people with other disabilities such as blindness and deafness.
Shelter WA and PWdWA provided a supplementary submission in response to questions raised during the hearing.
Supplementary Submission (PDF)
Review of the National Disability Standards for Transport 2018 Submission
This submission is a response to the issues paper on the Third Review of the Disability Standards for Accessible Public Transport 2002 (Transport Standards) released on 17 December 2017.
People with Disabilities (WA) conducted a survey and focus group in 2014, and again in 2018, to gain feedback on the accessibility of transport. The 2018 survey had 75 respondents, and the focus group 35 participants. This submission incorporates this feedback.
Review of the NDIS SDA Pricing and Payments Framework – Joint submission
This submission is made jointly by 20 organisations that are advocates for people with disability or providers of SDA housing and experienced with the way the SDA Framework is operating. The submission outlines key concerns about the SDA Framework that are hampering the potential to build a diverse, innovative and responsive SDA market meeting the housing needs and preferences of participants.
Elder Abuse National Plan Consultation
PWdWA is supportive of the Attorney-General’s proposed National Plan on Elder Abuse. This is a key step forward in creating a nationally consistent approach to the issue of Elder Abuse. While we are not providing a comprehensive response to the Consultation Paper we would like to highlight the need to include people with disabilities in any actions or initiatives proposed under the plan.
Senate inquiry: The need for regulation of mobility scooters, also known as motorised wheelchairs
In December 2017, the Senate moved that the motion by Senator John Williams for ‘the need for regulation of mobility scooters, also known as motorised wheelchairs’ be referred to the Rural and Regional Affairs and Transport References Committee for inquiry. PWdWA have provided a submission based on feedback from all members of the organisation, many of whom use powered mobility devices.
WA Parliament Inquiry into End of Life Choices - Joint Submission by PWdWA and AFDO
PWdWA and AFDO acknowledge the significant moral and ethical complexity that is associated with the concept of assisted dying. There are a range of views in the disability community about access to assisted dying.
Western Australian Legislative Council Inquiry into Elder Abuse
PWdWA is an organisation that represents people with disability and as such does not profess to be an expert in matters affecting elderly people. However, there is evidence to support that abuse and neglect that elderly people encounter in their daily lives is mirrored in those issues faced by people with disability due to the similar circumstances of likelihood of increased isolation, vulnerability and reliance on others for support. PWdWA has a great deal of evidence, knowledge and understanding in this area and are qualified in providing information that affects both groups of people.
National Disability Insurance Scheme Amendment (Quality and Safeguards Commission and other measures) Bill 2017. – Joint submission with DDWA
People with Disabilities (WA) Inc. (PWdWA) and Development Disability WA (DDWA) joint submission. The National Disability Insurance Scheme Amendment (Quality and Safeguards Commission and other measures) Bill 2017 establishes the Commonwealth’s regulatory responsibilities under the NDIS Quality and Safeguarding Framework. We strongly urge the Government to instruct a Royal Commission to investigate into the abuse and neglect of people with disability. We welcome that the Bill will establish a Quality and Safeguards Commission to provide national stability for quality and safeguards for people who use NDIS services.
Senate inquiry into the delivery of outcomes under the National Disability Strategy 2010 – 2020
This submission presented by PWdWA considers how effective the National Disability Strategy has been in achieving better outcomes for people with disability since its inception seven years ago. The submission is based on direct feedback from people with disability, their families and carers and data from other relevant submissions PWDWA have provided that relate to the six key areas of the National Disability Strategy.
Senate inquiry into the value and affordability of private health insurance and out of pocket medical costs
The submission is a synopsis of survey of PWdWA’s members all of whom have a disability or are a family member or carer of someone with a disability. The survey focused on two areas of the terms of reference which have the greatest impact on people with disability that is the take up of private healthcare and out of pocket expenses.
WA NDIS Information, Linkages, Capacity Building Commissioning Framework – Joint submission with DDWA
People with Disabilities WA and Developmental Disability WA thanks the WA Disability Services Commission for requesting feedback from peak advocacy groups representing those people directly affected by the services and supports likely to be offered under this part of the NDIS. Our organisations made written submissions to the ILC National Policy Framework and Commissioning Framework. The end result of the National Policy and Commissioning Framework was very good from our perspective and there is little we would consider needs changing from that work. Our submission highlights changes we hope will be considered in the grants process to ensure that organisation run by and for people with disability, their families and carers are prioritised.
Senate Inquiry hearing - Design, scope, cost-benefit analysis, contracts awarded and implementation associated with the Better Management of the Social Welfare System initiative
As an advocacy organisation we have not had people with significant disability coming to us in relation to automated debt recovery from Centrelink, nor have our advocacy partners. We are concerned there are many vulnerable people who are not on the DSP and will be caught up in automated processes.
Senate Standing Committee on Community Affairs, inquiry into Social Services Legislation Amendment (ending carbon tax compensation) Bill 2017
This Bill is being put in place to prevent new recipients of income support or concession cards from being paid the energy supplement. This includes people who will be on the Disability Support Pension or have a disability and are receiving New Start or a health concession card due to being on low income.
NDIS code of conduct submission
We welcome the introduction of the NDIS Code of Conduct and are encouraged that many of the recommendations made in previous consultations with respect to the NDIS Quality and Safeguarding Framework are part of the Code of Conduct. It’s important that people with disability continue to be engaged at all levels of system development to make sure their rights are upheld following the United Nations Convention on the rights of Persons with Disabilities.
You can read or download our submission in Word or PDF below:
Joint Standing Committee on the National Disability Insurance Scheme Inquiry into accommodation for people with disabilities and the NDIS
Accommodation issues are an extremely important aspect of PWdWA’s advocacy work at both a systemic and individual level. As the peak consumer voice for people with disability in Western Australia (WA), our submission is compiled on the experiences of people with disability, their families and cares. We have provided case studies where appropriate to furnish our statement. Accommodation covers a whole plethora of issues which are by nature, complex. Having read the transcript, we have focused on four key issues. These are:
- Best practice
Inquiry into the Social Services Legislation Amendment (Transition Mobility Allowance to the National Disability Insurance Scheme) Bill 2016
Opportunity to provide feedback to the senate inquiry into the proposed changes to Mobility Allowance eligibility. We have some concerns which we would like to raise due to potential inadequacy of transport costs being covered through the NDIS, and unintended consequences of what loss of the payment may mean too many people who rely on wheelchair accessible taxis.
New Disability Employment Services from 2018 – Discussion Paper
In 2015 PWdWA provided a submission on the National Disability Employment Framework- Issues Paper which was drawn on a representative sample of consumer advocacy cases expressing the types of issues and concerns that people with disability have around employment. As part of this submission we included a set of recommendations that people with disability consider necessary for Disability Employment Services to become more effective at delivering better outcomes for people. PWdWA encourages the Department of Social services to consider these recommendations in developing the new Disability Employment Services from 2018. These recommendations form an integral part of our feedback on the current discussion paper.
Joint Committee of Public Accounts and Audit’s Parliamentary Inquiry into qualifying for the Disability Support Pension (DCP)
People’s fair access to the Disability Support Pension is an extremely important aspect of PWdWA’s advocacy work at both a systemic and individual level. As the peak consumer voice for people with disability in Western Australia (WA), our submission is compiled on the experiences of people with disability, their families and carers. We have provided case studies where appropriate to furnish our statement.
Experiences of the National Disability Insurance Scheme Report
A report detailing feedback from the survey and forum about peoples’ experiences of the National Disability Insurance Scheme (NDIS) in Western Australia.
You can read or download the report in Word or PDF format below:
Inquiry into NDIS Savings bill
We were surprised, as were many other disability groups, to hear that legislation was being formed to set up the National Disability Insurance Scheme Savings Fund Special Account Bill. This raised a number of questions for us: Inquiry into NDIS Savings bill (Word) September 2016.
NDAP review submission
As part of the consultation for our submission on the National Disability Advocacy Program (NDAP), we circulated a short survey based on the questions posed in the discussion paper about advocacy services.
The survey was mostly completed by people who have used advocacy services. Most respondents cited individual advocacy as the main model they have used. There was also a recognition that there is a link between the different models of advocacy. “There is a need for all types of advocacy due to the diversity of individuals and families with disabilities as well as the reasons for needing advocacy”: NDAP review submission (Word) June 2016.
ILC commissioning framework joint submission PWDWA and DDWA
In the consultation draft of the Independent Living Centres (ILC) framework there is particular discussion on the need to be able to measure outcomes. In our view the outcomes that are outlined all sound like outcomes that might be good to have, but don’t sound specific and measurable enough: ILC commissioning framework Joint submission PWDWA DDWA (Word) April 2016.
NDIS savings bill hearing
A brief statement in support of our submission and our position that we don’t support this Bill: NDIS Savings Bill Hearing(Word) January 2016
On demand transport green paper
West Australians with a disability rely heavily on the on-demand transport system to access the community and go about their daily activities. So, it’s important that there is a system that responds and is flexible to what people with a disability need now and into the future: On Demand Transport Green Paper (Word)
A report detailing the survey and forum feedback about peoples’ experiences of the National Disability Insurance Scheme (NDIS) in Western Australia, November 2015:
Review of the NDIS Act
Do the objects and principles of the National Disability Scheme (NDIS) Act provide a sufficient basis for giving effect to Australia’s obligations under the Convention on the Rights of Persons with Disabilities? Review of the National Disability Insurance Scheme Act (Word) October 2015.
Behind closed doors
Prevention of violence, abuse and neglect against Western Australians with disabilities, July 2015:
National Disability Employment Framework
This submission draws on a sample of consumer advocacy cases expressing the types of issues and concerns that people with disabilities have around employment. Cases included in this submission came from issues or concerns around employment, or returning to work, that people with disabilities experienced using a range of different employment services and supports in W.A between January 2013 and June 2015: National Disability Employment Framework (Word) July 2015.
Review of the Disability (Access to Premises – Building) Standards 2010
It’s encouraging that the review focused on providing people with disability with dignified, equitable, cost effective access to public buildings and facilities and services within buildings and identifies any necessary changes to the standards.
In providing this submission we consulted with members through a combination of social media, group discussions and direct feedback. This submission reflects the views of people with disabilities who are networked with us. It’s vital that any proposed revisions to the standards are co-designed with people with disabilities: Review of the Disability (Access to Premises – Building) Standards 2010 (Word) June 2015.
Review of the Disability Standards for Education
Our and Developmental Disability WA’s response to the review refers to the experience of education in Western Australia only. In responding to the review we addressed the terms of reference in the context of the experience of our members and others as communicated to us by them: Review of the Disability Standards for Education (Word) June 2015.
Proposal for a National Disability Insurance Scheme (NDIS) Quality and Safeguarding framework
As part of this process, we worked with Developmental Disability WA, National Disability Service and the state Disability Services Commission on a consultation program to help people with disabilities to engage with, raise their concerns and recommend solutions and improvements about the framework. Individual advocates attended these sessions and the feedback is included in this submission: Proposal for a National Disability Insurance Scheme (NDIS) Quality and Safeguarding framework (PDF)
Senate Inquiry into the Adequacy of Existing Residential Care Arrangements Available for Young People with Severe Physical, Mental or Intellectual Disability
On 3 December 2014, International Day of People with Disabilities, the Senate referred the above concer to the Community Affairs References Committee for inquiry and report by 30 June 2015. On 17 February 2015 we and DDWA gave evidence to a hearing on this matter in Perth. A number of people with disabilities also attended the hearing and shared their personal experiences of living in residential care facilities which didn’t give them the kind of choice and control they needed to live the kinds of lives that they wish to: Senate Inquiry into the Adequacy of Existing Residential Care Arrangements Available for Young People with Severe Physical, Mental or Intellectual Disability (PDF) March 2015.
Information, Linkages, and Capacity Building Submission NDIS
We and Developmental Disability WA welcomes the understanding that the Information, Linkages and Capacity Building (ILC) framework is an important element of the National Disability Insurance Scheme (NDIS) because it allows for the development, advocacy, engagement and active participation for all people with disability and not just people who are eligible for Individual Funded Packages (IFD).
The ILC framework will provide one of the mechanisms which the NDIS can use to influence and shape mainstream services at a systemic level; to provide better outcomes for people with disability, their families and carers. It’s important to develop a framework that is transferable and can work across states, the success of which is critical for the implementation of the framework.
We see a focus on increasing the independence and capacity of the person with disability as part of the necessary work to increase participation of people with disability in the community. There is also the added benefit that this can potentially alleviate the pressure on families, carers, and systems that are already over stretched and under resourced, March 2015:
Submission options to add no-fault catastrophic injury cover to Western Australia’s compulsory third party insurance scheme
This submission addresses the options in the green paper, the issue of exclusions and potential models of support. Currently Western Australia operates a common law ‘fault’ based Compulsory Third Party (CTP) scheme, first introduced in 1943. For the injured third party it provides access to common law, that is, the injured person has a right to approach a law court to seek monetary compensation from the person ‘at fault’ for the personal injury and other related losses:
Review of the Criminal Law Mentally Impaired Accused Act 1996
This submission provides feedback to the WA Department of the Attorney General for the review of the Criminal Law (Mentally Impaired Accused) Act 1996 (WA) (the Act). The Act covers criminal proceedings for people charged with offences who are found by a court to be either mentally unfit to stand trial, or not guilty by reason of unsound mind. Recent media campaigns and targeted reviews have highlighted serious inequalities within the legislation and its procedures, where the fundamental human rights of people who have been found unfit to stand trial are not being met, December 2014:
- PWdWA Submission for the Review of the Criminal Law Mentally Impaired Accused Act 1996. (WORD)
- PWdWA Submission for the Review of the Criminal Law Mentally Impaired Accused Act 1996. (PDF)
This is a joint submission by disability and mental health stakeholders. You can find information about the signatories in Appendix 2.
The recommendations in this submission are divided into three main sections relating to overarching reforms to the Act, the processes that are prescribed by the Act, and the options available for treatment and support of individuals under the Act: Joint Criminal Law Mentally Impaired Accused Dec 2014 Submission Final. (PDF) December 2014
Justice Standing Committee
Submission to the WA Parliament Community Development and Justice Standing Committee’s Inquiry into Accommodation and Intensive Family Support Funding for People with Disabilities: WA Parliament Community Development and Justice Standing Committee’s Inquiry into Accommodation and Intensive Family Support (PDF) January 2014.
Review of transport standards
Submission for the 2012 Review of the Disability Standards for Accessible Public Transport: Review of the Disability Standards for Accessible Public Transport 2012 (PDF) May 2013.
Peel taxi and omnibus service
Submission for the Review of Peel’s taxi and omnibus services: Review of Peel’s Taxi and Omnibus Services (PDF) August 2013.
Rottnest Island Authority’s DAIP proposed publishing guidelines
Submission for the review of the Disability Access and Inclusion Plan (2007 – 2012): Review of the Rottnest Island Authority’s Disability Access and Inclusion Plan (PDF) January 2012.
Inclusive communication guidelines for emergency managers
Feedback provided on the Inclusive Communication Guidelines for Emergency Managers:
Groundwork document on the National Disability Strategy 2010–2020: National Disability Strategy 2010-2020 (PDF) January 2012.
National Disability Services groundwork
Feedback on the National Disability Services draft “Laying the Groundwork” (2011-2014): Laying the Groundwork 2011-2014 (PDF)
Human Rights Action Plan
Submission in Response to Australia’s Human Rights Action Plan, Exposure Draft. February 2012: Response to Australia’s Human Rights Action Plan (PDF)
Implementation of CRPD Article 9
Submission on the Implementation of Article 9 of the UN Convention on the Rights of Persons with Disabilities: Implementation of Article 9 of the UNCRPD (PDF) March 2012.
Review of the Fremantle Hospital Access and Inclusion Plan
Submission for the Review of the Fremantle Hospital and Health Services Disability Access and Inclusion Plan: Review of Fremantle Hospital Disability Access and Inclusion Plan (PDF) April 2012.
Review of Department of Commerce DAIP
Review of the Publishing Guidelines and Raising Public Awareness (2012-16) Disability Access and Inclusion Plan document: Department of Commerce DAIP 2012-16 (PDF) March 2012.
Base funding for higher education in Australia
Submission for the Review of Base Funding for Higher Education in Australia: Review of Base Funding for Higher Education in Australia (PDF) March 2011.
Review of education standards
Submission for the review of Disability Standards for Education: Review of Disability Standards for Education (PDF) April 2011.
Disability care and support
Submission to the Productivity Commission’s Inquiry into Disability Care and Support (Post Draft Report): Productivity Commission’s Inquiry into Disability Care and Support (PDF) May 2011.
Royal Australian College of GPs
Submission to the Royal Australian College of General Practices: RACGP Review of Standards for General Practices (PDF)
Standing Committee on Estimates and Financial Operations
Submission on the Standing Committee on Estimates and Financial Operations: Standing Committee on Estimates and Financial Operations (PDF) January 2009.
Access to premises
Submission on the Draft Disability Standards – Access to Premises: Disability Standards – Access to Premises (PDF) March 2009.
Australian disability parking scheme
Submission on the Harmonisation of Australian Disability Parking Schemes:
Australian Disability Parking Scheme (PDF) July 2009.
Submission to the Australian Government Pension Review: Australian Government Pension Review (PDF) September 2008.
National Disability Strategy
Submission to the National Disability Strategy: Submission to the National Disability Strategy (PDF) December 2008.