Policy Submission: Review of the National Disability Advocacy Framework
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JFA Purple Orange submitted this Review of the National Disability Advocacy Framework to the Department of Social Services in 2015.
The fundamental importance of advocacy for supporting and improving the life chances of people living with disability cannot be underestimated. A review of the National Disability Advocacy Framework is timely and necessary in a time when the National Disability Insurance Scheme (NDIS) has the potential for great change for people living with disability.
Our submission sets out our position and considerations on the matters raised by the Guidance Questions provided by the Department of Social Services.
We recommend that planning for advocacy needs and requirements in a competitive services marketplace is undertaken at the earliest opportunity. The interests of people living with disability may not coincide with the pursuit of profit of a competitive services sector. Advocacy will be essential to maintain a focus on the interests of individuals and groups in such an environment.
We strongly recommend that serious consideration be given to relocating the funding role for advocacy services with another, statutorily independent, administrative body.
We recommend that, consistent with the previous recommendation, NDAF outcomes and outputs be developed, which recognise the advocacy needs and requirements of people living with disability, particularly in circumstances where a competitive services marketplace operates.
We recommend that work be undertaken to determine whether Administrative Appeals Tribunal processes will accommodate NDAP-related services and supports, and adjustments made to NDAF to reflect these circumstances.
We recommend that NDAF Principles be developed to address the advocacy needs of people living with disability who are not eligible for participation in the NDIS.
We recommend that NDAF Principles be augmented to emphasise the importance of building capacity for self-advocacy.
We recommend that NDAF Principle(s) be developed that protects the independence of properly accredited NDAP providers. This is particularly necessary in environments where advocacy work is consistent with NDAP objectives, the interests of people living with disability and professional integrity and practice, but critical of policies and practices of governments and/or private or public sectors.
We recommend that, consistent with the previous recommendation, appropriate NDAF Outcomes and Outputs be developed that recognise the independence of NDAP providers.
We recommend that NDAF Outcome(s) be developed addressing the important role advocacy plays in identifying and mitigating disadvantage and/or inequality and/or precariousness which impacts the lives of people living with disability.
We recommend, as a matter of consistency with NDAF Principles and Outcomes, a suitably worded Output be developed that clearly supports the concept of selfadvocacy with appropriately structured integration with NDAP-related services (e.g. advice and support).
We recommend that the NDAF be subject to ongoing reviews, at frequencies to be decided, for a period of up to three years (i.e. within the electoral cycle), allowing realistic amendments to be made to the NDAF if necessary, reflecting circumstances arising from the operations of the NDIS and a competitive disability services market.