Proposed new Commonwealth individual disability advocacy program

Email:\ office@afdo.org.au
Website:\ www.afdo.org.au\ Phone:\ 1800 219 969
A.B.N.\ 25 105 510 898
Contact:\ Matthew Hall
E:\ matthew.hall@afdo.org.au
T:\ +61 414 678 520

16 January 2026

Disability Advocacy and Inclusion Reforms Advocacy and Inclusion Programs Branch Department of Health, Disability and Ageing

By email:\ disabilityadvocacyreforms@health.gov.au

Dear colleagues

Australian Federation of Disability Organisations (AFDO) welcomes the opportunity to

provide feedback on:

the matters raised by the Department in the consultation paper for the proposed new

Commonwealth individual advocacy program (Program),

the program policy framework (Framework).

This submission is informed by the lived expertise and experience of AFDO and our

members. Our members are disability-specific or cross-disability, population-based Disabled

Peoples Organisations, as well as family-led, disability-specific or cross-disability,

population-based, for-purpose organisations. As a result, this submission reflects the views

and needs of our communities.

AFDO agrees that individual disability advocacy services are important.

They are important as one essential component of a holistic, coordinated and properly

funded system.

This system includes disability advocacy (including; systemic disability advocacy, individual

disability advocacy, disability legal advocacy and self-advocacy), informal supports,

disability safeguarding, disability policy co-design and co-production, community capacity

building, and universally understood roles of grass roots campaigns, community service

organisations, Disabled People’s Organisations, Disability Representative Organisations,

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commercial service providers, regulators and government. It is within this context and

understanding of this system that AFDO broadly agrees with the Program as proposed.

However, we also have some recommendations to improve the Program and the

Framework.

In addition to the opportunity (as stated in the consultation paper (page 2)) to help the

Department understand our views on the Program and the Framework, we expect that our

views will inform and contribute to changes to the Program and Framework to ensure that

the Program supports people with disability in the best possible, and most efficient,

sustainable, and accessible ways to:

a. make our own choices

b. understand, protect and improve our rights

c. participate in Australian society on an equal basis with all Australians, and

d. make our lives safer by protecting us from all forms of abuse, and uncovering abuse when it occurs.

1. Feedback on the consultation paper

1.1. Role of disability-specific organisations in achieving Program outcomes

National disability policy processes and inquiries (including the Royal Commission into

Violence, Abuse, Neglect and Exploitation of People with Disability (DRC)) have

consistently recognised the importance of disability-specific expertise in addressing the

systemic barriers that people with disability face.

The DRC (Volume 6) found that disability-specific organisations are critical to identifying and

responding to systemic or structural discrimination embedded in systems, environments and

service design. This is particularly the case where barriers are not created from individual

circumstances, but from the way systems are designed, procured and implemented.

In practice, people with the same disability frequently encounter common and predictable

barriers arising from the way systems, environments, and technologies are designed.

Effective advocacy in these contexts requires specialist knowledge of how these barriers

operate in practice for the particular disability-specific cohort, and how these barriers can be

removed.

This is particularly important involving people from low prevalence disability cohorts (for

example, people who are blind or vision impaired). Individual disability advocates are

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unlikely to work with these disability cohorts, simply due to the small population size. As a result, they are likely to lack familiarity with core accessibility principles, relevant standards, and established solutions, reducing the effectiveness and timeliness of individual disability advocacy support.

The process risks addressing only the immediate presenting issue rather than the systemic issue, which is likely to lead to the systemic barrier continuing for other individuals requiring repeated individual disability advocacy interventions across the same systems.

This outcome is inconsistent with the consultation paper’s emphasis on advocacy that is effective, efficient and capable of resolving issues at the earliest possible stage.

Disability-specific advocacy organisations are better positioned to meet these objectives. This is particularly the case through repeated engagement with recurring barriers—such as inaccessible information, technology and built environments—these organisations develop deep, cumulative expertise that enables them to resolve individual matters more efficiently and in ways that align with established accessibility principles. This directly supports program objectives relating to rights protection, improved access to services, and sustainable resolution of issues, as articulated in both the current individual advocacy Guidelines and the consultation paper.

AFDO member, Blind Citizens Australia (BCA), has made a similar recommendation in its submission in response to the consultation paper. To the extent that the BCA recommendation aligns with our recommendation (below), AFDO endorses BCA’s submission.

RECOMMENDATION

That the Program expressly includes disability-specific
organisations (that are ACNC registered and run by people with
disability), including disability-specific organisations that service
people from low prevalence disability cohorts (such as people who
are blind or vision impaired) and that can provide disability-specific
individual disability advocacy services (whether in conjunction with
broader based individual disability advocacy services) as
organisations eligible to apply for funding under the Program.

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1.2. Role of cross-disability organisations in achieving Program outcomes

There is also a strong policy rationale, consistent with the direction set out in the Program consultation paper, for funding in each state and territory cross-disability advocacy organisations that deliver both individual and systemic disability advocacy services in an integrated manner.

The consultation paper explicitly recognises the value of advocacy models that can identify systemic issues through individual cases and contribute to broader system improvement, including through policy engagement and coordination.

Providing individual and systemic advocacy within a single organisational framework creates a mutually reinforcing cycle of knowledge and impact. Individual advocacy generates real-time evidence of how systems operate in practice, while systemic advocacy uses this evidence to pursue reforms that reduce the likelihood of future individual harm.

Conversely, systemic advocacy strengthens individual advocacy by equipping advocates with up-to-date knowledge of policy settings, standards and reform trajectories.

This integrated approach aligns with the Australia’s Disability Strategy 2021–2031, which emphasises coordinated, evidence-based responses to structural discrimination and improved accountability of systems and services.

Funding cross-disability advocacy organisations in each state and territory also promotes efficiency and consistency in the delivery of Program outcomes. It provides governments with a clear point of contact for policy engagement, supports consistent advocacy coverage across jurisdictions, and reduces duplication of effort, while enabling structured collaboration with disability-specific organisations that bring deep expertise in particular disability cohorts.

This approach reflects Department guidance that individual disability advocacy should be responsive, effective, and capable of contributing to broader system improvement, rather than operating in isolation.

AFDO member, Disability Voices Tasmania (DVT), has made a similar recommendation in its submission in response to the consultation paper. To the extent that the DVT recommendation aligns with our recommendation (below), AFDO endorses DVT’s submission.

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RECOMMENDATION

That the Program includes funds (whether in collaboration with and
supported by each relevant state or territory government) to be
allocated to establish and properly resource cross-disability
organisations (registered with the ACNC) that provide systemic and
individual disability advocacy services, run by people with
disability, in each state and territory.

1.3. Other matters

The Program goal must:

a. include a reference to people with disability understanding their individual rights, and

b. acknowledge that the support that may be needed to make individual choices which may include decision making supports, that may need to be provided independently of individual disability advocacy services.
The Program goal should not focus on or be “especially” for “those at the most risk of harm”, unless this is meant to convey that an individual with disability who does not understand their rights or is not able to make a free choice is at the most risk of harm.

Even if that is the case (and based on other references to risk of harm, we do not agree it is), the goal of the Program is better expressed as

all people with disability receive the support they need, when, where, and in the format they need, to make their own choices and understand and stand up for their rights.

Whilst the Framework includes several relevant definitions (about which we express our views in section 2.1 below), the Program must also clearly set out what the government means by “advocacy services” and “advocacy supports” within the overarching definition of “individual disability advocacy”.
Individual disability advocacy services are not services for or provided to family, kin, or carers of people with disability. Those people may be involved in accessing the services, but the services are not for them.

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In some circumstances, the family, kin or carer may provide some form of individual disability advocacy services (provided they can do so independently, and are not in any position of actual or perceived conflict of interest).

Accordingly, the first Program objective is better expressed as:

a. ensure people with disability can access individual disability advocacy services when needed, in the manner and location the person prefers or needs, and

b. provide information, resources and training to family, kin, and carers of people with disability to assist them and build their capacity to provide individual disability advocacy services (including training on when they are independent and recognising and managing conflicts of interest), only if that is the free choice of the person with disability.

The Program activities need to include:

a. in addition to building strong relationships between the department and funded individual disability advocacy organisations, mechanisms and supports to build strong relationships between or among:

(i) individuals who are professional or volunteer advocates

(ii) funded individual disability advocacy organisations and relevant disability communities, and

(iii) funded individual disability advocacy organisations and funded systemic disability advocacy organisations

b. in addition to using information from the Program to guide broader action, using information from the government’s programs funding systemic disability advocacy and other disability advocacy programs to guide broader action, and to inform the operation and possible improvements to the Program over time.

c. in addition to systems that monitor and evaluate the Program:

(i) a system for resolution of complaints by or on behalf of people with disability against an organisation or advocate that is offering or providing (or has offered or provided) individual disability advocacy services, and

(ii) a mandatory code of conduct for organisations offering to provide or providing individual disability advocacy services (whether under the Program or otherwise) and their employees, contractors and agents.

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2. Feedback on the Framework

2.1. Definitions

“Advocacy supports and services”

The wording set out in the column headed “Meaning” is the definition of “advocacy supports or services” (our emphasis) in section 8 of the Disability Services and Inclusion Act 2023. The Framework must also use the term “advocacy supports or services”.

Further, the Framework will provide greater clarity around the term, and the different roles of individual disability advocacy services (within the Framework and the Program) and other disability advocacy services or supports, including systemic disability advocacy (about which we provide further feedback, below), if the definition makes it very clear that an advocacy support or service does not need to satisfy ALL three paragraphs of the definition, but only one.

“Disability advocate”

A disability advocate does not have to be a trained or qualified professional. The consultation paper recognises this (on page 2), where it states individual disability advocacy:

can be delivered by a professional advocate, or a family member, friend or volunteer with support from an advocacy organisation.

The Disability Royal Commission (Volume 6, page 255) also recognised that individual disability advocacy can be delivered by:

a professional advocate, or a family member, friend or volunteer with support from an advocacy organisation.

AFDO accepts that an independent disability advocate must be a qualified professional.

“Disability advocacy”

As far as it goes, what is currently included as the definition is an accurate statement. However, it is not a complete definition. Further, to define a term by what it “enables” does not help know or understand what it is, or is not. As an example, voting in an election also “enables people with disability to participate in the decision-making processes that

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safeguard and advance their human rights”, but it is not a form of “disability advocacy” as understood or intended by the Framework or the Program.

We suggest that a better definition of “disability advocacy” is that adopted by the Disability Royal Commission (Volume 6, page 255), as follows:

acting, speaking or writing to promote, protect and defend the human rights of people with disability. There are several forms of disability advocacy:

Self-advocacy is where someone with disability speaks up and represents themselves, sometimes with support and training from community-based groups.

Individual advocacy is a one-on-one approach, undertaken by a professional advocate, relative, friend or volunteer.

Systemic advocacy involves working for long-term social change to ensure that the collective rights and interests of people with disability are met through legislation, policies and practices.

“Individual disability advocacy”

We accept the definition used is taken from the National Disability Advocacy Framework 2023 – 2025 (page 3). However, it is also important to note (on page 2) that document acknowledges that individual disability advocacy can extend to informal advocacy supports that may be provided through families, friends and carers of people with disability. The scope of the National Disability Advocacy Framework 2023 – 2025, however is on the provision of disability advocacy funded by Australian, state and territory governments.

The Framework would similarly benefit from making the same acknowledgement, and limiting the definition accordingly.

2.2. Make clear the Program is not to the detriment of systemic disability advocacy

AFDO is very concerned to ensure that the importance and separate role of systemic disability advocacy is not at the expense of, and is not lost by, the introduction of a much- needed program and framework for individual disability advocacy.

We are very concerned that the intention of the Framework may be to replace the existing system and role of systemic disability advocacy. Even if that is not the intention, we remain very concerned that others may misunderstand the intention, or misinterpret the Framework, because of imprecise language used about the role of individual disability advocacy in

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systemic disability advocacy and lack of a clear distinction being drawn between the two different forms of disability advocacy.

This is particularly the case in relation to the description of the “Sector strengthening stream” (on pages 4, 5, and 11 of the Framework):

The sector strengthening stream funds (individual disability advocacy) sector development by “working with government and community organisations to raise systemic issues” (page 4)

The sector strengthening stream “fund” (sic) sector development activities including …raising systemic issues” (page 5), and

The purpose of the sector strengthening stream will be to support “working with government and community organisations to address systemic issues for people with disability” (page 11).

AFDO accepts that there is a role for individual disability advocacy services to identify facts or circumstances that may indicate or give rise to potential systemic issues, to communicate those matters to government and to systemic disability advocacy organisations so they can be considered, and to provide any reasonable assistance requested by the government or by a systemic disability advocacy organisation in connection with those matters. If that is what is intended to be conveyed by the statements above, those statements need to be amended to properly reflect what is intended. For example, the reference on page 4 needs to be amended to read

working with government and systemic disability advocacy organisations funded by government to raise systemic issues.

If, however, the government’s intention or plan is for the Framework to give individual disability advocacy services a greater role in raising or addressing systemic issues, that is very concerning, and completely inconsistent with the analysis and recommendations of the Disability Royal Commission, and Australia’s obligations under the Convention on the Rights of Persons with Disabilities.

We urge the government to state clearly in the Framework the different role of systemic disability advocacy organisations and services, and that the Framework does not affect, and has no application, in the identification, funding or delivery of systemic disability advocacy services. We also recommend that the Framework confirms that the Program must

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supplement, connect and work with, existing systemic disability advocacy programs, funding, and services.

2.3. How grants will be awarded

Under the heading “How grants are awarded: an open and competitive grant process” (page 8), the Framework states the “new program” will be open for any eligible organisation to apply. It is not clear whether this is intended to refer to the Program (that is all three streams), or only to the “service delivery stream”.

Further, under the heading “Sector strengthening stream” (page 11) the Framework states that “the new program would not make major changes to the model. It would continue to be funded through a targeted process.” Again, it is not clear what is meant by the “new program”. To the extent to which it is the Program, this is directly inconsistent with what is stated on page 8.

To the extent to which it is a reference to the funding model for the sector strengthening scheme only, there is no valid or logical basis for applying different funding models and different conditions of eligibility to different activity streams within the same program. If the government considers that there are benefits to having new potential entrants apply for funding for the service delivery stream, the same benefits must exist for the other streams.

No part of the Program should be funded through a targeted process.

It is also possible that the Framework intends all “sector strengthening stream” services (perhaps except for “opportunities to strengthen the focus … around training and development”) to continue to be provided by the National Centre for Disability Advocacy. This is because of the wording (on page 11)

This support (that is, sector strengthening support) is currently delivered by the NCDA. The NCDA started in 2022 and is valued by organisations and advocates. The new program would not make major changes to the model.

This must be clarified in the Framework.

If the rest of the Program is open to any eligible organisation, there is no valid reason why the sector support stream will continue to be provided by the incumbent, without any testing of the market. This stream must be equally open to all eligible organisations.

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2.4. Other matters

BCA’s submission in response to the Framework has made several points or recommendations to those we make below. To the extent that the BCA submission aligns with our recommendations or submissions below, AFDO endorses BCA’s submission.

In allocating funding for individual disability advocacy services, the government must preference organisations:

a. run by people with disability

b. that employ advocates who are people with disability, and

c. that are ACNC registered.
The Principles of the Framework must reference the social model of disability, a human rights–based approach, with the individual at the centre and every interaction being evidence based and trauma-informed to provide a clear, principled foundation and ensure individual disability advocacy remains focused on achieving lasting, rights- based outcomes for individuals with disability who need advocacy supports or services.
Explicitly embed sustainable and adequate resourcing as a principle of the Framework.
Explicitly embed timeliness and responsiveness as a principle of the Framework and within the Program’s goals and outcomes.
Include service models for individual disability advocacy that use a mix of delivery approaches, incorporating face-to-face, phone, and online options, and local, regional, state, and national providers and services, that best meet the needs and preferences of the target group for the services, and that make effective and efficient use of available resources.
Include in the Framework systems and processes that provide a person with disability with access to specialised, high-quality, independent individual disability advocacy supports or services when needed, regardless of an individual’s location.
Apply the same contract funding periods to all disability advocacy services and supports funded by the Commonwealth.
Include provisions in the Framework for the funding models to balance stability with flexibility by supporting longer-term contracts whilst retaining mechanisms to introduce

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new providers to respond to emerging and unmet needs and to foster innovative advocacy approaches.

Expand workforce development opportunities beyond organisations funded through the Program to support aspiring and early-career advocates, build a sustainable future workforce, and strengthen capability across the disability, health and community service sectors.
Include education and awareness initiatives to improve understanding of individual disability advocacy with clear referral pathways for supporters and workers to connect people with disability to appropriate individual disability advocacy services.
Require all training, education, and information services, and all associated resources, to be co-designed and co-produced by people with disability, and to be delivered by people with disability or by organisations that are owned, led or staffed by, or by a minimum of (by number/percentage/dollar value) people with disability.
Include access to safe, accessible, inclusive, and free of charge specialised services including mental health support and independent legal advice within the services available through the Program.
Clearly outline whether administrative capacity is funded in addition to direct service provision.
Establish a single, nationally coordinated, de-identified data collection point for individual advocacy and complaints to enable timely identification of systemic discrimination, strengthen evidence-informed advocacy, and support government and sector accountability.

Yours faithfully

Matthew Hall National Manager – Systemic advocacy and policy Australian Federation of Disability Organisations (AFDO)

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