Australian Blindness Forum
PO BOX 1188
CANBERRA ACT 2601
www.australianblindnessforum.org.au
4 November 2016
Committee Secretary
Senate Standing Committees on Community Affairs
PO Box 6100
Parliament House
Canberra ACT 2600
By email: community.affairs.sen@aph.gov.au
Response to the Social Services Legislation Amendment (Transition Mobility
Allowance to the National Disability Insurance Scheme) Bill 2016
Thank you for the opportunity to respond to the above inquiry. ABF is the peak body representing the blindness and vision impairment sector. As a member-based organisation, we have drawn on input from our membership to formulate a response to the inquiry, with particular emphasis on the implications for Australians who are blind or vision impaired.
ABF and its member organisations support every person’s right to participate in and contribute to the community. This includes all people who are blind or vision impaired having the right to obtain and retain meaningful employment and live as independently as possible.
ABF has made the following 4 recommendations to the Senate Committee in relation to this Bill:
ABF recommends that recipients of the Mobility Allowance, who are eligible for the NDIS, be allowed to choose whether they transfer to the NDIS or continue receiving the Mobility Allowance. ABF recommends the Senate Committee reconsiders the reduction in the continuation period from 12 weeks to 4 weeks and reinstates it at 12 weeks. The reduction will have a detrimental effect on the employment prospects and overall wellbeing of a person who is blind or vision impaired as well as volunteering in Australia. ABF is calling for further information about how people who acquire a disability over the age of 65 and who need the Mobility Allowance are going to access subsidies that support transport to employment. ABF is seeking further clarity around continuity of support including further information on where the funding is coming from; how it is going to be
Australian Blindness Forum, PO Box 1188, Canberra, ACT 2601, www.australianblindnessforum.org.au
administered; what the eligibility requirements are; if it is adjusted for CPI; and, if it is for an individual’s lifetime.
Please see the attached submission for further detail surrounding these recommendations.
Thank you for the opportunity to respond to this inquiry.
Yours sincerely
Tony Starkey
Director
Australian Blindness Forum
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Australian Blindness Forum, PO Box 1188, Canberra, ACT 2601, www.australianblindnessforum.org.au
ABF response to
Social Services Legislation Amendment (Transition Mobility
Allowance to the National Disability Insurance Scheme) Bill 2016
4 November 2016
About the Australian Blindness Forum
The Australian Blindness Forum is the peak body representing blindness, low vision and rehabilitation in the blindness sector. ABF was formed in 1992 and is funded only by its members. ABF is an Australian public company limited by guarantee and governed by a Board of Directors.
Membership of ABF is open to any organisation that has as its primary objects the provision of services to people who are blind or vision impaired, or whose activities are substantially connected with the welfare of people who are blind or vision impaired. ABF is represented in every state and territory of Australia. All major organisations providing services to Australians who are blind or vision impaired are members of ABF.
As Australia’s representative to the World Blind Union, the ABF has strong connections with the international blind and vision impaired community. ABF comprises 16 blindness sector organisations whose expertise and knowledge are reflected in the following comments.
Background
ABF appreciates the opportunity to provide a response to the Senate Community
Affairs Legislation Committee on the Social Services Legislation Amendment
(Transition Mobility Allowance to the National Disability Insurance Scheme) Bill 2016 (the Bill).
ABF and its member organisations support every person’s right to participate in and contribute to the community. This includes all people who are blind or vision impaired having the right to obtain and retain meaningful employment and live as independently as possible.
This is consistent with:
the United Nations Convention on the Rights of Persons with Disabilities
(UNCRPD)
the Disability Discrimination Act 1992 National Disability Strategy 2010-2020.
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Due to the design of the National Disability Insurance Scheme (NDIS) individuals who acquire a disability such as blindness or vision impairment over the age of 65 will not be covered by the NDIS and must rely on aged care services. However, almost 75% of people who are blind or vision impaired are over the age of 65. Therefore, ABF has a very strong interest in ensuring the needs of people who are blind or vision impaired are included and recognised in any programs and services so they are not discriminated against or disadvantaged due to this arbitrary age delineation.
Research undertaken by Vision Australia in 2012 indicated that 58% of people who are blind or vision impaired of workforce age are unemployed compared with 14% of the wider population (ABS ‘Persons not in the labour force, Sept 2011)1. ABF believes, anecdotally, that this percentage may even be higher at around 70% of people who are blind or vision impaired being unemployed. This is a startling statistic and highlights the need to ensure people who are blind or vision impaired and who are in paid employment (or a qualifying activity) are provided as much support as possible to continue in that employment. The Mobility Allowance has always been crucial to maintaining employment with the flow-on effects of independence and social interaction for people who are blind or vision impaired.
National Disability Insurance Scheme
ABF understands that the purpose of the Bill is to transfer the Mobility Allowance to the NDIS to assist in funding its implementation.
ABF is aware that some people who are blind or vision impaired and who are eligible for the NDIS, are choosing not to apply for an NDIS package for a variety of reasons.
In particular, people who are blind or vision impaired are finding the registration process and planning and assessment processes inaccessible to a person with a vision impairment. For example, the registration material is not provided in an accessible format so a person with a vision impairment is unable to complete the registration form or ultimately read their plan. This is a huge deterrent for any independent person with a vision impairment to join the NDIS in order to obtain the funding to which they have previously had access.
Also, people who are blind or vision impaired often only need funding for a specific piece of equipment or episodic services and do not feel it is worth going through the NDIS registration, planning and assessment process for this support. Some people who are very active and who are participating in their community and employment may not need a large package under the NDIS but do still need access to the Mobility Allowance to assist them in maintaining their independence and employment. This could mean they are only applying for an NDIS package in order to get the Mobility Allowance and perhaps would be encouraged to demean themselves in order to ensure they are considered eligible. This seems like an
1 Blind Citizens Australia, Hello Employers, Blind Citizens Australia Employment Policy Suite,
http://wordpress.bca.org.au/polocy/, p.9, accessed on 4 November 2016
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unnecessary hurdle for people who are blind or vision impaired and, as a result, it will mean they will lose the Mobility Allowance and their ability to participate in employment.
ABF urges the Senate Committee to take into account how the transfer of the Mobility Allowance will affect those people who are blind or vision impaired and reliant on the Mobility Allowance to continue their employment but who are not receiving an NDIS package due to accessibility problems and other issues.
ABF recommends that recipients of the Mobility Allowance, who are eligible for the NDIS, be allowed to choose whether they transfer to the NDIS or continue receiving the Mobility Allowance.
Continuation period ABF understands the Mobility Allowance is currently available to recipients for a 12 week continuation period, during which they may continue to receive a payment while not participating in a qualifying activity (while they look for another job or another activity)2. The Bill will reduce the continuation period during which a recipient continues to receive the Mobility Allowance while they are no longer engaged in a qualifying activity from 12 weeks to four weeks.
ABF is very concerned this reduction in the continuation period will have a detrimental effect on people who are blind or vision impaired. As stated above, unemployment is very high in the blindness sector. It can take a long time for someone to find stable employment.
The Department of Social Services (DSS) provided data to ABF in October 2015 advising that, as at 31 August 2015, there were 2088 people participating in Disability Employment Services (DES) whose primary disability is identified as vision related3. DSS also said the data indicated that, overall, and without adjustment for people’s age and other characteristics, people whose primary disability is vision related do worse than the overall outcome for people in DES. The data indicated that: 22.7 per cent of people with primarily vison related disability are employed 3 months after their participation compared to 31.1 per cent for all participants 49.5 per cent are unemployed compared to 39.3 per cent for all participants. This data shows how hard it is for people who are blind or vision impaired to not only obtain some form of employment but also how hard it is to retain that employment. To lose the Mobility Allowance after only 4 weeks of not being engaged in a qualifying activity will have an enormous impact on an individual’s ability to continue to find work.
Further this reduction in the continuation period from 12 weeks to 4 weeks will have a detrimental effect on volunteers in Australia. If a person with a disability retires
2 Social Services Legislation Amendment (Transition Mobility Allowance to the National Disability Insurance
Scheme) Bill 2016 – Second Reading Speech, Thursday 13 October 2016, p.8 3 P.Broadhead, Department of Social Services, pers.comm., 13 October 2015.
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from paid work and seeks to engage in voluntary activities, it is unrealistic to expect arrangements to be made within 4 weeks.
ABF recommends the Senate Committee reconsiders the reduction in the continuation period from 12 weeks to 4 weeks and reinstates it at 12 weeks. The reduction will have a detrimental effect on the employment prospects and overall wellbeing of a person who is blind or vision impaired as well as volunteering in Australia. People over 65 years old
If people who are blind or vision impaired continue to work over the age of 65, they will be unable to access the NDIS and therefore the Mobility Allowance.
Given the government is raising the retirement age and the pension payment age, most people will need to continue to work over the age of 65. That is, the Government is creating programs and schemes, including the transition of the Mobility Allowance into the NDIS, that are not aligned to the age requirements in a variety of other Government policies and legislation such as the Social Security Act 1991, income support payments, the aged pension (age 67), NDIS (age 65) and tax benefits. The Government needs to ensure the age requirements and limits in all its programs and schemes are aligned with the Government’s expectations of an individual’s working life and retirement age.
In addition to paid employment, the removal of the Mobility Allowance for over 65s will restrict the volunteer capacity within the blindness community if those volunteers are unable to have supported travel over the age of 65.
With the transfer of the Mobility Allowance into the NDIS, it is not clear what equivalent support is going to be available to someone who acquires their disability over the age of 65 and who is still in employment or wants to contribute to the volunteer community and needs a Mobility Allowance in order to continue to these activities. These people would not benefit from continuity of support because they will not have received it in the past (they will not be ongoing recipients, they will be new to the allowance).
ABF is calling for further information about how people who acquire a disability over the age of 65 and who need the Mobility Allowance are going to access subsidies that support transport to employment. Continuity of support
ABF notes in the Second Reading speech, Minister Christian Porter said that the government is working to ensure that those not expected to transition into the NDIS (due to age or ineligibility) will continue to receive the support they need. He said the Bill “will ensure that continuity of support is provided to current recipients of Mobility Allowance who may not be eligible for the NDIS”4.
The Minister went on to say that “current recipients of mobility allowance who are still in receipt of the payment as at 30 June 2020, as they have been found to be
4 Social Services Legislation Amendment (Transition Mobility Allowance to the National Disability Insurance
Scheme) Bill 2016, Op.Cit., p.7
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ineligible for the NDIS, will continue to receive support in the longer term pursuant to a commitment to provide continuity of support for existing Commonwealth clients”5.
ABF is concerned that there is no detail as to how the continuity of support program is going to work in operation. ABF has not seen any specific information about continuity of support, particularly in relation to those people who are blind or vision impaired and over the age of 65 who will not qualify for an NDIS package and who will lose their current entitlements.
And, as stated above, continuity of support will only relate to existing Commonwealth clients. It is not clear what support will be available in place of the Mobility Allowance to people who enter the aged care sector (over 65) and are still in paid work but are not existing Commonwealth clients.
ABF is seeking further clarity around continuity of support including further information on where the funding is coming from; how it is going to be administered; what the eligibility requirements are; if it is adjusted for CPI; and, if it is for an individual’s lifetime.
Conclusion
ABF is concerned that the Bill transferring the Mobility Allowance into the NDIS will have a detrimental effect on people who are blind or vision impaired both under the age of 65 and over the age of 65. In particular, these amendments are taking away an individual’s choice and control which is contradictory to the original intent of the NDIS.
5 Ibid, p.8
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