Submission to the NDA Strategic Plan for 2004-2006
Introduction
Comhairle is pleased to have the opportunity to make a submission on the new NDA Strategic Plan for 2004-2006.
Since its establishment in 2000 the NDA has built a profile for itself both as an organisation impacting positively on the lives of people with disabilities and one which has sought to influence policy through submissions on forthcoming legislation and its involvement in working groups. Its submission on the Mental Health Act, 2001 received wide coverage. Its co-ordination of the Disability Legislation Consultative Group which was set up following the withdrawal of the Disability Bill 2001 has been influential in bringing the concerns of people with disabilities to Government. The development of research in the area of disability is an important part of the NDA's remit and it has had major achievements both in its range and its commitment to involving people with disabilities in research.
The publication of Guidelines for Involving People with Disabilities in Research was significant in the latter regard. The funding of the Chair of Disability Studies in UCD and the first annual NDA Disability Research conference, held in Dublin in 2002, are instances of the NDA's success in this field. Another innovative development has been the Research Promotion Scheme which facilitates disability groups to undertake research themselves. Comhairle is committed to cooperating with the NDA on research relating to people with disabilities, access and advocacy.
The four priorities highlighted in the NDA's First Strategic Plan have provided a useful framework for the NDA in its initial phase and they are broad enough to allow for further development.
The four priorities were:
- The equal status of people with disabilities.
- Guiding public service accessibility.
- Influencing attitudes in Irish society.
- Assuring best practice in services for people with disabilities.
1. The equal status of people with disabilities
Despite the advances produced by recent (and proposed) legislation in relation to the creation of equal status for people with disabilities there remain societal and institutional barriers which restrict the full exercise of that equality. Social, cultural and economic trends can unwittingly diminish citizenship possibilities for minorities not just in the statutory area but also in the area of attitudes. Parity of citizenship is a key factor in achieving equality as it encompasses the right of an individual to share to the full in all aspects of social and cultural life. For example, a culture which emphasises work (in the labour market) inevitably confers lower status on those not in employment. Although there have been improvements in the status of people with disabilities, negative attitudes and institutional practices based on stereotypes are still part of the background assumptions and need to be constantly questioned. Unemployment among this group is still high.
2. Guiding Public Service Accessibility
Guiding and monitoring implementation by the NDA of the programme to make public services accessible to people with disabilities is a very necessary initiative as the most visible form of discrimination is still a physical barrier to a building. The Building Regulations 2000, the introduction of "visitability" standards for new houses by the Department of the Environment and Local Government and the publication of a new edition of Buildings for Everyone by the NDA have been useful stages along this road. However, much remains to be done. For instance many older public buildings are still not accessible to those with mobility impairments and there is no agreed programme to make alterations. The last NDA Strategic Plan spoke of "'guiding and monitoring implementation of the programme to make public services accessible to people with disabilities within five years." This work will continue to require attention under the new plan. Access is not just a matter of level entry; it also concerns information and electronic systems. The NDA's development of website accessibility guidelines (IT Accessibility Guidelines - 2002 ) is a very valuable initiative to prevent new barriers arising.
3. Influencing attitudes in Irish society
The NDA's role in influencing attitudes is important - it can highlight the issue of public awareness through educational programmes aimed both at schools and the whole community, through challenging expressions of prejudice and through promoting positive images of people with disabilities in all areas of the media.
4. Assuring Best Practice in Services for People with Disabilities
In the area of best practice in services for people with disabilities the work that the NDA has begun in the area of standards and quality is very important. Standards in these services are essential to an enhanced quality of life for many people with disabilities. Because services in Ireland are frequently provided by voluntary organisations with different traditions and funding arrangements, the development of overall standards is also important in ensuring equity of access.
In involving user and service provider groups and the wider community in a partnership to develop standards, the NDA has increased the likelihood of wide acceptance of the standards to be agreed. It has also acknowledged the efforts of organisations which have worked internally to promote quality. This approach should continue in the context of the new strategic plan.
Strategic Plan 2004-2006
While the priorities from the NDA first Strategic Plan need continued emphasis in the new Strategic Plan 2004-2006, it is important the NDA examine areas which have been neglected significantly in the past, like the treatment of people with intellectual disability. It is also important that the NDA devise a strategy to highlight the effects of major changes in Government policy like the mainstreaming of services for people with disabilities and the forthcoming Disabilities Bill 2003.
Mainstreaming
Best practice in services has a wider remit than disability services. In relation to mainstreaming of services for people with disabilities it is important to ensure that mainstream agencies give a quality service, that any gaps in mainstream programmes are made good, and that specialist supports are available where needed.
Complaints System
The NDA, along with most organisations of people with disabilities, has emphasised the need for a rights approach to services. An aspect of such an approach and of quality of services is a fair and transparent complaints system. The NDA's work in developing standards has enhanced the quality of specialist services available to people with disabilities. Quality involves constant monitoring and the possibility of redress in the cases where things go wrong between the consumer and the voluntary or statutory body providing the service.
In the 2000-2003 Plan, under "Quality Services", the possibility of "taking appropriate action when services were inadequate" was mentioned. In some sectors, such as home help and personal assistance, present services are generally accepted to be inadequate either because of restricted funding or because of regional variations.
Adequate Resourcing of Services
Within the area of accessible information Comhairle would point to the fact that such accessibility is only meaningful if the services are available to meet people's needs. Information is of limited value if it can only tell people that, for example, the Disabled Person's Housing Grant is not available in their region this year, or that there is a twelve-month waiting list for the appliance that they need.
Cost of Disability Payment
Another area where services could be construed as being inadequate is that of income-maintenance. Studies have shown that people with disabilities are at greater risk of poverty and unemployment and as a result are precluded from equal participation in society. This is especially true for people with significant disabilities.
A recent studying the UK by Zaidi and Burchardt (2003) concludes that
"the extra costs of disability are substantial, especially for disabled people living alone and those extra costs rise with severity of disability."also states that:
"these are important findings since they have implications for the adequacy of disability related state benefits and for devising poverty thresholds when comparing poverty across people with varying severity of disability."
Disability payments at present make no provision for aids and appliances, extra medical costs or transport and travel even though people with significant disabilities may incur higher costs in all of these areas. All groups dealing with disability concur with the view that a cost of disabilities payment is essential to promote independent living. It is important that the NDA continues research to pursue this issue.
The NDA would have useful inputs to offer in the above areas. It is important that the NDA highlights gaps which are due to under-funding and underdevelopment of services alongside those due to under-performance by specific agencies.
Working in Partnership
There is a range of organisations working in the area of disability. These include voluntary and statutory organisations. There are possibilities of confusion in the public mind and overlap and duplication of effort inherent in the functioning of many of these organisations. It is important that the NDA in its Strategic Plan clarifies the role of the NDA and the boundaries of its work in relation to other specified organisations like the Equality Authority.
Comhairle hopes that these observations will be of some assistance to the NDA in the challenging task of drawing up a new Strategic Plan. Comhairle is committed to an effective and purposeful relationship with the NDA. We look forward to building on the close relationships that we have developed with the NDA to ensure that both our agencies are informed of and add value to each other's work and avoid unnecessary duplication.
