Women With Disabilities Australia (WWDA):
Submission to hhe National Disability Advocacy Program Review

Contents

Bibliography

Introduction

Women with Disabilities Australia (WWDA)

Women with Disabilities Australia (WWDA) is a federating body of individuals and networks in each state and territory made up of women with disabilities and associated organisations.

WWDA seeks to ensure equal opportunities in all walks of life for all women with disabilities. In this it aims to increase awareness of, and address, issues faced by women with disabilities in the community. It links women with disabilities from around Australia, providing opportunities to identify and discuss issues of common concern. WWDA works in partnership with other disability organisations and women's organisations, and generates and disseminates information to women with disabilities, their families and carers, service providers, government and the media. WWDA is inclusive and does not discriminate against any disability.

WWDA and the Disability Advocacy Program
The Disability Advocacy Program was established to support advocacy services as defined in the Disability Services Act 1986. The Program has enabled assistance for eligible organisations to provide three types of advocacy services - self advocacy, citizen advocacy and group advocacy which are defined under Sections 7 and 9 of the Act.

Since its inception there have been several reviews of the Program while, at the same time, advocacy services themselves have clarified and focused their role. WWDA's submission to the Disability Advocacy Program Review is made within this context of progressive change to the Program and changes within public policy debate around disabilities.

In addressing the six issue areas raised under the Terms of Reference of the Disability Advocacy Program Review, WWDA seeks to give particular emphasis to the following:

• the role of advocacy in public policy processes and debates;
• particular advocacy needs of women with disabilities; and
• accountability tools for resource distribution and management in disability advocacy.

Disability, Public Policy and Advocacy

The Social Construction of Disability
The position from which people with disabilities seek to participate fully in the community is socially constructed rather than in direct relationship with medically defined impairment. That is, social, economic and political realities impact directly on, and give meaning to, the degree to which a person with an impairment is regarded as disabled. In many respects disabling arises from the community's response to impairment.

These social, economic and political realities are made up of a multiplicity of factors which are reflected in a multitude of ever changing attitudes, relationships and communications. Each of these impinge on a person's ability to take part in the life of the community on an equal level with others.

Recent writers have noted that the analysis of the social construction of disability does not fully account for the experience of women with disabilities - as is the case with most current feminist analyses (Morris 1996, Meekosha 1997).

The rate at which these multiplicity of factors can change is reflected in our changing world. Community attitudes towards people with disabilities change. There are changes in community infrastructure and services which enable people with disabilities to participate more fully in the life of the community. Access to education, training and paid work has improved (though this is more for men than for women with disabilities).

A key contributor to these changes is organised advocacy – advocacy by people with disabilities, by others in the community and by the example of national and international systemic changes. Many of these positive changes and advances for people with disabilities are now more secure, through the enactment of the Disability Services Act (1986) and the Disability Discrimination Act (1992) and the enabling Commonwealth/State Disability Agreement and the Commonwealth Disability Strategy.

Advocacy, both individual and systemic, continues to play an essential part in seeking fundamental rights for people with disabilities and is strengthened in this work through both the legislation and its supporting agreements and programs.

However, the existence of legislation is not enough alone. It is through individual and systemic advocacy – for real outcomes – that conditions and integration within society can be gained for people with disabilities. Advocacy confronts discrimination from a legislative platform while also working within the wider community to educate and bring about positive, incremental changes.

Role of Advocacy in Public Policy
Disability advocacy is integral to any social, economic and political advancement for people with disabilities. It is the nature of advocacy that its focus will shift as changes occur in the social and material conditions of those for whom advocacy takes place.

For example, disability advocacy initially provided the impetus for legislative change and subsequently supported improved employment and living conditions, and improved access to mainstream services in education, training, housing, and so on. Recently, disability advocacy, including the work of WWDA, has brought to public notice the physical, sexual and financial abuse of people with disabilities in some institutional and group home settings.

Advocacy is not something which can be completed. It is dynamic and integral to the social, economic and political processes and debates in our community. Disability advocacy operates in this changing reality to:

• clarify and focus the opportunities for people with disabilities to participate fully in society;
• to inform and develop public debate around the position of people with disabilities;
• to grow and maintain that debate within, and for the benefit of, the broad community.

Whether it is individual or systemic, the importance of advocacy is that it advances and maintains the debate at a community level and amongst people with disabilities so that change can occur in the reality and perception of what is valued in human persons and human behaviour. Inevitably, the parameters of this debate change as milestones are achieved and incremental gains made in the advancement of the community, and the role of people with disabilities within that community. In this context, both individual and systemic disability advocacy is linked with the broader legislative base, and the funding of advocacy services by government must be maintained.

Individual and Systemic Advocacy
Advocacy challenges the viewpoint that people with disabilities can be treated in ways that are less than for other human beings in terms of their needs and rights to make decisions for themselves. A primary goal of linking individual and systemic advocacy is to develop acceptance of difference at both a personal level and at a community level, so that we have a society that is inclusive of people with disabilities and one that is responsive to their interests and human needs. Individual and self advocacy provide critical information and experience that enables systemic advocacy to represent the views and experience of people with disabilities. The outcomes of systemic advocacy can then inform the wider community of choices and strategies to make change necessary for the inclusion of people with disabilities.

Individual Advocacy
Individual advocacy recognises the person with disabilities as the direct client and either advocates with that individual, or assists them to advocate for themselves. Where possible, the aim of individual advocacy should be to skill the person to be able to advocate on their own behalf.

Self advocacy may be undertaken in conjunction with the family and other carers of the person or, where people are not self advocating, it may be undertaken by the family or others on behalf of the person. In other cases, where the family or other carers do not have the resources or expertise to advocate – or where it is inappropriate for them to be advocates – others may advocate on behalf of the person with disabilities, creating "bridges of understanding" between the individual, their families and carers and the person's immediate environment.

There have been significant, incremental steps over a period of time to protect and enhance the rights of people with disabilities and to respond to their needs as community members. Autonomous advocates can assist all of these processes with individual care, knowledge and expertise. Importantly, individual advocacy provides information of day by day situations upon which systemic advocacy builds a bigger picture.

Systemic Advocacy
Systemic advocacy can respond on a broader level to the immediate needs of this significantly disadvantaged group while at the same time analysing the information provided by individual advocacy to inform policy directions and program developments on the needs of individuals with disabilities. Systemic advocacy aims to ensure that public debate and funding is focussed on responding to what constitutes the best outcomes for the consumers – people with disabilities.

Systemic advocacy also aims to increase the participation of people with disabilities in self advocacy and the development of public debates.

The individual and systemic advocacy undertaken by advocacy organisations to date has resulted in improved services and greater accountability mechanisms in areas such as institutional and group house set ups. This has occurred largely as a result of individual advocacy on instances of physical, sexual and financial abuse and the capacity of systemic advocacy to ensure that these individual circumstances can inform a wider public debate (Sceriha 1996).

Critically, the linkages between individual and systemic advocacy must be maintained and developed further, possibly through the establishment of appropriate information systems and ethical research.

Gender and Disability

People with disabilities make up approximately 18% of the Australian population, and women and girls are at least half of this group. Yet they are still categorised as a special interest group and their experience is isolated from the mainstream and marginalised.

Women with disabilities in Australia:

• are less likely to be in paid work than other women, men with disabilities or the population as a whole;
• earn less than their male counterparts;
• are less likely than their male counterparts to receive a senior secondary and tertiary education;
• are less likely to own their own houses than their male counterparts;
• are more likely to be institutionalised than their male counterparts;
• often are forced to live in situations in which they are vulnerable to violence;
• are more likely to experience violence at work than other women, men with disabilities or the population as a whole;
• are less likely to receive vocational rehabilitation or entry to labour market programs; and
• report a greater need for unmet help than their male counterparts. (Anderson 1996).

The following sections summarise priority areas of concern to WWDA where equalising opportunities for women with disabilities requires a major effort on the part of advocacy services – both at an individual and a systemic level.

Citizenship
Women with disabilities share many of the ordinary aspirations that all women without disabilities have a right to. This includes being part of and participating in the social life and surrounding community within which they live. The right to such participation in the life of the community is protected in state and commonwealth legislation and in international conventions, yet for women with disabilities it is still not a reality and it is difficult for women with disabilities to attain true citizenship (Meekosha, forthcoming). It is encouraging that the current Federal Government is committed to encouraging people with disabilities to access the same opportunities as those enjoyed by the general community.

Basic Rights
Such opportunities include having the fundamental rights enjoyed by all citizens that they should be able to feel safe, to be free from exploitation and sexual abuse, to have access to public services and to be able to make their own life choices.

What is an accepted part of living for people without disabilities is still at the core of what many women with disabilities aspire to. This includes being able to live independently, to be accepted for who they are, and to have their emotional and psychological needs as human beings acknowledged.

Participating in Community Life
Women with disabilities also hold expectations to participate fully within society through relationships, caring for children and living with dignity and respect. Participating within society requires access to information, education, health, transport, housing, facilities and equipment, public services and work based and home based personal care.

Advocacy and Needs
The aspirations of women with disabilities are essentially no different to the aspirations of women and men without disabilities. However, women with disabilities face issues which would not necessarily be faced by women without disabilities. This therefore demands a careful analysis of their needs alongside their aspirations. Advocacy plays an important role in assisting women with disabilities to exercise full citizenship and should be supported by government to do so.

Employment
Women with disabilities, in general, have not participated fully in the employment revolution that has occurred for women in Australia in the last 20 years. This is due to the double disadvantage of both gender and disability discrimination encountered by women with disabilities (ADACAS 1994, Pane 1995).

The 1993 Australian Bureau of Statistics Survey, 'Disability, Aging and Carers' illustrates that in terms of paid employment, the participation rate of women with disabilities trails that of men with disabilities and women without disabilities.

The participation rate of females with disabilities in the workforce was 39.9%. This contrasts with participation rates of 52.6% for men with disabilities, 65.9% for women without disabilities and 88.2% for men without disabilities. These figures show that women with disabilities are seriously disadvantaged in labour market participation.

Systemic Barriers to Employment
Barriers to paid employment can be divided into two areas:

• Within the workplace, such as employers' and co-workers' inappropriate attitudes, job design, lack of attendant care and inflexible work arrangements.
• External to the workplace, such as lack of access to education and training, knowledge, access to employment services, issues of assertiveness, child care etc. Individual and systemic advocacy directed at employment for women with disabilities is critical in equalising the opportunities for women with disabilities to increase their paid employment rate, and enabling women with disabilities to have real choices and resources appropriate to quality of life.

Such advocacy needs be both systemic and individual, targeted to:

• remedy discriminatory attitudes of employers, industrial associations and workers, towards women with disabilities;
• increase access to education and skills training services to ensure that the employment needs of individual women are met;
• achieving flexible work arrangements which provide increased employment opportunities for all workers, including women with disabilities; and
• brokering access to and information about skills and employment opportunities for women with disabilities.

Poverty
The United Nations has recognised that women with disabilities women with disabilities are the poorest of all groups in society. Poverty is a fact of life for many women with disabilities who often lack the resources to attain what is considered essential in Australian society, including employment, adequate and appropriate housing, nutrition and health care.

The impact of poverty on the health status and quality of life experienced by women with disabilities is undeniable. Poverty also exacerbates the negative self image that many women with disabilities have about themselves in relation to others in society.

In Australia, the social security system validates the need for, and offers income support to, women facing specific disadvantage, including women who are aged, unemployed, sick or with a disability. Additional support is available to families to assist with the costs of raising children. However, women with disabilities face extra costs directly related to disability and these costs are often not accounted for in the calculation of benefits. Women with a disability who have a waged partner can lose all benefits related to their disability.

With the increasing feminisation of poverty, women with disabilities face a bleak future unless specific interventions are made to remedy the current inequalities in resources. The government is urged to work in partnership with women with disabilities to seek these remedies.

Health Services
It is well known amongst people with disabilities that more health research funds are directed towards the investigation of specific disabilities rather than towards the investigation of health for people with disabilities.

Women with disabilities have particular difficulty accessing general health information and services. For example there is little in the way of guidance for practical help in the management of general female health which means that important issues like education, menstruation, contraception, exploitative relationships, sexual assault, menopause, late onset incontinence and osteoporosis remain largely unaddressed.

Although women's health services are sometimes sympathetic, their services and that of mainstream health services and facilities are generally inaccessible for women with disabilities. There are few health services with disability specific programs.

A recent study by the Victorian branch of WWDA found that medical and health services treat women with disabilities firstly in relation to their disability and secondly to their needs as a woman (Temby 1996). This fact has been noted by other researchers who state that as long as women with disabilities are seen as less than whole people in a medical model, their anatomy will be the major focus of their identity (Blumberg 1993).

National Health Policies
Current national health policies, strategies and campaigns do not adequately address the health needs of women with disabilities (Cooper and Temby 1995).

The health needs of rural women with disabilities are largely unaddressed and the lack of appropriate health care in rural areas results in their remaining invisible. A result of this invisibility in rural areas is that women with disabilities are even more isolated.

The development of appropriate health models for pregnant women and mothers with disabilities is another area that is largely ignored as is the area of sexual health for women with disabilities.

Systems advocacy should be supported to bring the basic health needs of women with disabilities to the attention of government, the public, health service providers and women with disabilities so that they can be appropriately addressed. This should build on recent work by organisations such as Women With Disabilities Australia.

Violence
Many women and girls with disabilities live in situations where their dependency on others for assistance places them in powerless situations. Women with disabilities are targeted by perpetrators, and can be subjected to multiple forms of violence, including physical, psychological, sexual and financial.

Violence by attendant carers or institutional carers against women with disabilities is often not recognised by the organisation and can be tolerated by the woman because of a lack of perceived options and fear of retribution.

There are virtually no organisations set up to deal with violence against women with disabilities and many women do not know where to go for help. Most especially, where violence is occurring, services that are set up specifically to meet the needs of women often discriminate against women with disabilities, referring them to disabilities services who in turn refer them back to women's services.

It is critical that both individual and systemic advocacy should draw attention to violence against women with disabilities and support individual women as they escape situations of violence. This should build on the work currently being carried out by Women With Disabilities Australia, the Disability Council of New South Wales and others.

The Government's Policy Agenda

Wider Choices
WWDA supports the Coalition Government's commitment to providing people with disabilities and their families with a wider array of choices in their lives. In particular WWDA notes the Government's commitment to the provision of advocacy services to people with disabilities that are disadvantaged by distance, ethnicity, multiple disabilities or who are unable to provide self advocacy. WWDA also notes the Government's pre-election recognition of the importance of the continuation of advocacy as an important element in facilitating access and choice for people with disabilities, their families and carers.

The Family
It is important to acknowledge and support the contribution families provide to people with disabilities and WWDA is encouraged by the Government's recognition that providing an economic and social environment in which families can achieve their full potential is crucial to maintaining a strong, cohesive and compassionate society (Moylan 1996b).

However, WWDA rejects the proposition that "Advocacy services create barriers between people with disabilities and their family". Advocacy works in a support role to families who are seeking ways of increasing the participation of the person with disabilities within society. In these instances advocacy services can build bridges between families and the wider community while also supporting families in representing the interests of their family member with disabilities.

Furthermore, WWDA urges the government to take note of the fact that people live in different family structures. For example, there are families of origin and families of choice or destination, each of which has differing characteristics, relationships, decision making processes and power arrangements.

Family Jeopardy
However, even with additional resources and supports in place, there are times when the family is unable to deal with internal and external pressures. When families as carers are unable to deal with both internal and external pressures, in spite of additional resources, the most vulnerable member of that unit – the person with disabilities – can be placed in physical, economic and psychological jeopardy. Advocacy is critical where issues of safety and quality of life needs cannot be provided through the care of the family or where, as in many instances, the family does not exist as a support for the person with disabilities.

In instances where the family is a site of violence, the role of advocacy is not one of creating barriers between the person with disabilities and their family but quite properly the focus is on the safety, protection and the rights of the individual with disabilities.

In such instances, outcomes are sought that represent the person with disabilities best interests. This support identifies the person with disabilities as the primary consumer and is consistent with realising the government's goals of increasing consumer participation and better outcomes for people with disabilities. Skilled advocacy and negotiation can lead to better outcomes for all family members, even where separation has to occur.

Families as part of the Community
Families also need to be viewed within the context of a supportive, nurturing and inclusive community which holds, as core value, its role in assisting the families as carer. Advocacy plays a role in communicating the needs of families to the wider community and to the government and services. Where families don't exist or are unable to provide appropriate support, advocacy represents the community and its values of providing worth, dignity and respect to the individual – within a supportive and caring context.

Competition
As part of the government's direction of providing wider choices for consumers a new competition environment is being created within the health and community services sector. Competition between government and non government providers will be a reality as the government implements the separation of the purchaser and provider functions of many disability services. It is essential that accountability mechanisms are put in place to ensure that all clients found unsuitable by some services will have their needs met by other appropriate agencies.

However, competition alone does not create systems of services – but rather the needs of people with disabilities should determine service design and response. This is particularly important in the current Review of Advocacy Services, and the needs of women with disabilities should be sought to ensure that they are met within this new environment.

Program Effectiveness

Current Accountability Mechanisms
As emphasised above, any assessment of the Advocacy Program Objectives, in line with the Government's community services policy agenda, needs to occur in the context of:

• the needs of people with disabilities, as defined by people with disabilities themselves;
• changes which have already happened since the enactment of relevant pieces of legislation.

To date the Program's objectives and accountability mechanisms have been inferred from the definitions in the legislation, and a statement of outcomes for people with disabilities in the service agreements of funded advocacy services. This circumstance has allowed the development of a range of funded advocacy services which reflect the diversity of situations within the disabilities sector.

Combined with a view of consumer needs informed by people with disabilities themselves, this range of service provision and diversity of conditions now provides a position from which to establish:

• a clear goal for the Program in line with the legislative intent, consumer needs and the Government's policy direction;
• objectives which reflect the diversity of need for disability advocacy services, including individual and systemic advocacy and the needs of particular groups within the sector;
• guiding principles, practice standards and protocols for advocacy which are accepted by consumers and advocacy services;
• accountability mechanisms which demonstrate strategic, outcomes focussed work by funded advocacy services.

In general, WWDA supports the findings of the review undertaken in 1995 by MGM Consultants and agrees with the general direction of its recommendations, particularly in reference to:

• Chapter 5: Disability Advocacy Evaluation Framework, and Chapter 6: Effectiveness Measures.

However, WWDA also notes that:

• changes in the government's policy direction since then need to be taken into account in the formulation of any new direction; and
• issues relating to women with disabilities were not referred to in this review and these too need to be incorporated in any new direction.

Specific issues of priority to WWDA, or any variance from the recommendations of MGM, are incorporated in the discussion below.

Advocacy Program Goal
The Program needs a clear goal statement and objectives underpinning funding allocation, thus providing a strategic direction in line with the legislative intent, consumer needs and the Government's policy direction.

While MGM Consultants provide a suitable generic Goal for the Advocacy Program in their review, (see p.43) WWDA would argue for a more focussed Goal statement which clearly describes the purpose of the Program rather than a more general principle of advocacy work.

The Goal statement needs to:

• reinforce the role of advocacy, both individual and systemic, as intrinsic to the provision of disability services and autonomous from service providers;
• endorse the role of advocacy services in supporting people with disabilities, their families and carers;
• uphold the role of advocacy in informing and maintaining public debate on disabilities issues.

WWDA proposes the following Goal Statement for the Disability Advocacy Program:

GOAL STATEMENT

• To ensure that a full range of advocacy services are available for the following purposes: to increase the control people with disabilities have over their lives;
• to inform and to support people with disabilities, their families and carers in achieving such increases in control that people with disabilities have over their lives;
• to inform and maintain public debate of disabilities issues so that the community may support people with disabilities, their families and carers in achieving increased control over their lives.

Program Aims and Objectives
Program Aims and Objectives need to delineate clear policy directions and strategic milestones for the Program – in line with the Goal and linked to the legislative intent, consumer needs and the Government's policy direction.

These Aims and Objectives should reflect also the existing diversity of advocacy service provision in order to ensure that a full range of advocacy service is maintained from which consumers can make choices.

Aims
WWDA supports simplifying the existing categories of self advocacy, citizen advocacy and group advocacy into individual and systemic advocacy and defining these within the following Aims:

Aim 1: To provide support and training to individuals with disabilities (and where appropriate their families and carers) who are seeking recognition for and full participation in the life of the community.

Aim 2: To take action which influences or produces systemic change to ensure that people with disabilities can achieve:

• full participation in the community
• recognition of their contribution to the community.

Objectives
A range of Program Objectives should be developed in support of each of these Aims and these should be developed in consultation with consumers and advocacy services.

Several drafts of such Objectives have been written since the inception of the Program and are included in various Departmental documents under headings such as Self Advocacy, Citizen Advocacy, Parent Advocacy, Group Advocacy, etc.

New Objectives should:

• reflect the diversity of needs of advocacy consumers (and obviously include the needs of women with disabilities)
• reflect the public policy concerns of the sector.

These Objectives should be reviewed every five years in light of achievements of milestones. WWDA is particularly concerned to see that the interests of women with disabilities are reflected in the Program Objectives, and that these are articulated in their own right as well as being integrated into all other Objectives.

Descriptors reflecting the particular concerns of women with disabilities which should be included in Program Objectives include:

• Safe and dignified access to the full spectrum of services provided to the public
• Sexual, parental and reproductive rights
• Equality of opportunity in employment and workplace promotion
• Equality of access to mainstream health, housing, education and transport services
• Promotion of positive attitudes towards the dignity and lives of women.

Guiding Principles, Practice Standards and Operational Protocols
WWDA supports a diversity of advocacy services which reflects the diversity of need within the sector and assists in equalising resource distribution across a range of disability areas.

In this context, the Government needs to be assured that advocacy services are provided by organisations with clear goals and organisational structures. The MGM report indicates that funded organisations see this as a priority for Government and for organisations themselves. However, rather than focus Departmental attention on strategic, organisational frameworks (mission, goal, objectives, etc.) a more productive approach is to support the introduction of an agreed set of guiding principles, practice standards and operational protocols for advocacy.

Guiding Principles – Code of Practice
The National Advocacy Workshop in June 1994 agreed on a minimum set of principles for advocacy. In 1995 MGM Consultants sought feedback on this minimum set and reported "considerable agreement that these are all important core principles for advocacy."

These principles are:

• Advocacy is/must strive to be: independent; autonomous; on the side of the disadvantaged party (partisan);
• Advocacy must focus on the fundamental human needs and/or rights and interests of people or persons;
• Advocacy should have a clear value base of social justice and full inclusion of people with disabilities as contributing/participating members of the community;
• Advocacy is about achieving justice;
• Advocacy is about achieving equity;
• Advocacy must minimise conflict of interest;
• Advocacy must remain loyal and accountable to the disadvantaged party over the long term where necessary;
• Advocacy is distinct from service delivery;
• Advocacy is not service provision or personal care support.

The Principles outlined should be incorporated into a formal Disability Advocacy Code of Practice or Code of Ethics at some later date. (See also MGM Report p. 83.) Funding should be conditional on acceptance of these set of operational principles.

Advocacy Practice Standards
MGM indicates the strong support in the sector to the development of Advocacy Practice Standards (p82). WWDA urges the development of such standards for the following reasons:

• to support the proper and ethical behaviours and work undertaken on behalf of people with disabilities by the multiplicity of vested interests in the sector ;
• to establish standards of competence from which regulated, accredited training of personnel working within the sector can be developed;
• to ensure that the special factors relating to women with disabilities must be taken into account by advocacy services.

WWDA is of the strong view that it is not possible for disability service providers to provide advocacy services without either an actual or perceived conflict of interest. However, the recent review of Service Standards for Disability Services should be considered in the light of their potential to link with and inform Practice Standards for Disability Advocacy.

WWDA believes that at least three of the eleven Standards need to be linked to advocacy services in order to be implemented across the range of disabilities. These are:

Standard 2: Individual Needs
Each person with a disability receives a service which is designed to meet, in the least restrictive way, his or her individual needs and personal goals.

Standard 3: Decision Making and Choice
Each person with a disability has the opportunity to participate as fully as possible in making decision about the events and activities of his or her daily life in relation to the service he or she receives.

Standard 7: Complaints and Disputes
Each consumer is free to raise and have resolved any complaints or disputes he or she may have regarding the agency or service.

Other Standards around Access, Privacy, Dignity and Confidentiality, Participation and Integration, Valued Stakes, Service Management, and Employment, Conditions, Support and Skills Development also lend themselves to linkages with advocacy services.

A working party with a majority of consumer controlled advocacy organisations and consumer oriented peak bodies should be set up to:

• Examine the Service Standards for Disability Services in the light of establishing Practice Standards for Advocacy Services
• Undertake the development of Practice Standards for Advocacy Services
• Provide linkages between the Service Standards for Disability Services and Advocacy Services.

Operational Protocols
Operational protocols have been initiated in other social and community services sectors, such as those developed in some States for sexual assault workers, police, hospitals, and Public Prosecutions. WWDA supports the development of protocols, based on practice standards, especially for some situations requiring individual advocacy - such as where there is a relationship of violence between consumers of an advocacy service.

Accountability Mechanisms

Outcomes, Indicators and Unit Costs
WWDA supports outputs/outcomes based funded with measurable indicators and associated unit costs where outputs and outcomes are understood to represent quantitative and qualitative results of advocacy work undertaken in the interests of people with disabilities. In supporting and outputs/outcomes based funding WWDA wishes to emphasise the sectors' overall disquiet in this approach and recommends that its introduction be done in full consultation with services and consumer organisations.

Furthermore, WWDA rejects a model of unit costs based on a case mix model which is then the basis for funding. By its nature, advocacy does not fit neatly into such categories and is not a process by which people enter into certain categories of negotiated activity. The opportunities for exploitation by both funding bodies and advocacy services under such a system would require Departmental attention to monitoring the system rather than the advocacy outputs/outcomes.

Whatever the funding model and whatever the process undertaken in providing advocacy services, advocacy should be focussed clearly on achieving measurable results for people with disabilities and these outputs/outcomes need to be clearly spelled out by each advocacy service in terms of the change that has been sought or taken place. For example, is the resulting change one of information, knowledge or understanding, is it legislative, is it in relationships, is it changed status, etc?

Both qualitative and quantitative measures and derivative unit costs can be drawn from each organisation establishing proper outputs/outcomes and indicators for advocacy work undertaken. The requirement should be for funded services to outline these in their service agreement. These should be reviewed after two years to establish whether overarching outcome and output measures and generic unit costs make sense. To move directly to generic unit costs at this stage is pre-emptive and nonsensical.

The MGM report outlines several outcomes supported by the sector which could serve as a starting point in requiring these in the service agreements of advocacy services (See pp 72-79).

In addition, WWDA notes that the Working Party reviewing the Disability Service Standards has been reconvened to:

• define performance indicators
• establish benchmarks for accreditation

WWDA recommends that a working party with a majority of consumer controlled advocacy organisations and consumer oriented peak bodies be set up to consider possible links and applicability of this work to the establishment of qualitative and quantitative outcome/output measures and unit costs in advocacy services.

Cost Effectiveness

The Disability Advocacy sector contributes remarkable energy and effort into improving the position of people with disabilities and it gains considerable results from the work undertaken. The contribution from the non-government sector, together with additional voluntary contributions from people with disabilities, their families and carers means overwhelming cost effectiveness for Government from funding these Advocacy Services.

The requirement is now on the Department to ensure that this work can be undertaken more effectively and smoothly to the benefit of all people with disabilities so that its current value for money is enhanced.

Distribution of Resources

There is a demonstrated need for both specialist and generic services in advocacy. Some specialist services are needed, but it is imperative that generic services are maintained and increased so that the broader analysis of disability within the community is continued. Disability is essentially socially constructed, and many issues that people with disabilities face are not confined to a diagnostic category, eg discrimination in the workplace.

WWDA urges the continuation of funding a diversity of agencies in order to reflect the diversity of need within the sector.

Gaps In Services

As emphasised throughout this submission, WWDA is concerned to ensure that issues relating to the particular needs of women with disabilities are given proper consideration through ensuring that these needs are taken into account by all advocacy services and that advocacy services addressing the particular needs of women with disabilities are properly resourced.

Organisations need to be resourced to overcome geographic distance to effectively reach rural and remote women with disabilities.

The structure of the Advocacy Program should ensure that people with disabilities with dual disabilities can receive appropriate services. For example, people with both intellectual disability and behavioural issues are often referred back and forth, and can miss out on services altogether. Standards, protocols and the maintenance of generic services are ways to address this issue.

WWDA also notes the lack of advocacy available for Indigenous women with disabilities and the need for this to be addressed.

WWDA recommends the investigation of different models for reaching people who are doubly, or triply disadvantaged. For example, attaching special advocacy services for women with disabilities to general advocacy services and specialist women's services such as Women's Legal Resource Centres, gender training for advocacy services and an array of specialist women's advocacy services should be considered. The needs of women from non English speaking backgrounds should be particularly addressed.

Duplication In Services

It is difficult to ascertain whether there is duplication of systemic advocacy services in the sector. However, WWDA believes there is scope to develop better links between individual and systemic advocacy services and to develop flexibility best practice models.

WWDA recommends that flexibility in systemic advocacy service provision be encouraged to reflect the diversity of need within the sector and to establish best practice examples linked with Practice Standards.

Locale of Disability Advocacy Program

WWDA is aware of suggestions that the Disability Advocacy Program move to the Attorney General's Department. Such a move could emphasise the necessary autonomy of advocacy from the disabilities services providers and the major funding body.

However, the Attorney General's Department has experience with legal models of advocacy and there are concerns that this would lead to a more legalistic and adversarial approach rather than one which supports incremental, community focussed change. If this move were to occur, WWDA supports the appointment of disability and advocacy trained personnel within the Attorney General's Department.

Conclusion

WWDA urges the Government to take note of the fact that women with disabilities are not a separate group simply because of the degree of discrimination imposed on this significant proportion of the Australian population by society. Their marginalisation is one that requires addressing through individual and systemic advocacy.

Individual advocacy directly assists in improving the social and material conditions of life experienced by women with disabilities. Systemic advocacy can take these individual experiences and provide information and critiques to policy makers, community leaders and the wider community, thereby informing and stimulating public debate. This is essential to the full participation by women with disabilities in the diverse life of our community.

WWDA plays an important role in providing a voice for women with disabilities at a policy, program and service level and in communicating their needs directly to government. This role is not fulfilled by any other organisation in the disability or women's sector. A broader community goal of WWDA is to develop acceptance of difference so that we have an Australian society that is inclusive of people with disabilities and one that is responsive to their interest and human needs.

The Disability Advocacy Program currently supports this goal and should be maintained through a more focussed Program which is underpinned by a recognition that:

• Successful advocacy is essential to and dependent on informed public debate about disability
• The particular needs of women with disabilities must be considered and given priority in the context of advocacy
• Advocacy services will be improved by establishing clear accountability mechanisms based on measurable outcomes.

Recommendations

Section 2.2
Legislation alone will not meet the challenges posed to people with disabilities by the consequences social response to disability. Advocacy is a key component of informing debate and implementing legislative projections and funding for advocacy by the Commonwealth government should be maintained.

Section 2.3
Linkages between individual and systemic advocacy should be maintained and developed further. This could be done through the establishment of appropriate information systems, national training and development, and ethical research.

Section 3.1
Advocacy plays an important role in assisting women with disabilities to exercise full citizenship and should be supported by government to do so.

Section 3.2
Individual and systemic advocacy directed at productive employment for women with disabilities is critical in equalising the opportunities for women with disabilities to increase their paid employment rate and enabling women with disabilities to have real choices and resources appropriate to quality of life. Systemic and individual advocacy should be resourced, and targeted to:

• changing attitudes of employers and workers within workplaces towards women with disabilities;
• education and skills training services to ensure that the employment needs of individual women are met;
• achieving flexible work arrangements and conditions which provide increased employment opportunities for women with disabilities;
• brokering access to and information about skills and employment opportunities for women with disabilities.

Section 3.3
With the increasing feminisation of poverty, women with disabilities face a bleak future. Systemic advocacy is needed to identify issues, research and analyse, and recommend remedies.

Section 3.4
Systemic advocacy should be supported to identify appropriate areas for research which addresses the health needs of women with disabilities. This research would be used by government to develop appropriate health care structures.

Section 3.5
Individual and systemic advocacy should be resourced to continue to analyse, research, consult and encourage collaboration to address the issue of violence against women with disabilities.

Section 4.2
WWDA urges the government to take note of the fact that people live in different kinds of family. For example, there are families of origin and families of choice or destination, each of which has differing characteristics, relationships, decision making processes and power arrangements.

Section 5.1
In general WWDA supports the 1995 report by MGM Consultants, but also notes that:

• changes in the government's policy direction since then need to be taken into account in the formulation of any new direction; and
• issues relating to women with disabilities were not referred to in this review and these too need to be incorporated in any new direction.

Section 5.2
WWDA proposes the following Goal Statement for the Disability Advocacy Program:

To ensure that a full range of advocacy services are available for the following purposes:

• to increase the control people with disabilities have over their lives;
• to inform and to support people with disabilities, their families and carers in achieving such increases in control that people with disabilities have over their lives;
• to inform and maintain public debate of disabilities issues so that the community may support people with disabilities, their families and carers in achieving increased control over their lives.

Section 5.3
WWDA supports simplifying the existing categories of self advocacy, citizen advocacy and group advocacy into individual and systemic advocacy and defining these within the following Aims:

Aim 1: To provide support and training for self advocacy to individuals with disabilities (and where appropriate their families and carers) who are seeking recognition for and full participation in the life of the community.

Aim 2: To take action which influences or produces systemic change to ensure that people with disabilities can achieve:

• full participation in the community;
• recognition of their contribution to the community.

Section 5.3: Objectives
A range of Program Objectives should be developed in support of each of the above Aims and these should be developed in consultation with consumers and advocacy services.

New Objectives should:

• reflect the diversity of need of advocacy consumers ( and obviously include the needs of women with disabilities);
• reflect the public policy concerns of the sector.

These Objectives should be reviewed every five years in light of achievements of milestones.

Section 5.4: Advocacy Principles
The Principles outlined in MGM Report p. 83 should be incorporated into a formal Disability Advocacy Code of Practice or Code of Ethics at some later date. Funding should be conditional on acceptance of these set of operational principles.

Section 5.4: Advocacy Practice Standards
WWDA recommends that a working party with a majority of consumer controlled advocacy organisations and consumer oriented peak bodies should be set up to:

• Examine the Service Standards for Disability Services in the light of establishing Practice Standards for Advocacy Services;
• Undertake the development of Practice Standards for Advocacy Services;
• Provide linkages between the Service Standards for Disability Services and Advocacy Services.

Section 5.4: Operational Protocols
WWDA recommends the development of operational protocols, based on practice standards.

Section 5.5
WWDA supports outputs/outcomes based funded with measurable indicators and associated unit costs where outputs and outcomes are understood to represent quantitative and qualitative results of advocacy work undertaken in the interests of people with disabilities. Both qualitative and quantitative measures and derivative unit costs can be drawn from each organisation establishing proper outputs/outcomes and indicators for advocacy work undertaken. The requirement should be for funded services to outline these in their service agreement.

These should be reviewed after two years to establish whether overarching outcome and output measures and generic unit costs make sense. In addition, WWDA notes that the Working Party reviewing the Disability Service Standards has been reconvened to:

• define performance indicators;
• establish benchmarks for accreditation.

WWDA recommends that a working party with a majority of consumer controlled advocacy organisations and consumer oriented peak bodies be set up to consider possible links and applicability of this work to the establishment of qualitative and quantitative outcome/output measures and unit costs in advocacy services.

Section 7
WWDA recommends the continuation of funding a diversity of agencies in order to reflect the diversity of need within the sector.

Section 8
WWDA recommends investigation of a range of delivery models for advocacy services for women with disabilities. WWDA also recommends that models for linking systemic and individual advocacy be investigated.

Section 9
WWDA recommends that flexibility in systemic advocacy service provision be encouraged to reflect the diversity of need within the sector and to establish best practice examples linked with Practice Standards.

Bibliography

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This site was developed by Carolyn Frohmader for Women With Disabilities Australia.