Vision 2020 Australia

Mr David Thodey AO

Chair, Independent Review Panel

Department of Prime Minister and Cabinet

PO Box 6500

Canberra ACT 2600

Redacted

Dear Mr Thodey

Vision 2020 Australia welcomes the opportunity to provide a brief submission to the Independent

Review of the Australian Public Service.
As the national peak body for the eye health and vision care sector, Vision 2020 Australia

represents around 50 member organisations involved in local and global eye health and vision

care, health promotion, low vision support, vision rehabilitation, eye research, professional

assistance and community support.
Together, we advocate for policy and legislative enhancements to provide the optimal level of

care and support for people who are blind or have low vision and to maximise opportunities for

participation in all aspects of daily life, including meaningful employment.
Noting the Panel is seeking to make practical recommendations within the scope of the

capability, culture and operating model of the Australian Public Service (APS), Vision 2020

Australia makes this submission in relation to the term of reference Acquiring and maintaining

the necessary skills and expertise to fulfil the APS’ responsibilities, and wishes to comment

on the employment of people with disability in the APS.
People with disability represent only 3.6 per cent of the APS workforce, far below the roughly 18

per cent of Australians who identify as having a disability. While the APS As One: Disability

Employment Strategy 2016-19 sets out a number of action areas for meaningful change to

increase the representation of employees with a disability across the APS, the strategy does not

include concrete targets for representation. It is recommended that any successor goals and

actions include employment targets for people who identify as having a disability, as several

state and territory public sector employers have recently done. While the limitations of existing

data are recognised, this should not be a barrier to setting targets to actively measure and drive

improvements in this important area given the substantial benefits it can deliver to the APS and

the broader Australian community.
The As One Strategy highlights, that an increasingly diverse workplace provides four crucial

advantages to the APS: strategic policy insight, retention of workforce, mainstreaming of

productivity enhancing technology and the promotion of inclusive leadership practices. Through

your time at Telstra and its roll out of the Supported Workforce Program, you will have

witnessed firsthand the empowering nature of inclusive employment for both the employers and

the employee. The APS has the capacity to emulate this success on a much broader scale and

provide inclusive corporate leadership to employers across Australia, further enhancing the

ability of the APS to demonstrate the advantages of inclusive workplaces to employers

nationally.

National body working in partnership to prevent avoidable blindness and improve vision care
Position statement on meaningful

employment for people with disability in the

Australian Public Service

October 2017

Executive Summary

Access to meaningful employment free from discrimination is a fundamental

human right of all Australians and is essential for building a prosperous and

egalitarian society. Meaningful employment is integral to an individual’s ability to

remain independent, empowered and connected with their community, and to maximise

opportunities for participation in all aspects of daily life.
Australia strengthened its commitment to the rights of people with disability, including

the right to employment, ratifying The United Nations Convention on the Rights of

Persons with Disabilities (CRPD) in 2008. Additionally, the Federal Disability

Discrimination Act 1992 (DDA) provides protection for all Australians against

discrimination based on disability. Building on the principles of the CRPD and the DDA,
Australia has fully committed to the implementation of the National Disability Insurance

Scheme (NDIS), which has the potential to empower people with disability by providing

the freedom of choice and control over the services and supports they need to fully

participate in social and economic life.
Despite these commitments, people who are blind or vision impaired and people who

identify as having a disability more broadly, remain significantly underrepresented, and

face multiple barriers when it comes to participating in the workforce. Nearly one in

seven working aged Australians (16-64 years) are living with a disability with a

workforce participation rate of just 53.4 per cent, compared to 83.2 per cen t for the

remainder of the population.i More so, it is estimated that 58 per cent of working aged

Australians who are blind or vision impaired are unemployed and one third of those who

are employed would like to work more hours, highlighting the issue of

underemployment.ii It is estimated that if an additional 100,000 people with disability

were employed by 2050, this would add an additional one per cent to Australia’s Gross

Domestic Product.iii

While the Australian Public Service (APS) is a major employer across Australia, there has

been a consistent decline in the inclusion of people who identify as having a disability in

the APS workforce, from 6.6 per cent in 1986iv, down to 4.1 per cent in 2005 to 3.74 per

cent in 2016.v Notably, one such way in which the APS is seeking to improve career

pathways into the APS is the RecruitAbility scheme, offering candidates who identify as

having a disability automatic access to the next stage of the selection process, typically

an interview. However, while all agencies are encouraged to adopt the scheme, it is

currently not mandatory.
The current lack of visibility of people who identify as having a disability in public roles

such as the APS makes it difficult for private sector employers to recognise the

potential of people with disability. People with disability have a range of skills,
capabilities and interests to bring to the workforce. Supporting workplace diversity,
leads to increased representation of people with disability in the public and private

sector workforce and improves effectiveness and productivity. As an important first

step, direct leadership by the Australian Government will work to diminish the negative

National body working in partnership to prevent avoidable blindness and improve vision care
assumptions and pervasive stereotypes surrounding people with disability that continue

to contribute to discriminatory employment practices.
Vision 2020 Australia therefore considers it critical that the Australian Government

address this issue and demonstrate their commitment to diversity by implementing the

following package of measures:

1. Implement an overall target of seven per cent for people who identify as having
   a disability, including people who are blind or vision impaired, employed in the
   APS workforce to be achieved within five years (2018-2023).
2. Implement an APS disability internship initiative.
3. Ensure the RecruitAbility scheme is mandatory across all APS agencies and
   levels.
4. Ensure recruitment processes and information and communication technology
   (ICT) policies facilitate accessibility for people with a disability.

Vision 2020 Australia position

1. Implement an overall target of seven per cent for people who identify as

having a disability, including people who are blind or vision impaired, employed

in the APS workforce to be achieved within five years (2018-2023)
Setting specific measureable targets and establishing a plan to meet them is an

effective way to improve disability inclusion in the workplace by improving

accountability and transparency. Vision 2020 Australia recommends implementing an

overall target of seven per cent for people who identify as having a disability, including

people who are blind or vision impaired, employed in the APS workforce to be achieved

within five years (2018-2023). Meeting this target will move the APS beyond where they

were more than 30 years ago in 1986 at 6.6 per cent and will double APS inclusion

efforts from 3.74 per cent of people who identify as having a disability employed in

2016.
In order to meet this target within a five-year timeframe:
a. It will be essential for APS annual recruitment strategies to include a progressive
percentage target of people who identify as having a disability.
b. The target should be applied in a meaningful way with a true commitment to
workplace participation by people who identify as having a disability, across all APS
departments and across all levels, including the Executive Level and Senior
Executive Service classification level.
c. The target should stimulate career pathways for young people with a strong
emphasis on recruitment at the Trainee, Graduate, APS 1 and APS 2 classification
levels.

2. Implement an APS disability internship initiative

Existing schemes such as work-for-the-dole programs and proposed policy commitments

such as Youth Jobs PaTH require individuals to take part in employment that may not be

relevant to their individual goals and aspirations and therefore will be unlikely to have a

long-term impact on their employment outcomes. As such, it is essential that an APS

disability initiative for young people takes a holistic approach in order to meet a

person’s individual goals and career objectives.
The purpose of the disability internship is twofold; not only will the initiative promote

job readiness for people who identify as having a disability and stimulate career

Position statement on meaningful emploment for people with disablity in the APS 2
pathways into the APS workforce, but it will simultaneously increase visibility with the

view to diminish negative attitudes and misconceptions surrounding people who identify

as having a disability.
It is anticipated that individuals participating in the APS disability internship initiative

will be aged between 16 and 25 years, with an expectation to complete a minimum of

15 to 25 hours per week, over the course of a minimum of three months, or as

negotiated with their employer.
At an operational level, the APS disability internship initiative must:
a. implement flexible working arrangements and reasonable adjustments to meet the
individual needs of interns;
b. design placements which are tailored to the specific goals and aspirations of the
individual;
c. not affect any government payments, allowances or concessions;
d. reimburse interns for costs associated with travel;
e. be applied across all APS departments, with a minimum requirement of 50
internship placements in year one, with the intent to double intake each year with
the aim of 200 placements by the end of year three.

3. Ensure the RecruitAbility scheme is universally applicable

Ensuring the RecruitAbility scheme is mandatory across all APS agencies and all level

vacancies, rather than operating on an opt-in basis, will better support people who

identify as having a disability in the APS selection processes, while ensuring that merit

remains the foundation for employment and promotion. In the long term, a universally

applicable RecruitAbility scheme will work to facilitate cultural change during the

recruitment process, contributing to a workforce that is diverse and skilled.

4. Information and communication technology (ICT) procurement and

recruitment

In September 2016, the Australian Government announced their intention to adopt an

Australian Standard on ICT accessibility, to support access to ICT for people who

identify as having a disability. While this presents a promising opportunity for creating

inclusive work environments, current recruitment processes are often a significant

barrier to employment for people who are blind or vision impaired, and people with

disability more broadly. As such, it is essential all recruitment processes are viewed

through the lens of accessibility to ensure the entire application, interview and

contracting process is accessible.
To ensure that recruitment processes are accessible for people with disability, it is

essential the APS conduct a review of their recruitment processes and agencies, and

identify the necessary steps to become fully compliant. It is also important that

unconscious bias training be undertaken by recruiters.
In relation to ICT procurement policies, the APS must lead by example to explore

opportunities to improve ICT procurement guidelines that support workplace diversity,
by:
a. conducting an immediate review of ICT Procurement Guidelines;
b. appointing a director for ICT procurement to oversee a strategic review process and
to ensure accessible ICT systems form part of action plans;

Position statement on meaningful emploment for people with disablity in the APS 3
c. including accessibility and disability procurement standards in all government
tendering guidelines and ensuring government contractors also meet minimum
requirements especially with respect to ICT procurement policies; and

d. Mandatory reporting on disaggregated data.
While the APS reports annually on the number of employees who identify as having a

disability, this information is not disaggregated, and therefore cannot be used to

extract meaningful information. To this end, Vision 2020 Australia recommends that the

APS employ mandatory reporting to capture and monitor data on the number of people

who identify as having a disability employed in the APS, disaggregated according to

level of employment and primary disability, with a specific category for blindness and

vision impairment. This data should be transparent and presented to the Australian

Parliament on an annual basis to ensure accountability towards a target of seven per

cent over five years (2018-2023).

Policy context

In Australia it is estimated that 58 per cent of working aged Australians who are blind or

vision impaired are unemployed, compared to 5.6 per cent unemployment rate of the

wider population.vi This means that people who are blind or vision impaired are more

than ten times more likely to be unemployed when compared to the general population.
Additionally, one in four people who are blind or vision impaired report experiencing

some level of discrimination in relation to their employment.vii

Australia is committed to the full and equal enjoyment of all human rights for people

with disability, including access to rewarding and dignified employment. The CRPD

considers a universal access approach to all aspects of civil, political, social, economic

and cultural life, and promotes equity and fairness for all people with disability.
Article 27 of the CRPD Work and Employment, requires that ‘States Parties recognise

the right of persons with disabilities to work, on an equal basis with others.’viii Australia

ratified the CRPD in 2008 and is therefore committed to promoting and protecting the

articles contained within it.
Additionally, the domestic legal framework in Australia includes the DDA and Fair Work

Act which prohibit employment discrimination on the basis of disability. Section 15 of

the DDA makes specific provision that it is ‘unlawful for an employer or a person acting

or purporting to act on behalf of an employer to discriminate against a person on the

ground of the other person’s disability.ix’ Embedded within the principles and values of

the CPRD, the NDIS is set to be one of the most significant reforms in disability policy in

Australia’s history. While the NDIS does not provide specific funding for employment

support for people with disability, it does provide a range of services and supports that

have the potential to empower and enhance the capacity of people with disability to

achieve their career aspirations. A recent analysis of the potential scale of NDIS

economic benefits suggests that when fully implemented the NDIS will lead to between

25,000 and 40,000 new jobs for persons with disability.x

While the APS has taken steps to improve the inclusion of people with disability,
through implementation of the As One: Making it Happen APS Disability Employment

Strategy 2016–19, there is still much work to be done. According to recent estimates,
the majority of APS employees who identify as having a disability are clustered at mid-
level classification level APS 4 and APS 6 at 26.2 per cent and 21 per cent respectively.xi

The average age of APS employees who identify as having a disability is 47.2 years,
compared to 43.4 years for the remainder of the APS workforce.xii

Position statement on meaningful emploment for people with disablity in the APS 4
Evidence suggests that people who are employed by the APS and identify as having a

disability are of mature age, with significant skills and valuable years of work

experience. Comparatively, the proportion of employees with disability is considerably

less at the Trainee, Graduate and APS 1 and APS 2 level classifications.
This demonstrates that there are inadequate career pathways for young people who

identify as having a disability entering into the APS workforce. Additionally, the

proportion of people who identify as having a disability steadily declines at the

Executive Level and Senior Executive Service level classifications, indicating insufficient

access to opportunities for promotion, training and professional development.
Recruitment practices can act as a significant barrier to employment for people who are

blind or vision impaired and people with disability more broadly. As such, it is integral

that the concept of ‘reasonable adjustment’ in inclusion planning is extended to ensure

recruiting departments are actively encouraged to provide support to candidates with a

disability. Additionally, while people who are blind or vision impaired may require

adaptive technology to assist them with performing work functions, ICT procurement

policies can act as a barrier to workforce participation for people with disability.
However, many programs subsidise the aids and equipment required to continue

performing productively in the work place.

Vision 2020 Australia

Established in October 2000, Vision 2020 Australia is part of VISION 2020: The Right to

Sight, a global initiative of the World Health Organization and the International Agency

for the Prevention of Blindness. Vision 2020 Australia is the peak body for the eye

health and vision care sector, representing around 50 member organisations involved in:
local and global eye care; health promotion; low vision support; vision rehabilitation;
eye research; professional assistance and community support.

The Vision 2020 Australia Independence and Participation Committee

Vision 2020 Australia’s Independence and Participation Committee (the Committee)
brings together a diverse group of members providing services and supports to people

who are blind or vision impaired across Australia; enabling an unique platform for

stakeholders to collaborate, foster consensus and develop a shared understanding on

matters of significance affecting member organisations and consumers. Through drawing

on the knowledge, experience, and resources of the Committee’s broad and inclusive

membership, the Committee is central to supporting one of Vision 2020 Australia’s key

roles as an effective conduit to government, offering a unified and consistent voice.

i
Australian Bureau of Statistics, Disability, Ageing and Carers, Australia: First Results, 2015,
available at http://www.abs.gov.au/ausstats/abs@.nsf/mf/4430.0.10.001

ii
Vision Australia, Employment Research Survey Report, Research and Measures Team, May 2012.
iii Australian Government Productivity Report, Disability Care and Support, August 2011,
available at http://www.pc.gov.au/inquiries/completed/disability-support/report

iv Australian Government: Australian Public Service Commission, Employment of people with

disability in the APS, August 2012, available at http://www.apsc.gov.au/publications-and-
media/archive/publications-archive/people-with-disability

v Australian Government: Australian Public Service Commission, State of the Service Report

2014-15, available here https://stateoftheservice.apsc.gov.au/learn-more/representation-of-
people-with-disability-data/#Table2

vi
Vision Australia, Employment Research Survey Report, Research and Measures Team, May 2012

and Australian Bureau of Statistics, Labour Force, Australia: August 2017, available at

http://www.abs.gov.au/ausstats/abs@.nsf/mf/6202.0

Position statement on meaningful emploment for people with disablity in the APS 5
vii
Vision Australia, Employment Research Survey Report, Research and Measures Team, May

2012.
viii
The United Nations Convention on the Rights of Persons with Disabilities, available at

http://www.un.org/disabilities/convention/conventionfull.shtml

ix
Australian Government Disability Discrimination Act 1992, available at

https://www.legislation.gov.au/Details/C2015C00252

x
Dr B Long, Senior Research Fellow for National Disability Services, Every Australian Counts and

Centre for Applied Disability Research, Economic Benefits of the NDIS, May 2015, available at

https://www.nds.org.au/policy/nds-report-projects-economic-benefits-of-the-
ndis?_cldee=aGZpdHpzaW1tb25zQHZpc2lvbjIwMjBhdXN0cmFsaWEub3JnLmF1

xi
Australian Government: Australian Public Service Commission, State of the Service Report

2014-15, available here http://stateoftheservice.apsc.gov.au/learn-more/representation-of-
people-with-disability-data/#Table2

xii
Ibid

Position statement on meaningful emploment for people with disablity in the APS 6