Policy Submission to Department of Human Services: Draft State Disability Inclusion Plan 2025-29
JFA Purple Orange (JFAPO) welcomes this consultation into South Australia’s draft State Disability Inclusion Plan 2025-2029 (‘the Plan’). We recognise the considerable work that has gone into its development and we are grateful for the opportunity to provide feedback. We hope our recommendations provide clear, practical guidance on how the Plan could be further strengthened.
Our submission will begin by presenting our Model of Citizenhood Support, which we believe could serve as a useful lens with which to review the draft Plan. We will then set out key components of the legal and policy framework that underpin the Plan and should inform its implementation. These comprise the United Nations Convention on the Rights of Persons with Disability (‘the UNCRPD’), Australia’s Disability Strategy 2021-2031 (‘ADS’) and the final report of the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability (‘the DRC’).
We will suggest some overall considerations for the Department for Human Services (‘DHS’) to keep in mind when reviewing the draft Plan: the need for a stronger overall commitment to co-design; the importance of using inclusive, respectful language; the need for inter-agency collaboration to maximise the impact of the Plan; and the pending introduction of Foundational Supports by the Commonwealth Government.
We will then suggest introducing two new sections towards the start of the Plan: a vision statement and high-level commitments for all state authorities. The idea behind a vision statement (co-designed alongside people with disability) is to ensure that all state authorities have a clear, shared understanding of what they are working towards. It would also be helpful for the disability community to understand what is driving the actions of state authorities in this space.
We suggest adding high-level commitments in the Plan, as there are multiple cross-cutting considerations that all state authorities should have in mind when developing and implementing all aspects of their Disability Access and Inclusion Plans (‘DAIPs’). It does not make sense to slot each of these within the five Domains, as they apply across them all. Our suggested high-level commitments are: involvement of people with disability in decision-making; accessible communication and information; universal design; intersectional approaches; inter-agency collaboration; procurement policies; employment of people with disability; and effective data and reporting.
It is critical to use inclusive and respectful language and terminology throughout the Plan. We have some concerns with the descriptions of the Priority Groups, as well as the names of the Domains. We will therefore make some suggestions as to how these could be reframed using a rights- and strengths-based approach.
Finally, we will explore each of the Domains in detail, offering suggestions as to how the outcomes framework could be strengthened. The outcomes framework must be strong if the intent of the Plan is to be realised. In working through the Domains, several themes emerged. Firstly, many of the outcomes lack ambition. For example, they refer to key stakeholders having knowledge about disability, but do not call on state authorities to take meaningful action to improve accessibility and inclusion. The first State Plan should have already led to increased knowledge and understanding about disability inclusion. This second Plan should go beyond knowledge to action.
Secondly, the Plan does not include qualitative measures that capture the perspectives and experiences of people with disability. It is disappointing that the Plan proposes to measure progress in achieving more inclusive attitudes, services, policies and practices without asking people with disability themselves. The mere presence of a policy or service, and even its use by the disability community, does not give any insight into its quality, inclusiveness or impact.
Thirdly, critical gaps remain in the draft Plan in respect to the DRC’s vision of a society free from violence, abuse, neglect and exploitation against people with disability. Concerningly, the Plan is silent on ending segregation in all its forms, including in education, housing and employment. The final report of the DRC signalled a genuine shift in disability policy and a real step forward for Australia to create an inclusive society free of stigma, abuse and segregation. However, the disability community is yet to see any real action or solid commitment from state and territories or the Commonwealth Government. We sincerely urge DHS to review the DRC’s recommendations as they relate to South Australia (“SA”) and incorporate these into the Plan. Failing to do so would take us backwards, rather than paving the way forward.
We are regularly contacted by local Councils and State Government Agencies to provide advice and support with developing and implementing their DAIPs, both directly and through a JFA Purple Orange-led Community of Practice for Councils that promotes inclusive employment. These conversations have strongly indicated that individuals within Councils and State Government Agencies are eager to develop strong, meaningful DAIPs that will result in positive outcomes for people with disability. However, we are often told (particularly with respect to Councils) that drive and commitment from internal leadership is lacking. Further, responsibility for access and inclusion often sits with one or two individuals who work quite separately from the rest of their Council/Agency. In order to secure commitment from Council and State Government staff at all levels and across all teams, it is vital that the State Plan models strong leadership, provides clear guidance, requires concrete commitments in all DAIPs, and holds state authorities accountable for achieving progress.
Please note that we refer throughout the submission to recent amendments to the Disability Inclusion Act 2018 (SA). These amendments are not yet reflected in the Act itself, as while the Disability Inclusion Review Recommendations Amendment Bill 2024 (SA) passed both Houses of Parliament, it is still awaiting assent. This is just a formality, so it is important that these amendments are reflected in the Plan. JFA Purple Orange are proud to have worked with all political parties to secure many of these amendments; we therefore have detailed understanding of their origins and purpose.