Pre-Budget Submission: Top priorities for the 2024-25 Federal Budget

The release of the final reports of the Royal Commission into Violence, Abuse, Neglect, and Exploitation of People with Disability (DRC) and the National Disability Insurance Scheme (NDIS) Review last year marked significant milestones for the disability community. People living with disability are now looking to the Federal Government to provide strong leadership on reforms that will deliver on the promises of the NDIS and Australia’s Disability Strategy 2021-2031 to create an inclusive Australia where everyone gets a fair go at what life has to offer. This Budget will be critical in laying the foundations for much needed change and setting the tone for how governments will involve Australians living with disability in a partnership to co-design and co-produce new approaches and policies.

To assist in compiling the 2024-25 Federal Budget, we have identified a list of priority areas for federal investment this year. This is not a definitive list of all the problems and barriers faced by people living with disability in Australia. Rather, it is a selection of policy opportunities in the federal sphere brought together in a priority list to draw attention to some of the ways in which the Albanese Government can make tangible impacts toward improving the life chances of Australians living with disability and ending segregation and discrimination in our communities.

 

Our priority areas for the 2024-25 Budget are:

1) Fund co-designed transition plans to end segregation

In its Final Report, the DRC shone a spotlight on the ongoing segregation and exclusion of Australians living with disability across our society, including in the critical areas of housing, education, and employment – all of which have a profound impact on a person’s overall wellbeing and quality of life. Significantly, the Commissioners with lived experience of disability underscored the consequences of segregation, exclusion, and discrimination, and the opportunities and benefits for all Australians that will result from fully including people living with disability in our communities, schools, and workplaces. This stance is consistent with Australia’s international obligations under the United Nations Convention of the Rights of Persons with Disabilities (UNCRPD). The Federal Government should take a strong position against disingenuous claims, particularly those of sector lobbyists, that segregated options can constitute ‘choice’. ‘Choices’ made in a context where safe, high-quality, and inclusive alternatives are not available are not genuine choices.

Ending segregation cannot happen overnight – many mainstream settings are simply not yet equipped to enable this to happen effectively. Change will require a significant investment of resources and effort in co-designing comprehensive transition plans that maximise outcomes while avoiding adverse consequences. The transition must not be rushed before mainstream settings are fully accessible and enabled to provide necessary supports, however it must also be recognised that establishing clear timeframes for each transition stage and a final deadline is essential to ensure change actually occurs.

 

Recommendation 1.1: The 2024-25 Federal Budget should fund and provide a clear pathway for the creation of co-designed comprehensive national transition plans to end the segregation of people living with disability in housing, education, and employment including clear timebound transition stages. It should endorse a final deadline to ensure segregated settings and practices are eliminated nationally within the term of Australia’s Disability Strategy 2021-2031.

Recommendation 1.2: The 2024-25 Federal Budget should specifically preclude any funding for new segregated provisions in housing, education, and employment, including, but not limited to, new group houses (including via individual NDIS budgets), ‘special’ schools and programs, and supported employment options, such as Australian Disability Enterprises (ADEs). All public money should be invested in authentically inclusive infrastructure, services, and programs that provide the foundations for transition plans to succeed.

 

2) Invest in actions under Australia’s Disability Strategy 2021-2031

Australia’s Disability Strategy 2021-2031 sets out the commitments of all tiers of government to create a more inclusive Australia. However, as occurred in relation to the first Strategy from 2010 to 2020, a lack of funding to implement the actions and achieve progress toward the outcomes are hindering impact. Significant investment is required to ensure good intentions become genuine results. This will be a crucial part of making mainstream settings and services inclusive to enable an end to segregation. We urge the Federal Government to lead a review of the Strategy in light of the DRC and commit to negotiate a new single National Disability Agreement with all states and territories with funding commitments to ensure the implementation of actions in line with the policy priorities that are contained in the Strategy. 

Further, it is essential that progress under the Strategy be monitored, measured, and tracked. The Outcomes Framework that accompanies the Strategy underpins this, yet many of the data points identified are not measured frequently enough or are not well-matched to the associated goal. In particular, the Outcome Framework relies heavily on the ABS Survey of Disability, Ageing, and Caring (SDAC), which is yet to report regarding the 2022 survey, and is not scheduled to occur again until 2028. The data currently available is from 2018, well before the start of this Strategy and, notably, well before the Covid-19 pandemic, which has undoubtedly had long-lasting impacts across a number of indicators, such as employment outcomes. We understand that the recent three-yearly frequency for conducting the SDAC relied on top-up funding to the ABS. At a minimum, this top-up funding provision needs to continue, otherwise a six-year gap will severely hamper the measurement of progress toward Strategy outcomes. 

While the Strategy’s Data Improvement Plan is a step in the right direction, in its current form it is inadequate to ensure robust measurement of outcomes. The Budget should invest in the ABS’ data collection capacity. There is a significant opportunity to include disability as a variable in more of the ABS’ regular surveys, for example the monthly Labour Force Survey (LFS) that currently measures a range of other characteristics that are less relevant to understanding the state of the labour force, but not disability. Adding additional variables to capture disability data is a cost-effective way of improving data availability about the experiences and life circumstances of Australians living with disability.

 

Recommendation 2.1: The 2024-25 Federal Budget should invest in the actions required to realise the outcomes identified in Australia’s Disability Strategy 2021-2031. This should be supported through the negotiation of a single new National Disability Agreement between all governments with Strategy implementation prioritised.

Recommendation 2.2: The 2024-25 Federal Budget should, at a minimum, continue to provide top-up funding to the Australian Bureau of Statistics (ABS) in order to maintain the three-yearly frequency of the Survey of Disability, Ageing, and Carers (SDAC), and should invest new funding in a program of work for the ABS to evaluate and update the variables measured in each of its regular surveys beginning with the monthly Labour Force Survey (LFS).

 

3) Pilot co-designed NDIS reforms to maximise the quality of outcomes

The Final Report of the NDIS Review provides a blueprint for reforms with many details and specific policy settings yet to be resolved. It is critical that NDIS participants and other people living with disability are key participants in co-designing and co-producing Scheme changes to ensure their experiences, insights, and ideas are leveraged to give the NDIS the best chance of fulfilling its original promises. Investment in co-design should be accompanied by an effective process design project to ensure changes achieve the intended outcomes in the most effective way. It is also critical that proposed changes are fully tested before being rolled out across the Scheme to ensure problems are identified early and rectified.

Piloting the proposed new role of ‘navigator’ should be a high priority and can proceed quickly. The Final Report identifies the critical need for increased navigation support across the Scheme, suggesting the establishment of local ‘navigation hubs’ with both general ‘navigators’ and ‘specialist navigators’. There are a range of models for how this role and its functions could be designed and the best way to determine good practice approaches (which may vary across cohorts and geographic locations) would be to pilot options utilising different features. Among the most important features that should be trialled is choice of navigator. The current approach to providing Local Area Coordinators (LACs) does not adhere to the critical Scheme value of ‘choice and control’, which seems deeply counterintuitive and incoherent. Additionally, options to mitigate the conflicts of interest inherent in a role encompassing both supply and demand functions should be explored. These conflicts have been recognised in relation to the existing roles that ‘navigators’ are proposed to replace.

Further, the NDIS Review’s Final Report emphasised the importance of ensuring foundational supports are in place before removing existing structures and supports. The upcoming Budget should reflect this and ensure adequate funding continues during the transition phase. For example, there continues to be significant uncertainty across the disability sector regarding the future of some Information, Linkages, and Capacity Building (ILC) program funding streams. While new grant rounds for individual capacity building and social and community participation have recently been advertised via GrantConnect, the future of economic participation grants remain unknown. With less than six months remaining of current funding, this not only puts successful high-impact projects in jeopardy but has created significant uncertainty for organisations and staff. The Federal Government should urgently provide clarity on the status of all aspects of the ILC program, and the Budget should make provision for transitional arrangements until foundational supports are fully established.

 

Recommendation 3.1: The 2024-25 Federal Budget should invest in a comprehensive program of co-design with people living with disability to progress the recommendations of the NDIS Review. This should be accompanied by an effective process design project drawing on expertise from inside and outside government, as well as stakeholders including people living with disability.

Recommendation 3.2: The 2024-25 Federal Budget should invest in a trial of a range of ‘navigator’ models that are co-designed with people living with disability and disability organisations and implemented as pilot projects to provide an evidence base for how this role and its functions can be most effectively rolled out.

Recommendation 3.3: The 2024-25 Federal Budget should continue existing funding arrangements for all services, programs, and supports for which the NDIS Review proposes replacement foundational support approaches until such options are fully established. This includes, but is not limited to, all streams of the Information, Linkages, and Capacity Building (ILC) program, about which organisations urgently require future funding certainty.

 

4) Boost availability of accessible affordable housing

The challenges so many Australians are currently facing in finding an affordable place to live are made even more difficult for those with access needs. With Australia’s ageing population, it has never been more important to ensure we are building homes that will meet the needs of the future without expensive retrofitting. Therefore, all new housing and substantial renovations should be built to be accessible and highly adaptive to individual needs.

We welcome the decision that all builds funded through the Housing Australia Future Fund Facility (HAFFF) and National Housing Accord Facility (NHAF) must comply with the National Construction Code 2022 (NCC 2022) Livable Housing Design Standard. We believe the Federal Government can build on this important step forward through its current negotiations with the states and territories regarding a new National Housing and Homelessness Agreement. All Federal Government funding negotiated under the new Agreement should be conditional on each state and territory implementing the NCC 2022 Livable Housing Design Standard within their jurisdictions in full without undue exemptions or concessions including for private market construction. At the very least, federal funding should only be available for NCC 2022 compliant projects.

We have concerns about the Federal Government’s intention to return to housing policies based on enabling shared ownership to assist a very limited number of people to access quasi-home ownership, rather than address the fundamental policy issues affecting low- and middle-income Australians, including many people living with disability. There is, at best, mixed evidence regarding the effectiveness of shared ownership schemes, particularly for low-income people, with a report by the Australian Housing and Urban Research Institute (AHURI) highlighting concerns about the risks of people becoming trapped in their house with insufficient equity to move elsewhere, exposure to high levels of debt, and inadequate income to afford basic or emergency maintenance. As the proposed Help to Buy scheme will be capped at 40,000 buyers, it fails to treat all people with like financial circumstances alike, resulting in a quasi-lotto scheme in which Australians living with disability are unlikely to benefit proportionally with non-disabled people due to factors such as inaccessible and unfair application processes. We strongly urge the Federal Government to urgently and seriously engage with the broader fundamental policy problems that are locking Australians, including many people living with disability, out of home ownership and will continue to do so for future generations without genuine reform.

 

Recommendation 4.1: The 2024-25 Federal Budget should ensure all federal funding, including that under a new National Housing and Homelessness Agreement with the states and territories, is only used to support housing construction that is fully compliant with the National Construction Code 2022 (NCC 2022) Livable Housing Design Standard.

Recommendation 4.2: The 2024-25 Federal Budget should include measures to genuinely address the fundamental policy problems that are locking so many Australians, including people living with disability, out of home ownership. These should be prioritised over short-term measures that only assist a select number of people without broader long-term benefit.

 

5) Invest in health to break down access barriers

The escalating inflationary pressures on household budgets in recent years has focused attention on the rising costs of accessing healthcare in Australia. Many people living with disability interact with the health system more than non-disabled community members, but these higher costs are not met by NDIS funding. The cost of specialist and allied health appointments, an apparent reduction in the availability of bulk-billing GP appointments, and difficulties in accessing dental care without encountering out-of-pocket expenses that are unaffordable for those with low incomes are among the many concerns of people living with disability. As a disability-focused organisation, we are not well-placed to provide specific evidence-based recommendations on the solutions to these issues, but strongly encourage the Albanese Government to engage with experts and other relevant stakeholders about these problems as a matter of priority.

 

Recommendation 5.1: The 2024-25 Federal Budget should invest in a plan to address the escalating costs of healthcare, and to ensure essential services and supports remain readily available to all Australians, including people living with disability.

 

6) Update DSP work rules and increase rate to meet rising costs of living

The rules and requirements of the Disability Support Pension (DSP) are currently too complicated and not well understood by many recipients. This creates significant disincentives to doing any amount of paid employment, which needs to be addressed urgently. The process to apply for the DSP is so lengthy and taxing that many recipients regard gaining access as akin to achieving the ‘holy grail’ and fear losing it if they do any work or attempt to re-enter ongoing employment. The rates of transition from DSP to employment are currently extremely low.

Given current workforce shortages and the steps taken to allow people receiving the Age Pension to work more hours without penalty, thereby boosting the national labour force, it is an opportune time for the Budget to make equivalent provision for recipients of the DSP. This would help to mobilise underutilised workers, increase productivity, and lift the national workforce participation rate. Doing so would also have the added benefit of testing how incentives and disincentives impact on the employment outcomes of recipients in order to inform future long-term changes to DSP rules.

While significant and welcome attention has been given to increasing the rate of Jobseeker, people receiving the DSP are also facing substantial increases in the costs of living and should not be overlooked again in this Budget. Indeed, a person living with disability faces significantly higher costs compared to non-disabled people, with research by the National Centre for Social and Economic Modelling (NATSEM) in 2019 indicating a household including a person aged 16 and over living with disability requires an additional $107 per week to obtain the same standard of living as similar households without a person living with disability. In its 2023-24 report, the Interim Economic Inclusion Advisory Committee noted it had been unable to fully consider the level of the DSP payment in the short time of its operation, but this would form part of its future work. We anticipate the Committee will make more detailed recommendations based on expert modelling of an adequate rate in this year’s report and it is critical the Budget heeds this advice to ensure those receiving the DSP are not left further behind.

 

Recommendation 6.1: The 2024-25 Federal Budget should make financial provision for changes to the rules for receiving Disability Support Pension (DSP) payments to remove the disincentives for people living with disability to work, particularly by:

• increasing the income thresholds so people can earn more from employment without impacting their DSP payments; and

• increasing the period that a person can pause their DSP payments, but remain eligible to restart, and make sure that this rule is promoted and understood by people on DSP, many of whom fear the loss of future access to payments if they work.

Recommendation 6.2: The 2024-25 Federal Budget should make financial provision to fully action the recommendations of the Economic Inclusion Advisory Committee in its forthcoming report regarding the level of the Disability Support Pension (DSP), as well as other income support payments.

 

7) Commit to a Disability Action Plan to help end violence against women

The National Plan to End Violence against Women and Children 2022-2032 is a significant step forward in protecting women and children across our communities. The development of the dedicated ‘Aboriginal and Torres Strait Islander Action Plan 2023-2025’ under the National Plan is also a very welcome step. However, given that the National Plan highlights that women and children living with disability are also more likely to experience violence and that they experience ‘specific forms of gender-based violence including reproductive coercion, forced sterilisation, and forced medical interventions’ (p.36), it is essential that there also be a co-designed Action Plan focused on ending violence against these women and children. Importantly, this is a recommendation (8.23) of the DRC, which highlighted in its Final Report that the National Plan currently ‘does not identify specific actions to address the drivers of violence against women and girls with disability, the specific experiences of violence against women and girls with disability, or the dearth of accessible supports’ (p.138).

 

Recommendation 7.1: The 2024-25 Federal Budget should invest in a co-designed Action Plan for women and children living with disability under the National Plan to End Violence against Women and Children 2022-2032, and provide funding in line with that allocated for the ‘Aboriginal and Torres Strait Islander Action Plan 2023-2025’, adjusted for recent inflation.

 

8) Reinvigorate the transition to fully accessible transport

Accessible transport provides a gateway into all aspects of an ordinary life in community, be it accessing employment, education, health services, shops, recreation facilities, and much more besides. Therefore, it is extremely disappointing that Australia failed to achieve its 20-year targets on delivering accessible public transport that expired in 2022, despite the two-decade-long transition period being an adequate timeframe in which to do so. When the Disability Standards for Accessible Public Transport 2002 (Transport Standards) were introduced in 2002, they were supposed to ensure that all public transport networks and associated infrastructure, except for the trains and trams, would be fully accessible by the end of 2022 (train and tram conveyances have until 2032 to comply).

This disappointment is compounded by the continuing lax approach to reviewing and updating the Transport Standards with new deadlines, as well as credible reporting and accountability mechanisms to ensure outcomes are delivered. The new Transport Standards are now long overdue, and this delay is detrimental to achieving change. The Budget should include resources to reinvigorate the transition, involve people living with disability in the co-design of an outcomes framework, and establish an independent monitoring and reporting capability, for example through the Australian Human Rights Commission (AHRC) or a future National Disability Commission that was proposed by the DRC.

 

Recommendation 8.1: The 2024-25 Federal Budget should invest in reinvigorating the transition to fully accessible transport through new Transport Standards. It should make financial provision for the development and implementation of a comprehensive auditing and reporting outcomes framework to ensure all parties with obligations to meet accessibility requirements are independently and transparently evaluated at least once every three years.

 

About us

JFA Purple Orange is an independent social profit organisation based in South Australia that undertakes systemic policy analysis and advocacy across a range of issues affecting people living with disability and their families. We also host a range of peer networks for people living with disability including people living with intellectual disability, physical and sensory disability, younger people, people from culturally and linguistically diverse backgrounds, and people in regional South Australia. Our work is characterised by co-design and informed by a model called Citizenhood. 

To discuss our Pre-Budget Submission in more detail, please contact Tracey Wallace, Strategy Leader at JFA Purple Orange, on (08) 8373 8333 or traceyw@purpleorange.org.au.