On this page you can read submissions that we have made to Federal and State governments, Senate Inquiries and to other government and non-government agencies to advocate for issues affecting people who are blind or vision impaired.
Read our latest published submission to the Joint Standing Committee Inquiry on General Issues around the Implementation and Performance of the NDIS.
You can also browse by topics:
- Access to Information
- Aged Care
- Audio Description
- Banking and Finance
- Disability Service Standards
- Dog Guides and Assistance Animals
- Domestic and Family Violence
- Health and Emergencies
- National Disability Insurance Scheme
- Payments, Benefits and Allowances
- Royal Commission into Violence, Abuse, Neglect & Exploitation of People with Disabilities
Access to Information
Review of Accessibility Strategy for the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability
The options provided for people to contribute submissions to the Royal Commission must be flexible. As well as being able to submit electronically, there must also be a dedicated phone line for people to make submissions by phone, as well as to submit by post and in a person’s preferred format. These options must be widely advertised and communicated to both the disability and broader community.
TGA Medicine Labelling and Packaging Review
Clear, accessible information on medication is important for all consumers. For someone who is blind or vision impaired, that clear, accessible information is critical to ensure that the right medication is being taken at the right dosage
Read BCA’s 2012 submission Medicine Labelling and Packaging Review (Word doc).
Royal Commission into Aged Care Quality and Safety (2019) Submission
Vision impairment is predicted to become the most prominent health issue within the population of older Australians. People who are blind or vision impaired can live rich and active lives and make meaningful contributions to their communities; however the extent to which people are able to actively and independently participate in community life does rely on facilities, services and systems that are available to the public being designed in a way that makes them inclusive of the needs of all citizens.
Submission to The Aging and Disability Commission – Disability Advocacy Review
A commitment by government to continue providing advocacy funding is essential to the wellbeing of all people with disabilities. Advocacy is essential not only to prevent instances of blatant discrimination or neglect. It is necessary to highlight issues which are unintentionally overlooked by government, which will inevitably occur. Advocacy services should therefore be funded to provide advocacy in its purest form, and not be expected to couch grant applications in terms which governments feel comfortable with.
Discussion paper: Streamlined Consumer Assessment for Aged Care
Based on feedback from previous reviews, from individual member cases, and in line with views from the sector, we made a submission on the Streamlined Consumer Assessment Process for Aged Care in February 2019.
BCA recommends disability being a special needs group in the Aged Care Act, assessments to be holistic and individualised, stronger referral processes in place, and for Assistive Technology to be available independently from the Aged Care system.
Aged Care Legislative Review
A robust and responsive aged care system is core to the needs of Australians who are blind or vision impaired. According to Vision 2020 Australia, around 80% of vision loss in Australia is caused by conditions that become more common as people age. This raises a number of implications for Australia’s aging population, with one in every four Australians projected to be 65 years of age or older by the year 2056.
BCA asserts that older Australians who are blind or vision impaired, when provided with the appropriate support, can continue to lead full and active lives and make valuable contributions to their communities. To this end, we welcome the opportunity to contribute to the review of Aged Care services in Australia and thank the Aged Care Sector Committee for providing us with this opportunity.
Audio Description on Commercial TV
Securing a permanent audio description service for Australians who are blind or vision impaired has remained one of our top priorities for many years now.
Keep up to date with our campaigns for audio description on commercial TV, audio description in cinemas and on DVDs, the digital switchover and all things media access. Read more here.
Banking and Finance
Submission to the Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry
Posted: 21 August 2018
BCA’s submission to the Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry focuses on two Clauses in particular that hold relevance to the issues faced by people who are blind or vision impaired. These are:
- Whether any conduct, practices, behaviour or business activities by financial services entities fall below community standards and expectations.
- The adequacy of forms of industry self-regulation, including industry codes of conduct; to identify, regulate and address misconduct in the relevant industry, to meet community standards and expectations and to provide appropriate redress to consumers.
Touch screen EFTPOS devices are inherently inaccessible to people who are blind, and to many more who are vision impaired, and this submission specifically addresses this issue.
Disability Service Standards
Draft National Standards for Disability Services
Read BCA’s Draft National Standards for Disability Services submission (Word doc) about the Draft National Standards for Disability Services.
Our 2012 submission includes recommendations for service provider information accessible formats, independent dispute resolution processes, proportional representation of people with disability on boards and mentoring opportunities, in addition to the provision of high quality services.
Dog Guides and Assistance Animals
Australian Dental Association on regarding assistance animals
Read BCA’s Australian Dental Association submission (Word doc) on access to treatment rooms for persons accompanied by assistance animals.
This submission aims to address the high level of discrimination that still occurs in dental settings and will help to inform the Australian Dental Association’s revised disability policy.
Domestic and Family Violence
National Women’s Branch Submission on Violence Against Women
This submission was prepared by the National Women’s Branch on behalf of BCA, in response to a call for submissions from the United Nations Special Rapporteur on Violence Against Women. The submission highlights issues specific to violence against women who are blind and vision impaired.
Further to this, you can also read BCA’s recommendations arising from the submission.
Submission to Inquiry of All Aspects of the Federal Election
BCA has been involved on an ongoing basis in advocating for an accessible and fully independent system for voting in Australian federal and state elections. Our position is based on extensive feedback and consultation within the sector and we believe that a system should be implemented which allows people with disability to exercise their democratic right of citizenship in voting in elections in a 100% secret, independent and verifiable system which is based on the iVote system used in both NSW and WA elections.
Blindness Sector Submission to the NSW Electoral Commission following the NSW Election in March 2019
Following the March 2019 election, feedback was sought from members of the Blind and Vision Impaired community regarding their experience using iVote to cast their vote. 34 people provided feedback. While we recognise this is a small sample size we believe it is sufficient to identify aspects of iVote that could be improved to improve its usability in future elections.
Response to Issues Paper: Employment
According to a survey conducted by the World Blind Union, the employment percentages were 62.39% currently employed, 14.32% not currently employed but employed within two years, and 31.67% unemployed long-term. Why are the unemployment figures this high? This submission highlights the barriers to employment which reflect negative assumptions and attitudes, and addresses the questions raised in the Disability Royal Commission (DRC) Issues Paper on Employment, providing evidence through procured case studies to answer the questions pertaining to people who are blind or vision impaired seeking or participating in employment.
Review of Disability Employment Services Framework
The unemployment rate of people who are blind or vision impaired is still four times the national average, and current approaches to this problem are failing. A survey conducted by BCA between October 2013 and April 2014 found that only 35 per cent of respondents had been successful in gaining employment through a disability employment service. We believe disability employment services could be achieving far better outcomes for people who are blind or vision impaired and welcome the opportunity to provide feedback to inform the review of the disability employment services framework.
A New System for Better Employment and Social Outcomes
Work is the cornerstone of social inclusion. It generates wages, less reliance on welfare, dignity, a sense of purpose and productivity. Given the long-term unemployment, or under-employment experienced by many Australians who are blind or vision impaired, we believe that a shift in the current system is necessary to ensure systemic change. These reforms should be underpinned by a sustainable welfare system that is targeted towards those in need and that guarantees that no Australian will be worse off or left behind as a result of the changes.
Read BCA’s submission: A New System for Better Employment and Social Outcomes (Word doc)
Blind Citizens Australia Employment Submissions
BCA released a report for the then Department of Families, Housing, Community Services and Indigenous Affairs focusing on the employment of people who are blind or vision impaired.
Inquiry into improving the employment participation of people with disability
Take a look and read our submission on improving employment participation (Word doc) to the 2013 Inquiry which outlines the barriers experienced by people who are blind or vision impaired in gaining meaningful employment and career progression.
Recommendations of how the Australian government can meet their national and international obligations and practical solutions to improve employment are included in this submission.
Health and Emergencies
Response to Issues Paper: Emergency Planning and Response
BCA responded to the Issues Paper: Emergency Planning and Response, which also incorporates feedback and recommendations specifically on education from the South Pacific Educators in Vision Impairment (SPEVI Inc). The paper focuses namely on the Black Summer bushfires of 2019-2020 and the COVID-19 pandemic.
Submission to Senate Select Committee on COVID-19
BCA made a submission responding to the Senate Select Committee on COVID-19. There have been significant and wide-ranging issues faced by people who are blind or vision-impaired during the pandemic, including access to information and essential support services, access to food and nutrition, healthcare and housing, income security, education, community participation and social isolation and more.
National Disability Insurance Scheme
Joint Standing Committee Inquiry into General Issues around the Implementation and Performance of the NDIS
This submission to the Joint Standing Committee on the National Disability Insurance Scheme relates to some specific issues around the operation of the NDIS.
In our submission, we commented on some of the newly proposed legislative changes, as well as identifying some possible areas where we would like to see reform – including an expectation that assistive technology is a fixed item in plans for people who are blind or vision impaired, and ensuring the new training that is being promised for NDIA planners and other staff includes specific awareness on the needs of people who are blind or vision impaired.
Joint Standing Committee on the National Disability Insurance Scheme: Independent Assessments Consultation
This submission to the Joint Standing Committee on the National Disability Insurance Scheme relates to the introduction of independent assessments. BCA would like to respond to the proposed changes for NDIS eligibility assessments and planning, based on consultations with members, previous and current submissions, and advocacy work in the sector. This submission is based on existing legislation and frameworks, noting gaps in the fulfilment of requirements laid out in existing documentation.
Response to Consultation Paper: Access and Eligibility Policy with independent assessment
The process of Independent Assessments needs to be available to all NDIS participants in a clear, transparent manner. In introducing a new process to the Access Request and Planning process, information needs to be communicated in a range of manners, including Easy Read, for all people with disabilities to be able to understand. There is a large amount of anxiety around a shift to new processes. BCA has therefore responded to the proposed changes for NDIS eligibility assessments and planning, based on consultations with our members, previous and current submissions, and advocacy work in the sector.
NDS and NDIS Outcomes Frameworks: Introductory Paper Response
This submission is in response to the Introductory Paper titled Improving outcomes for people with disability under the National Disability Strategy (NDS) and the National Disability Insurance Scheme (NDIS). BCA’s response is based on consultations with our members, previous and current submissions, and advocacy work in the sector. The outcome areas covered include accessible communities, economic security, health and wellbeing, legislation, learning and skills, and personal and community support.
Response To Member Concerns – NDIS And Thin Markets
Blindness and vision impairment are considered to be low incidence disabilities. Hence, there are a very limited number of services which have specialist knowledge pertaining to them. This paper outlines BCA’s response to member concerns, and articulates strategies for overcoming the challenge of thin markets, as well as the limitations which BCA faces as a peak body in addressing this matter.
Review of the NDIS Act and the new NDIS Participant Service Guarantee
This review covers a number of issues experienced by BCA members, as well as recommendations, in relation to the National Disability Insurance Scheme’s processes, particularly those around planning and plan reviews.
Joint Standing Committee on the National Disability Insurance Scheme: NDIS Planning
Consultation with BCA members over several years, as well as more focussed consultation for this inquiry, identified several broad concerns with current NDIS Planning. This submission includes individual experiences and concerns from members; collated feedback from a couple of BCA’s state-based branches; and a series of recommendations for change.
Submission to the Productivity Commission’s position paper on NDIS costs
Further to BCA’s submission to the Productivity Commission issues paper in March 2017 (below), we thank the Commission for prioritising a number of issues that were raised. This latest submission focuses on those aspects of our March submission that were not adequately addressed in the Productivity Commission’s position paper, but continue to compromise the independence, participation and dignity of many people who are blind or vision impaired. These issues relate to the support needs of people with disability aged 65 or over, and the interfacing arrangements between the NDIS and the aged care system.
Submission to the Productivity Commission on the Costs of the NDIS
The Productivity Commission released a consultation paper asking a range of questions about the costs associated with rolling out the NDIS, with a focus on how costs could be reduced and how the NDIS could be run in the most cost-efficient manner. BCA has responded with a submission stating that it is not appropriate to view the effectiveness of the NDIS purely through the lens of economics and costs. We have also argued for the continuation of block funding for services such as braille production and library services, orientation and mobility and adaptive technology training. For example, it is not appropriate for people to be required to calculate how much orientation and mobility they will need in their plan, because this could change suddenly. We have taken this opportunity to discuss the benefits of ensuring that quality NDIS plans are implemented for consumers in the first place.
NDIS ACT Review
The Australian Government commissioned an independent review of the National Disability Insurance Scheme Act 2013 (Cth) (NDIS Act), as required under Section 208 of the NDIS Act. In accordance with this legislative requirement, Disability Ministers had agreed that Ernst & Young (EY) conduct the review.
The purpose of the review is to assess the operation of the legislative framework (comprising the NDIS Act and the NDIS Rules) and develop recommendations as to whether any improvements can be made to better support the objectives and principles of the NDIS Act.
The Blind Citizens Australia submission to the discussion paper can be found here: BCA NDIS ACT Review October 2015 (Word doc)
Payments, Benefits and Allowances
BCA Submission – Response to the Senate Standing Committee’s Community Affairs inquiry on the DSP
The Disability Support Pension (DSP) is a major contributor to the economic sustainability of living for people with disability. It is an economic safety net that enables people with disabilities to navigate the higher cost of living due to disabilities, and problems gaining and maintaining employment which leads to economic vulnerability, if not total unsustainability altogether.
In this submission, BCA makes recommendations to the Senate Standing Committee’s on Community Affairs taking into consideration that for people with disabilities, there are increased costs of living, and issues with sustaining those costs due to issues gaining and maintaining stable employment. Further, there are issues in gaining access to the DSP initially, with strong anecdotal evidence of requirement of advocacy support to navigate eligibility criteria to gain access.
Mobility Allowance Legislative Amendment November 2016
BCA was pleased to have the opportunity to comment on the amendment to legislation which would see the mobility allowance be transitioned into the NDIS, as part of the support available under that scheme. There are, however, some grave concerns that need to be addressed fully, so that the wellbeing of people who are blind or vision impaired who are not eligible for the NDIS will be assured. These changes will affect people with other types of disability who are not eligible for the NDIS in similar ways.
BCA Submission – DSP Impairment Table Review 2010
Approximately 90% of Blind Citizens Australia members are people who meet the criteria of legal blindness, many of whom receive the Disability Support Pension (Blind) or Age Pension (Blind). This high proportion is due to our membership classification, which until 2006, only permitted full membership to people who are legally blind, with people who are vision impaired or sighted able to join as associate members of the organisation. We therefore caution that our comments may not be reflective of the full and varying needs of people experiencing each visual condition.
In preparation for this review, we spoke with a number of orthoptists and professionals who work with people on the cusp of legal blindness or who have vision conditions which impacts on their daily living skills. Agencies included Royal Society for the Blind in South Australia, Centre of Eye Health in NSW (an initiative between Guide Dogs NSW/ACT and University of NSW) and Vision Australia.
This DSP Impairment Table Review (Word doc) submission supplies recommendations on a number of standards and tests which can be used to provide more effective assessments.
Royal Commission into Violence, Abuse, Neglect & Eploitation of People with Disabilities
Response to Promoting Inclusion Issues Paper: Hospitals
Hospitals have often been constructed in many stages, reflecting changing standards in building design and community expectations. Often people with sight require assistance with directions. There are seldom clues to assist people who are blind or vision impaired with wayfinding. Often a trip to hospital has not been planned and there has been no time for training in how to navigate the building, ward or room. Hospitals are usually busy places. Staff have little time to assist people who are blind or vision impaired to their destination. Even if a person feels confident to make their own way, things move often in hospitals, with corridors frequently obstructed and waiting-rooms difficult to navigate. These issues have all been exacerbated during the current pandemic, where physical contact is problematic and where accompanying people have been discouraged or banned.
Response to Promoting Inclusion Issues Paper: Education
Higher education is generally associated with better employment outcomes and higher income, yet people with disability are more likely than people without disability to leave school early. It is also generally recognised that most people will need to update or replace their qualifications many times throughout their working lives. Inaccessible resources, lack of access to technology and training and lack of confidence engendered by years of frustration limit the ability of people who are blind or vision impaired to participate in post-school learning options. This can compromise their employability and reduce their chances of career progression.
Response to Promoting Inclusion Issues Paper: Public Transport
This submissions covers a range of overarching issues across all transport, including tactile indicators, audible announcements, technology, staff assistance, dog guide issues, regional and remote issues, buses and trams, airports and airlines, electric vehicles, and e-scooters.
Response to Promoting Inclusion Issues Paper: Civic Participation
Statistics cannot capture exclusion. They do consistently reflect the lower proportion of people with disability who participate in various aspects of society, including employment, higher education and home ownership. While many individuals who are blind or vision impaired first experience exclusion as a personal issue, their repeated exposure to it and their discovery, through meeting or discussing with their peers, that these experiences have been shared by so many others, eventually lead them to realise that the barriers we confront are systemic. Versions of these exclusions have been experienced by all members of the BCA Board, its volunteers and the majority of the staff, who are blind or vision impaired. These concerns are demonstrated in the numerous case studies of people BCA has supported with individual advocacy.
Response to Promoting Inclusion Issues Paper: Technology
Not everyone can or wants to use technology to achieve day-to-day tasks and a society which does not respect this is not an inclusive one. Increasingly, government departments, utilities and private businesses rely on the fact that they provide websites and apps to diminish the availability of human assistance or nondigital services. To progress through a phone queue and reach an operator, it is often necessary to enter a series of numbers on a telephone keypad, which may be contained in printed information, usually in a small time window. To book an appointment with Centrelink, a restaurant, a hairdresser or a doctor, it will frequently be necessary to complete an online form.
Response to Promoting Inclusion Issues Paper: Employment
13 studies found that employers had positive attitudes towards people with disabilities. This includes highly rating employees with disabilities, comparative to employees without disabilities, for desirable traits for their workplace. Further, employers who had already employed people with disabilities held positive attitudes about employing others with disabilities. However, these positive attitudes did not translate into hiring and retention of people with disabilities in workplaces. Research indicated that employers are inclined to hire a candidate without disabilities, comparative to a candidate with disabilities, when both candidates have identical experience and qualifications.
Response to Issues Paper – Rights and Attitudes Towards People with Disabilities
BCA is pleased to have the opportunity to respond to this important issues paper on the rights of, and attitudes towards people with disabilities. This paper cites case studies to effectively highlight the ongoing challenges for people who are blind or vision impaired, and the continuing need for advocacy in addressing these issues, both at an individual and a systemic level. This paper addresses the question of “Where and when in life do people learn about the rights of people with disability? How could this be reinforced and/or improved?”.
Submission to NSW Point to Point Independent Review
A major point in the terms of reference for the NSW Point to Point Independent Review is to “examine the impact of the point to point reforms to date and advise if further structural adjustments are needed to ensure the long term viability of the sector and to realise positive customer outcome.” In this respect, this submission explores the experiences of people who are blind or vision-impaired in NSW in regards to using taxi and rideshare services, and whether the point to point reforms to date have achieved increased levels of accessibility or whether there are still outstanding issues. This submission was also provided to the Senate Inquiry about NSW Operation of the Point to Point Transport Act (Taxi and Vehicle Hire) 2016.
Submission to Inquiry about electric buses in regional and metropolitan public transport networks in NSW
A trial of electric buses will be commencing in Sydney’s inner west. Historically, the switch to electric rather than traditional, diesel buses has been driven by the desire for more economical and environmentally-friendly options for public transit. BCA would like to address the issues relating to electric or hybrid vehicles and their silent nature, which will cause significant safety issues for pedestrians who are blind or vision impaired.
Update: March 2019
BCA’s overarching view is that accessibility to public transport has improved in some areas in Australia since the second review in 2012, particularly in metropolitan areas. However, there is still substantial work to be done to ensure the right to accessible public transport for people with disability is recognised. This is particularly relevant to rural and regional areas where accessible public transport has not improved as much as metropolitan areas (if at all) and demonstrates the inconsistency of the application of the Transport Standards across Australia.
We are concerned that while there are some stated targets for the Transport Standards, there is no stated accountability, measurements or penalties for not meeting those targets.
All Australians want to be able to travel safely and independently. For people who are blind or vision impaired, being able to travel in their local area or between towns and cities keeps people connected and social which has long term benefits for them and the community. This also has broader benefits for older Australians, particularly given Australia is an ageing population. A consistent, national approach to accessibility of public transport across all areas of Australia – rural, regional and metropolitan – must be paramount.
The Department of Infrastructure, Regional Development and Cities has released the Issues Paper for the Third Review of the Disability Standards for Accessible Public Transport 2002 (Transport Standards). The Transport Standards were the first standards made under the Disability Discrimination Act 1992 (DDA) and commenced in October 2002. The Transport Standards were made to enable public transport operators and providers to remove discrimination from public transport services by providing specific details about the standards they need to meet.
BCA sought feedback on the experience of public transport for people who are blind or vision impaired, particularly over the last 5 years since the previous review of the Transport Standards in 2012.