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Submissions

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.

You can browse our Submissions by year:

2025

February

  • Response to the Aviation Customer Rights Charter
    The Australian Government’s Department of Infrastructure, Transport, Regional Development, Communication and the Arts has developed a draft Aviation Customer Rights Charter, as part of the ongoing reforms coming out of the Aviation White Paper. This charter sets out the expectations of fair and reasonable conduct by airlines and airports, and the obligations they have to their customers.
  • Submission to the Independent Review of NDIS Art and Music Supports
    The Federal Government announced an Independent Review of NDIS Art and Music Supports would be undertaken by Dr Stephen Duckett AM. This includes a review of the evidence of the effective of art and music therapy for people with disability, the qualifications and registration of art and music therapy practitioners, and pricing of art and music supports. BCA has collaborated with Vision 2020 Australia on a joint submission to this Review.In our submission we noted while further research is needed in an Australian context, international research on the effectiveness of play and music therapy on the anxiety, depression and self-esteem of school age children who are blind or vision impaired found that play and music therapy were “cost-effective, simple, familiar, and fun” for the children involved. We also highlighted the impacts and benefits of National Braille Music Camps in helping young people to develop skills, engage in recreational activities and socialise amongst their peers. We concluded that we encourage the NDIS to continue to offer art and music therapy as a funded support.

2024

December

  • Submission to DSS on Visual Descriptions
    The Department of Social Services conducted a review into the use of ‘visual descriptions’ of people at their events. In our submission, BCA argues that while well-intentioned, these visual descriptions can often end up being unhelpful. We make recommendations of more helpful forms of accessibility to consider.

  • Submission to Consultation on Foundational Supports
    The Department of Social Services (DSS) released a Consultation Paper on the design and implementation of new ‘General Supports’ that will deliver access to information and advice and build the capacity of people with disability to fully participate in the community. In our submission, BCA raised our concern with the way individual advocacy was separated out from other forms of disability support and considered ‘out of scope’, and outline how individual advocacy can support the capacity of people with disability. We also highlight the importance of ensuring access to Assistive Technology

June

  • Response to the Proposed Automated Vehicle Safety Reforms
    Continuing BCA’s active interest in automated vehicle regulation, this submission provides detailed feedback on the National Transport Commission’s proposed framework for Automated Vehicle Safety Reforms. BCA’s submission is based on extensive consultations with members and other people who are blind or vision impaired, and our ongoing advocacy work in the disability sector.

May

  • Submission to the NDIS Provider and Worker Registration Task Force
    Recommendation 17 of the NDIS Review’s Final Report proposes the development and delivery of ‘a risk-proportionate model for the visibility and regulation of all providers and workers.’ BCA’s submission considers the possible impacts of mandatory registration, with a focus on thin markets, support workers, orientation and mobility specialists, and the purchase of essential items from non-NDIS providers. BCA’s submission is based on extensive consultations with members and other people who are blind or vision impaired, and our ongoing advocacy work in the disability sector.
  • Feedback on the NDIS Amendment Bill 2024
    BCA continues its engagement with the NDIS Review in this submission to the Senate Community Affairs Legislation Committee’s inquiry into the National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No. 1) Bill 2024. BCA’s submission considers the draft legislation’s potential impacts on people who are blind or vision impaired, and calls for genuine co-design and collaboration. BCA’s submission is based on extensive consultations with members and other people who are blind or vision impaired, and our ongoing advocacy work in the disability sector.

March

  • Submission to the Inquiry into the Transition to Electric Vehicles
    This submission to the House of Representatives Standing Committee on Climate Change, Energy, Environment and Water builds on BCA’s recent submissions to government on Australia’s transition to electric vehicles (EVs) and automated vehicles (AVs). BCA’s submission is based on extensive consultations with members and other people who are blind or vision impaired, and our ongoing advocacy work in the disability sector.

February

  • Response to the Aged Care Bill 2023 
    Recommendation 1 of the Royal Commission into Aged Care Quality and Safety was that the Commonwealth government develop a completely new Aged Care Act. In this submission, BCA provides feedback on the exposure draft for the Aged Care Bill 2023. This submission builds on BCA’s contribution to the Aged Care Royal Commission. BCA’s submission is based on extensive consultations with members and other people who are blind or vision impaired, and our ongoing advocacy work in the disability sector.

  • Submission to the Inquiry Into NDIS Participant Experience in Rural, Regional and Remote Australia
    Following the publication of the NDIS Review’s Final Report in December 2023, BCA has made a submission to the Joint Standing Committee on the National Disability Insurance Scheme (NDIS) regarding participant experience in rural, regional and remote Australia. The need for additional supports is felt very keenly by people with disability in rural, regional and remote Australia. BCA’s submission is based on extensive consultations with members and other people who are blind or vision impaired, and our ongoing advocacy work in the disability sector.

January

  • Submission to the Senate Economics Legislation Committee’s Inquiry into Digital ID Bill 2023
    After BCA made a submission on the Commonwealth government’s proposed Digital ID legislation in October 2023, the Senate Economics Legislation Committee asked us to write a follow-up submission for its inquiry into the Digital ID Bill 2023. This submission builds on the previous one and provides some additional information that legislators should consider when examining the proposed legislation. BCA’s submission is based on extensive consultations with members and other people who are blind or vision impaired, and our ongoing advocacy work in the disability sector.
  • Response to the Disability Royal Commission Final Report (Commonwealth)
    On 29th September 2023, the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability handed down its final report. This document spans three million words and contains 222 recommendations on how to improve laws, policies and practices to ensure a safer and more inclusive society for people with disability. BCA’s response identifies a key omission from the final report and highlights the recommendations that the Commonwealth government should take urgent action on. BCA’s submission is based on extensive consultations with members and other people who are blind or vision impaired, and our ongoing advocacy work in the disability sector.
  • Response to the Disability Royal Commission Final Report (New South Wales)
    In formulating its response to the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability’s final report, the New South Wales government asked for BCA’s input. BCA’s response identifies a key omission from the final report and highlights the recommendations that the New South Wales government should take urgent action on. BCA’s submission is based on extensive consultations with members and other people who are blind or vision impaired, and our ongoing advocacy work in the disability sector.

2023

December

  • Feedback on the National Road Transport Technology Strategy
    BCA has already made two submission this year concerning vehicular technologies and road safety. This submission builds on those, with BCA providing feedback on the Commonwealth government’s draft National Road Transport Technology Strategy and draft 2024–27 National Connected and Automated Vehicle (CAV) Action Plan. These documents will help shape nationally coordinated and consistent rollouts of new road transport technologies across Australia. BCA’s submission is based on extensive consultations with members and other people who are blind or vision impaired, and our ongoing advocacy work in the disability sector.

November

  • Response to the Aviation Green Paper
    People who are blind or vision impaired often encounter challenges when travelling by air. BCA’s response to the Commonwealth government’s Aviation Green Paper builds on our submission earlier this year to the 2022 Review of the Disability Standard for Accessible Public Transport. BCA’s submission is based on extensive consultations with members and other people who are blind or vision impaired, and our ongoing advocacy work in the disability sector.

October

  • Feedback on the Digital ID Bill 2023 and the Digital ID Rules 2024
    The Commonwealth government has cited ‘recent cyber events’ as the catalyst for the voluntary Australian Government Digital ID System. Hoping that the solution does not create even greater problems, BCA has provided feedback on the proposed legislation. BCA’s feedback highlights the need for bolstered cybersecurity and greater digital inclusion for Australians who are blind or vision impaired.

September

  • Response to the Alternative Commonwealth Capabilities for Crisis Response Discussion Paper
    Australia faces increasingly frequent and severe emergency events. This submission to the Department of Home Affairs provides the Commonwealth government with a series of policy recommendations to improve its crisis responses and recovery capabilities, particularly as they pertain to the needs of people who are blind or vision impaired. This submission draws from BCA’s new Policy Report, entitled “Risk Reduction, Resilience and Response: Preparing for Emergency Events as a Person Who is Blind or Vision Impaired.”

August

  • Submission to the NDIS Review
    In late 2022, the Federal Government announced a review of the National Disability Insurance Scheme (NDIS) that would look at the design, operations and sustainability of the Scheme. The overarching goal of the Review is to put people with disability back at the centre of the NDIS. It aims to help restore trust, confidence and pride in the NDIS, as well as how to make the market and the workforce more responsive, supportive and sustainable.

    As a Disability Representative Organisation (DRO), BCA was funded to conduct consultations with people who are blind or vision impaired about their experience with the Scheme. Throughout July and August, we held four online sessions, and in-person consultations in Perth, Adelaide, Melbourne, Hobart, Canberra, Sydney and Brisbane. This report was submitted to the NDIS Review.

July

  • Response to the 2022 Review of the Disability Standards for Accessible Public Transport 
    BCA’s submission is in response to the discussion paper for the Department of Infrastructure, Transport, Regional Development, Communications and the Arts’ 2022 Review of the Disability Standards for Accessible Public Transport 2002. BCA’s response addresses the questions for people who use public transport on page five of the discussion paper. BCA’s submission is based on extensive consultations with members and other people who are blind or vision impaired, and our ongoing advocacy work in the disability sector. BCA’s submission is endorsed by several organisations.

June

  • Response to the Consultation Impact Analysis for AVAS on Electric Vehicles
    This submission concerns the Department of Infrastructure, Transport, Regional Development, Communications and the Arts’ proposal to mandate Acoustic Vehicle Alerting Systems (AVAS) for new electric, hydrogen fuel cell and hybrid vehicles in Australia. In this submission, BCA strongly recommends the introduction of AVAS for all electric, hydrogen fuel cell and hybrid vehicles in Australia. As requested by the Consultation Impact Analysis paper, BCA’s submission provides pertinent information to assist decision-making in this area. BCA’s submission is based on extensive consultations with members and other people who are blind or vision impaired, and our ongoing advocacy work in the disability sector.
  • Response to the NDIS Quality and Safeguarding Framework Issues Paper
    As part of the broader Independent Review of the NDIS, this submission is BCA’s response to the review of the NDIS Quality and Safeguarding Framework. BCA’s submission identifies what needs to be improved to ensure the Framework remains fit for purpose and reflects the lived experiences of people with disability. BCA’s response is based on extensive consultations with members and other people who are blind or vision impaired, and our ongoing advocacy work in the disability sector.

May

  • Response to the Inquiry into the Impact of Road Safety Behaviours on Vulnerable Road Users
    This submission to the Victorian Legislative Assembly Economy and Infrastructure Committee’s Inquiry concerns the impact of road safety behaviours on vulnerable road users since the onset of the COVID-19 pandemic. BCA strongly recommends that all electric, hydrogen fuel cell and hybrid cars, trucks and buses and e-scooters in Victoria be fitted with an Acoustic Vehicle Alerting System. BCA’s response is based on extensive consultations with members and other people who are blind or vision impaired, and our ongoing advocacy work in the disability sector.
  • Response to the Administrative Review Reform Issues Paper
    This submission to the Attorney-General’s Department concerns the creation of a new federal administrative review body to replace the existing Administrative Appeals Tribunal (AAT), the body which reviews decisions made by the National Disability Insurance Agency. This submission addresses questions 1, 2, 17, 18, 39, 61, 63, 64 and 65 from the Issues Paper. BCA’s response is based on extensive consultations with members and other people who are blind or vision impaired, and our ongoing advocacy work in the disability sector.

April

  • Response to the Consultation Paper for the New Disabilities Act
    This submission addresses each of the seven sets of questions put forward in the Department of Social Services’ Consultation Paper for the new and improved Disability Services Act, which will provide a basis for continued services and supports outside the NDIS for people with disability. BCA’s response is based on extensive consultations with members and other people who are blind or vision impaired, and our ongoing advocacy work in the sector.
  • Response to the proposed Disability Inclusion (Review Recommendations) Amendment Bill 2022
    BCA believes the proposed Disability Inclusion (Review Recommendations) Amendment Bill 2022 provides the South Australian government with a unique opportunity to make voting accessible for people who are blind or vision impaired. This submission examines accessible voting in South Australia and offers several recommendations. BCA’s response is based on extensive consultations with members and other people who are blind or vision impaired, and our ongoing advocacy work in the disability sector.

January

  • Submission to the Technology-Assisted Voting Review
    The principle of free and equal participation in the political process is a fundamental tenet of democracy which includes the right of citizens to cast a secret vote in government elections. Australia was the first country in the world to allow citizens to cast their vote anonymously, a concept that was quickly adopted in democracies across the world. Yet electoral processes in NSW, which rely on pencil and paper voting, means that people who are blind or vision impaired are forced to rely on another person to assist them to vote – whether that is a support worker, a spouse or other family member, or Electoral Commission staff – and trust that they have completed the ballot paper accurately according to their wishes. This submission is a response to the TAV Review Consultation Paper and Terms of Reference. Our response is based on extensive consultations with members and other people who are blind or vision impaired during the elections that were held throughout 2021 – 2022, extensive sector engagement, as well as our ongoing advocacy work in this area.

2022

December

  • Submission to the Disability Royal Commission: Audio Description
    Blind Citizens Australia has been campaigning for audio description on Australian TV for over 25 years. Although audio description is now provided on the ABC and SBS, there remains a lack of systemic change in this space.In September 2022, the UN Committee on the Rights of Persons with Disabilities handed down its finding that Australia has failed to comply with its obligations under the Convention on the Rights of Persons with Disabilities because it has not taken appropriate measures to identify and eliminate barriers to accessibility to ensure people who are blind or vision-impaired can enjoy equal access to television programs. The Australian Government’s failure to guarantee the provision of audio description on free-to-air television is ongoing.BCA asks that the Commission:

    • Monitors and reports on the Australian government’s response to this UN CRPD finding
    • Explores complaints mechanisms through the Disability Discrimination Commission, and the UN CRPD Committee, to promote a more fair, accessible and equitable process by which Australians with disability can make complaints against disability discrimination.
    • Investigates how Australia’s Disability Strategy can monitor and report on accessibility improvements in the community, in the business sector and in government and public policy.
  • Response to Employment White Paper
    According to the Australian Bureau of Statistics (ABS), over 4.4 million Australians have some form of disability – roughly equating to 1 in every 5 Australians having a disability. As a signatory to the UNCRPD, governments in Australia have an obligation to “safeguard and promote the realisation of the right to work”, and to protect the rights of people with disability “to just and favourable conditions of work”, on an equal basis with others. This submission is a response to the White Paper Terms of Reference, and is based on existing legislation and frameworks.

August

  • Submission to the Disability Standards on Accessible Public Transport
    BCA has written a submission in response to the Stage 2 Consultations on Reforms to the Disability Standards on Accessible Public Transport. The submission focuses on how the reforms impact people who are blind or vision impaired, and identifies the issues with accessibility to transport and navigation that still exist for people who are blind or vision impaired.

March

  • Joint Standing Committee on the NDIS Inquiry on Scheme Forecasting and Implementation
    This submission to the Joint Standing Committee focused on several issues around the further implementation of the scheme. These included the importance that new training being proposed for NDIA and LAC staff includes specific information about the needs of people who are blind or vision impaired, ensuring all communication is accessible in a range of formats, an awareness of the importance of Orientation and Mobility (O&M) supports, and the complex interface between the NDIS and other support systems.

2021

October

  • 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.

July

  • 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.

June

  • 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.

May

  • 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.

March

  • 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

February

  • 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.

2020

December

  • 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.

November

  • 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.

October

  • 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?”.

August

  • 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.

July

  • Response to Issues Paper: Emergency Planning and Response
    There have been significant and wide-ranging issues faced by people who are blind or vision-impaired in recent crisis in Australia, namely the Black Summer bushfires of 2019-2020 and the current COVID-19 pandemic.Pertinently, people with disability have been disproportionately affected by the COVID-19 pandemic.In global terms, an estimated 46% of people over the age of 65 have disabilities.  Aging is a known correlation for higher likelihood and severe contraction of COVID-19. Additionally, people with disabilities are at greater risk of contracting COVID-19 due to barriers to implementing basic protection measures and the need for physical contact with other people to meet support needs.  Further, some people with disabilities are at greater risk of developing more severe health complications or dying from COVID-19.
  • Report on Banking Services and Products for People who are Blind or Vision Impaired
    This report compiled by BCA examines the access of banking and financial services or products for people who are blind or vision impaired. This report will highlight the additional challenges and barriers that people who are blind or vision impaired face daily, and will provide recommendations outlining best practice solutions to these challenges and barriers.

May

  • 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 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.

2019

December

  • 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.

October

  • 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.
  • 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.
  • 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.

September

  • 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.
  • 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.

August

June

February

  • 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.

2018

November

  • Submission to the Third Review of the Disability Standards for Accessible Public Transport 2002
    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.

August

  • Submission to the Royal Commission into Misconduct in the Banking, Superannuation and Financial Services Industry
    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.

2017

July

  • 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 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.

March

  • 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.

February

2016

December

  • 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.
  • 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.

November

  • 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.

2015

October

  • 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.

2014

August

  • 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.

2013

September

June

February

  • Inquiry into improving the employment participation of people with disability
    Take a look and read our submission on improving employment participation 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.
  • 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.

2012

August

  • 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.

June

  • 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.

2010

October

  • 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.