This section of the Interim Report summarises the main issues raised in submissions which relate to the job search phase of employment. Those issues include:

1. the main government-funded services available to assist people with disability to find a job;

2. the primary concerns regarding changes to the government-funded employment services as announced in the 2005 Commonwealth Budget;[1]

3. the role of private recruitment agencies;

4. the recruitment strategies of three large employers;

5. potential problems encountered in the job selection process; and

6. the possibilities offered by self-employment.

5.2 What government-funded employment services are available to people with disability?

The Inquiry received a large number of submissions regarding access and improvements to certain government-funded employment services. The number of submissions reflects both the importance of these services (from the employer, employee and government perspectives) and the concern about changes announced in the Commonwealth 2005-06 Budget.

The following text discusses those services that were raised most often in the submissions to the Inquiry. For a more general description of Commonwealth government-funded services see the Inquiry's Issues Paper 5.[2]

Employment services can provide a vital service to many people with disability. One employment agency, Job Futures, describes the model within which they work as follows:

Job Futures supports an employment services model for people with a disability that:

<>offers financial security to people who are not in work, and appropriate opportunities and incentives for people who can work to move into employment;
promotes a rapid return to work where possible, and backs that expectation with services that build capacity, place people in the right jobs, and support both clients and employers to ensure people get a secure foothold in the labour market;
recognises the diversity of people's individual needs and outcomes, without assuming that some people can't work because of the type of disability they have or the degree of disability;
recognises the diversity of people's lives and circumstances;
provides tailored, flexible services to support people to return to work;
matches services to the client rather than clients to the services; and
leads to increased social participation, such as work readiness activity, more social connection or increased contribution to the community.[3]

There are a variety of different types of employment services available to people with disability. This section of the report briefly addresses the following:

1. Referrals to appropriate employment services

2. Disability Open Employment Services (DOES)

3. Job Network employment services (JN)

4. Commonwealth Rehabilitation Services (CRS)

5. Personal Support Program (PSP)

6. Funding for employment services

7. Coordination between employment services and other support services

8. Specific disability employment specialists.

5.2.1 Referrals to appropriate employment services

The first stop for many people with disability who are out of work is Centrelink, which provides the Disability Support Pension (DSP) or other relevant welfare support. Centrelink will generally conduct an assessment of a person's abilities and then refer that person to what is believed to be the most appropriate agency to assist in finding employment.

Some submissions expressed concern about this referral processes. For example, Stepping Stone Clubhouse told the Inquiry that they often receive inappropriate referrals from Centrelink.[4] The Disability Council of NSW also note that significant numbers of inappropriate referrals are made and that this contributes to substantial delays for people with disability:

Timeliness is key to the success of supports offered to jobseekers. The longer a person with disability is out of the workforce the lower their chances are of successfully re-entering the workforce. The emphasis needs to be placed on swift and effective early intervention, involving referral to the most appropriate employment support provider with capacity to start the service immediately, or rehabilitation.[5]

Scope Employment questioned whether Centrelink is the best place for people with disability to receive referrals, as people with disability often view Centrelink in a negative light.[6]

In the May 2005 Budget, the government allocated funding to develop a 'high quality information technology link to provide streamlined servicing to job seekers'. This system is intended to:

link all service providers, increasing opportunities for job seekers to have the provider of their choice and enabling more effective monitoring service delivery standards . [and] will allow rapid referral to, and between, appropriate employment assistance services and work capacity assessors.[7]

The Budget also announced the introduction of new 'Comprehensive Work Capacity Assessments' to 'determine medical impairment, work capacity, intervention needs and referral options.'[8]

Further, the Budget announced that from1 July 2005, people on the Disability Support Pension can directly approach Job Network members whether or not they have a Centrelink referral.[9]

Some submissions to the Inquiry respond positively to the freedom to directly access a Job Network or Disability Open Employment Service provider. For example the NSW Disability Discrimination Legal Centre (DDLC) argues that the new system will assist in the streamlining and integration of existing arrangements, reduce the administrative load and enable more effective assessment of demand.[10]

Others have expressed concern that Job Network agencies are insufficiently trained to meet the needs of a job seeker with disability, and therefore self referral to such agencies may not be in the best interests of the individual.[11] For example, DEAC told the Inquiry that:

We believe that Job Network staff are ill equipped to service clients with complex needs. In our view what is needed are highly specialised case managers with skills and experience in servicing people with complex need i.e. ABI, psychiatric disability, MS etc.[12]

5.2.2 Disability Open Employment Services (DOES)

The ACE National Network, a peak body representing disability employment services across the country, describes the role of DOES as follows:

Disability Employment Services provide a range of services to jobseekers with disabilities in order to prepare them to return to work.

Vocational guidance and support
Support in managing disability-related issues before and after starting work
On-the-job support to assist in settling into a new job
Off-site support for those who do not disclose their disability

They also provide a range of services to employers including;

Recruitment and selection assistance
On-the-job training with new employees
Follow-up and back-up support
Re-training of employees should they move from one duty to another or if a new skill is required
Advice and training to co-workers about issues related to employing people with disabilities.[13]

Department of Employment and Workplace Relations (DEWR) figures indicate that as at January 2005, there were 227 organisations across Australia providing DOES services from 324 outlets. Further, DOES agencies assist approximately 46,000 people with disability each year.[14]

The DOES program was transferred from the Department of Family and Community Services (FaCS) to DEWR in early 2005. From 1 July 2006, the Commonwealth Budget allows for funding for an additional 21,000 DOES places over three years (see further below).

It is difficult to assess the effectiveness of DOES programs. FaCS reports on DOES outcomes have consistently shown that around 50 per cent of service users are in jobs, and in 2001-02, 39 per cent of those people were working more than 30 hours a week.[15] However, ACOSS recently estimated that there is a less than 20 per cent chance that an average DSP recipient would obtain ongoing fulltime employment in a mainstream job within twelve months of participating in an employment program.[16]

Some submissions to the Inquiry noted that these services have considerable benefits, including specialist knowledge of disability related issues and access to wage subsidies and workplace modifications.[17]

Others expressed a number of concerns about the manner in which the DOES program is funded. In particular, there was concern about:

(a) The cap on Commonwealth funded places in DOES; and

(b) The transition to a Case Based Funding (CBF) model.

(a) Capped places in DOES

Several submissions suggest that the cap on the number of places available in DOES leads to unmet needs and long waiting lists.[18]

... service providers [are forced] to turn away some job seekers or make them wait months for a service. Sitting on a long waiting list - particularly for people who face other barriers to employment - is a significant discouragement.[19]

Various organisations and employment services argued that the cap should be removed.[20] For example, the Brotherhood of St Laurence recommended:

more places in disability open employment services, preferably by removing the funding appropriation cap. This could be done administratively or by amending the Disability Services Act 1986 to introduce an entitlement to employment service job assistance to the current target group (those people with permanent disabilities who need ongoing support to achieve sustainable open employment).[21]

Others asked for an overall increase in investment into DOES.[22]

As noted above, the May 2005 Budget provides funding for an additional 21,000 places in DOES for three years starting from 1 July 2006.

17,000 of those places are for people with disability who, from 1 July 2006:

(a) are assessed to have a capacity to work between 15 and 29 hours per week at award wages; and

(b) do not need ongoing assistance for more than two years.

These people will have part-time work obligations under the new welfare reforms (and will receive the Newstart Allowance). Although there is an allocation for an extra 17,000 DOES places, funding will be provided on a demand-driven (as opposed to capped) basis.

The extra funding for the remaining 4,000 places are for people who:

(a)    do not have participation requirements;

(b)   need support for more than two years; or

(c)    cannot work at award wages.[23]

These places will be capped. Thus the cap on the provision of DOES services remains for those capable of working under 15 hours per week and who therefore receive the DSP. Consequently, if a service has reached the limit of DSP clients for which it is contracted to provide services, it either has to service that person out of its own funds or turn the client away.

(b) Transition to case based funding (CBF)

From 1 July 2005 all agencies providing DOES to new clients will be funded by the government through a case-based funding (CBF) model rather than 'block' funding.

This means that rather than general funding allocated on the basis of the number of DOES places allocated to a particular agency, the funding will vary depending on the number of persons serviced by that agency, the assessed needs of each person and the outcomes achieved by the agency.[24]

The idea behind the transition to case based funding for DOES is that the funding will better reflect the individual needs of the clients. For example, an agency servicing a person with higher needs will receive a higher level of funding.

Several submissions to the Inquiry suggest that, in principle, a move to a funding model that focuses on the varying needs of job seekers should lead to improvements in the services provided. [25]

However, submissions also suggest that while an individualised assessment is a good idea in principle, the restrictions within DEWR's proposed case based funding model will mean that the needs of some groups will not be met.

For example the NSW Council for Intellectual Disability (NSW CID) states that while the CBF Model is a positive step toward focusing on a person's individual requirements, the real costs of providing an appropriate employment service for a person with an intellectual disability is likely to be greater than the highest funding band available under the CBF model.[26] NSW CID further argues that the model has limited funding for people whose initial placements do not work out.[27]

ACROD suggests that there may be similar concerns for people with a psychiatric disability and recommends that:

The structure and levels of funding for employment assistance programs should be reviewed to ensure that they do not unintentionally create disincentives to servicing particular disability groups.[28]

Other submissions expressed concern about the operational impact of case based funding for DOES. For example, the Disability Services Commission of Western Australia suggests that the movement to case based funding has led to a significant range of uncertainties for service providers which impact on their capacity to deliver quality services to people with disability.[29]

ACROD argues that the move to case based funding supports an argument for reducing the cap on all disability open employment services, as the system reduces financial risk to government:

... because, under that system, fees are paid to service providers only on the basis of services delivered and employment outcomes achieved. Unfilled places attract no payments.[30]

5.2.3 Job Network (JN)

Job Network is a national network of community and private organisations contracted by the Federal Government to find jobs for unemployed people.

In the past, Job Network members provided employment services to people with disability who did not have support needs for more than 26 weeks after getting a job and DOES provided employment services to those who did have ongoing support needs.[31] Some Job Network members had staff with speciality disability training and others did not.

Changes announced in the Commonwealth Budget mean that the boundaries between Disability Open Employment Services and Job Network agencies will be less clear. As discussed above, from 1 July 2005, Job Network agencies can directly register any job seeker, including those who are on the Disability Support Pension and who have ongoing needs. DEWR hopes to develop a simplified process of cross referral between agencies in the event that Job Network is not the most appropriate place for a job seeker.

Some submissions suggested that because Job Network places are funded according to successful job placement outcomes, there is less incentive to focus on clients with higher needs.[32] For example, the Australian National Organisation of the Unemployed state that:

The Star Rating performance assessment encourages Job Network members to focus on easy to place job seekers. The more difficult clients are either churned through a series of activities programmes which attract lucrative government fees, or are simply consigned to the too hard basket.[33]

Job Futures suggested that:

There is currently no additional funding under Job Network to place people with a disability which may result in some providers viewing people with a disability as a 'higher cost' employment outcome.[34]

Furthermore, the episodic nature of some disabilities is not reflected in Job Network outcomes. Consequently, a person with disability whose capacity to work fluctuates may be perceived as a client who is harder to place and receive a reduced service.[35]

The Government announced funding for an additional 31,700 places in Job Network over three years starting 1 July 2006. These places will be for people with disability who have been assessed with a work capacity for 15-29 hours a week.[36]

(a) Job Network and the DEWR DSP Pilot

In October 2004, DEWR published the initial results of a trial conducted to explore strategies to engage DSP recipients with Job Network services.[37]

The pilot involved 12 disability specialist Job Network providers in 37 sites across Australia. They were required to develop marketing and communication strategies to encourage eligible DSP recipients to approach a Job Network member for employment assistance and to liaise, network and engage with employers.[38]

Over 1,100 job seekers registered their interest in participating in the pilot study. Eight hundred of these people were eligible for the services and 671 applicants commenced the program, receiving immediate access to the highest level of assistance available. Thirty six percent of those participants remaining on the program were successfully placed in employment or education. Out of all job seekers placed, 39 per cent were in casual employment, 31 per cent were in part-time positions, 22 percent were in full-time employment, and 8 percent had entered into education.[39]

Amongst other things, the Pilot results indicate that DSP recipients are more likely to engage with Job Network when they are directly approached and assisted in navigating the services.[40]

While the Pilot indicates the potential of Job Network to service DSP recipients, there have been some criticisms of the Pilot. In particular there is concern that the Job Network trial participants were not reflective of Job Network members generally because they were specialist services. The suggestion is that while there would be a very steep learning curve for many Job Network providers, DOES already have the necessary skills and it therefore makes little sense to divert people with disability to Job Network.[41]

(b) Job Network and people with mental illness

A number of submissions expressed concern about the adequacy of Job Network services for people with mental illness. For example, the Network for Carers of People with a Mental Illness suggest that:

Case loads are too high for provision of an effective service. Consequently contact times and ability to provide one-on-one post-placement support are reduced.
Support is focussed around a three month and six month outcome period, making it inflexible in relation to the episodic nature of mental illness.
There may be no formal training or recruitment requirements regarding knowledge of mental health.
There is no structure for family involvement in services.[42]

UnitingCare and Scope Victoria suggest that Job Network members require further training in order to work effectively with clients with mental illness.[43]

5.2.4 Commonwealth Rehabilitation Services Australia (CRS)

As discussed in Chapter 6, whereas Job Network services are intended to assist those people with disability who do not have support needs for more than 26 weeks, and DOES are intended to assist those people who do have ongoing support needs, Commonwealth Rehabilitation Services Australia (CRS) provides vocational, rehabilitation and employment assistance to people disability who acquire an injury, medical condition or specific disability and require rehabilitation assistance to get back into work. These people may have needs both on a preliminary and ongoing basis. [44]

Some of the services provided by CRS include:

assessment of the person's abilities and their vocational, physical or psychological needs;
disability management strategies;
advice and counselling on employment options;
development of a persons' work related skills and abilities;
increasing participant motivation through professional motivational techniques;
on-the-job assessment, workplace training and job search training programs;
assistance with job redesign, alternative duties or workplace modifications; and
a client supported in the workplace for up to three months
career planning sessions (funded by Department of Education, Science and Training - DEST).[45]

The Commonwealth government announced funding for an additional 42,000 vocational rehabilitation places over three years from 1 July 2006. It is not clear how much of that funding will go to CRS in particular.[46]

5.2.5 Personal Support Program (PSP)

The Personal Support Program (PSP) is intended to bridge the gap between crisis assistance and employment assistance programs. It provides help to people whose non-vocational barriers (such as mental health issues, drug or gambling problems, homelessness or social isolation) prevent them from getting a job or benefiting from Job Network or other employment assistance services.[47]

The program is open to people of workforce age receiving income support (including the DSP), as well as those aged 15-20 who do not receive any payment but are registered as job seekers with Centrelink. Eligibility for the PSP is assessed by Centrelink. The program is funded to assist 45,000 participants in 2004-05.[48]

The Federal Government currently funds 148 organisations covering 600 sites across Australia to deliver PSP services. Of the 600 Australian sites, 230 are non-metropolitan sites. There are approximately 60 sites (10%) registered as having a speciality in mental health and 10 sites registered as having a speciality in physical/intellectual disabilities.

Services provided by the PSP can include assessment (such as psychological assessment or functional capacity assessment), counselling (general counselling, or for specific issues such as grief counselling), referral and advocacy (linking participants into their community and accessing services), practical support (such as assistance to find stable housing or with transport) and development of personal skills (for example anger management or self-esteem training).

Several submissions suggest that this is a useful program for those with multiple barriers to workforce participation, particularly those with a mental illness. However its effectiveness is limited by inadequate funding and poor links with employment programs.[49]

The 2005 Standing Committee Working for Australia Report recommended that:

[T]he Australian Government initiate further cross-portfolio coordination to increase the provision of places in holistic type projects (through the Personal Support Program, Green Corps and traineeship programs) which assist the long-term unemployed enter the labour force.[50]

There are indications in the 2005 Budget papers that that funding for the PSP will increase.[51]

5.2.6 Disability Recruitment Coordinator

As discussed in Chapter 2, Disability Works Australia has been contracted by the Department of Family and Community Services to act as the national Disability Recruitment Coordinator. They operate as a central point of contact for employers and facilitate recruitment on a large scale. The Inquiry heard that while this may be a successful strategy for large employers, it may not adequately address the needs of small and medium employers. [52]

5.2.7 Funding for employment services

Some of the submissions to the Inquiry argued for increased government funding for employment services:

Australia currently has one of the lowest funding rates as a percentage of GDP spent on employment programs in the western world. If governments are serious about meeting skills shortages and placing people with disabilities into employment hey need to dramatically increase spending on employment programs.[53]

The Inquiry has already noted that the 2005-06 Commonwealth Budget did announce additional funding for extra places in DOES, JN and vocational rehabilitation services over the next three years. However, as discussed above, several groups are of the view that the way in which the funding is managed, and the caps on certain types of services, will not provide the optimum outcomes.

5.2.8 Coordination of services

A large number of submissions expressed concern to the Inquiry about coordination between services available to people with disability. [54] The issue is well explained by the Disability Council of NSW:

People with disability can receive more than one service in a day that is to meet their disability-related needs. It is essential that these services are coordinated across jurisdictions and delivered in a flexible and reliable manner so that they do not hinder a person from the pursuit or retention of employment. By way of example, the provision of in home support service for people with a physical disability.[55]

Many of these problems arise because some services are Commonwealth government programs and others are State and Territory programs. For example, employment services are Commonwealth funded and rehabilitation services are generally State-funded:

The fact that employment support services are funded federally and rehabilitation is funded by the states compounds the lack of coordination. State-funded programs will often focus on social and recreational activities that although important to do not assist people to develop the necessary skills and stamina to become more prepared for employment. Employment support workers often find they are not able to assist a jobseeker because they are not 'work ready' and need more support than the pre-vocational opportunities that exist can provide. It is not clear to the state funded services exactly what is meant by 'not work ready' and what role their programs can play to assist people to become more work ready. These programs are also not always funded to provide the level of support required and community programs such as neighbourhood houses etc. do not always have the skills and resources to provide them either.[56]

Some submissions called for greater integration between vocational and clinical services. For example, the Centre of Full Employment and Equity argues that there is:

Growing recognition that the integration of clinical and vocational approaches is likely to be most effective in improving employment outcomes of people with mental health conditions.[57]

Social Firms Australia argues that there needs to be:

A commitment from Commonwealth and State governments to support more collaboration between the clinical, rehabilitation and employment sectors with more transfer of specialist skills between them.[58]

Many of the submissions concerning mental illness mention the need for better coordination between employment and mental health services.[59] For example, the Mental Illness Fellowship of Victoria states that :

The split between state funded health services and commonwealth funded employment services also presents a major barrier to providing an integrated approach. An integrated approach allows for rapid placement, individually tailored and responsive employment support, and coordination of vocational and treatment goals.[60]

Waghorn and Lloyd suggest that the inter-sectoral collaboration called for in the National Mental Health Strategy has not eventuated.[61]

5.2.9 Specific disability employment specialists

Groups representing people with mental illness, vision impairment and Deafness or hearing impairment all highlighted the need for specialist services in those areas.

(a) People with mental illness

People with mental illness may require specialised services, including assistance with pre-vocational issues, social preparation for employment, and flexible post-placement support.[62] As noted earlier, there is a general concern that there are insufficient numbers of specialist trained staff in Job Network services.

The Royal Australian and New Zealand College of Psychiatrists (RANZCP) highlighted the magnitude of the problem:

A report by the . Department of Family and Community Services shows that people with psychiatric disabilities make up the largest proportion of those using publicly funded disability employment services, but achieve the lowest outcome rates.[63]

The RANZCP argued that:

It is essential to examine the current situation regarding the current situation of services for people with mental illness. Mental health, employment and disability support are served by multiple agencies across both the public and private sector social support system, and an unemployed person recovering from a mental illness must navigate several systems. Gaining data on the real life experiences of people who use these systems would be beneficial in planning for service improvement.[64]

Other submissions suggest that some of the problems in providing appropriate specialist employment services for people with a mental illness may be overcome by locating employment services in the same place as public mental health services.[65]

Waghorn and Lloyd suggest a need for more innovative approaches for people with mental illness:

Demonstration projects specialising in cutting-edge vocational services for people with mental illness are needed in a range of Australian urban and rural sites to assess the feasibility of more evidence based practices and the range of methods by which the inter-sectoral problems can be overcome.[66]

There are a few examples of open employment services focussing on people with a mental illness including members of Ostara Australia[67] and Open Minds in Brisbane.[68]

(b) People who are Deaf and hearing impaired

The Australian Association of the Deaf highlights that general employment services and even broad-based disability employment services do not have a good understanding of Deaf people's needs.[69] These specific needs include access to funding for interpreters and accessible phones (TTYs), including an internet relay system. Staff in employment agencies may also need to spend more time explaining the various processes with Deaf and hearing impaired clients.[70]

The Australian Federation of Deaf Societies and ACE National Network describe how the absence of Auslan interpreters hinder communication between caseworkers and their clients and make job interviews impossible in some circumstances.[71] The Australian Federation of Deaf Societies provided the following example:

An employment service refused to pay for an interpreter for a job interview for a Deaf client despite the clear requirement for an Auslan interpreter. Being unaware of her rights, the Deaf client did not press the issue and instead the client's mother was used as a notetaker during the job interview.[72]

The Deafness Forum of Australia recommended training for employment service staff so they can better understand the wide variety of hearing impairments and communication strategies to deal with them.[73]

(c) Blind and visually impaired people

A vision impaired individual told the Inquiry that the Australian Government Jobsearch website is not 'JAWS' friendly (JAWS is a screen reader for blind and vision impaired people). She stated that while Centrelink and other employment service providers have computers with advertised positions, these computers are not fitted with any screen reading or large print software products. [74]

Blind Citizens of Australia highlights that job classifieds in print form are inaccessible to people who are blind or vision impaired, and ads using the internet medium are, in most cases, not configured for adaptive technology used by people who are blind or vision impaired. Even when a job can be accessed electronically, the electronic application forms are usually in an inaccessible format. Further, job details and application forms mailed to recipients in print form are often useless to people who are blind or vision impaired.[75]

5.2.10 Employment services for graduates

A number of submissions suggest that the needs of specific client groups are not being met, and call for the establishment of a greater range of dedicated employment services, for example services focussing on recent school leavers,[76] and retrenched workers.[77]

In particular, the National Regional Disability Liaison Officers and Disability Co-Ordination Officers Network (RDLO) and Disability Employment Action Centre (DEAC) highlight that there are an insufficient number of employment services that can properly assist graduates with disability to find a job.[78]

DEAC suggests that the current service models are not designed to meet the meet the needs of graduates with disability.[79] RDLO suggests that there is an erroneous assumption that graduates with disability do not need special assistance on the basis that 'if they have got this far, they will know what to do':

there appears to be a pre-conceived view from within government departments and employment organisations that graduates with a disability do not have issues in accessing employment because they have formal tertiary qualifications. As a result no services or support structures are made available.[80]

5.3 How might private recruitment agencies assist people with disability?

Not all people with disability will use government-funded employment services to help them find a job. Many job vacancies, particularly more senior professional positions, are advertised through private recruitment agencies.

Several submissions expressed concern that the both the private and public sector increasingly used recruitment agencies without ensuring that they use non-discriminatory selection criteria and practices.[81] For example, the Australian Federation of Deaf Societies reports:

The increasing use of external recruitment agencies by public and private sector organisations creates an additional barrier for job seekers. Such agencies will obviously vary in their policies and attitudes towards people with a disability and these will not necessarily reflect the view of the client for whom they act.[82]

Blind Citizens Australia recommends that:

Government agencies that outsource recruitment should revise their contracts to make explicit the requirement that recruitment organisations actively encourage expressions of interest and applications from people with disabilities. Targets for the participation of people with disabilities in the recruitment process should be included in the contracts.[83]

Manpower, itself a recruitment agency, informed the Inquiry that recruitment providers are not skilled in disability issues:

Support for the placement of [people with a disability] is negligible, with no guidelines or standards provided, and a general lack of consideration for this work sector.[84]

Westpac notes that people with disability seem not to use recruitment agencies because those agencies are not properly trained or have not made the appropriate adjustments. Westpac has therefore tried other approaches to targeting people with disability in their recruitment process.[85] IBM and National Australia Bank also note that they have preferred recruitment agencies - who have the appropriate expertise and approach - in order to encourage hiring people with disability.[86]

Some submissions noted the inaccessibility of recruitment agencies for people who are blind and vision impaired. For example, recruitment agencies are generally not equipped with adaptive technology.[87] They argue that significant education of recruitment agencies and their peak body may overcome some of these barriers.[88]

From 2002 to 2004 the Equal Opportunity Commission of Victoria (EOCV) conducted an inquiry into the recruitment industry's awareness and understanding of Victoria's equal opportunity laws and practice. The inquiry identified the potential role of the recruitment industry to ensure appropriate selection practices for job seekers with disability (amongst other disadvantaged groups).

The EOCV reported that recruiters felt that they were sometimes hamstrung by employers who wanted to influence the type of people referred to them. In the face of this pressure by employers, 76 per cent of respondents (people who had agreed to participate in the survey with the EOCV) said they always made every possible effort to comply with Victorian equal opportunity laws. Nine out of 10 agreed that they tried to inform or educate businesses about the law. However, in exploring the practices of recruitment agents, a further 33 per cent agreed that they sometimes rule out candidates even though they know they should not do so.[89]

5.4 What are some of the recruitment strategies of large employers?

Submissions from three large companies outlined their strategies to encourage recruitment of people with disability.

IBM told the Inquiry that its strategies include:

Partner with Disability Works Australia . to tap into the national disability candidate pool for all available roles
Partner with universities to put direct campaigning in place for proactive hiring of graduates with a disability
Engage preferred recruitment supplier [recruitment agencies] to source professionals with a disability through education and incentives
Choose [recruitment agencies] that support IBM's diversity initiatives
Engage employees through IBM's Employee Referral program which encourages employees to refer their peers with a disability to IBM
Provide work experience placements for students with a disability
Provide disability awareness training for IBM Recruitment Specialists and Hiring Managers to raise awareness.
Participate in the Willing and Able Mentoring Program, an external national mentoring program for tertiary students with a disability that builds the pipeline of candidates with a disability for the corporate sector.[90]

Westpac told the Inquiry that in order to recruit people with disability, it:

currently broadcasts our entry level job vacancies in to Disability Employment Services through Disability WORKS Australia. This ensures that jobseekers with a disability have an opportunity to apply for vacant roles that come up in our high volume area within Westpac. We have also held briefings for Disability Employment Service providers so that they are familiar with our recruitment processes and can adequately prepare their jobseekers for interview and assessment.[91]

The National Australia Bank described the following recruitment strategy:

The National either directly or through its preferred suppliers sends all externally advertised positions to [Disability Works Australia - DWA] . They in turn liaise with Disability Employment Services across Australia to source candidates for the vacancies.

DWA conducts pre-screening for candidates and provides reasonable adjustment advice and education and support direct to the hiring managers and to the preferred suppliers of candidates.[92]

5.5 How might the job selection process be improved for people with disability?

Identifying an appropriate position to apply for - with or without the help of an employment service or recruitment agency - is only the first step in the job seeking process. The person must then apply for the job, and in some circumstances, participate in an interview.

Selection practices can have a significant impact on whether a person with disability is appointed to a position.

The 2005 Standing Committee Working for Australia Report recommends that:

[T]he Australian Government, in consultation with the peak disability agencies, recruitment services and business and industry organisations, develop guidelines on appropriate criteria and protocols for the recruitment of people with a disability.[93]

Issues considered in this section include:

1. Disclosure of disability in a job application or interview

2. Using appropriate selection criteria

3. Addressing discrimination in the selection process

4. Accessibility of the selection process.

5.5.1 Disclosure of disability

For people with a disability whether to disclose or not to disclose it is a bit like being between a rock and a hard place - damned if you do and damned if you don't. The benefits may be that the employer can provide simple equipment or re-organise working arrangement to improve job efficiency. The disadvantage may be that other employees and/or managers will focus on the disability rather than a person's skills and ability to do the job, and may discriminate against that person.[94]

Submissions to the Inquiry suggest that the question of whether to disclose a disability during the job seeking and application process may be confronting and can have a very real impact on the chances of finding a job.[95]

DEAC told the Inquiry that disclosure is particularly difficult for people with mental illness and can have an almost immediate and catastrophic effect on their prospect for future employment and continuing employment.[96] beyondblue argues that:

Disclosure of conditions to employers often results in an inability to obtain further work, or if in current employment, people being undermined, denied promotional opportunities, and in some cases resulting in demotion or job loss.[97]

People with HIV/AIDS face similar issues. The National Association of People Living with HIV/AIDS reported that:

43.3% of people living with HIV/AIDS currently in work [have] not disclosed their HIV status to anyone at their workplace with the most common difficulties for those who do want to maintain confidentiality at work being gossip and explaining absences from work, for doctors appointments and other treatment related matters . there are cases known to NAPWA where people have lost their jobs because of their HIV status.[98]

The Disability Discrimination Legal Centre NSW suggested that:

Guidelines need to be developed and instituted on the issue of whether and, if so, when, a person with a disability should disclose that they have a disability and what rights and protections that person has and what obligations and limitations bind the employer in that regard.[99]

The RDLO has developed a website resource regarding disclosure. The site provides information about disclosure, clarifies legal obligations and rights and suggests practical steps to take in relation to disclosure for both employers and potential employees.[100]

Vocational professionals may also be able to assist with the process of disclosure through strategic disclosure to employers and other third parties:

The use of explicit strategies to counter workplace stigma, and structured counselling to optimise disclosure strategies, are also expected to enhance outcomes in psychiatric vocational rehabilitation by improving job commencement and job retention. Strategies are needed throughout vocational rehabilitation to counter past and present stigma and strategically manage disclosure of personal mental health information in the workplace.[101]

The question of whether or not to disclose is often precipitated by the need for people with disability to explain significant gaps in their work history.[102]

5.5.2 Ensuring appropriate selection criteria

As discussed in Chapters 2 and 6, good job matching is an important feature of the recruitment process.

Sometimes job advertisements list selection criteria that are not necessarily vital for the job. The consequence may be that the selection processes can work against people with disability in situations where they are actually well suited to a position.

Several submissions suggest that selection criteria requiring a drivers licence may exclude a range of people with disability despite the fact that driving (as opposed to independent travel) may not be an essential part of the job.[103]

Centacare gave an example of where a lengthy selection process for a supermarket job puts a person with an intellectual disability at a great disadvantage, even though he or she could do the actual job as well as any other person. Similarly, a person with dyslexia may not pass a written selection test, but may still be a good pastry chef.[104]

The Australian Federation of Deaf Societies noted that selection criteria for many positions require oral and written communication skills even when a position requires little communication that cannot be achieved by other means (for example written notes, email, SMS (short messaging services) and National Relay Services as well as speech and lipreading in some circumstances).[105]

Australians for Diversity Employment suggested that where a position has anything to do with people with disability, the advertisement should contain the words 'people with disabilities are encouraged to apply'.[106] The Australian Public Service Commission also recommended that public sector agencies should promote their commitment to equal opportunity.[107]

5.5.3 Discrimination in selection processes

Many submissions suggest that people with disability experience discrimination in the recruitment and selection process.

A fear of discrimination may be experienced by people who submit applications through disability-specific employment agencies, as this tends to highlight that the applicant has a disability.[108]

DEAC told the Inquiry that graduates with disability do, at times, encounter discrimination in the process of finding and applying for employment because of their disability and that graduates whose disability is visible can experience more difficulty in securing employment.[109]

Several submissions suggested that staff involved in writing position descriptions, recruitment and selection criteria should be trained to avoid potentially discriminatory practices.

The Disability Discrimination Legal Centre told the Inquiry that:

The protection afforded by the disability discrimination laws really only operates once a person with a disability has gained employment. Protection is far more limited in the pre-employment recruitment phase. The recruitment process needs to be made more transparent so that there is more objectivity and merits-assessment in that process, rather than subjective influences that are often based on false, discriminatory and misguided preconceptions. People with a disability need attainable rights and protection during the recruitment phase.[110]

The Welfare Rights Centre recommends:

A change to discrimination legislation to forbid questions as to mental illness on pre employment questioning. Only when the job is obtained and one is considering accommodating the mental illness should this questioning appear.[111]

The Disability Discrimination Act 1992 (Cth), and possible amendments to that legislation to improve its effectiveness, is discussed in some detail in the 2004 Productivity Commission Review of the Disability Discrimination Act 1992.[112] The Government released its response to that report in January 2005, accepting many of the Productivity Commission's recommendations for reform in full or in part.[113] Draft legislation to implement that response is expected to be available in coming months.

5.5.4 Accessibility of the selection process

Some people with disability have difficulties in engaging in recruitment processes for accessibility reasons. For example the hearing impaired may have trouble engaging in oral information sessions or interviews and those with physical disabilities may have trouble travelling to the employment services and interviews.

The Australian Public Service Commission recommended that public sector agencies ensure that the methods of accessing information about a position and submitting a job application process are not discriminatory.[114]

5.6 Self-employment and the New Enterprise Incentive Scheme (NEIS)

Maybe the underlying philosophy of entrepreneurship is that people who wanted to set up their own businesses had to be driven by a strong sense of self-interest and if someone was hungry enough for success, they would achieve it by one means or another. However, for people with a disability, the overarching philosophy has been one of supporting them in society. It is only in the past decade that this philosophy has been added to by people with a disability demanding that they play an equal part in society. While there may not be a deafening clamor of people with a disability, especially from ethnic backgrounds, wanting to set up their own businesses, the option should be open to them nonetheless, as this option is also open to all other people. [115]

Self-employment is an option for any person wanting to enter the open work place, whether or not they have a disability.[116] For some people, this choice may be driven by an entrepreneurial desire.[117] For others is an employment opportunity that allows greater control over day-to-day life and the future.[118]

For some people with disability the option to work as a consultant, start an independent business or work from home may be particularly attractive depending on:

the nature of disability
difficulties in adapting to an employer-employee relationship in the open marketplace
difficulties in accessing assistance with personal care in the workplace
concerns about stigma in the workplace; or
a need for flexible working hours.

Several submissions suggest that people with disability need assistance to start their own home business:

The Chambers of Commerce in conjunction with a government department [should] establish an advisory service to assist mental health consumers work through all the legal and financial requirements of establishing a home business in the market of their choice, including affordable education sessions/workshops/seminars on how to establish a home business, the pitfalls, the legislative requirements and so forth. To assist consumers to make informed decisions on whether this is a viable option.[119]

Family Advocacy suggest that the option of self-employment is particularly important for people with high support needs. They note a government-funded model in the United States which has assisted many people with high support needs:

Griffin and Hammis[120] provide a framework that has guided many people with high support needs in the US into self employment in small businesses. In the US grants available for the establishment of small businesses have been available to assist in these projects and funds for the support of individuals have been available to provide support to people with high support needs in small businesses. [121]

DEAC Legal Services notes that graduates with disability are more likely to work part-time and be self-employed.[122].

The Commonwealth New Enterprise Incentive Scheme (NEIS) is a self-employment program for unemployed people who wish to start their own independent businesses:

The New Enterprise Incentive Scheme (NEIS) is an Australian Government initiative that helps eligible unemployed people to start and run their new, viable small business. For the first year of the business, NEIS is there to train, support and help the participant to become self-supporting and independent. NEIS participants undertake an accredited 3 month small business management course. In the first year, business advice and mentor support helps the business become successful. NEIS provides this support through a network of private, community and government organisations known as NEIS providers, which are local organisations such as Business Enterprise Centres; TAFE Small Business Centres; community organisations and private sector organisations contracted by the Department of Employment and Workplace Relations to deliver NEIS throughout Australia.[123]

Acceptance into the NEIS is competitive and the ability to meet all the criteria does not guarantee entry and assistance. Applicants are evaluated on both personal and business criteria including:

Personal Criteria

To participate in the New Enterprise Incentive Scheme (NEIS) you must be eligible for the full range of Job Network Services and:

be at least 18 years of age at the time of signing a NEIS Participant Agreement
be available to participate in Training and work full time in the business
be in receipt of an allowance specified by DEWR from time to time as NEIS eligible
not be an undischarged bankrupt
agree to hold and maintain a controlling interest in the business during the terms of the NEIS Participant Agreement
have not received NEIS assistance in the previous 2 years
have not received NEIS assistance previously for a similar business activity.

Business Criteria

Proposed NEIS businesses must:

have never operated on a commercial basis
be independent, reputable and legal
be assessed as commercially viable by a NEIS provider and approved by DEWR
not involve the purchase of takeover of an existing business
not compete directly with existing businesses, unless it can be demonstrated that there is an unsatisfied demand for the product or service, or that the product or service is to be provided in a new way.[124]

The 2005 budget announced funding for an additional 1000 places in NEIS under this criteria.[125] However, the Inquiry heard that the NEIS scheme does not generally meet the needs of people with disability.[126]

One of the problems identified by Action on Disability within Ethnic Communities (ADEC) is that the scheme does not specifically target people with disability in the eligibility criteria:

In order to improve the participation rate of people with a disability in NEIS, one of the issues that needs to be addressed is that of targeting. Though existing agreements between NEIS providers and DEWR only mention targeting of the program to disadvantaged groups, including people with a disability, there are no formal guidelines on targeting and there are no requirements on managing agents to target particular clients.

In particular, the ability to participate full time in training and work may be a barrier for many people with disability.

ADEC recommends the following changes to NEIS to enable people with disability the opportunity to become self-employed:

The development of a NEIS program specifically targeting people with disabilities, encouraging people from ethnic backgrounds to participate;
Clear identification of the barriers and issues confronting people with a disability from seeking self-employment;
Development of training options suitable for people with a disability who want to establish an enterprise;
Establishment of a supportive, self-help network of people with a disability who are interested in self-employment;
Encouragement of people with a disabilities to see themselves as potential business people, rather than dependents or employees, or worse, unemployable;
Self-employment as a positive alternative to employment, in an environment where discrimination on the grounds of disability is felt by many people with a disability, especially people from ethnic backgrounds;
Changes in attitudes from continuing dependence to fostering independence.[127]

Similarly, Family Advocacy makes the following recommendation:

That Government grants for small business are made available for the establishment of small businesses designed specifically to facilitate work opportunities for people with disability.[128]

Australians for Diversity Employment suggest that Commonwealth, State and Territory governments should demonstrate leadership and specifically encourage people with disability to apply for consultancy projects in tendering processes:

In order to promote self employment opportunities by PWD, it is important that a pro-active approach is taken to getting PWD to undertake these consultancy services where possible. The tendering process should stipulate 'Submissions from people with disabilities are encouraged.'[129]

ACE National Network suggests that the Workplace Modifications Scheme be expanded so that people with disability who are, or seeking to be, self-employed can obtain appropriate financial assistance to establish a workplace.[130]

5.7 Conclusion

The job seeking process has several elements, including the process of identifying an appropriate position, applying for the job and participating in a selection process.

Most people who are on income support will use a government-funded employment services to assist them through this process. The 2005 Budget announced a variety of changes to the structure and funding of those employment services. Some of those changes commenced on 1 July 2005 and some will commence on 1 July 2006. It is therefore too early to assess the impact of those changes on the employment rates for people with disability.

Nevertheless, the Inquiry received many submissions expressing concern about government-funded employment services. In particular the submissions highlight the following major concerns:

the transition to Case Based Funding for people with high needs;
the ability of Job Network to provide the appropriate service to people with disability;
retaining a cap on places in DOES for people on the Disability Support Pension from 1 July 2006;
inadequate funding for the Personal Support Program;
poor coordination between Commonwealth and State services available to people with disability.

It is important to keep in mind, however, that not all people with disability will use government-funded employment services. Private recruiting agencies are increasingly used by both the public and private sector. The submissions recommend that they be encouraged to take up inclusive selection practices and that employers identify 'preferred agencies'.

Regarding the application and selection process, the submissions suggest that there be better guidance for interviewees (for example, whether or not to disclose a mental illness) and interviewers (for example, how to ensure that the process is accessible and non-discriminatory).

Finally, it is important not to ignore self-employment as an option for people with disability to participate in the open marketplace. The development of a NEIS program that takes into account any additional needs of people with disabilities may assist in making this a more realistic option.

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Endnotes: Chapter 5

[1] The Inquiry notes that its submission deadline preceded the Budget announcements, however the Inquiry has included those comments that remain relevant.

2] http://www.humanrights.gov.au/disability_rights/employment_inquiry/pape…

3] Submission 43, Job Futures, p2.

4] Submission 76, Stepping Stone Clubhouse, p18.

5] Submission 49, Disability Council of NSW, p6.

6] Submission 72, Scope Employment, p4.

7] DEWR, Fact Sheet, Welfare to Work - Increasing participation of people with a disability at http://www.dewr.gov.au/publications/budget/2005/factSheets/factsheets.a….

8] Australian Government, Budget 2005-06, Budget Paper No.2, Employment and Workplace Relations

9] Submission 85, DDLC, p41.

10] Submission 85, DDLC, p43.

11] Submission 41, Edge, p2; Submission 72, Scope Victoria, p9.

12] Submission 27, DEAC, p12. See also Submission 76, Stepping Stone Clubhouse, p10.

13] http://www.acenational.org.au/public/who.shtml

[14] DEWR, Next Steps for Disability Open Employment Services, DEWR, January 2005 at 2, available at www.jobable.gov.au/Files/ Disability%20OE%20Paper%20-%2017Jan.doc. Submission 85, DDLC, p20.

15] Submission 100, Brotherhood of St Laurence, p3.

16] Submission 100, Brotherhood of St Laurence, p3.

17] Submission 72, Scope Employment, p12.

18] Submission 49, Disability Council of NSW, p6; Submission 68, ACE National Network, p8. See also Submission 100, Brotherhood of St Laurence, p5; Submission 72, Scope Victoria, p12.

19] Submission 114, ACROD, p2.

20] Submission 72, Scope Employment, p7; Submission 107, Uniting Care Australia, p5; Submission 27, DEAC, p13.

21] Submission 100, Brotherhood of St Laurence, p7. A similar recommendation is made in Submission 68, ACE National Network, p8.

22] Submission 68, ACE National Network, p8. See also Submission 100, Brotherhood of St Laurence, p3.

23] See http://www.budget.gov.au/2005-06/overview2/download/overview_welfare.pdf. See also Speaker Presentation by Barry Sandison, DEWR at http://www.acrod.org.au/conferences/e-forum2005/speakers.htm

24] For more detailed information about case-based funding see http://www.jobable.gov.au/openemploymentprovider.asp#news. See also Issues Paper 5, Mapping of Commonwealth Government Services, p5.

25] See for example, Submission 21, Disability Services Commission WA, p2; Submission 114, ACROD, p3; Submission 72, Scope Victoria, p16.

26] Submission 45, NSW Council for Intellectual Disability, p10-11.

27] Submission 45, NSW Council for Intellectual Disability, p10-11. See also the presentation by Phil Tuckerman from Job Support during the Inquiry's Sydney Roundtable on 31 March 2005 at http://www.humanrights.gov.au/disability_rights/employment_inquiry/foru….

28] Submission 114, ACROD, p4.

29] Submission 21, Disability Services Commission WA, p2.

30] Submission 114, ACROD, p3.

31] Issues Paper 5, p9.

32] Submission 43, Job Futures, p4. See also, Submission 42, Villamanta Legal Service, p7; Submission 76, Stepping Stone Clubhouse, p10.

33] Submission 12, The Australian National Organization of the Unemployed, p8. See also Submission 43, Job Futures, p4 See also, Submission 48, Network for Carers of People with a Mental Illness, p6.

34] Submission 43, Job Futures, p4.

35] Submission 43, Job Futures, p4.

36] See http://www.budget.gov.au/2005-06/overview2/download/overview_welfare.pdf. See also Speaker Presentation by Barry Sandison, DEWR at http://www.acrod.org.au/conferences/e-forum2005/speakers.htm.

37] See http://www.jobable.gov.au/home/DSP_Pilot_Interim_Evaluation.asp#intro. See also Submission 85, DDLC, p21.

[38] Employment Analysis and Evaluation Group, Job Network Disability Support Pension Pilot: Interim Evaluation Report, Canberra, Department of Employment and Workplace Relations, October 2004, at 4, available at http://wwwjobable.gov.au/home/DSP_Pilot_Interim_Evaluation.asp

[39] Employment Analysis and Evaluation Group, Job Network Disability Support Pension Pilot: Interim Evaluation Report, Canberra, Department of Employment and Workplace Relations, October 2004, at 5, available at http://wwwjobable.gov.au/home/DSP_Pilot_Interim_Evaluation.asp

40] Submission 85, DDLC, p21.

41] See for example Submission 12, ANOU, p9.

42] Submission 48, Network for Carers of People with a Mental Illness, p6; Submission 76, Stepping Stone Clubhouse, p10.

43] Submission 107, UnitingCare, p3; Submission 72, Scope Victoria, p11.

44] See http://www.jobable.gov.au/fact_sheets/fs_servicechoice.asp

45] Issues Paper 5, Mapping of Commonwealth Government Services, p3 at http://www.humanrights.gov.au/disability_rights/employment_inquiry/docs…

46] See http://www.budget.gov.au/2005-06/overview2/download/overview_welfare.pdf. See also Speaker Presentation by Barry Sandison, DEWR at http://www.acrod.org.au/conferences/e-forum2005/speakers.htm

47] Submission 48, Network for Carers of People with a Mental Illness, p7.

48] See Issues Paper 5, p10-11; See also http://www.workplace.gov.au/workplace/Category/SchemesInitiatives/PSP/A…

49] Submission 100, Brotherhood of St Laurence, p8; Submission 48, Network of Carers for People with a Mental Illness, p7; Submission 68, ACE, p11.

50] House of Representatives Standing Committee on Employment, Workplace Relations and Workforce Participation, Working for Australia's future: Increasing participation in the workforce, March 2005, Recommendation 7, p131.

51] See DEWR Fact Sheet, Welfare to Work - Increasing participation of people with a disability at http://www.dewr.gov.au/publications/budget/2005/factSheets/factsheets.a….

52] Submission 85, Disability Discrimination Legal Centre NSW, p47.

53] Submission 73, RDLO Network, p16; Submission 114, ACROD, p2; Submission 68, ACE National Network, p8. See also Submission 100, Brotherhood of St Laurence, p3.

54] See for example, Submission 19, Action on Disability within Ethnic Communities, p2; Submission 11, Department of Families and Communities SA, p3; Submission 17, Family Advocacy, p2; Submission 30, Mental Illness Fellowship Victoria, p5; Submission 45, NSW CID, p13; Submission 52, Ability Technology, p2; Submission 54, SANE, p2; Submission 77, RBS.RVIB.VAF Limited p4; Submission 92, Social Firms Australia, p4; Submission 109, Waghorn and Llyod, p27-28; Submission 119, Parents and Professional Advocates ACT, p8; Submission 126, South Australian Government, p16.

55] Submission 49, DCNSW, p8.

56] Submission 92, Social Firms Australia, p4.

57] Submission 58, Centre of Full Employment and Equity, p6.

58] Submission 92, Social Firms Australia, p5.

59] Submission 109, Waghorn and Lloyd, p18.

60] Submission 30, Mental Illness Fellowship of Victoria, p5.

61] Submission 109, Waghorn and Lloyd, p4.

62] Submission 68, ACE National Network, p6; Submission 105, Hanlon.

63] Submission 53, RANZCP, p2.

64] Submission 53, RANZCP, p3.

65] Submission 69, Mental Illness Fellowship of Australia, p5-6; Submission 109, Waghorn and Lloyd, p21.

66] Submission 109, Waghorn and Lloyd, p31.

67] Ostara Australia: http://www.ostara.org.au/

68] Open Minds: www.openminds.org.au.

69] Submission 32, Australian Association of the Deaf, p6.

70] Submission 32, Australian Association of the Deaf, p6. See also Submission 79, Australian Federation of Deaf Societies, p7; Submission 40, Australian Sign Languages Interpreters Association, p2.

71] Submission 79, Australian Federation of Deaf Societies, p7; Submission 68, ACE, p6.

72] Submission 79, Australian Federation of Deaf Societies, p7.

73] Submission 50, Deafness Forum of Australia, p10.

74] Submission 71, Pearce, p1.

75] Submission 80, Blind Citizens Australia, p7-8.

76] Submission 85, DDLC, p23-26, 62.

77] Submission 85, DDLC, p62.

78] Submission 73, RDLO, p2-5; Submission 73A, RDLO, p1-3; Submission 27, DEAC, p8-9.

79] Submission 27, DEAC Legal Services, p12.

80] Submission 73A, National Regional Disability Liaison Officers and Disability Co-Ordination Officers Network, p3.

81] Submission 44, Australians for Diversity Employment, p2.

82] Submission 79, Australian Federation of Deaf Societies, p5.

83] Submission 80, Blind Citizens Australia, p22.

84] Submission 34, Manpower, p6.

85] Submission 95, Westpac.

86] Submission 65, IBM, p2; Submission 127, National Australia Bank, p2.

87] Submission 77, RBS.RVIB.VAF Limited, p5; Submission 80, Blind Citizens Australia, p21.

88] Submission 77, RBS.RVIB.VAF Limited, pp5-6. See also Submission 73, RDLO Network, p9.

89] Submission 118, EOCV, p9.

90] Submission 65, IBM, p2.

91] Submission 95, Westpac.

92] Submission 127, National Australia Bank, p2.

93] Working for Australia Report, Recommendation 20, p170.

94] Submission 27, DEAC, p3. See also, Submission 64, WCIG, p1.

95] Submission 118, EOCV, p4; Submission 10, Davies, p5; Submission 85, DDLC, p12-13.

96] Submission 27, DEAC, p3. See also Submission 30, Social Firms Australia, p4; Submission 26, National Network of Private Psychiatric Sector Consumers and Carers, p2; Submission 105, Hanlon, p9; Submission 48, Network for Carers of People with a Mental Illness, p3; Submission 87, Welfare Rights Centre, p9.

97] Submission 70, beyondblue, p2.

98] Submission 91, National Association of People Living with HIV/AIDS, pp10-11.

99] Submission 85, DDLC, p61. See also Submission 77B, RBS.RVIB.VAF Limited, p2.

100] Submission 85, DDLC, p19, http://sites.uws.edu.au/rdlo/disclosure/.

101] Submission 109, Waghorn and Lloyd, p33.

102] Submission 48, The Network for Carers of People with a Mental Illness, p3. See also Submission 10, Davies, p7.

103] Submission 99, City of Darebin Disability Working Party, p2; Submission 44, Australians for Diversity Employment, p2; Submission 84, Name Witheld, p6; Submission 71, Pearce, p2.

104] Submission 46, Centacare, p3.

105] Submission 79, Australian Federation of Deaf Societies, pp9-10.

106] Submission 44, Australians for Diversity Employment, p4.

107] Submission 113A, Australian Public Service Commission, p2. See also Submission 60A, TAFE NSW, p1.

108] Submission 99, City of Darebin, p2.

109] Submission 27, DEAC, p9.

110] Submission 85, DDLC, p61.

111] Submission 87, Welfare Rights Centre, p10.

112] Productivity Commission Inquiry Report, Review of the Disability Discrimination Act 1992, No 30, April 2004 see http://www.pc.gov.au/inquiry/dda/index.html.

113] See http://www.ag.gov.au/PCDDA.

114] Submission 113A, Australian Public Service Commission, p2.

115] Submission 19, ADEC, p3.

116] See for example: Submission 7, Name withheld, p1.

117] Submission 19, ADEC, p3.

118] Submission 17, Family Advocacy, p6.

119] Submission 2, Casey, p8.

120] Cited in Submission 17, Family Advocacy, page 6: Griffin, C., & Hammis, D., Making self employment work for people with disabilities, Paul Brookes Publishing, Baltimore 2003.

121] Submission 17, Family Advocacy, p6.

122] Submission 27, DEAC Legal Services, p9.

123] http://www.workplace.gov.au/workplace/Category/SchemesInitiatives/NEIS/ accessed 5 August 2005.

124] http://www.workplace.gov.au/workplace/Category/SchemesInitiatives/NEIS/… (Accessed 5 August 2005).

125] See DEWR Presentation to Budget Sessions at http://www.dewr.gov.au/publications/budget/default.asp

126] Submission 19, ADEC, p2.

127] Submission 19, ADEC, p5.

128] Submission 17, Family Advocacy, p6.

129] Submission 44, Australians for Diversity Employment.

130] Submission 68, ACE National Network, p6. See further Chapter 2 on the Workplace Modifications Scheme.