National Disability Advocacy Program (NDAP) Quality Assurance Consultations Report

Table of Contents

PART 1: Quality Assurance framework for advocacy agencies

PART 2: Summary of written submissions

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Introduction


Quality Assurance system

The 2007–08 Australian Government budget provided funding for the introduction of an independent third-party Quality Assurance (QA) system for advocacy agencies funded under the National Disability Advocacy Program (NDAP). This will replace the current system of departmental audits against the 101 supporting standards which currently apply to non-employment services.

A key feature of the new system is the development of a set of Disability Advocacy Standards and Key Performance Indicators (KPIs), which agencies will need to be certified against as a future condition of funding.

The purpose of these Standards is to introduce a minimum set of performance requirements for NDAP funded agencies. The Standards aim to establish what is expected of funded advocacy agencies by Government and the Department. The KPIs represent an outcome that needs to be demonstrated or measured in order to meet each Standard. The Standards will have as their basis the 1993 National Disability Services Standards which were developed in the context of the Commonwealth State Territory Disability Agreement (CSTDA). The National Disability Services Standards are a core set of Standards applicable to all CSTDA funded disability services, including advocacy.

In 2006, two consultative bodies were created to develop the draft set of Disability Advocacy Standards and KPIs. These groups identified a draft set of 11 Standards and 24 KPIs as the basis for consultation with the sector.

Consultations

During 2007 and early 2008, FaHCSIA undertook two rounds of consultations with funded advocacy agencies to get their views on the appropriateness of the:

  • Broad definition of advocacy and current descriptions of the six models of advocacy funded under the NDAP (Refer Working Towards a Common Understanding of Advocacy presentation paper)
  • draft Disability Advocacy Standards and KPIs to the work of advocacy agencies (Refer Disability Advocacy Standards and Key Performance Indicators consultation paper)
  • approach to introducing specifically tailored evidence guidelines for each of the different models of advocacy (and examples of the types of evidence appropriate to different models of advocacy
  • Objectives and Principles for the change process (Refer Objectives and Principles consultation paper).

Agencies were also asked to consider how FaHCSIA can work with agencies to ensure that the Disability Advocacy Standards and KPIs are accessible to people with disability.

Advocacy agencies were invited to make written submissions in response to the consultation papers prepared by FaHCSIA. In total, 64 submissions were received from 39 advocacy agencies and one individual. The submissions varied significantly in depth and detail, as well as the nature of the comments.

ARTD Consultants were engaged by FaHCSIA to prepare a summary report of the written submissions and to independently prepare recommendations for a revised set of Disability Advocacy Standards, Key Performance Indicators, Evidence Guidelines, advocacy definitions and Objectives and Principles that incorporated the feedback from the sector. These recommendations are included as part of an overall Quality Assurance framework.

Consultation report

This report summarises the consultation submissions from advocacy agencies and makes recommendations for incorporating their feedback into the new quality assurance system (Section 2). Detailed findings are presented in two parts. Part 1 of the report (Section 3) presents ARTD’s proposal for the revised Quality Assurance framework, and Part 2 (Section 4, 5 and 6) presents a detailed summary of the consultation submissions.

It is intended that the consultation report be made publically available to ensure the feedback from the sector is widely disseminated to all key stakeholders. The report will be used as the basis for:

  • Practically using the Standards and KPIs during the trial of the National Disability Advocacy Program Quality Assurance system
  • Feeding into the development of the third party certification system for the NDAP
  • Developing a Quality Assurance system handbook that can be used by advocacy agencies in preparing for and participating in the quality system.
  • Disseminating feedback on the QA Consultations to the NDAP sector

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Summary and recommendations


Principles guiding the change process

The disability advocacy sector was supportive of the overall objectives and principles for the change process to the NDAP as well as the development and implementation of the new quality system (Consultation Paper 1), highlighting the importance of acknowledging the shared responsibility for the effectiveness of the National Disability Advocacy Program between funded agencies and the funding body.

Recommendation 1: That the objectives and principles for the development and implementation of the new NDAP quality system be adopted as follows:

OBJECTIVES

To enhance the efficiency of the NDAP and the effectiveness of funded agencies in order to:

  • Meet the advocacy needs of people with disability.
  • Develop the capacity of NDAP funded agencies to respond to the advocacy needs of people with disability.
  • Meet the performance and accountability needs of the Australian Government.

PRINCIPLES

For people with disability

  • People with disability receive advocacy appropriate to their needs (i.e. culture, disability type, gender) to address and prevent disadvantage, abuse and neglect
  • People with disability access advocacy that is timely to address and prevent instances of disadvantage, abuse and neglect
  • People with disability have increased access to advocacy services

For NDAP funded agencies

  • NDAP funded agencies are supported to increase their capacity to respond to the advocacy needs of people with disability
  • NDAP funded agencies with specialist expertise (i.e. expertise in servicing cultural groups, particular disability types etc) are supported to share this knowledge with the disability advocacy sector.
  • NDAP funded agencies are supported to deliver advocacy accountably and to continually improve quality

For FaHCSIA

  • FaHCSIA works in partnership with NDAP funded agencies to implement the NDAP changes
  • FaHCSIA supports collaboration between NDAP funded agencies as part of the NDAP changes.
  • FaHCSIA draws on the knowledge and expertise of people with disability and the disability advocacy sector to guide the NDAP changes.

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Overall perceptions of the Quality Assurance system

The disability advocacy sector is generally supportive of the proposed third-party QA system, although consistently flagged through the consultation process the need to ensure that the KPIs and assessment methods recognise the:

  • fundamental difference between advocacy and service provision
  • diverse range of approaches to advocacy (and hence the different ways in which different advocacy agencies may demonstrate conformity with the KPIs)
  • modest resources available to most NDAP advocacy agencies to develop and improve their management systems
  • best way for advocacy agencies to demonstrate conformity with the KPIs is through observations of on-the-ground practices and service user feedback.

Advocacy agencies highlighted that these issues need to be addressed at a number of levels – ensuring the principles underpinning the QA system are articulated, ensuring the Standards and KPIs are relevant to advocacy, ensuring the evidence guidelines reflect the diverse range of approaches to advocacy; and ensuring the audit process is grounded in an appropriate understanding of advocacy and the NDAP.

Recommendation 2: That a Disability Advocacy Quality Assurance Framework be developed to articulate the principles, definition, standards and quality requirements for the NDAP QA system. Specifically, the draft framework developed on the basis of advocacy agency consultations (see Section 3) should be used as the basis for piloting the new NDAP QA system.


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Definition of advocacy

There was broad agreement with the definition of advocacy proposed in the consultation paper (see Section 3.1), although there were divergent views on the descriptions of the six main approaches to advocacy (individual, systemic, citizen, family, self, and legal advocacy).

Approximately one-third of agency submissions raised issues with the proposed ‘Advocacy Model Descriptions’ of different advocacy approaches presented in the consultation paper – highlighting that the descriptions were not consistent and tended to ‘pigeon-hole’ the approaches into artificial silos. Advocacy agencies also highlighted that they often adopt multiple approaches – for example, undertaking both individual advocacy and systemic advocacy.

At the same time, advocacy agencies recognised the importance of communicating to third-party certification bodies and auditors the difference between advocacy and service provisions and the diversity of advocacy approaches.

Recommendation 3: That the broad definition of advocacy be accepted as follows:

In broad terms, advocacy for people with disability can be defined as speaking, acting or writing with minimal conflict of interest on behalf of the interests of a person or group, in order to promote, protect and defend the welfare of and justice for either the person or group by:

  • Being on their side and no-one else’s
  • Being primarily concerned with their fundamental needs
  • Remaining loyal and accountable to them in a way which is empathic and vigorous.

That the current set of ‘Advocacy Model Descriptions’ be replaced in the QA Framework with high-level description of the suite of advocacy approaches and a sample of key descriptors. More detailed descriptions and examples of the range of advocacy approaches would be incorporated into a NDAP QA Handbook (see Recommendation 6). The proposed high-level descriptions are as follows:

There are a range of different approaches to undertaking advocacy, with many advocacy agencies adopting multiple approaches. Among others, advocacy approaches include:

  • Individual advocacy – seeks to uphold the rights and interests of people with all types of disabilities on a one-to-one basis by addressing instances of discrimination, abuse and neglect.

    Key descriptors for this model include:

    Individual advocates work with people with disability on either a short-term or issue-specific basis.

    Individual advocates:

    • work with people with disability requiring one-to- advocacy support;
    • develop a plan of action (sometimes called an individual advocacy plan) in partnership with the person with a disability that maps out clearly defined goals;
    • educates people with disability about their rights; and
    • work through the individual advocacy plan in partnership with the person with a disability.
  • Systemic advocacy – seeks to influence or secure positive long-term changes that remove barriers and address discriminatory practices to ensure the collective rights and interests of people with disability are upheld.

    Key descriptors for this model include:

    The systemic advocacy agency:

    • pursues positive changes to legislation, policy and service practices in partnership with groups of people with disability, advocacy agencies and other relevant organisations;
    • seeks to address barriers and discriminatory practices to produce long-term positive changes.
  • Citizen advocacy – seeks to support people with a disability (also called protégés) by matching them with volunteers. Some of the matches made may last for life.

    Key descriptors for this model include:

    Through citizen advocacy:

    • people with a disability who are isolated with no family or community supports or networks are sought out
    • volunteers are encouraged to represent the interests of a person with a disability as if they were their own and be free from conflict of interest
    • volunteers are recruited, trained and supported by a coordinator who manages the work of the citizen advocacy agency.
  • Family advocacy – works with parents and family members to enable them to act as advocates with and on behalf of a family member with disability. Family advocates work with parents and family members on either a short-term or an issue-specific basis. Family advocates work within the fundamental principle that the rights and interests of the person with disability are upheld at all times.

    Key descriptors for this model include:

    Through family advocacy:

    • family members are provided with advice and support;
    • the person with disability is assisted via the family member being directly supported by the agency to advocate on their behalf.
  • Self advocacy – supports people with disability to advocate on their own behalf, to the extent possible, or on a one-to-one or group basis.

    Key descriptors for this model include:

    Through self advocacy:

    • advocates work with people with people with disability to develop their personal skills and self-confidence to enable them to advocate on their own behalf.
    • educates people with disability about their rights.
  • Legal advocacy – seeks to uphold the rights and interests of people with all types of disabilities on a one-to-one basis by addressing legal aspects of instances of discrimination, abuse and neglect.

    Key descriptors for this model include:

    Legal advocates may provide:

    • legal representation for people with disability as they come into contact with the justice system;
    • pursue positive changes to legislation for people with disability; and
    • assist people with disability to understand their legal rights.

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Standards and KPIs

The majority of advocacy agency consultation submissions proposed alterations to the draft Standards and KPIs – in particular to ensure that the Standards and KPIs reflected the objectives of advocacy and were relevant and appropriate to the full range of advocacy approaches. Key issues related to:

  • ensuring the wording of the Standards was broad enough to encompass of all advocacy approaches
  • ensuring the wording of the Standards sufficiently distinguished the objectives and scope of influence of advocacy to that of service provision
  • ensuring the wording of individual KPIs related to ‘on-the-ground’ advocacy practices, rather than service delivery practices

More broadly, some advocacy agencies raised issues about the confusing nature of the term ‘Key Performance Indicator’ – given the use of this term in broader compliance and performance management contexts (e.g. performance reporting).

While some agencies raised significant issues with individual standards and KPIs, most proposed straightforward refinements to improve their utility and clarity. However, given the extensive range of proposed refinements, there is no consensus view of the ‘best’ Standards and KPIs.

Section 3.2 of the report presents a revised set of 11 Standards and 24 KPIs – that is consistent with the intent of the vast majority of submissions and captures many of the key suggestions.

Recommendation 4: That the revised Standards, and KPIs for each Standard, (see Section 3.2) be used as the basis for piloting the new NDAP QA system


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Evidence guidelines

There was a strong view that separate evidence guidelines be prepared for each of the different advocacy approaches – to highlight the different ways in which advocacy agencies may demonstrate conformity with the KPIs.

It was recognised that some types of evidence for a particular Standard may be appropriate for all advocacy agencies but, in general, different types of evidence would be relevant for different advocacy approaches.

It was also highlighted that much of the evidence for a particular Standard would cut across the specific ‘KPIs’ for the Standard. This raised the issue of whether separate evidence guidelines were needed for each ‘KPI’, or simply for each Standard.

Section 3.2 of the report presents a draft set of evidence guidelines for each Standard (rather than for each ‘KPI’). These guidelines draw on the detailed feedback from advocacy agencies about the possible sources of evidence that could be used for different advocacy approaches. However, it was recognised that these examples would need to be supplemented by more detailed descriptions and examples that could be incorporated into a NDAP QA Handbook using examples from Section 6.

Recommendation 5: That the generic Disability Advocacy Standards and KPIs be accepted within the QA framework and that tailored Evidence Guidelines be developed suitable for each of the advocacy approaches.


Recommendation 6: That a NDAP QA Handbook be prepared and tested as part of the QA trial that incorporates:

  • Characteristics of the six advocacy models currently funded under the NDAP
  • a practical overview of the QA process (a ‘how to’ guide to the audit process and demonstrating conformity with the Standards)
  • a detailed set of evidence guidelines that draws on the feedback from the consultation submissions (see Section 7)

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Ensuring that the Disability Advocacy Standards and KPIs are accessible to people with disability

Many of the agency submissions highlighted the importance of ensuring that the Disability Advocacy Standards and KPIs are accessible to people with disability, and suggested that agencies work with FaHCSIA to develop appropriate communication materials.

Advocacy agencies were particularly keen to ensure ongoing consultation and opportunities for discussion in ensuring the accessibility of the Standards for people with disabilities.

Agencies indicated that information about the Standards should be made available in formats accessible to people with disabilities – formats would include print, audio, online, Braille, and multilingual, with appropriate testing of materials with clients.

Additionally, the Standards themselves should be made available in plain English versions possibly with illustrations – with one agency indicating they had already developed illustrated posters for their office. It was suggested that the resources developed by Disability Services Queensland their disability advocacy quality system may be useful in this context.

Recommendation 7: That FaHCSIA develop a set of resources to ensure the Disability Advocacy Standards and KPIs are accessible to people with disability. Resources should include:

  • The standards in various accessible formats, including Braille, audio and Plain English
  • The standards in electronic format, for example, on FaCHSIA’s website
  • Posters and/or pamphlets providing information on the Standards.

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PART 1: Quality Assurance framework for advocacy agencies

This section of the report provides a possible framework for implementing an independent third-party Quality Assurance (QA) system for advocacy agencies funded under the National Disability Advocacy Program (NDAP).

The revised QA framework is based on ARTD Consultants’ independent assessment – balancing the diverse views of advocacy agencies with the Government’s stated intent of introducing a system consistent with the Disability Services Standards.

Quality Assurance framework

The purpose of the National Disability Advocacy Program (NDAP) Quality Assurance (QA) system is to ensure that people with a disability have opportunities to access advocacy which is delivered in ways that meets the Disability Advocacy Standards.

The QA system will operate so that, as a condition of funding, all NDAP advocacy agencies will need to be certified by an independent third-party assessor that they meet the Disability Advocacy Standards. In doing so, the certification process will recognise:

  • The nature of advocacy – Advocacy is different to service provision and therefore the processes needed to assess advocacy agencies will be different to the assessment of service providers. Assessors in the quality system will need to have a good understanding of the nature of advocacy and the different types of advocacy approaches that are funded under the NDAP
  • Diversity – NDAP covers a diversity of advocacy approaches (see 2.1) and demonstrating conformity may be different for different advocacy agencies. For example, an agency that predominately undertakes systematic advocacy work may demonstrate conformity in a very different way to an agency that predominately undertakes individual advocacy
  • Proportionality - Most NDAP agencies have only modest resources available to develop and improve their management systems. The quality assurance process should take this into account when considering the resources required to prepare for certification, as well as the certification assessment itself, and then the ongoing maintenance and improvements.
  • Practicality – the focus of evidence for certification will be on practical observations of on-the-ground practices and service user feedback that demonstrate that the agency has a systematic approach to meeting the Standards
  • Streamlining – the QA system will be implemented in ways that minimise duplications with other accountability and performance arrangements. In particular, streamlining opportunities exist in terms of reduced overlaps with contractual compliance and performance reporting under the NDAP, and recognition of evidence from certifications under other quality systems (e.g. Queensland Disability Advocacy Quality System).

The focus of the QA system is on ensuring funded advocacy agencies have appropriate systems in place which are used to organise and control their work to achieve consistent practices and outcomes in line with the disability advocacy standards. It is separate from the ongoing contractual compliance and performance reporting requirements that relate to the delivery of agreed output, the achievement of immediate program results, and the contribution to broader program outcomes (Strategic Reporting Framework for Advocacy, FACSIA / DSQ 2007).

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Definition of advocacy

In broad terms, advocacy for people with disability can be defined as speaking, acting or writing with minimal conflict of interest on behalf of the interests of a person or group, in order to promote, protect and defend the welfare of and justice for either the person or group by:

  • Being on their side and no-one else’s
  • Being primarily concerned with their fundamental needs
  • Remaining loyal and accountable to them in a way which is empathic and vigorous.

There are a range of different approaches to undertaking advocacy, with many advocacy agencies adopting multiple approaches. Among others, advocacy approaches include:

  • Individual advocacy – seeks to uphold the rights and interests of people with all types of disabilities on a one-to-one basis by addressing instances of discrimination, abuse and neglect.

    Key descriptors for this model include:

    Individual advocates work with people with disability on either a short-term or issue-specific basis.

    Individual advocates:

    • work with people with disability requiring one-to- advocacy support;
    • develop a plan of action (sometimes called an individual advocacy plan) in partnership with the person with a disability that maps out clearly defined goals;
    • educates people with disability about their rights; and
    • work through the individual advocacy plan in partnership with the person with a disability.
  • Systemic advocacy – seeks to influence or secure positive long-term changes that remove barriers and address discriminatory practices to ensure the collective rights and interests of people with disability are upheld.

    Key descriptors for this model include:

    The systemic advocacy agency:

    • pursues positive changes to legislation, policy and service practices in partnership with groups of people with disability, advocacy agencies and other relevant organisations;
    • seeks to address barriers and discriminatory practices to produce long-term positive changes.
  • Citizen advocacy – seeks to support people with a disability (also called protégés) by matching them with volunteers. Some of the matches made may last for life.

    Key descriptors for this model include:

    Through citizen advocacy:

    • people with a disability who are isolated with no family or community supports or networks are sought out
    • volunteers are encouraged to represent the interests of a person with a disability as if they were their own and be free from conflict of interest
    • volunteers are recruited, trained and supported by a coordinator who manages the work of the citizen advocacy agency.
  • Family advocacy – works with parents and family members to enable them to act as advocates with and on behalf of a family member with disability. Family advocates work with parents and family members on either a short-term or an issue-specific basis. Family advocates work within the fundamental principle that the rights and interests of the person with disability are upheld at all times.

    Key descriptors for this model include:

    Through family advocacy:

    • family members are provided with advice and support;
    • the person with disability is assisted via the family member being directly supported by the agency to advocate on their behalf.
  • Self advocacy – supports people with disability to advocate on their own behalf, to the extent possible, or on a one-to-one or group basis.

    Key descriptors for this model include:

    Through self advocacy:

    • advocates work with people with people with disability to develop their personal skills and self-confidence to enable them to advocate on their own behalf.
    • educates people with disability about their rights.
  • Legal advocacy – seeks to uphold the rights and interests of people with all types of disabilities on a one-to-one basis by addressing legal aspects of instances of discrimination, abuse and neglect.

    Key descriptors for this model include:

    Legal advocates may provide:

    • legal representation for people with disability as they come into contact with the justice system;
    • pursue positive changes to legislation for people with disability; and
    • assist people with disability to understand their legal rights.

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Standards and KPIs

The Disability Advocacy Standards covers 11 standards aligned to the National Disability Services Standards. Within the Standards, 24 KPIs are specified that must be met in order to comply with the Standards (Table 1).

Conformity with the KPIs is best demonstrated by evidence of how things currently operate ‘on-the-ground’ and how the agency will ensure consistent delivery in the future. Suitable evidence will include descriptions from management and staff of the intended advocacy processes, with confirmation of actual implementation of these processes from observations and feedback from service users.

Examples of evidence used to demonstrate conformity with the KPIs are presented in Table 1. These examples are NOT a checklist of mandatory requirements. Not all signposts will be relevant to all advocacy contexts and other signposts may be more relevant to some agencies. It is up to each agency to determine the evidence they should use to demonstrate conformity with the KPIs.

 
DISABILITY ADVOCACY STANDARDS KEY PERFORMANCE INDICATORS EXAMPLES OF EVIDENCE (Summary)
Standard 1: Accessing advocacy

People with disability have opportunities to access advocacy on the basis of relative need and available resources.
1.1 The agency adopts, applies and promotes non-discriminatory entry rules in respect of age, gender, race, culture, religion or disability, living arrangements, consistent with the contractual obligations and purpose of the agency.

1.2 The agency’s entry and exit procedures are fair and equitable and consistently applied.

1.3 People with disability are informed about how decisions about access and prioritisation are made.
All agencies
  • Purpose statement that makes it clear who the agency works with to promote, protect and defend the welfare of and justice for people with disability

Agencies undertaking individual advocacy
  • Observation of entry and exit policies and procedures highlighting non-discriminatory practice
  • Cultural awareness training
  • Agency information highlighting that there are no criteria to exclude people from the agency other than they must meet the funded target group’s criteria
  • Monitoring and review of profile of clients assisted

Agencies undertaking systemic advocacy
  • Established practices and policies for providing information and referrals where individual clients request advocacy
  • Established practices and/or policies for deciding and communicating which systemic issues the agency will work on
  • Established practices and policies of providing people with disability opportunities to contribute to / participate in the prioritising processes that determine which issues receive attention

Agencies undertaking citizen/ family/ self advocacy
  • Established non-discriminatory practices and policies for identifying and/or responding to requests from people with a disability for opportunities to access advocacy
  • Annual protégé recruitment plan that reflects diversity and level of vulnerability of people with disability [citizen advocacy]
Standard 2: Individual needs

People with disability receive advocacy that is designed to meet their individual needs and best interests.

[Note: The term ‘individual need’ is used in this Standard to cover both the needs of an individual person (that may be met through individual advocacy) and the collective needs of people with disability (that may be met through systemic advocacy)]
2.1 Advocacy objectives are negotiated with the person or people with disability and reflect their needs.

2.2 All advocacy activities reflect and respond to these needs, including opportunities to involve a support person of their choice

2.3 In meeting the needs of a person or people with disability, the advocacy agency will seek to minimise conflict of interest or to deal with it transparently.
All agencies
  • Agency policy on conflict of interest
  • Established practices and policies for identifying and transparently dealing with conflicts of interest
  • Management, staff and volunteer training in recognising and dealing with conflicts of interest
  • Examples of how the agency has taken into account the specific needs of people from Indigenous and CALD backgrounds

Agencies undertaking individual advocacy
  • Established practices and policies for identifying, documenting, reviewing and closing individual cases
  • Observations of advocacy plans and activities being developed in partnership with people with disability or their guardians/carers where appropriate
  • Evidence of collecting and reviewing feedback about the extent to which the needs of the person with a disability are being met

Agencies undertaking systemic advocacy
  • Established practices and policies for consulting with people with disability prior to systemic advocacy actions being undertaken on their behalf. In reactive cases (which often require quick responses), evidence that people with a disability and/or their agents have been informed of actions being undertaken on their collective behalf
  • Evidence of reporting of outcomes / review of advocacy process

Agencies undertaking citizen advocacy
  • Established practices and policies for developing confidential individual written profiles detailing ‘need’ and seeking advocates based on their skills in relation to these needs
  • Observations of individual being given opportunity to discuss their draft profile
  • Details of completed relationships, and/or those being rematched or awaiting rematching
  • Established practices and policies for reviewing the extent to which the needs of the person with a disability are being met

Agencies undertaking self advocacy
  • Client Action Plans showing links between identified needs and personal goals
  • Observations of the development of Client Action Plans being client led
Standard 3: Decision-making & choice

People with disability have the opportunity to participate as fully as possible in making decisions about the advocacy activities undertaken.
KPI 3.1 People with disability are supported to make their own decisions about the advocacy activities they require.

KPI 3.2 The advocacy agency acts upon the choices made by the person with a disability. Where a person with a disability has impaired decision making capacity, ethical guidelines will be used to inform decisions about advocacy activities.
All agencies
  • Code of Practice or Ethics Guidelines for supporting people with disability in making decisions about advocacy activities
  • Observations of the way advocates interact with people with disability in making decisions about advocacy activities
  • Established practices and policies for determining a decision on behalf of person who has impaired decision making capacity e.g. consultation with them, documenting factors taken into account including knowledge gathered over time
  • Evidence of the involvement of people with disability in agency decision-making (e.g. representation on the Board)
  • Evidence of the involvement of people with disability involvement in all aspects of the quality system (e.g. participation in internal audits)

Agencies undertaking individual advocacy/citizen advocacy
  • Observation of information, strategies and ideas presented in ways that the person is able to understand
  • Observation of regular review processes to confirm the advocacy actions reflects the person’s choices and decisions
  • Feedback from service users

Agencies undertaking systemic advocacy
  • Established practices and policies whereby people with disability are consulted prior to systemic advocacy actions being undertaken on their behalf, where appropriate and feasible
  • Observations of individual people with disability becoming involved in systemic advocacy activities of their choice

Agencies undertaking family advocacy
  • Established practices and policies for sending clear and consistent messages to family members about discussing advocacy action with the person with a disability
Standard 4: Privacy, Dignity & Confidentiality

The right of people with disability to privacy, dignity and confidentiality is recognised and respected.
4.1 The advocacy agency complies with the Information Privacy Principles of the Privacy Act 1988 in order to protect and respect the rights of people with disability.

4.2 The advocacy agency promotes privacy, dignity and respect for people with disability.
All agencies
  • Observations of the way advocates and agency staff talk and write about people with a disability
  • Clear privacy policy ensuring that decisions relating to privacy are made in the best interests of the person with a disability
  • Established practices and policies for obtaining consent where relevant and possible
  • Confidential information safely stored e.g. locked filing cabinets
  • Staff [and volunteers and contractors] sign confidentiality agreements
  • Provision of information about privacy in information kits or brochures to service users

Agencies undertaking individual advocacy/citizen advocacy
  • Feedback from service users about the attitude of agency staff to people with a disability
  • Feedback from service providers on the attitudes of the advocacy agency to people with disability
  • Feedback from service users

Agencies undertaking systemic advocacy
  • Language used in reports to describe people with disability
  • Feedback from stakeholders on the attitudes of the agency to people with disability

Agencies undertaking family advocacy
  • Established practices and policies for sending clear and consistent messages to family members about discussing advocacy action with the person with a disability
Standard 5: Participation & Integration

People with disability are supported and encouraged to participate and be involved in the community.
5.1 Through advocacy, opportunities for participation and involvement in the community are promoted.

5.2 Where appropriate, the advocacy agency takes action to introduce, influence or produce positive systemic change in the community.
All agencies
  • Purpose statement that makes it clear that the agency seeks to promote participation and integration
  • Examples of barriers to community participation raised with service providers and systemic advocacy agencies
  • By modelling acceptance and valuing people with disability in all advocacy activities

Agencies undertaking individual advocacy
  • Examples of activities and issues that the agency engages in that support participation in community life
  • Examples of referrals of issues to systemic advocacy agencies

Agencies undertaking systemic advocacy
  • Periodic reports of systemic advocacy activities

Agencies undertaking citizen advocacy
  • Examples of activities service users and advocates are involved in – while recognising that the citizen advocates and the person with a disability make their own decisions outside of the control of the funded agency
  • Observation that community participation is covered in citizen advocate orientation
Standard 6: Valued Status

The intrinsic value of people with a disability is recognised and each person is supported and encouraged to enhance their valued status in the community.
6.1 Through advocacy, the aspirations and strengths of people with disability are promoted.

6.2 The advocacy agency promotes the intrinsic value and the valued status of people with a disability in all its activities.
All agencies
  • The way people with disability are referred to in agencies promotional material and reports
  • Public speaking at conferences, lectures and professional gatherings to promote a positive image of people with disabilities
  • Observations of the practices used by the advocacy agency in undertaking its work
  • Examples of issues raised with service providers and systemic advocacy agencies

Agencies undertaking individual advocacy
  • Examples of activities and issues that the agency engages in that support the valued status of people with a disability
  • Examples of referrals of issues to systemic advocacy agencies

Agencies undertaking systemic advocacy
  • Periodic reports of systemic advocacy activities

Agencies undertaking citizen advocacy
  • Examples of activities service users and advocates are involved in that promote the intrinsic value and the valued status of people with disability– while recognising that the citizen advocates and the person with a disability make their own decisions outside of the control of the funded agency
  • Observation that valued status is covered in citizen advocate orientation
Standard 7: Complaints & Disputes

People with disability who have a complaint or dispute with the advocacy agency, are encouraged to raise it, and have it resolved, without fear of retribution.
7.1 The advocacy agency informs people about how to raise complaints or disputes about any areas of dissatisfaction with the advocacy agency, without fear of retribution.

7.2 The advocacy agency seeks to resolve complaints or disputes raised by people with disability, with access to both internal and external complaints resolution mechanisms.
All agencies
  • Documented complaints policy and procedures
  • Established practices and policies for investigating and resolving complaints – cover both internal and external complaints resolution mechanisms, including the Complaints Resolution and Referral Service (CRRS)
  • Observations and file review of the processes used in investigating and resolving complaints
  • Established practices and policies for promotion of complaints mechanism
  • Reviews of complaints mechanism involving service users to ensure mechanisms are appropriate to potential complainants
  • Staff attributes to complaints and disputes
  • Service user feedback about the complaints mechanism
  • Complaints register
Standard 8: Agency Management

Each agency adopts quality management systems and practices that optimise the effectiveness of advocacy for people with disability and facilitates continuous improvement.
8.1 The advocacy agency has clearly stated aims and objectives that communicate to people with disability and other relevant stakeholders the scope and limitations of the agency.

8.2 The advocacy agency has management systems in place that facilitate quality management practices and continuous improvement.

8.3 The advocacy agency is structured and operates independently, in such a way that it is as free as possible from conflicts with the best interests of people with disability.
All agencies
  • Documented agency aims and objectives
  • Established practices and policies for promotion and communication of agency aims and objectives with service users and stakeholders
  • Reviews of agency management systems involving service users – including documented annual internal audits and continuous improvement plans
  • Clear governance arrangements
  • Established practices and policies for performance and risk reporting to the governing body
  • Documented policy on agency independence
  • Agency management and staff can provide practical examples of how they operate to ensure they are as free as possible from things that conflict with the best interests of people with disability
  • Evidence of the involvement of people with disability involvement in all aspects of the quality system (e.g. participation in internal audits)
  • Minutes of management committee meetings
  • Documented roles and responsibilities of management committee office bearers
Standard 9: Employment - Not relevant to advocacy agencies
Standard 10: Training & Support

People with disability are supported to self-advocate, where appropriate.

[Note: Advocacy agencies are not training and support providers. Under some advocacy approaches, training and support is delivered to assist people with disability, either directly or through their family/ citizens, to meet their advocacy objectives]
10.1 The advocacy agency supports the capacity of people with disability to self-advocate. All agencies
  • Agency promotional material that makes it clear the extent, if at all, the agency provides training and support
  • Established practices and policies for supporting people with disability where they want to self-advocate

Agencies undertaking self-advocacy
  • Established practices and policies for developing the capacity of people with disability to self-advocate

Agencies undertaking citizen advocacy
  • Established practices and policies for developing the capacity of protégés to assist people with disability meet their advocacy objectives

Agencies undertaking family advocacy
  • Established practices and policies for developing the capacity of family members to assist people with disability meet their advocacy objectives
Standard 11: Staff, Recruitment, Employment & Training

Each person who has an employment relationship with the advocacy agency has appropriate skills and competencies.

[Note: This standard only relates to paid and unpaid staff who come under the control of the advocacy agency. In citizen and family advocacy, the advocates do not have an employment relationship with the advocacy agency.]
11.1 The advocacy agency ensures that staff have relevant skills and competencies.

11.2 The advocacy agency provides opportunities for the appropriate and continuing training and skills development for each staff member.
All agencies
  • Current list of all people who have an employment relationship with the advocacy agency
  • Position descriptions of all paid and unpaid staff that describe skills and competencies needed for the advocates role
  • Established practices and policies for recruitment & induction that ensure paid and unpaid staff have the necessary skills and competencies for their position, including relevant qualification (where appropriate)
  • Annual staff appraisals conducted
  • Training and development plans for all staff

Agencies undertaking citizen advocacy
  • Independent evaluations of practices for developing the capacity of citizen advocates to assist people with disability meet their advocacy objectives
Standard 12: Protection of Human Rights & Freedom from Abuse

The advocacy agency acts to prevent abuse and neglect and to uphold the legal and human rights of people with disability.
12.1 The advocacy agency takes all practical and appropriate steps to prevent abuse, neglect and discrimination of people with disability.

12.2 The advocacy agency upholds and promotes the legal and human rights of people with disability.
All agencies
  • Staff knowledge and skills in recognising and report criminal activities, abuse and neglect
  • Agency management and staff can provide practical examples of how they act to prevent abuse and neglect – including seeking out people with disability who are abused or neglected and who would not normally come to the attention of other agencies [e.g. outreach programs]

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PART 2: Summary of written submissions

Principles guiding the change process

Only twelve submissions addressed the objectives and principles for change. Of these, the majority (n=9) indicated they were generally supportive of, or positive about, the proposed objectives and principles. However, most of these also indicated some level of concern or need for clarification. The issues raised included:

  • concern that reference should be made specifically to systemic advocacy (not only individual advocacy) and that access to a generalist disability advocacy service should be a priority
  • concern that there was no reference to the underlying philosophy that, whenever possible, people with disabilities should be supported to self advocate
  • an objective should be to ‘improve quality’
  • reference should be made to the broader role of advocacy in ‘protecting and promoting the rights of people with disabilities’
  • reference should be made to addressing disadvantage
  • adequate reference is not made to prevention
  • clarity is needed, particularly in regard to what is meant by increased capacity and quality improvement
  • the principle relevant to agencies servicing cultural groups be extended to include increasing these agencies’ capacity
  • all models of advocacy and individual needs should be referenced
  • there should not be an implication that bad things will stop happening to a person when they receive advocacy, as this cannot be guaranteed
  • concern about how FaHCSIA will draw on the knowledge of people with disabilities, particularly those who are vulnerable and whose voices are not generally heard
  • current examples of good practice in capacity building should be built upon to create a more robust sector.

Recommendation 1: That the objectives and principles for the development and implementation of the new NDAP quality system be adopted as follows:

OBJECTIVES

To enhance the efficiency of the NDAP and the effectiveness of funded agencies in order to:

  • Meet the advocacy needs of people with disability.
  • Develop the capacity of NDAP funded agencies to respond to the advocacy needs of people with disability.
  • Meet the performance and accountability needs of the Australian Government.

PRINCIPLES

For people with disability

  • People with disability receive advocacy appropriate to their needs (i.e. culture, disability type, gender) to address and prevent disadvantage, abuse and neglect
  • People with disability access advocacy that is timely to address and prevent instances of disadvantage, abuse and neglect
  • People with disability have increased access to advocacy services

For NDAP funded agencies

  • NDAP funded agencies are supported to increase their capacity to respond to the advocacy needs of people with disability
  • NDAP funded agencies with specialist expertise (i.e. expertise in servicing cultural groups, particular disability types etc) are supported to share this knowledge with the disability advocacy sector.
  • NDAP funded agencies are supported to deliver advocacy accountably and to continually improve quality

For FaHCSIA

  • FaHCSIA works in partnership with NDAP funded agencies to implement the NDAP changes
  • FaHCSIA supports collaboration between NDAP funded agencies as part of the NDAP changes
  • FaHCSIA draws on the knowledge and expertise of people with disability and the disability advocacy sector to guide the NDAP changes

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Overall perceptions of the Quality Assurance system


Agencies were asked to provide feedback on the Quality Assurance (QA) system and the proposed set of Disability Advocacy Standards, which comprises 11 Standards and 24 KPIs, and replaces the 101 supporting standards which currently apply to non-employment services.

The applicability of the Standards and KPIs to the work of agencies

Approximately nine submissions indicated that the generic standards and KPIs were appropriate for their agency in their current form. These agencies deliver advocacy across a range of the models including individual, self, personal (classified under the citizen advocacy model), one citizen advocacy agency, and an indigenous agency. However, one of these agencies raised some minor issues with the KPIs and another indicated that they supported the generic standards on the proviso that the supporting evidence is relevant to the type of advocacy provided by the agency.

The majority of agency submissions proposed alterations to the Standards and KPIs and/ or additional KPIs. There were a number of agencies that posed significant issues reaching across several Standards. These concerns are outlined below.

Applicability of the standards to all models

A number of agencies noted that the standards and KPIs are more applicable to certain models of advocacy, particularly individual advocacy than others, and that evidence guidelines must be flexible (28). One agency noted that Standards 1, 2 and 3 are particularly problematic, although some of these issues could be modified if the phrase ‘advocacy support’ replaced ‘advocacy’ or ‘the support of an advocate’ (22).

A handful of agencies raised issues with reporting under a generic set of standards:

  • One agency noted the standards were not a perfect fit for citizen advocacy, and the limitations entailed by a generic set of standards should be taken into consideration when future quality assessments are made (14)
  • Another agency indicated difficulties in providing evidence for systemic advocacy under a generic model under which individual advocacy agencies also report, and suggested a different model (see attachment 4, section 6.14)
  • One agency noted that although specific evidence guidelines go some way to addressing concerns, consideration could be given to some specific standards for advocacy types (22)

Applicability of the standards to self advocacy

One agency noted that the standards and KPIs are written in terms of individual service delivery, which makes relating them to self advocacy difficult, as self advocacy is counter to a service delivery focus.

Applicability of the standards to citizen advocacy

A number of citizen advocacy agencies indicated that the Standards and KPIs need to be amended to ensure applicability to their work. One agency indicated that some of the KPIs are incompatible with the mission of citizen advocacy to recruit, prepare and support suitable members of the community to act as advocates for people with disabilities. To ensure the applicability of the standards to citizen advocacy the phrase ‘where consistent with its mission’ should be added to certain standards and KPIs (15).

One of the agencies, which supports the generic standards for the most part, noted that standards 1 to 4 may not be relevant to systemic advocacy, particularly Standard 2, which they suggest is the only standard that is completely irrelevant their systemic work (25).

In contrast, one citizen advocacy submission indicated that Standards 1, 2 and 3 would apply to the model given citizen advocacy coordinators are in direct contact with people with a disability before citizen advocates are recruited and keep advocates well informed about the person with a disability before the match is made (12).

Applicability of the standards to systemic advocacy

A handful of agencies indicated some or all of the Standards and KPIs are generally applicable to individual advocacy, but are not really relevant or easily transferable to systemic advocacy. Certain Standards do not provide a meaningful structure for documenting and reporting on systemic advocacy work.

One agency suggested separate Standards and KPIs for systemic advocacy should be developed by a working group including representatives of funded agencies (6). While another suggested that some fine tuning could ensure the Standards are relevant to systemic advocacy (26).

Applicability of the standards to family advocacy

It should be recognised in the Standards and KPIs that in family advocacy service provision, it is almost always the family member who ‘accesses’ the advocacy agency. The phrase ‘people with a disability and/ or their agent’ should be used where necessary in Standards (and KPIs) 1, 2 and 7, and attached to a footnote that describes an agent e.g. parent, family member or friend.

Capacity of the person with the disability

Several agencies highlighted issues with the orientation of the Standards when people with impaired decision making abilities and capacity are concerned.

The first concern is the assumption that it is possible or desirable for all people with disabilities to assume a proactive role in accessing advocacy and making decisions about their needs and goals but, in some cases, a person’s disability makes it difficult for them to communicate or influence certain decisions concerning them (15). Not all people with a disability are equally capable of decision making, self-advocacy, etc. There are cases where acting in the person’s ‘best interests’ does not necessarily mean doing what the client says (18).

The second concern outlined by a number of agencies is the lack of recognition in the Standards agencies’ role in seeking out those who are vulnerable, subject to abuse and neglect, and who may not have the capacity to self refer. This was particularly noted in relation to Standard 1. This was also an issue raised in relation to the advocacy models

People from non English speaking backgrounds

Some of the standards and KPIs need to be altered to take into account the significant barriers faced by people from a non English speaking background with a disability in accessing services. People from non English speaking backgrounds are 3-5 times less likely to access a government funded disability service and access to mainstream disability advocacy providers is similarly constrained (19).

Reference to advocacy outcomes

A number of citizen advocacy agencies and a family advocacy agency indicated that ‘advocacy objectives’ (or in standard 8 ‘effectiveness of advocacy’) should replace references to ‘advocacy outcomes’. There would be a number of issues in measuring advocacy outcomes, including:

  • Some cases have existed for years with still no clearly identifiable outcome. In measuring outcomes, account must be taken of some work requiring longer term effort to achieve change, and there must be some capacity to report on incremental results (27, 35)
  • referring to outcomes assumes advocacy can achieve all of a client’s requests, but this is not the case, especially as many issues require service system responses (10), and advocacy agencies are almost solely in an ‘influencing role’ (35)
  • In assessing outcome measurement, the impact what is being measured has on what agencies do, must be considered e.g. work may be done to suit data collection rather than best practice (27)
  • Assessing outcomes may over-emphasise resolution of an advocacy issue when feedback from clients has indicated that the quality of support is also valued, and a positive outcome may be that the person has had a chance to get a fair hearing and be supported (27)
  • Systemic and individual advocacy must have separate outcome measures (27)
  • Measuring outcomes risks orientating agencies to cases with easily achieved and assessable outcomes (35)
  • often there is not clear causal link (35)

Qualification of statements

Several of agencies indicated that a number of the standards and KPIs are not significantly qualified statements and require the addition of phrases such as ‘where possible’ (14).

Standard 9: training and support

A number of agencies raised significant concerns with Standard 9 and whether it is applicable to all models of advocacy (or to advocacy at all).

Recommendation 2: That a Disability Advocacy Quality Assurance Framework be developed to articulate the principles, definition, standards and quality requirements for the NDAP QA system. Specifically, the draft framework developed on the basis of advocacy agency consultations (see Section 3) should be used as the basis for piloting the new NDAP QA system.


Recommendation 4: That the revised Standards, and KPIs for each Standard, (see Section 3.2) be used as the basis for piloting the new NDAP QA system


Recommendation 5: That the generic Disability Advocacy Standards and KPIs be accepted within the QA framework and that tailored Evidence Guidelines be developed suitable for each of the advocacy approaches.


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Concerns with the Quality Assurance system

Scope of the QA system

The submission representing 10 agencies indicated the quality system should be viewed in the context of different levels of outcomes – systems, services, immediate results and results (ultimate outcomes/ impacts). The quality arrangements should operate at the systems level focusing on the way funded agencies organise and control their work to ensure consistent practice (17).

One agency suggested that with the implementation of the quality assurance system and emphasis on continuous improvement, it would be appropriate to have a separate section ensuring and promoting good management practice and good governance (27).

Standard on Employment

One agency indicated that Standard 9 on employment from the Disability Services Standards should be used, as many employees and volunteers of agencies are people with disabilities, and KPIs should cover wages, employment conditions, and incorporate volunteers. Evidence would include Employee working conditions and salary range, and Enterprise Bargaining Agreements.

Recognising additional components of advocacy

One submission indicated they also provide secondary consultancy of training to staff to increase awareness of acquired brain injury and reduce discrimination (e.g. to Centrelink). The KPIs do not reflect this type of advocacy, which is an important aspect of their systemic advocacy work. Many clients only require information to advocate on their own behalf or understand their rights, and it would be good if this was reflected in the KPIs (40).

Linking individual and systemic advocacy

Individual advocacy work should be linked to systemic advocacy – providing systemic responses to aggregated information from individual advocacy work should be a major feature of the NDAP (27). Another agency also highlighted the importance of a close working relationship between individual and systemic advocacy agencies, because it is difficult to pursue systemic advocacy adequately without first thoroughly understanding what is important to individuals with disabilities.

Implementing management systems

One agency indicated that establishing management systems must involve advocates and clients to ensure the reality of disability advocacy is reflected, there must also be scope in the agency’s workload for this (10).

Code of Ethics/ ethical guidelines

One agency indicated that FAHCSIA should develop an agreed code of ethics for the sector. An agency suggested that if ethical guidelines are applied in the advocacy sector, training will be needed in these. A development of a hierarchy of priorities in conjunction with ethical guidelines would assist resolution of conflict of interest, for e.g. the highest priority could be human rights and, where a person’s goals conflict with this, the former would take priority (10).

Funding

Concerns about funding were raised by a number of agencies for varying purposes.

  • In relation to standards 9, 10 and 11, in particular, additional funding may be required or helpful in meeting the standards, for example, in bearing training costs (22)
  • significant funding will be required to provide the training proscribed in Standard 10 (28).
  • The agency believes financial commitment to the sector has diminished over the years and ‘new investment should be used as an incentive for structural change and reform’ (27)
  • The agency has recently had to reduce service delivery due to insufficient funds. Also funding assistance from FaHCSIA to assist agencies to instigate preventative systemic advocacy initiatives will greatly enhance the individual advocacy initiatives undertaken within the regions (29)
  • Funding must be sufficient to attract highly skilled staff. Funding has not accommodated wage increases. Support is needed in bringing agency’s capacity up to standard, only after the time is given for this to occur can the sector ‘truly participate in a much needed QA system that ‘professionalises’ the sector’. Financial resources are also needed in providing ongoing training (30)

Training

In consultation with agencies, FAHCSIA should develop an accredited training package for advocates and Board members including competencies, information on legislation etc (30).

Disability Services Queensland

DSQ indicated support for the introduction of the system. It was suggested linkages should be established between State and Commonwealth Governments in cases of organisations funded by both Governments, particularly mutual recognition of quality standards. Possibly, agencies that meet the Queensland standards should not go through the same check again to meet accreditation measures for FaHCSIA, or there could be a collaborative process that responds to both sets of standards.

The submission also suggests use of the term quality management rather than quality assurance as the process does not necessarily result in ‘quality assurance’. Also, the term ‘key service indicators’ is more appropriate than ‘key performance indicators’. The introduction of a set of measurable performance needs clarification, that quality improvement is to be achieved not by measuring performance, but by confirming systems are in place to measure service outcomes.

The certification process under the new Quality Assurance system will recognise:

  • The nature of advocacy – Advocacy is different to service provision and therefore the processes needed to assess advocacy agencies will be different to the assessment of service providers. Assessors in the quality system will need to have a good understanding of the nature of advocacy and the different types of advocacy approaches that are funded under the NDAP
  • Diversity – NDAP covers a diversity of advocacy approaches (see 2.1) and demonstrating conformity may be different for different advocacy agencies. For example, an agency that predominately undertakes systematic advocacy work may demonstrate conformity in a very different way to an agency that predominately undertakes individual advocacy
  • Proportionality - Most NDAP agencies have only modest resources available to develop and improve their management systems. The quality assurance process should take this into account when considering the resources required to prepare for certification, as well as the certification assessment itself, and then the ongoing maintenance and improvements.
  • Practicality – the focus of evidence for certification will be on practical observations of on-the-ground practices and service user feedback that demonstrate that the agency has a systematic approach to meeting the Standards
  • Streamlining – the QA system will be implemented in ways that minimise duplications with other accountability and performance arrangements. In particular, streamlining opportunities exist in terms of reduced overlaps with contractual compliance and performance reporting under the NDAP, and recognition of evidence from certifications under other quality systems (e.g. Queensland Disability Advocacy Quality System).

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Definition of Advocacy


Although a number of submissions posed issues with the advocacy models, only two submissions raised concerns with FaHCSIA’s proposed definition of advocacy, outlined below.

In broad terms, advocacy for people with disability can be defined as speaking, acting or writing with minimal conflict of interest on behalf of the interests of a person or group, in order to promote, protect and defend the welfare of and justice for either the person or group by:

  • Being on their side and no-one else’s
  • Being primarily concerned with their fundamental needs
  • Remaining loyal and accountable to them in a way which is empathic and vigorous

One agency (5) believes that the rights of people with disabilities to express their wishes and have advocacy executed exactly as expressed in their wishes is an important aspect of advocacy, that is not adequately reflected in this definition. It is only a minority of people with disabilities who cannot express their wishes and, in these cases, consideration is given to what would be the wishes of the person (consistent with their proper care and protection). In this light, the agency proposed the following definition1:

Advocacy is speaking, acting or writing with a clearly documented mandate on the expressed wishes of a person with disabilities or groups of people with disabilities in order to promote, protect and defend the welfare of and justice for people with disabilities in our disabling society, while vigorously avoiding any kind of conflict of interest between advocate, the organisation the advocate works for and the person with a disability.

The second agency (27) largely agrees with the broad definition for advocacy, however, insists it is critical to reference the UN Convention on Human Rights for People with Disabilities, and that principles for defining advocacy should include:

  • a clear value base of social justice, equity and full inclusion of people with disabilities as full contributing/ participating members of their communities
  • advocacy should focus on the fundamental human needs, rights and interests of people with disabilities
  • advocacy is on the side of people with a disability and remains loyal and accountable to them over the long term where needed
  • advocacy needs to be independent and to minimise conflict of interest
  • advocacy needs to be empathic and vigorous and prepared to endure negative impacts for both advocate and their agency as well as the person with a disability.

Disability Services Queensland (DSQ) indicated that although any review of the definition would be welcomed, frequent changes to the definition could potentially result in confusion about the scope and interpretation relating to advocacy services across different levels of government. It was further suggested that once a definition is selected other documentation containing definitions of advocacy be revised to reflect the same definition.


1. However, the agency acknowledged that their definition may exclude other advocacy agencies.

Advocacy ‘models’

FaHCSIA discussion paper outlined descriptions of six different models of advocacy – individual, self, family, citizen, systemic and legal – which are currently funded under the National Disability Advocacy Program (NDAP).

Approximately a third of agency submissions raised issues with the proposed models, generally proposing alterations to specific models. There were, however, a handful of agencies that highlighted overall issues with the models, as well as substantial overlap between the issues raised for separate models.

Several agencies highlighted the overlap between advocacy models, with two submissions (one representing 10 agencies) also highlighting that many agencies employ more than one model (17, 35). A couple of these agencies suggested that this overlap should be specifically recognised in the descriptions.

One of the submissions (27) suggested that two models – individual and systemic – would be appropriate to all agencies funded under the NDAP, and other models for delivering advocacy fit within these. The simplified model, allowing a variety of approaches would be more effective, as listing various approaches to the models for funding purposes can be prescriptive and hinder necessary flexibility.

Another agency indicated that there may be issues for agencies reporting on more than one model of advocacy. In reporting against the standards there may be instances where complying with the standard for one model of advocacy will conflict with complying with the standard for another model of advocacy (e.g. if an individual requests pursuit of a systemic outcome that might be detrimental or controversial to a community as a whole) (25).

A significant proportion of the issues raised were raised in some form across a number of the advocacy models, particularly:

  • Target population descriptions introduce unnecessary constraints, for example, working with people with a certain type of disability
  • Role to pro/ actively seek out those who are vulnerable, subject to abuse and neglect or lack the capacity to self refer and provide them with opportunities to access advocacy should be recognised in the models (work can be by referral or direct contact). One agency suggested that ‘method of contact’ be included in the model descriptions.
  • The terms treatment and prevention a number of agencies highlighted the importance of prevention not recognised in some of the descriptions
    • An individual advocacy submission indicated advocacy must be about more than addressing instances of discrimination, abuse and neglect. If the underlying disadvantage and vulnerability is not addressed the personal will be at risk once the advocate leaves and if assistance is not provided in cases of perceived risk, the person with a disability is left open to preventable harm (1)
    • Two submissions indicated there is a continuum between reactive and proactive activities for all types of advocacy and reference to ‘prevention or treatment’ should be removed from all models
    • One agency indicated a problem with the terms and suggested ‘responsive or pro-active’ replace the terms.
  • Duration of the advocacy the length of the activity depends on each case/ situation (rather than the model type), and it should be recognised that as people with disabilities often face ongoing issues that are rarely short term and related to one issue, so advocates ‘work to address issues as they arise and until the issue is resolved’. Advocacy can be on ‘either short-term, long-term or issue specific basis’ (17, 34)
  • Role to educate was not recognised by many advocacy agencies. They have a role to ‘inform’ or ‘assist’ but not a specific role to ‘educate’ (some agencies suggested there is no role to educate). The reference to educating was only unchallenged in the legal advocacy model (35, 34)
  • Voluntary staff not all staff are paid
    • e.g. systemic advocates can involve people with a disability on committees and reference groups in a voluntary capacity (25), and families and allies of people with a disability (32)
    • In some cases the issue could be addressed by referring to ‘staff of the advocacy agency’ not ‘a paid advocate’
  • Advocating ‘on behalf of’ a number of agencies suggest this should be replaced by ‘with and on behalf of’
  • Prescriptive descriptions
  • Positive community attitudes – reference to changing community attitudes should be prefaced with the word ‘positive’. However, an agency indicated that the ability to influence is not decided by the advocacy agency, they can strive to influence

Disability Services Queensland (DSQ) indicated that advocacy services in Queensland can be classified under two models – individual and systemic – with a range of models used within these, including citizen, family, parent and self. Although acknowledging the distinction between the two is important, it could be problematic to group services specifically in one model as they may provide both.

It is critical to have a clear definition of the models to best meet individual’s needs. For simplification, DSQ suggested that individual and self advocacy models could be grouped with specific mention of the sub-models. DSQ also indicated that identifying legal advocacy as a formal model of advocacy risks duplicating a system already in place (legal aid) and confusing clients and service providers.

Another agency suggested that the role descriptions are quite limited across the models and could be expanded, and that the primary and secondary functions of agencies could be described.

Recommendation 3: That the broad definition of advocacy be accepted as follows:

In broad terms, advocacy for people with disability can be defined as speaking, acting or writing with minimal conflict of interest on behalf of the interests of a person or group, in order to promote, protect and defend the welfare of and justice for either the person or group by:

  • Being on their side and no-one else’s
  • Being primarily concerned with their fundamental needs
  • Remaining loyal and accountable to them in a way which is empathic and vigorous.

That the current set of ‘Advocacy Model Descriptions’ be replaced in the QA Framework with high-level description of the suite of advocacy approaches and a sample of key descriptors. More detailed descriptions and examples of the range of advocacy approaches would be incorporated into a NDAP QA Handbook (see Recommendation 6). The proposed high-level descriptions are as follows:

There are a range of different approaches to undertaking advocacy, with many advocacy agencies adopting multiple approaches. Among others, advocacy approaches include:

  • Individual advocacy – seeks to uphold the rights and interests of people with all types of disabilities on a one-to-one basis by addressing instances of discrimination, abuse and neglect.

    Key descriptors for this model include:

    Individual advocates work with people with disability on either a short-term or issue-specific basis.

    Individual advocates:

    • work with people with disability requiring one-to- advocacy support;
    • develop a plan of action (sometimes called an individual advocacy plan) in partnership with the person with a disability that maps out clearly defined goals;
    • educates people with disability about their rights; and
    • work through the individual advocacy plan in partnership with the person with a disability.
  • Systemic advocacy – seeks to influence or secure positive long-term changes that remove barriers and address discriminatory practices to ensure the collective rights and interests of people with disability are upheld.

    Key descriptors for this model include:

    The systemic advocacy agency:

    • pursues positive changes to legislation, policy and service practices in partnership with groups of people with disability, advocacy agencies and other relevant organisations;
    • seeks to address barriers and discriminatory practices to produce long-term positive changes.
  • Citizen advocacy – seeks to support people with a disability (also called protégés) by matching them with volunteers. Some of the matches made may last for life.

    Key descriptors for this model include:

    Through citizen advocacy:

    • People with a disability who are isolated with no family or community supports or networks are sought out
    • volunteers are encouraged to represent the interests of a person with a disability as if they were their own and be free from conflict of interest
    • volunteers are recruited, trained and supported by a coordinator who manages the work of the citizen advocacy agency.
  • Family advocacy – works with parents and family members to enable them to act as advocates with and on behalf of a family member with disability. Family advocates work with parents and family members on either a short-term or an issue-specific basis. Family advocates work within the fundamental principle that the rights and interests of the person with disability are upheld at all times.

    Key descriptors for this model include:

    Through family advocacy:

    • family members are provided with advice and support;
    • the person with disability is assisted via the family member being directly supported by the agency to advocate on their behalf.
  • Self advocacy – supports people with disability to advocate on their own behalf, to the extent possible, or on a one-to-one or group basis.

    Key descriptors for this model include:

    Through self advocacy:

    • Advocates work with people with people with disability to develop their personal skills and self-confidence to enable them to advocate on their own behalf.
    • Educates people with disability about their rights.
  • Legal advocacy – seeks to uphold the rights and interests of people with all types of disabilities on a one-to-one basis by addressing legal aspects of instances of discrimination, abuse and neglect.

    Key descriptors for this model include:

    Legal advocates may provide:

    • legal representation for people with disability as they come into contact with the justice system;
    • pursue positive changes to legislation for people with disability; and
    • assist people with disability to understand their legal rights.

Citizen advocacy

Citizen advocacy seeks to support people with a disability (also called protégés) by matching them with volunteers. Some of the matches made may last for life.

Key descriptors for this model include:

Through citizen advocacy:

  • People with a disability who are isolated with no family or community supports or networks are sought out
  • volunteers are encouraged to represent the interests of a person with a disability as if they were their own and be free from conflict of interest
  • volunteers are recruited, trained and supported by a coordinator who manages the work of the citizen advocacy agency.

Feedback on the citizen advocacy model

A total of four submissions proposed changes or highlighted issues with the model as proposed by FaHCSIA. The agencies comments are outlined below.

  • Relationship with the advocate the work can be on a one-to-one or ‘near one-to-one basis’ (4, 12)
  • Target Population
    • not necessarily limited to people with an intellectual disability, service users include those with a psychiatric disability or a dual or multiple disability (10); or simply ‘people with a disability’ (17, 35)
    • another agency indicated that the population should be qualified by ‘some of whom may be isolated...’ (38)
  • Functions
    • Advocates ‘provide encouragement [replaces support] that may enable the person with intellectual disability to advocate for themselves’ (12)
    • in performing their functions advocates ‘have the capacity to educate...’ (replaces the function ‘educates people...’) (12)
    • Agencies also ‘identify’ advocates (12)
    • Additional functions include: ensuring people with intellectual disabilities have the same opportunities and life conditions available to everyone else; to help safeguard the person from abuse, neglect, discrimination and exploitation; affirm the value of people with intellectual disabilities within the community; protect and uphold the legal and human rights of people with a disability (4)
    • Omit reference to matches volunteer advocates to people with an intellectual disability(4)
  • Qualification of statements
    • staff of the citizen advocacy office who support the advocate are only ‘usually’ paid workers (17)
    • matched advocates are ‘suitably skilled members of the community’ (12); or ‘responsible and competent’ (35)
  • The role of the advocate also includes ensuring a person’s human rights are upheld, helping them gain access to services, support in decision making and choice, encouragement to develop new skills and participation in all aspects of community life (4)
  • Accommodating personal advocacy within the model it was previously agreed that personal advocacy is most closely aligned within citizen advocacy. However, to accommodate this within the model some changes to the prescriptive wording are needed, for examples, a more inclusive name, such as: Civilian, community or volunteer advocacy. Other changes include:
    • remove references to citizen advocates, the citizen advocacy office, and terms not used by personal advocacy (e.g. protégé, follow-along)
    • Advocacy support is provided over the long term, and may last for life if the person requires it (replaces ‘matches may last...’)
    • Assists’ people to develop an awareness about their rights (replaces ‘educates’)
    • Personal advocacy’s primary approach is preventative

Individual advocacy

Individual advocacy – seeks to uphold the rights and interests of people with all types of disabilities on a one-to-one basis by addressing instances of discrimination, abuse and neglect.

Key descriptors for this model include:

Individual advocates work with people with disability on either a short-term or issue-specific basis.

Individual advocates:

  • work with people with disability requiring one-to- advocacy support;
  • develop a plan of action (sometimes called an individual advocacy plan) in partnership with the person with a disability that maps out clearly defined goals;
  • educates people with disability about their rights; and
  • work through the individual advocacy plan in partnership with the person with a disability.

Feedback on the individual advocacy model

Issues with the model of individual advocacy were raised by approximately five agencies:

  • Narrow description and role so as not to cover the activities individual advocacy entails, for example, discrimination does not encompass ensuring clients have access to services they need, or improving the quality of the service received (22)
  • Capacity for decision making the functions currently focus on individuals with limited capacity for independent decision making, which is not appropriate to the advocacy clients of Blind Citizens Association (25)
  • Role may also include facilitating systemic outcomes in some cases (25)
  • Self advocacy – delete reference to supporting the person to advocate on their own behalf
  • Addresses a range of issues including obtaining funding and support and addressing issues in relation to service providers’ practices (35)
  • ‘Individual’ advocacy plans are developed (17, 35)
  • Role to direct information in relation to systemic issues

Family advocacy

Family advocacy works with parents and family members to enable them to act as advocates with and on behalf of a family member with disability. Family advocates work with parents and family members on either a short-term or an issue-specific basis. Family advocates work within the fundamental principle that the rights and interests of the person with disability are upheld at all times.

Key descriptors for this model include:

Through family advocacy:

  • family members are provided with advice and support;
  • the person with disability is assisted via the family member being directly supported by the agency to advocate on their behalf.

Feedback on the family advocacy model

There was a lack of submissions with reference to family advocacy, and only three submissions (32, 35, 34) raised issues with the proposed description. The issues are outlined below:

  • Interests of the person with disability
    • The persons interests are paramount and agencies operate within this principle
    • The advocate acts ‘with or on behalf of’ the person with disability, recognising that many families advocate on behalf of babies and children who cannot advocate on their own behalf
    • Change the word order of interest alignment so ‘the interest of the family is consistent with the interests of the person with a disability’ (rather than the inverse order as currently proposed because this may risk putting the interests of the family member first)
    • When referring to who is assisted – refer to the person with a disability – ‘the person with a disability is assisted via the parent or family member being directly supported’
  • Influencing community attitudes agencies can only ‘endeavour to influence’, as control often held by others e.g. governments
  • The term ‘family members and allies’ should replace ‘parents and family members’ to avoid confusion as to who the model applies to.

Self advocacy model

Self advocacy supports people with disability to advocate on their own behalf, to the extent possible, or on a one-to-one or group basis.

Key descriptors for this model include:

Through self advocacy:

  • Advocates work with people with people with disability to develop their personal skills and self-confidence to enable them to advocate on their own behalf.
  • Educates people with disability about their rights.

Feedback on the self advocacy model

Five submissions highlighted issues with the self advocacy model (one of which represented 10 agencies).

Issues

  • Target population
    • The submission representing 10 agencies proposed removing the reference to predominately working with people with intellectual disabilities (17)
    • Although self advocacy is primarily aimed at people with an intellectual disability, it should be noted that peer support groups have the same function for other people with disabilities (25)
    • People with impaired decision making ability may not be able to self advocate and, where they can, it will likely only be on some (limited) issues – the current definition may convey an inappropriate impression about what is achievable, and should be qualified with ‘to whatever degree possible’ (35)
    • Self advocacy supports people with ‘complex needs and acquired brain injury’, which should be added to the description (37)
    • Concern that if the NDAP is designed to target the most vulnerable people with disabilities, that an emphasis on vulnerable people advocating for themselves would be the least potent form of advocacy for them
  • Overlap with individual advocacy was highlighted by one agency that indicated their self advocacy clients vary in confidence and ability and, on a number of occasions, they have also required individual advocacy services (22)
  • Advice and support the person with disability advocates on their own behalf, but they are ‘assisted by staff of the advocacy agency who provide advice and support to the individual’ (17, 35)
  • Additional function in informing decision making should be outlined – provides or has translated information into appropriate formats to enable informed decision making and choice (37)

Systemic advocacy

Systemic advocacy seeks to influence or secure positive long-term changes that remove barriers and address discriminatory practices to ensure the collective rights and interests of people with disability are upheld.

Key descriptors for this model include:

The systemic advocacy agency:

  • pursues positive changes to legislation, policy and service practices in partnership with groups of people with disability, advocacy agencies and other relevant organisations;
  • seeks to address barriers and discriminatory practices to produce long-term positive changes.

Feedback on the systemic advocacy model

A handful of submissions had concerns with the systemic advocacy model, a number of which were also raised in relation to other models. The issues were:

  • Who undertakes the advocacy two submissions (one on behalf of 10 agencies) removed the reference to policy officers and peak bodies, suggesting alternatives:
    • staff and volunteers [under the guidance of the Board] of the advocacy agency’ (17, 35)
    • systemic advocates employed by advocacy agencies, and people with a disability and their families and allies’ (32)
  • ‘Collective rights’ (rather than ‘rights’) are ensured by systemic advocacy undertaken to ‘remove barriers and address discriminatory practices’ (17)
  • Role in promoting development of appropriate policy, services and legislation (35)
  • Education one agency proposed an alternative function – ‘acts as an ‘early warning system’ so that actions can be taken preventatively’ (32)
  • Changes pursued are ‘in areas identified by the Board’ (17, 35)
  • Who is assisted an agency indicated that more that people with a disability are assisted ‘all of community’ is also assisted ‘as this supports an integrated and cohesive community’ (37)
  • Systemic advocacy should be separate from individual advocacy as if one agency undertakes both, there is a risk that they will address issues of their target group
  • Systemic advocacy must be vigilant in issues pursued, or there is a risk that issues of physical access/ structural issues will overtake social issues, as structural issues are more easily remedied.

Legal advocacy

Legal advocacy seeks to uphold the rights and interests of people with all types of disabilities on a one-to-one basis by addressing legal aspects of instances of discrimination, abuse and neglect.

Key descriptors for this model include:

Legal advocates may provide:

  • legal representation for people with disability as they come into contact with the justice system;
  • pursue positive changes to legislation for people with disability; and
  • assist people with disability to understand their legal rights.

Feedback on the legal advocacy model

Few submissions were received from agencies undertaking legal advocacy and few submissions made reference to this model of advocacy. Four submissions raised issues with the Legal advocacy model:

  • Clearer definition is needed of the work done by legal advocates, as opposed to individual advocates in pursuing a case. ‘Appropriate legal knowledge’ should be clearly defined, for example, whether this necessitates a formal qualification. (25)
  • Wider legal representation is provided than that indicated by the functions – i.e. the ‘justice system’ in general and ‘other areas of the legal system’, not only the ‘criminal justice system’. An agency indicated they provide legal representation not only in cases that come before the criminal justice system, but cases in other aspects of the legal system e.g. children’s court, complaints mechanisms and the civil justice system (36)
  • Concern with the model – one agency was concerned the model discriminates against people with disability through lack of general access to the legal system; the usual function of a social advocate is to facilitate access to the appropriate service not to provide that service; and other specialist legal representation, such as HREOC and Community legal Services, already address issues of discrimination.

1. However, the agency acknowledged that their definition may exclude other advocacy agencies.

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Standards and KPIs


Standard 1: Accessing advocacy

Recommendation: That Standard 1and KPIs 1.1, 1.2 and 1.3 be adopted as follows

Each person with a disability who is seeking the support of an advocate has access to an agency on the basis of relative need and available resources.

1.1 The agency adopts, applies and promotes non-discriminatory entry rules in respect of age, gender, race, culture, religion or disability, living arrangements, consistent with the contractual obligations and purpose of the agency.

1.2 The agency’s entry and exit procedures are fair and equitable and consistently applied.

1.3 People with disability are informed about how decisions about access and prioritisation are made.

Feedback on FaHCSIA’s proposed Standards and KPIs

Standard 1

  • Seeking the support of an advocate a number of agencies (from a range of models) suggested reference to ‘seeking the support...’ be removed – there are other ways of identifying those in need who do not initiate advocacy. Suggestions were:
    • ‘...have the opportunity to have access to an advocacy...’ (2)
    • ‘...has[ve] opportunities to access advocacy on the...’ (4, 8, 12, 14, 16, 35)
    • who requires the support...’ (to replace ‘who is seeking’) (15)
    • ‘who needs an advocate...’ as the most vulnerable people with a disability often do not or cannot seek advocacy. Legislative reforms should be considered to ensure access to advocacy for vulnerable people, for e.g. mandatory notification (34)
  • Who accesses the support parents and/ or family of people with disabilities also want to access support and, in some cases, the person with a disability could not access the service without their support (18); the standard should refer to ‘all people with disabilities and their carers, organisations, and representatives’ (26)
  • Proactively seeking
  • People plural three submissions (one representing 10 agencies) indicated ‘people with a disability’ should replace ‘each person’ (2) (17) (32)
  • Applicability
    • systemic, family and citizen advocacy should not be affected by this standard provided they have adequate policies and procedures in place (e.g. feedback to and supervision of staff, and understanding of roles and responsibilities) (18)
    • different standard and KPI would be needed to reflect the different nature of systemic advocacy work (40)
    • ‘who is seeking advocacy support’ (replacing ‘who is seeking the support of an advocate’) would better reflect self and systemic advocacy (22)

KPIs 1.1, 1.2, 1.3

  • Systemic advocacy KPIs specifically related to systemic advocacy would be useful (27). However, another agency delivery systemic advocacy indicated the KPIs would be applicable (as they consult before undertaking systemic actions) provided there was an understanding of how systemic advocacy ought to be delivered (26)
  • Target population three agencies (from a range of models) indicating the reference to not discriminating on the basis of ‘disability’ is confusing, as some agencies only or primarily deliver services to people with certain types of disabilities as per their funding agreements and purpose (10 26 24 40)
  • Access to information ‘and can be made available to anyone who wishes to access the rules’ should be added to 1.2 (26)
  • Modification of the KPIs
    • 1.1 should refer to the organisation articulating it’s model of advocacy and who is eligible (i.e. within their target population) (34)
    • 1.2 should also refer to organisation demonstrating criteria by which decisions are made (34)
  • Alternative and additional measures
    • Non discriminatory processes on paper don’t necessarily translate to numbers using the service (e.g. NESB). More appropriate measures would be reporting on population group utilisation and the application of a cultural component in delivering advocacy (19). One of the agencies indicated that despite processes they believe people with different cultural needs have not successfully accessed the services (24)
    • There should be a KPI requiring reporting on proactive strategies to reach those who are unable or unlikely to access advocacy for various reasons (27) (This was also a significant issue for several agencies in relation to the advocacy models)
    • There should be a KPI requiring agencies to record the number and nature of issues presented by individuals with disability accessing each agency service, and data would inform the agency of the systemic issues that should be addressed (and what level they should be addressed at) (9)
    • Instead of the current 1.3, 1.3 and 1.4 should refer to referrals to other agencies, with 1.4 focussed on exit procedures and informing people how they can be referred to another agency (or end the association).

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Standard 2: Individual needs

Recommendation: That Standard 2 and KPIs 2.1, 2.2 and 2.3 be adopted as follows

People with disability receive advocacy that is designed to meet their individual needs and best interests.

[Note: The term ‘individual need’ is used in this Standard to cover both the needs of an individual person (that may be met through individual advocacy) and the collective needs of people with disability (that may be met through systemic advocacy)]

2.1 Advocacy objectives are negotiated with the person or people with disability and reflect their needs.

2.2 All advocacy activities reflect and respond to these needs, including opportunities to involve a support person of their choice

2.3 In meeting the needs of a person or people with disability, the advocacy agency will seek to minimise conflict of interest or to deal with it transparently.

Feedback on FaHCSIA’s proposed Standards and KPIs

Standard 2

  • Personal goals a significant number of agencies across the spectrum posed issues with the reference to personal goals (also in the KPIs): (2, 32)
    • some individual’s goals can be unrealistic and some individuals need help in establishing goals as their decision (24)
    • The reference to goals can be confusing, and these goals may not relate to the advocacy needed (17, 35)
    • In case of significant cognitive impairment, who decides on personal goals and priorities? In this case, would advocacy focus on their needs and best interests – who would determine these? (10)
    • It cannot be assumed that needs and goals align – they can be in conflict, and in this case give rise to moral, ethical and practical dilemmas (10)
    • The standards and KPIs must recognise that some people with disabilities cannot conceptualise and articulate their needs and goals – these people may be those in greatest need of advocacy. In the proposed form the KPIs could entail that advocates deal with people with a disability who have more abilities in communicating their needs etc., while those incapable of this may be in greater need of advocacy (15)
  • ‘Meet[ing]’ individual needs ‘promote and protect their individual needs’ (2 18)
    • Agencies are able to ‘respond’ to a person’s needs, but not to ‘meet’ a person’s needs (32)
    • In KPI 2.3 ‘In responding to’ to replace ‘in meeting’ (8, 4, 12, 14, 31, 35)
  • Applicability to systemic advocacy which does not address individual needs but those of the group as a whole. The standard may need rewording to reflect aims of systemic advocacy (40). There should be consultation with people with a disability prior to systemic actions, however, there are other factors that generate systemic advocacy e.g. government driven reviews and policy changes (22); The standard should be renamed as client consultation or ‘meeting the needs of the client’ (not ‘individual needs’) to include systemic advocacy (26)
  • Clarification the agency is uncertain what the term ‘in the least restrictive way’ adds to the standard (32)
  • ...their expressed wishes, needs, and goals’ should replace references to needs and personal goals (26)
  • The phrase ‘in the person’s best interests’ should be added to the standard and make the provision for a support person of choice to accompany the person with disability to advocacy meetings (40)

KPIs 2.1, 2.2, 2.3

  • Avoiding conflict of interest
    • is important, particularly in cases where legal issues are involved – may have implications for an advocate’s professional indemnity insurance (18)
    • Move 2.3 to standard 12 – no one should receive advocacy services where there is a conflict of interest – the person should be referred to another agency (26)
    • 2.3 should read agencies ‘will seek to minimise conflict of interest and to deal with it transparently’ (to replace ‘or to deal with it transparently if it is unavoidable’) (8, 4, 12, 14, 31)
  • Acting on the decisions of people with a disability
    • KPI 2.1: remove ‘and agreed’ (17)
    • It is important to side with the client, but also to base decisions on all available evidence, and the feasibility of outcomes/ courses of action requested by clients must be considered (18)
    • KPIs should be qualified with the phrase ‘as much as (is) possible’ (8, 4, 12, 14, 31, 15, 16, 35)
    • 2.2 should be further qualified ‘activities are designed to reflect...’ or ‘developed to...’ (8, 4, 12, 14, 31, 35)
    • Goals should be planned ‘with the fullest possible involvement of the person...through a collaborative and consultative process’
  • Applicability to systemic advocacy KPIs should refer to clients in plural (26)
  • Advocacy outcomes 2.1 ‘advocacy objectives’ or ‘advocacy goals/objectives’ should replace ‘advocacy outcomes’ (8, 4, 12, 14, 31)
  • Culture, religion and language need to be taken into account in 2.1
  • Alternative and additional KPIs
    • Alternative KPI ‘the advocacy agency shall implement inclusive strategies to meet the needs of people with disabilities’ (2)
    • Alternative KPI related to waiting time ‘All clients will be informed about the time they may have to wait for an advocacy process by letter within five days of making a request for assistance and they will be informed about how and why the decision about their waiting period was made’ (26)
  • Modifications to the KPIs
    • 2.1 should refer to processes ‘advocacy outcomes and processes are...’ then 2.2 would be unnecessary (26)
    • Rather than 2.2 advocacy activities reflecting the person’s goals and needs, advocacy should ‘vigorously defend and promote’ these, as an effort by half measure risks building hope but causing further harm. An additional 2.4 should state advocacy will cause no further harm (34)
  • Additional KPIs for self-advocacy
    • ‘Advocacy outcomes in the provision of self advocacy support must reflect the self determination of the self advocate’ (9)
    • All self advocacy information must be provided in appropriate format accessible to each individual (9)

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Standard 3: Decision-making and choice

Recommendation: That Standard 3 and KPIs 3.1 and 3.2 be adopted as follows

People with disability have the opportunity to participate as fully as possible in making decisions about the advocacy activities undertaken.

KPI 3.1 People with disability are supported to make their own decisions about the advocacy activities they require.

KPI 3.2 The advocacy agency acts upon the choices made by the person with a disability. Where a person with a disability has impaired decision making capacity, ethical guidelines will be used to inform decisions about advocacy activities.

Feedback on FaHCSIA’s proposed Standards and KPIs

Standard 3

  • Applicability
    • Although there must be processes in systemic advocacy for enabling input, there would be difficulties for agencies in ensuring ‘each person with a disability has the opportunity to participate...’ (22)
    • To ensure relevancy systemic and family advocacy the standard should read ‘all person(s) with disabilities and their supporters’
  • People plural so the standard reads ‘people with disabilities (2)
  • Has the opportunity
    • ‘shall have the opportunity’ is more appropriate (2)
    • has opportunities’ is more appropriate (12)
  • Simplify wording ‘advocacy objectives’ should replace ‘advocacy activities undertaken’ (10)
  • Duplication one submission suggested this was already covered in Standard 2, and evidence would be similar (40)

KPIs 3.1, 3.2

  • Duty of care and ‘best interests’
    • It would be difficult to monitor – where decisions present dangers to clients and other duty of care responsibilities may need to be considered (7)
    • In legal advocacy there may be cases where acting in the ‘best interests’ of the client does not necessarily mean doing what the client says. All cases should be assessed on merit. The advocate should discuss and explain with the client, then determine the case plan (18)
  • In cases of impaired decision making capacity (3.2), who makes the judgement that a person’s decision making is impaired? Having an intellectual disability does not automatically entail impaired decision making capacity and there are people who are able to make decisions in some areas of life but not others. (10)
  • Informing
    • The KPIs should refer to acting on the person’s ‘informed decisions’, and an additional KPI should refer to the advocate supporting the person to understand information regarding the advocacy undertaken on the behalf, as the vulnerability of the person must be considered. Duty of care and dignity of risk must also always be considered (34)
  • Influence of decision making both KPIs are applicable, however, suggestions may unintentionally influence individuals goal choice; and if the individual has family members the agency will also consult with them (24)
  • Ethical guidelines (3.2)
    • Would welcome documented procedure outlining required ethical guidelines and associated training (7)
    • The KPI should give clear direction, in cases where a client’s decision making is impaired, with direction based on the South Australian Guardianship and Administration Act (not just reference to ‘ethical guidelines’ informing decisions) this includes reference to consistency with ‘proper care and protection’ (26)
    • FaHCSIA needs to support the Advocacy Sector to develop an agreed ‘Code of Ethics’ (16)
  • Culture, religion and language need to be taken into account in 3.1
  • Alternative and additional KPIs
    • ‘The advocacy effort is discussed and actions are planned in consultation with people with disabilities and key stakeholders (if applicable) to achieve their individual or group objective(s)’ (2)
    • Additional KPI regarding accessibility of information – ‘all self advocacy information must be provided in appropriate format accessible to each individual’ (9)
  • Modifications to the KPIs
    • To account for the notion of possibility 3.2 and 3.3 should be qualified with a phrase such as ‘as much as possible’ (10)
    • 3.1 should be qualified by the phrase ‘as much as possible’ (8, 4, 12, 14, 31, 16, 35) and in 3.2 ‘acts upon the choices made by the person with a disability’ should be qualified with ‘where/ver appropriate and possible
    • advocacy objectives they require’ to replace ‘advocacy activities they require’ (8, 4, 12, 14, 31, 16, 35)
    • The agency acts on ‘decisions’ (as well as choices) (4, 12, 14)

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Standard 4: Privacy, dignity and confidentiality

Recommendation: That Standard 4 and KPIs 4.1 and 4.2 be adopted as follows

The right of people with disability to privacy, dignity and confidentiality is recognised and respected.

4.1 The advocacy agency complies with the Information Privacy Principles of the Privacy Act 1988 in order to protect and respect the rights of people with disability.

4.2 The advocacy agency promotes privacy, dignity and respect for people with disability.

Feedback on FaHCSIA’s proposed Standards and KPIs

Standard 4

  • Only one submission raised with the standard itself or the wording. The agency suggested the following: ‘Each person with a disability is entitled to be treated with dignity and have their privacy and confidentiality acknowledged and respected’, as dignity is crucial to promoting a positive image of people with disabilities and should be acknowledged more clearly (34)

KPI 4.1, 4.2

  • Duty of care there are cases where duty of care may entail some breach of confidentiality e.g. disclosure of the abuse or neglect of children (18, 10). One suggestion was that these instances could be resolved by examining how other professions (such as psychologists and social workers) resolve conflicting interests.
  • 4.1 informed consent a significant number of submissions, predominantly from citizen advocacy agencies (six, with one representing 10 agencies), recommended removing the second sentence that refers to not disclosing information without informed consent (8, 4, 12, 14, 31, 17, 35)
  • Revising 4.2
    • the same agencies recommended revising 4.2 with ‘promotes privacy, dignity and respect’ (or ‘...privacy, dignity and confidentiality’) to replace ‘demonstrates respect’ (8, 4, 12, 14, 31, 17, 35)
    • Another submission suggested 4.2 could currently be interpreted variously, and should instead cover privacy and confidentiality – ‘The advocacy agency will record, maintain and destroy client’s files and all other business documents in accordance with the agency’s Privacy Policy and the requirements of the principles of the Privacy Act 1988’ (26)
    • A KPI should refer to the agency promoting a positive image of people with disabilities in its work (34)
    • The KPI referring to the Privacy Act should also refer to informing the person about their information and their entitlement and access to it.

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Standard 5: Participation and integration

Recommendation: That Standard 5 and KPIs 5.1 and 5.2 be adopted as follows

People with disability are supported and encouraged to participate and be involved in the community.

5.1 Through advocacy, opportunities for participation and involvement in the community are promoted.

5.2 Where appropriate, the advocacy agency takes action to introduce, influence or produce positive systemic change in the community.

Feedback on FaHCSIA’s proposed Standards and KPIs

Standard 5

There were several issues raised in relation to the standard and KPIs. However, there was generally less overlap/ agreement across the issues raised.

  • Changing the standard
    • one agency considered the proposed standard impossible to uphold, suggesting it should refer to community development, not ‘community involvement’ – ‘people with a disability are supported and encouraged to speak up on issues of their concern, to form groups, and to present their issues in the wider community’ (26)
    • Only one other agency suggested changing the standard –‘people with disabilities are supported and encouraged to be involved in the community’ (2)
    • Emphasis on the organisation and advocating – ‘The organisation vigorously and persistently advocates for the participation...’ , as people with disabilities are often denied access to full community involvement and agencies should ensure participation in pursued vigorously(34)
  • Evidence may take a long time to demonstrate, evidence should be of steps/ actions agreed and/or taken towards this goal (40)

KPI 5.1, 5.2

  • Community involvement reporting against 5.1 needs to be flexible to take into account different advocacy services and individual’s contexts e.g. people may visit individual advocacy services only once with a discrete concern; in rural and remote areas fuller access to the community may not be possible. Given this, appropriate evidence for the KPI could be providing an information pack to the client at first contact, with information on service providers and organisations that could assist with participation in community life (28)
  • Budgetary constraints two agencies noted this issue with one suggesting 5.2 should be qualified with ‘where possible’ (26), and the other agency indicating they work with other organisations in handling issues to overcome budget shortfalls (24)
  • Data collection a statistical tool that collates and identifies systemic issues would be valuable in measuring 5.2
  • Producing systemic change in the community a handful of agencies raised issues with this aspect of 5.2 and suggested several alternatives
    • ...actions are intended to bring about change that enhances participation and integration for people with disabilities’ (10)
    • ‘...takes action to introduce, and provide information/links to systemic advocacy that will influence community change’ (16)
    • To qualify the KPI and ensure applicability across the models, the phrase ‘where consistent with its mission’ should replace ‘where appropriate’ (15)
    • In its current form 5.2 confuses the meaning of systemic change, which refers to altering formal structures (e.g. legal), not informal community structures. The two are separate, although advocacy should attempt to do both (10); another agency also removed reference to ‘systemic’ in referring to community change (34)
  • Modifications to the KPIs
    • A number of citizen and one family advocacy agency indicated ‘in every aspect of’ should be removed from 5.2 (8, 4, 17, 14, 31, 32, 35)
    • 5.2 should refer to ‘positive systemic change’ (17, 35)
    • Emphasis on the organisation and advocating – 5.1 and an additional KPI should refer to the activity of the advocates in promoting opportunities for community involvement, and these goals should be documented in vision statement and/ or advocacy plan (34)
  • Alternative KPIs
    • KPI 5.1 should be replaced with ‘The agency’s advocacy program supports the development of consumer groups, self-advocacy groups, and other action groups for people with disabilities. All advocates encourage people with disabilities to speak up for themselves, and to represent the interests of people with disabilities in the wider community by informing clients and members of opportunities to participate in consultations, inquiries, and other events’ (26)

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Standard 6: Valued status

Recommendation: That Standard 6 and KPIs 6.1 and 6.2 be adopted as follows

The intrinsic value of people with a disability is recognised and each person is supported and encouraged to enhance their valued status in the community.

6.1 Through advocacy, the aspirations and strengths of people with disability are promoted.

6.2 The advocacy agency promotes the intrinsic value and the valued status of people with a disability in all its activities.

Feedback on FaHCSIA’s proposed Standards and KPIs

Standard 6

  • Valued status constituted by skill in self advocacy a significant number of agencies from across the spectrum highlighted this issue, and proposed alternative standards
    • Some agencies indicated the two are separate issues (10)
    • One agency indicated feedback from people with a disability showed developing skill in self advocacy can have the opposite effect to giving valued status (26)
    • Another agency indicated that this is not an appropriate measure of valued status, as many people do not have the opportunity or capacity to develop advocacy skills (2)
    • A number of agencies (predominately citizen and Queensland advocacy agencies) proposed the following alternative – ‘the intrinsic value of the/ each person with a disability is recognised and each person is supported and encouraged to enhance their valued status in the community’ (17 32 8 4, 12, 14, 31, 35)
    • Another alternative would be ‘each person with disability has the opportunity to achieve roles in the community that have status and value’ (10)
    • The vulnerable person with disability has the least power to change the way society treats people with disability. This Standard and KPI’S must reflect who takes action to influence change – ‘The organisation will vigorously advocate that the person with disability has the opportunity to develop and maintain skills and to participate in activities that enable him or her to take up valued roles in the community’ (34)

KPI 6.1

  • Demonstrating evidence
    • would be difficult even though the agency encourages self advocacy at all times (7)
    • may take a long time, evidence should be of steps/ actions agreed and/or taken towards this goal (40)
  • Subjectivity ‘status’ and ‘value’ are subjective and this should be reflected in the KPIs (i.e. that the person perceives the roles are valued) (10); ‘status’ and ‘value’ are also interpreted differently in different cultures (19)
  • Modifications to the KPIs
    • Through the advocate’ to replace ‘through advocacy’ in 6.1
    • a number of agencies (predominately citizen and Queensland advocacy agencies) indicated ‘aspirations and strength/s’ should replace ‘abilities, aspirations and resilience’ in 6.1 (17, 8 4, 12, 14, 31, 35)
    • another alternative was ‘...people with disability are provided with opportunities to acquire, enhance or maintain valued roles and valued status within the community’ (32)
  • An additional KPI was proposed by a number of agencies (predominately citizen and Queensland advocacy agencies) 6.2 – ‘the advocacy agency promotes the intrinsic value and the valued status of people with a disability in all its activities’ (17 32 8 4, 12, 14, 31, 35)
  • Alternative KPIs
    • one agency suggested the proposed KPI was too general to provide evidence against, and proposed two new KPIs (26): KPI 6.1 The advocacy agency promotes the abilities of people with disabilities to fulfil valued roles in the community by providing opportunities for participation in the activities of the advocacy program and by delivering training opportunities to gain and refresh skills in the area of advocacy; KPI 6.2 The advocacy agency provides opportunities for people with disabilities to participate on all levels of the decision-making process within the agency and identifies opportunities for clients and members to represent the interests of people with disabilities on other committees and at events organised by the disability sector.
    • Another agency proposed alternative standards, one referring to vigorous promotion of the belief that the person is able to lead a valued life in the community; the second, that agencies take a leadership role in demonstrating to the community the gifts and talents of people with disabilities and how they can be included in valued roles (34)
  • Rearranging the standards KPI 10.1, which refers to self advocacy fits within this standard (16)

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Standard 7: Complaints and disputes

Recommendation: That Standard 7 and KPIs 7.1 and 7.2 be adopted as follows

People with disability who have a complaint or dispute with the advocacy agency, are encouraged to raise it, and have it resolved, without fear of retribution.

7.1 The advocacy agency informs people about how to raise complaints or disputes about any areas of dissatisfaction with the advocacy agency, without fear of retribution.

7.2 The advocacy agency seeks to resolve complaints or disputes raised by people with disability, with access to both internal and external complaints resolution mechanisms.

Feedback on FaHCSIA’s proposed Standards and KPIs

Standard 7

  • Each person a significant number of agencies across the spectrum indicated the standard should refer to ‘each person’ rather than people with disabilities in plural (17, 32, 8, 4, 17, 12, 14, 31, 35)
  • Inverse order a significant number of agencies (predominately citizen and Queensland advocacy agencies) indicated the standard should read ‘Each person with disability who has a complaint or dispute with the advocacy agency is encouraged to raise it and have it resolved without fear of retribution
  • Emphasising the role of the agency – ‘Advocacy organisations must listen to and strive to resolve complaints or disputes raised by people with disability with fairness and equity’ (34)

KPIs 7.1, 7.2, 7.3

  • Combining 7.1 and 7.2 a number of citizen advocacy agencies proposed this change, most suggesting the same version
    • ‘The advocacy agency informs people with disability of how to raise complaints...without fear of retribution’ to replace ‘...encourages the raising of complaints...’ and standard 7.2 which refers to fear of retribution (8, 4, 17, 12, 14, 31, 35)
    • An alternative suggestion was ‘the advocacy agency seeks to reassure people with disability that they need have no fear of retribution in raising complaints’ (16)
  • Informing
    • a number of citizen advocacy agencies suggested agency ‘informs’ people of ‘how to raise complaints’ should replace ‘encourages’ (7.1) (8, 4, 17, 12, 14, 31)
    • Access to information was also important to a self advocacy agency that suggested an additional KPI measuring that ‘complaints and disputes resolution process must be appropriately accessible’ (9)
    • People from non English speaking backgrounds are often not aware of the processes or fear retribution, so an additional KPI should be ‘people with disability are made aware of agency complaint processes, taking account of their culture, religion and language’ (19)
    • Informing clients they can take complaints to an external organisation should be covered in an additional KPI – ‘people with disabilities are encouraged to involve other appropriate agencies, such as the Complaints Resolution and Referral Service or the Abuse Hotline, or our funding body the Department for Family and Community Services and Indigenous Affairs (FaHCSIA) in the resolution process of their complaint should they derive no satisfaction from the grievance procedure with the advocacy agency’ (26)
    • Another agency also recommended a KPI regarding supporting the person to take complaints that cannot be resolved to external organisations, and another that indicates the agency ‘has a clear complaints process and supports...’ (34)
  • Evidence for 7.2 a submission indicated uncertainty regarding how evidence could be measured or what evidence would demonstrate achievement (40)
  • Fear of retribution a few agencies indicated the statement needed qualification that the person has ‘no reason to fear’ (26); or ‘no grounds for fear...’ (as it is not possible to control a person’s emotions). Another agency proposed 7.2 read ‘Each person with a disability is assured there will be no retribution in raising complaints’ (12)
  • A view to service improvement a couple agencies indicated that complaints should be taken in this light and KPIs should refer to this:
    • An additional KPI is needed to show ‘agencies address all complaints seriously, particularly with a view to improving the agency generally and its advocacy activities in particular’ (10)
    • The sentence ‘Everyone is encouraged to come forward with a grievance as this is seen as an opportunity to improve the service’ should be added to 7.2 (26)
  • Modifications and additional KPIs
    • Incorporating agency staff and volunteers as many agency employees and volunteers also have a disability, this should be reflected in the 7.1 – ‘all people with disabilities, volunteers, and employees are encouraged...’ (26)
    • A measurable outcome for resolution timeframe should be covered in 7.3 – ‘the Chief Executive Officer and/or the Chairperson of the Management Committee (or his/her delegate) facilitate the resolution of complaints or disputes within an agreed timeframe’ (26)

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Standard 8: Agency management

Recommendation: That Standard 8 and KPIs 8.1, 8.2 and 8.3 be adopted as follows

Each agency adopts quality management systems and practices that optimise the effectiveness of advocacy for people with disability and facilitates continuous improvement.

8.1 The advocacy agency has clearly stated aims and objectives that communicate to people with disability and other relevant stakeholders the scope and limitations of the agency.

8.2 The advocacy agency has management systems in place that facilitate quality management practices and continuous improvement.

8.3 The advocacy agency is structured and operates independently, in such a way that it is as free as possible from conflicts with the best interests of people with disability.

Feedback on FaHCSIA’s proposed Standards and KPIs

Standard 8

  • Outcomes a significant number of agencies across the spectrum raised issues with the reference to ‘outcomes’ in the standard, suggesting this should be replaced with ‘optimise/s the effectiveness of advocacy’ or ‘optimise effective advocacy’ (17, 32, 8, 4, 12, 14, 31, 35)
  • Changing the standard was suggested by one agency, who indicated that, if the intent is to provide clear and accountable management systems, the following would be appropriate ‘advocacy agencies shall ensure they adopt effective corporate governance through sound policies and practices’ (2)

KPIs 8.1, 8.2, 8.3

  • Conflict of interest
    • A number of agencies proposed the following amendment to 8.3 – addition of the word ‘independently’, so ‘the advocacy agency...operates independently [and] in such a way...’ that it is as ‘free as possible from associations that conflict with the best interests of...’ (replaces ‘...from the interests that conflict with people with a disability’ ) (8, 4,12, 14, 31, 35)
    • one submission indicated 8.3 should require agencies to be ‘free from conflicts of interest’ (26)
    • one submission indicated agencies should be free from the conflict of being a provider of other services so no conflict arises (30)
  • Modifications to the KPIs
    • a number of agencies (mostly citizen advocacy and one family advocacy agency) proposed inverting the word order of 8.1 ‘the advocacy agency has clearly stated aims and objectives that communicate to people with disability and other relevant stakeholders the scope and limitations of the agency’ (8, 4,12, 14, 31, 32, 35)
    • One agency suggested ‘quality management’ and ‘continuous improvement’ can be interpreted variously, so it would be better to refer to specific elements of a quality system in 8.2 – ‘the advocacy agency has management systems in place that enable members to vote for a Board of Directors with office holders who will guarantee adequate financial accountability and reporting to the membership and management which facilitate best practice and continuous quality improvement
    • Rather than ‘management systems’ 8.2 should refer to ‘policies and procedures’ (34)
  • Alternative and additional KPIs
    • One agency suggested using Disability Services Queensland KPI’s ‘8.1 The advocacy agency’s corporate governance structure, values, strategies, objectives and practices demonstrate effective compliance with all relevant legislative, financial, administrative, advocacy performance and delivery requirements’ and ‘8.6 The agency implements and maintains a continuous improvement approach that supports effective processes for advocacy’ (2)
    • Client participation one agency suggested another KPI was needed to incorporate this – 8.4 ‘The advocacy agency commits to an annual strategic planning day and the development of an annual work and business plan together with clients, interested members of the community and other relevant stakeholders’
    • Cultural competence approach at each level of the organisation should be an additional KPI under the standard (19)

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Standard 9: Wages and conditions

Not applicable


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Standard 10: Training and support

Recommendation: That Standard 10 and KPI 10.1be adopted as follows

People with disability are supported to self-advocate, where appropriate.

[Note: Advocacy agencies are not training and support providers. Under some advocacy approaches, training and support is delivered to assist people with disability, either directly or through their family/ citizens, to meet their advocacy objectives]

10.1 The advocacy agency supports the capacity of people with disability to self-advocate.

Feedback on FaHCSIA’s proposed Standards and KPIs

Standard 10

A number of significant issues were raised with this standard by numerous agencies across the spectrum. Responses centred around three main issues

  • Applicability to advocacy
    • Two submissions (one representing 10 agencies) stated that the standard is not relevant to the work of advocacy agencies, with one of the agencies stating in a separate submission that advocates are not training providers (17, 35)
    • Another submission also indicated the standard was not appropriate as it is not in the best interests of people with disabilities. In the proposed form, as it places the responsibility for social change with the most vulnerable person (who is not responsible for society’s mistreatment). It is important that advocacy supports skills development, but it is not typical for service users to undertake advocacy training (34)
  • Applicability to certain advocacy models
    • Two submissions indicated that the standard is only relevant to self advocacy agencies (32, 35)
    • A number of citizen advocacy agencies suggested the phrase ‘consistent with contractual obligations and the purpose of the agency’ should preface the KPI (an alternative suggestion was ‘where consistent with its mission’ (15)), and the same phrase or ‘consistent with the purpose of the agency’ should preface the standard (8, 4, 12, 14, 31, 35)
  • Sufficient resources
    • A couple of agencies emphasised the impact funding has on providing training, suggesting significant or additional resources would be required (22, 24)(note: references to funding in general, and for other purposes, were made by several other agencies)
  • Capacity to self advocate a few agencies indicated that a proportion of clients would not be capable of self advocacy due to intellectual capacity or mental health and would always need someone to advocate on their behalf (18, 15, 35). One of these agencies suggested that supporting people to become self advocates could distort the mission of citizen advocacy (15). Another of the submissions suggested that the KPI and standard should state ‘but not those with impaired decision making capacity for a matter’ (35)

KPI 10.1

  • Consumer representation one agency indicated the need for an additional KPI importance of this as an aspect of empowerment – 10.2 ‘the advocacy agency delivers a consumer representative training program to increase the participation of people with disabilities on decision-making boards and committees’ (26)
  • Additional KPIs
    • One agency suggested a new KPI that had been proposed by other agencies for standard 6 would be appropriate under standard 9 ‘the advocacy agency promotes the intrinsic value and the valued status of people with a disability in all its activities’ (16)

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Standard 11: Staff recruitment, employment, and training

Recommendation: That Standard 11 and KPIs 11.1 and 11.2 be adopted as follows

Each person who has an employment relationship with the advocacy agency has appropriate skills and competencies.

[Note: This standard only relates to paid and unpaid staff who come under the control of the advocacy agency. In citizen and family advocacy, the advocates do not have an employment relationship with the advocacy agency.]

11.1 The advocacy agency ensures that staff have relevant skills and competencies.

11.2 The advocacy agency provides opportunities for the appropriate and continuing training and skills development for each staff member.

Feedback on FaHCSIA’s proposed Standards and KPIs

Standard 10

  • Encompassing all involved
    • Volunteers a number of agencies indicated the standards and KPIs also need to refer to ‘volunteers’. One agency suggested this could be covered with the phrase ‘an employment relationship with the agency’ (2, 10, 17, 26, 35)
    • One of the agencies said those with either operational or governance responsibilities must also be referred to (10)
    • A few submissions (one representing ten agencies) noted that citizen advocates are not employed by the agency and citizen advocacy staff are not advocates (17, 12, 35)
  • Impact on resources
    • several agencies highlighted the funding that would be required for training; some were also concerned with the accessibility of appropriate training. One of the agencies indicated that training should be built into funding agreements and budgets (16, 22, 28, 30). However, another agency suggested the financial impact on training opportunities is minimised by management forward planning (12)
    • another agency noted that training opportunities could impact on advocacy activities (10)
    • one agency suggested the financial impact should be considered in the evidence guidelines (as well as where the training can be sourced)(34)
    • an additional submission also referred to costs associated with training, conferences or bringing in consultants with particular knowledge or expertise. Also that no one course or training is available so often work is around individual clients and their issues (40).
  • Changing the standard
    • One agency suggested using the Disability Standards Queensland version – ‘recruitment, selection and development of paid and unpaid staff ensures that they have the relevant values, skills, knowledge and competencies to support the advocacy provided by the advocacy agency’ (2)
  • Modification to the standard
    • One agency suggested ‘values’ should also be mentioned beside skills and competencies (34)

KPIs 11.1, 11.2

  • Employing people with disabilities
    • one agency suggested the following additional KPI 10.3 ‘the advocacy agency provides the opportunities for employment of staff with empathic attitude toward people with disability’ (i.e. people with disability involved in recruitment process) (9)
    • another agency noted that the KPIs don’t take into account the training and support needed for people with disabilities on Management committees/ Boards (30)
  • Identifying appropriate training for this to occur agencies must be clear about their work and be able to articulate their style and model (34)
  • Modifications to the KPIs
    • One agency suggested 11.1 refer to the process for ensuring staff’s skills – ‘organisation undertakes rigorous recruitment processes and ongoing appraisal to ensure...’ (34)
  • Alternative KPIs one agency proposed the following KPIs (2)
    • 10.1 ‘the advocacy agency maintains documented recruitment practises for all staff (paid, volunteer, permanent or temporary)’
    • 10.2 ‘recruitment, employment and training policies and procedures include position descriptions, roles & responsibilities, staff training & development for all staff’

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Standard 12: Protection of human rights and freedom from abuse

Recommendation: That Standard 12 and KPIs 12.1 and 12.2 be adopted as follows

The advocacy agency acts to prevent abuse and neglect and to uphold the legal and human rights of people with disability.

12.1 The advocacy agency takes all practical and appropriate steps to prevent abuse, neglect and discrimination of people with disability.

12.2 The advocacy agency upholds and promotes the legal and human rights of people with disability.

Feedback on FaHCSIA’s proposed Standards and KPIs

Standard 12

Very few issues were raised with this standard, and those raised were not in opposition to the proposed standard, but suggesting additional components to the standard.

  • One agency suggested it would be good if there was an expectation that reporting on individual advocacy would record attempts to document types of issues being addressed and recommendations for systemic actions that might assist in informing systemic advocacy work (27)
  • One agency indicated that a mechanism for resolving conflicts of interest between a person’s goals and their human rights is necessary. A defined hierarchy of priorities and ethical guidelines would be valuable (10)
  • Another agency suggested education and training on the issues would help ensure the issues referred to in this standard are prioritised (22)
  • One agency suggested reference be made to the UN Convention on Human Rights for people with a disability and state and federal equal opportunity and anti-discrimination legislation, and it would be useful to measure agency’s knowledge of these.
  • One agency suggested the following modification – ‘Advocacy will vigorously expose and challenge the abuse and neglect of people with disabilities and strive to prevent further abuse and neglect of their human rights’

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Feedback on the Evidence Guidelines


Support for the specifically tailored Evidence Guidelines for each of the different models of advocacy

A significant number of agencies from across the spectrum indicated their support the introduction of the specifically tailored evidence guidelines, particularly due to the differences between advocacy models.

Another eight agencies also indicated support for the specifically tailored evidence guidelines with certain provisos, which are outlined below:

  • Flexibility
    • examples are not mandatory or prescriptive; clarify the scope for agencies to modify the guidelines
    • take into account agencies providing a mix of advocacy models to suit individual needs
    • variations will likely be necessary in rural and remote regions
    • agencies operating under the different models may demonstrate conformity differently and this should be outlined in the evidence guidelines (17, 35)
  • Consultation guidelines developed with the agencies
  • Simplicity they must be clear, easily understood and simple to administer (for small agencies)
  • Systemic advocacy evidence in relation to systemic advocacy is harder to collect due diversity and complexity of the work
  • Clarity
    • Some KPIs should be more specific for ease in the provision of evidence (26)
    • Clarify the purpose of data collection so most appropriate data can be collected, whether qualitative or quantitative
    • Guidelines for statistical data e.g. whether several phone calls from one person constitute one case or several
    • Procedures for resolving conflict where it occurs within the standards when different models cross over e.g. where fulfilling a KPI for individual advocacy would conflict with fulfilling a KPI for systemic advocacy.
  • Auditors understanding two agencies indicated that auditors will need significant knowledge of the advocacy models (17, 35)

There were a number of agencies that did not comment on their support or otherwise for the specifically tailored evidence guidelines.


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Ability to provide examples of evidence

A significant number of agencies provided detailed or reasonably detailed examples of evidence their agency could provide for some or all of the KPIs. Approximately seven other agencies indicated that it would be possible for their agency to provide evidence, but only supplied minimal examples. A couple of the agencies (2, 23) indicated that it would be possible to provide evidence, but did not give any examples. One agency (6) providing both individual and systemic advocacy suggested some indicators would be difficult to demonstrate against, except for pointing to a policy or procedure or specific casework examples.

There were also issues raised by a couple of agencies with providing evidence for systemic advocacy. It was claimed that evidence in relation to systemic advocacy is more difficult to collect because the work is complex and diverse (6). Another agency (27) suggested that, in light of the difficulties reporting on systemic advocacy (particularly within the same framework as individual advocacy) a different structure for providing evidence might be appropriate (see attachment 4, section 6.14)

Recommendation 5: That the generic Disability Advocacy Standards and KPIs be accepted within the QA framework and that tailored Evidence Guidelines be developed suitable for each of the advocacy approaches.


Recommendation 6: That a NDAP QA Handbook be prepared and tested as part of the QA trial that incorporates:

  • Characteristics of the six advocacy models currently funded under the NDAP
  • a practical overview of the QA process (a ‘how to’ guide to the audit process and demonstrating conformity with the Standards)
  • a detailed set of evidence guidelines that draws on the feedback from the consultation submissions (see Section 7)

Examples of evidence that may be used in the trial of the NDAP Quality Assurance system, based on agencies suggestions in the consultation papers, are provided here. However, these examples do not represent a definitive list – detailed Evidence Guidelines will be made available in the NDAP QA Handbook. The guidelines will not be prescriptive and agencies will able to provide evidence appropriate to their agency.

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Standard 1

Examples of evidence for Standard 1

All agencies

  • Purpose statement that makes it clear who the agency works with to promote, protect and defend the welfare of and justice for people with disability

Agencies undertaking individual advocacy

  • Observation of entry and exit policies and procedures highlighting non-discriminatory practice
  • Cultural awareness training
  • Agency information highlighting that there are no criteria to exclude people from the agency other than they must meet the funded target group’s criteria
  • Monitoring and review of profile of clients assisted

Agencies undertaking systemic advocacy

  • Established practices and policies for providing information and referrals where individual clients request advocacy
  • Established practices and/or policies for deciding and communicating which systemic issues the agency will work on
  • Established practices and policies of providing people with disability opportunities to contribute to / participate in the prioritising processes that determine which issues receive attention

Agencies undertaking citizen/ family/ self advocacy

  • Established non-discriminatory practices and policies for identifying and/or responding to requests from people with a disability for opportunities to access advocacy
  • Annual protégé recruitment plan that reflects diversity and level of vulnerability of people with disability [citizen advocacy]

Evidence examples indicated by advocacy agencies

A number of agencies suggested the following examples:

  • Entry and exit policies and procedures outline non-discriminatory practice
  • Information kit or protégé handbook distributed to all accessing the services

Other examples:

  • Staff inform service users of entry and exit policies and procedures
  • verbal information provided at initial contact
  • Statistics measuring access based on disability, age, cultural background, and where clients were living (regional, remote or city based)
  • Similarly, review of complaints register (for complaints regarding exclusion)
  • Agencies have regular cultural awareness training (1.1)
  • Examples of means of ensuring equitable access e.g. a single entry point to the service, a 1800 number to access the service (1.2)
  • Letter of engagement (informs client of procedures)
  • ‘Triage approach’ to intake – specific factors considered when assessing the merit of a case
  • All information presented so that people understand are aware that there is no criteria to exclude people from the agency other than they must meet the funded target group’s criteria (1.1)
  • information readily available on waiting times etc., also keeping in mind agencies are not crisis services (1.3)
  • agency monitors entry and exit procedures ensuring equity e.g. on 6 monthly basis
  • client agreement clarifies relationship between service and client, with reference to resources and disbursement of any court fees (‘legal advocacy’)
  • entry and exit procedures articulate ‘relative need’

Self

  • Records kept of number and nature of issues with accessing the service to inform agency of systemic issues to be addressed
  • In cases of waiting list prioritisation methods are transparent
  • Prioritisation of services is explained to the client
  • Options for alternative advocacy services are provided

Systemic

  • Purpose statement that makes it clear that the agency does not work with individual clients
  • Documented policy and procedures for providing information and referrals where individual clients request advocacy
  • Rules and practices for deciding and communicating which systemic issues the agency will work on
  • Evidence of opportunities to contribute to/ participate in the prioritising processes that determine which systemic issues receive attention
  • Examine the selection processes for committees, governance succession planning and the accessibility of forums for consultation.
  • practices that ensure people with a disability and/ or their agents are consulted and kept informed of systemic issues taken up
  • Policies and practices stating the agency does not undertake individual advocacy
  • Statistics of access, based on disability, age, cultural background, and where clients were living (regional, remote or city based);
  • Review of complaints register to assess whether there were any complaints about exclusion.

Family

  • Policy and practices stating that focus is on people with disabilities
  • practices documenting requests for advocacy consistent with vision and mission of the agency
  • written policies and practices of the agency and their target group
  • documents describing the agency’s priority focus areas, which have been informed by stakeholders
  • policies and practices state the agency does not undertake individual advocacy
  • people with a disability and/or their agents invited to participate in policy review

Citizen

A number of agencies suggested the following examples:

  • Annual protégé recruitment plan that reflects diversity and level of vulnerability, and is reviewed annually (or biannually) by management to ensure continued diversity
  • Handbook with explanations of entry and exit procedures distributed
  • Process in place to access those suitable for citizen advocacy intervention
  • Staff proactively seek out people with disability who are unable to access advocacy themselves and who would not otherwise come to the attention of any agency
  • Policies and procedures reviewed annually and people with intellectual disability invited to participate in policy review
  • As much as possible, the Citizen Advocacy agency informs people with disabilities—especially when first recruiting them to be matched with advocates—about the agency’s entry and exit policies.

Other examples:

  • Non discriminatory entry and exit policies and procedures
  • Entry and exit procedures monitored six monthly to ensure equity
  • Purpose statement that makes it clear that the agency staff are not the advocates – rather they facilitate individual clients access to advocates
  • Rules and practices for identifying and/or responding to requests from people with a disability for opportunities to access advocacy
  • Offices clearly identifiable from the street or in a central location
  • Ongoing dialogue with people with a disability about access
  • Information on entry and exit procedures, describing prioritisation, available in plain English
  • policies and procedures for recruitment of protégés demonstrates entry and exit procedures for people with intellectual disabilities
  • Policies and procedures subcommittee has diverse members
  • Variety of means are in place to promote the work of the agency in the community.
  • Staff are initially and directly in contact with the people with intellectual disability at this point.
  • Staff deliberately seek those individuals with intellectual disability who may not otherwise come to the attention of the agency.
  • The office has an answering service, on which CA staff provide their mobile phone numbers for any after hours emergencies.
  • The agency recruits and maintains a ‘pool’ of Crisis Advocates who can be called on to address the urgent need of a person with a disability who does not have a Citizen Advocate.
  • The profiles of people with disabilities receiving advocacy support reflect the entrance criteria outlined in the Service Access Policy.
  • All requests for support of people with disabilities are followed up and people are informed whether or not the agency is able to provide immediate assistance.
  • If immediate support cannot be provided for an individual, his/her name is recorded on the agency’s database and considered in the planning of any new network groups. New groups established (according to available resources) where a cluster of people with disabilities have been identified in the same locality.
  • The number of people with disability involved in the program is determined by available resources, to ensure that the organisation is able to provide appropriate support over the long-term

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Standard 2

Examples of evidence for Standard 2

All agencies

  • Agency policy on conflict of interest
  • Established practices and policies for identifying and transparently dealing with conflicts of interest
  • Management, staff and volunteer training in recognising and dealing with conflicts of interest
  • Examples of how the agency has taken into account the specific needs of people from Indigenous and CALD backgrounds

Agencies undertaking individual advocacy

  • Established practices and policies for identifying, documenting, reviewing and closing individual cases
  • Observations of advocacy plans and activities being developed in partnership with people with disability or their guardians/carers where appropriate
  • Evidence of collecting and reviewing feedback about the extent to which the needs of the person with a disability are being met

Agencies undertaking systemic advocacy

  • Established practices and policies for consulting with people with disability prior to systemic advocacy actions being undertaken on their behalf. In reactive cases (which often require quick responses), evidence that people with a disability and/or their agents have been informed of actions being undertaken on their collective behalf
  • Evidence of reporting of outcomes / review of advocacy process

Agencies undertaking citizen advocacy

  • Established practices and policies for developing confidential individual written profiles detailing ‘need’ and seeking advocates based on their skills in relation to these needs
  • Observations of individual being given opportunity to discuss their draft profile
  • Details of completed relationships, and/or those being rematched or awaiting rematching
  • Established practices and policies for reviewing the extent to which the needs of the person with a disability are being met

Agencies undertaking self advocacy

  • Client Action Plans showing links between identified needs and personal goals
  • Observations of the development of Client Action Plans being client led

Evidence examples indicated by advocacy agencies

A number of agencies suggested the following examples:

  • agency operational policies include conflict of interest procedures
  • demonstrated evidence that advocacy plans and activities have been developed in partnership with people with disability
  • Relevant policies and procedures

Other examples:

  • case file should have evidence of partnership with the client. However, agencies should not be tied down by complicated evidentiary documents or formal procedures to confirm this.
  • Evidence of documented mandate of clients;
  • Evidence of ongoing consultation with clients;
  • Evidence of directives given by clients and followed by an advocate;
  • Reports of outcomes to clients.
  • Vision statement (or similar) outlines advocacy goals and strategies
  • Reports of review of advocacy goals and strategies.
  • Persistence in the face of adversity – e.g., following up phone calls with a letter, raising issues repeatedly if needed
  • Advocacy outcomes discussed at initial contact point before referral (2.1)
  • All actions clearly note whether it is person’s choice or a recommendation (2.2)
  • Outcomes negotiated and agreed to by the person (2.2)
  • If advocate unable to assist as much information as possible given to ensure the person aware of the risks, etc (2.3)
  • Client referred to alternate staff member or agency if necessary (2.3)
  • The organisation is consumer managed and the Board consists substantially of people with a disability, demonstrating consultation in all aspects of work
  • Developed and evaluated information and advocacy plans that reflect process of and agreements for advocacy (2.1)
  • Feedback and discussion as part of advocacy process – issues identified are recognised and addressed immediately (2.2)
  • Service user informed of conflict of interests as soon as it appears/ is recognised (2.3)
  • Measures put in place to minimise conflict of interest to ensure positive outcomes (2.3)
  • Client advocacy plan signed by legal practitioner and client (‘legal advocacy’)

Self

  • Client Action Plans show link between needs and personal goals, show goal reviews, are client led, and are signed by the client (clients encouraged to bring support person if their wish) (2.1)
  • Staff trained in ‘conflict of interest’, and procedures for obtaining alternative advocate followed where conflict identified (2.3)

Systemic

  • demonstrated evidence that people with disability have been consulted prior to systemic advocacy actions being undertaken on their behalf.
  • Evidence of consultations with client groups
  • Evidence of reporting of outcomes and review of advocacy process
  • Policies and Procedure Manuals
  • In reactive cases (which often require quick responses), evidence that people with a disability and/or their agents have been informed of actions being undertaken on their collective behalf, and in proactive cases, that they have been consulted prior.

Family

A number of agencies suggested the following example:

  • demonstrated evidence about how the best interest of a person with a disability is determined when advocates work directly with family members of the person with a disability.

Citizen

A number of agencies suggested the following examples:

  • Policy and procedures to assess individual need – e.g. process includes speaking to client and, where possible and appropriate, family and service providers involved
  • Confidential individual written profiles detail ‘need’ and advocates are sought and matched based on their skills in relation to these needs [and individual given opportunity to discuss their draft profile]
  • Adherence to principles of citizen advocacy including program independence
  • Established ‘meeting individual needs’ policy [and procedures]
  • Advocates have no conflict of interest (and are not matched if they do
  • Prior to matching, all new Citizen Advocates are carefully oriented about the needs of their particular protégé, and possible ways to address those needs

Other examples:

  • demonstrated evidence about how the best interests of people with disability are determined when paid coordinators work directly with volunteer advocates.
  • Annual relationship reviews and regular follow up with advocate to identify changing needs of the person with a disability
  • Future Citizen Advocate recruitment is based entirely on the individual needs of the person with intellectual disability.
  • Where protégés are unable in any way to express their needs or wishes, staff will carefully assess and determine these, through a process of observation and speaking to any concerned parties in the person’s life.
  • Citizen advocates supported (follow along) to support clients changing needs in most timely and effective manner
  • unpaid ‘Advocate Associates’ - people who have skills, professional expertise and experience in areas where an advocate may have little knowledge - who offer advocates the benefit of their knowledge, their advice and support to maximise the response of the advocate to their protégé’s needs.
  • Advocates supported to maintain independence from parties in the protégé’s life to ensure minimal conflict
  • The agency is not allied to any organisation which directly provides a service to any of its protégés, ensuring minimal conflict of interest
  • A preliminary consultation is carried out with the person with a disability, family and/or carer to identify and define his/her individual needs and personal goals.
  • Registration Forms record necessary information and document individual needs before each person with a disability is matched with his/her personal advocate, and advocate matched on this basis.
  • Fortnightly reviews, conducted within the network groups, look at each person’s most pressing/changing needs and evaluate how well those needs are being addressed by the advocate. Support is provided for the advocate as and when needed.
  • Formal reviews are carried out on an annual basis, with input from the person with disability, his/her family or carer, and other concerned parties.
  • Further enrichment training is provided for network group leaders and advocates to enhance the quality of their advocacy intervention.
  • Input is sought from family members, carers and other concerned parties, where appropriate, but advocates provide support that is always in the best interests of the person with disability, not the other parties.

A query was raised as to why Evidence for citizen and family advocacy (unlike the other models) refers to ‘best interests’, who would determine best interests was questioned.


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Standard 3

Examples of evidence for Standard 3

All agencies

  • Code of Practice or Ethics Guidelines for supporting people with disability in making decisions about advocacy activities
  • Observations of the way advocates interact with people with disability in making decisions about advocacy activities
  • Established practices and policies for determining a decision on behalf of person who has impaired decision making capacity e.g. consultation with them, documenting factors taken into account including knowledge gathered over time
  • Evidence of the involvement of people with disability in agency decision-making (e.g. representation on the Board)
  • Evidence of the involvement of people with disability involvement in all aspects of the quality system (e.g. participation in internal audits)

Agencies undertaking individual advocacy/citizen advocacy

  • Observation of information, strategies and ideas presented in ways that the person is able to understand
  • Observation of regular review processes to confirm the advocacy actions reflects the person’s choices and decisions
  • Feedback from service users

Agencies undertaking systemic advocacy

  • Established practices and policies whereby people with disability are consulted prior to systemic advocacy actions being undertaken on their behalf, where appropriate and feasible
  • Observations of individual people with disability becoming involved in systemic advocacy activities of their choice

Agencies undertaking family advocacy

  • Established practices and policies for sending clear and consistent messages to family members about discussing advocacy action with the person with a disability

Evidence examples indicated by advocacy agencies

A number of agencies suggested the following examples:

  • Agency operational policies align with the Convention of the Rights of People with a Disability (CRPD)
  • Demonstrated process to determine a decision on behalf of person who is unable to make informed decision and articulated values base for process e.g. consultation with team, knowledge gathered overtime, cultural valued norm

Other examples:

  • Information, strategies and ideas presented in ways that the person is able to understand (e.g. plain English used)
  • Client signs Client Action Plan
  • Evidence of documented mandate of clients
  • Evidence of ongoing consultation with clients
  • Evidence of directives given by clients and followed by an advocate
  • Reports of outcomes to clients.
  • Policies and Procedure Manuals
  • Use of ethical guidelines demonstrated (in cases of limited decision making capability)
  • Client receives information package on legal rights, the law and the legal system (‘legal advocacy’)

Self

  • Information, strategies and ideas presented in ways that the person is able to understand (e.g. plain English used)
  • Options and consequences are discussed and explored prior to final decisions being made
  • Staff are trained in the use of the Capacity Toolkit (Attorney Generals Dept)

Systemic

A number of agencies suggested the following examples:

  • demonstrated evidence that people with disability have been consulted prior to systemic advocacy actions being undertaken on their behalf, where appropriate and feasible.
  • Evidence that people with a disability and/or their agents have been consulted prior to actions being undertaken on their collective behalf

Other examples:

  • Individual given the ability to become involved in systemic activities of their choice through appropriate consultation processes, or even having the choice to participate in the first place through the acquisition of appropriate skills through capacity building activities.
  • Evidence of reporting of outcomes and review of advocacy process.
  • Policies and Procedure Manuals

Family

  • Policy guidelines encourage family members to discuss advocacy action with the person with a disability

Citizen

A number of agencies suggested the following examples:

  • Established decision making policies and procedures
  • draft client profile discussed with person [and/or their family or guardian] for consent where possible/ appropriate
  • citizen advocate to follows decisions currently being made by the client where possible/ appropriate [this is outlined during orientation and encouraged during follow along]
  • Advocate consults with and encourages person in making decisions as much as possible
  • In cases where decision-making capabilities are impaired, established procedure and ethical guidelines are demonstrated

Other examples:

  • Final decision made by the person with a disability or their legal guardian
  • Opportunity given to accept or reject appointed advocate
  • Protégés who are able to express their needs are asked whether they would like a Citizen Advocate; if they are unable to express their preference, this will be decided by staff in consultation with any concerned parties in the protégé’s life.
  • Where protégés have a decision making disability, staff, together with any concerned parties in the protégé’s life, will make careful decisions and choices, based on what is assessed to be in the best interests of the protégé.
  • Where protégés have a decision making disability, Citizen Advocates will make decisions based on the perceived best interests of the protégé, in conjunction with other concerned parties in the protégé’s life who also have this focus.
  • Advocate provides the relevant opportunities and proportionate assistance for the person with the disability to make decisions by him/herself.
  • The Citizen Advocacy agency orients and sensitises the advocate to the primacy of acting in the best interests of the person with the disability, most notably in those instances where the welfare of the person with the disability is demonstrably jeopardised by his/her decision, due to an impaired decision-making capacity.
  • 3.1 The focus of advocacy should remain the individual – measures needed to ensure families don’t take over the process. Service users decisions could be ticked off regularly on a consultation sheet
  • 3.2 Where necessary the agency applies for a guardian or administrator to ensure family or staff do not compromise choices when the person has impaired capacity to make decisions on their own behalf and the families or staff interests are in conflict with the service user
  • policies and procedures enhance the right and ability of each person with a disability to exercise as much control as possible over his/her life. Everything is offered by invitation, encouraging personal choice while recognizing personal readiness.
  • structured format provided within each group gathering to ensure each person with a disability has the opportunity and support needed to make informed decisions and choices.
  • The leaders/facilitators of each network group liaise with advocates on a regular basis to see that each person with a disability is encouraged to make choices about preferred activities and relationships, and to learn the consequences of such choices.
  • Every effort is made to ensure the person with disability is able to comprehend and express choices. Training is provided for advocates to enhance the quality of support they are able to offer in this area.
  • Where appropriate, PAS staff and/or advocate inform the person with a disability of other services that may meet his/her needs.

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Standard 4

Examples of evidence for Standard 4

All agencies

  • Observations of the way advocates and agency staff talk and write about people with a disability
  • Clear privacy policy ensuring that decisions relating to privacy are made in the best interests of the person with a disability
  • Established practices and policies for obtaining consent where relevant and possible
  • Confidential information safely stored e.g. locked filing cabinets
  • Staff [and volunteers and contractors] sign confidentiality agreements
  • Provision of information about privacy in information kits or brochures to service users

Agencies undertaking individual advocacy/citizen advocacy

  • Feedback from service users about the attitude of agency staff to people with a disability
  • Feedback from service providers on the attitudes of the advocacy agency to people with disability
  • Feedback from service users

Agencies undertaking systemic advocacy

  • Language used in reports to describe people with disability
  • Feedback from stakeholders on the attitudes of the agency to people with disability

Agencies undertaking family advocacy

  • Established practices and policies for sending clear and consistent messages to family members about discussing advocacy action with the person with a disability

Evidence examples indicated by advocacy agencies

A number of agencies suggested the following examples:

  • Observations of the way agency staff talk and write about people with a disability (in individual advocacy)
  • Privacy policy and approach to ensuring that decisions relating to privacy are made in the best interests of the person with a disability
  • privacy and confidentiality policies and procedures
  • Demonstrated process to obtain consent where possible e.g. signed consent forms (consent forms kept up to date)
  • Information safely stored e.g. locked filing cabinets [and service user informed of this]
  • Verbal discussions held as privately as possible [in space chosen by the service user] (4.1)
  • Staff [and volunteers and contractors] sign confidentiality agreements
  • Provision of information about privacy in information kits or brochures to service users (4.1)

Other examples:

  • Demonstrated use of positive language and image promotion.
  • Documented policies and practices coherent with Privacy Principles
  • Agency file documentation
  • Authority to release information form signed by the client (‘legal advocacy’)

Self

  • Ensure informed consent to act as an advocate is obtained, with client aware of their rights and consequence of any consented disclosure (4.1)
  • Verbal discussions held as privately as possible (4.1)
  • The agency informs the self advocate about information recorded during self advocacy procedure, and the individual information collected during the advocacy procedure must be acknowledged as the property of the individual.

Systemic

A number of agencies suggested the following examples:

  • The language used in reports to describe people with disability
  • feedback from stakeholders on their attitudes to people with disability

Other examples:

  • performance against this standard might be measured by the way in which committees and other consultations are governed.
  • Policies/Training Manuals;
  • File Management, entries into files, culling of files;
  • Complaints Registers to ascertain whether there have been any breaches of privacy.
  • Commitment to upholding of privacy as stipulated in the Act in agencies policies and procedures
  • Policy and practice related to privacy in the best interests of person with a disability
  • Materials reflect inherent dignity of people with a disability

Family

  • Commitment to upholding of privacy as stipulated in the Act in agencies policies and procedures
  • Policy and practice related to privacy in the best interests of person with a disability
  • Materials reflect inherent dignity of people with a disability

Citizen

A number of agencies suggested the following examples:

  • Established privacy [dignity and confidentiality] policy and procedures
  • Signed consent obtained from all individuals in the program, or where this is not possible, consent from family or guardian sought where possible
  • [following orientation] Advocates, staff and Board members required to complete confidentiality agreement (4.2)
  • Person’s identity protected unless consent given in a signed form. Where this is not possible, attempts made to gain consent from family or guardian where possible and staff are discerning and sensitive about what information is passed on (4.2) (this includes use of information or photos of individuals in newsletters)

Other examples:

  • Observations of the way the advocate and person with a disability interact and talk
  • Information about the person kept confidential in line with the Privacy Act
  • 4.2 During Orientation and follow along, Citizen Advocates are orientated and reminded to be very sensitive about respecting the privacy, dignity and confidentiality of their protégé at all times
  • Staff document the minimal amount of information necessary to meet the unmet needs of the protégé. Both protégé (where possible) and citizen advocate are made aware of this and of their right to access this. Their permission will be sought before giving any such information to anyone else.
  • A/A
  • Uses positive images/language in all materials
  • Before any information about a person with disability is passed on to another individual or agency, consent is always obtained, either through personal agreement with the person with disability/family member/carer or through written consent when and where it is required.
  • Recorded information is regarded as strictly confidential and will only be used for planning and review purposes.
  • To ensure that all recorded data is accurate and up to date; an individual printout is distributed to all people with disability/ families/ carers and all advocates every three years. Each person is asked to verify the accuracy of the data and state whether or not they are comfortable with the information that has been recorded in their name.
  • Permission is always sought from individuals (both people with disability and advocates) where photographs are being used in promotion of the service.
  • When publishing information about the activities of the agency, it is customary to use first names only in the ‘human interest stories’ that are used to highlight the effectiveness of the program.

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Standard 5

Examples of evidence for Standard 5

All agencies

  • Purpose statement that makes it clear that the agency seeks to promote participation and integration
  • Examples of barriers to community participation raised with service providers and systemic advocacy agencies
  • By modelling acceptance and valuing people with disability in all advocacy activities

Agencies undertaking individual advocacy

  • Examples of activities and issues that the agency engages in that support participation in community life
  • Examples of referrals of issues to systemic advocacy agencies

Agencies undertaking systemic advocacy

  • Periodic reports of systemic advocacy activities

Agencies undertaking citizen advocacy

  • Examples of activities service users and advocates are involved in – while recognising that the citizen advocates and the person with a disability make their own decisions outside of the control of the funded agency
  • Observation that community participation is covered in citizen advocate orientation

Evidence examples indicated by advocacy agencies

A number of agencies suggested the following examples:

  • ‘Mission Statement’ or ‘Statement of Purpose’ and other relevant documentation of the advocacy agency
  • Examples of barriers to community participation raised with service providers and systemic advocacy agencies
  • Review of file notes to demonstrate the strategies and goals for addressing barriers to community participation
  • Examples of activities agency engages in that support participation in community life e.g. programs (5.1)

Other examples:

  • Individual vision statement/plan describes valued roles and interests
  • Demonstrated knowledge of person’s community, local services etc.
  • Reports and reviews of training programs or community education participation
  • Client evaluations about community education programs
  • service users encouraged and supported sit on steering committees relative to the systemic activities associated with their needs (5.1)
  • Individual advocacy agencies need to ensure appropriate referral, follow up and support to any systemic agency if they have requested that an issue be pursued on a systemic level in the community (5.2)
  • evidence of steps/ actions agreed and/or taken towards this goal
  • documented evidence of trends in advocacy that can be shared with other agencies to inform systemic advocacy (‘legal advocacy’)

Self

  • Networks established to support community participation
  • Networking with other agencies to promote change (5.2)
  • Issues identified through client experiences/ consultation reported to relevant bodies (5.2)
  • The abilities of people with intellectual disabilities to be self advocates are promoted as a positive example to the community (5.2)
  • Production of ‘Plain English’ products to increase the ability of people with intellectual disabilities to participate in the community (5.2)
  • Provision of training to community and mainstream organisations to increase their disability awareness and understanding (5.2)
  • Supports individuals with intellectual disabilities to take part in systemic advocacy action (5.2)

Systemic

  • Quarterly reports of systemic advocacy programs

Family

A number of agencies suggested the following example:

  • Vision and Mission Statements or other relevant documentation of the advocacy agency

Other examples:

  • Demonstrated examples of the activities the agency engages in that encourage this Standard

Citizen

A number of agencies suggested the following examples:

  • Examples of activities service users and advocates are involved in (while recognising that the citizen advocates and the person with a disability make their own decisions outside of the control of the funded agency)
  • Community participation covered in citizen advocate orientation [and in advocate’s handbook]
  • Advocates encouraged to be involved in activities in the community with the person and to involve others from their network in the person’s life, where appropriate, and supporting evidence collected
  • Established participation and inclusion policy (5.1)
  • By modelling acceptance and valuing their protégé in public, and by insisting on such valuing treatment towards their protégé by members of the public, Citizen Advocates positively influence community attitudes.

Other examples:

  • The inclusion of a citizen advocate in the person’s life is in itself a valuable tie
  • Advocates encouraged to create opportunities for protégés to participate in community life that are appropriate to the person’s needs and interests
  • Workshops conducted for advocates, family members and carers – creates awareness in the community about the need for change
  • The link to a Citizen Advocate in a long term relationship inevitably facilitates involvement in the community.
  • Established Citizen Advocates are advised of opportunities for community involvement which come to the notice of the office that might be appropriate for their protégé.
  • All Citizen Advocates are reminded, encouraged and supported, through the newsletter, through support meetings and during regular support calls (follow along), to look for new opportunities to engage and involve their protégé in the community.
  • All Citizen Advocates are encouraged, during Orientation, to consider membership of voluntary associations concerned with class advocacy on behalf of people who share their protégé’s disability (5.2)
  • When necessary, a Citizen Advocate will, with the encouragement and support of the CA office, take appropriate action to strongly advocate at the highest levels of government for changes in the system (5.2)
  • Citizen advocates are not generally involved in systemic change but they can influence community attitudes (5.2)
  • Advocates ensure that any publicity is dignified and valuing (5.2)
  • Citizen advocacy agencies maintaining contact with, and giving our moral support to agencies which specialise in systemic advocacy (5.2)
  • Agency policies e.g. a policy on participation and integration outlines the way in which group leaders and advocates work towards optimum participation and integration in the community for each person with a disability.
  • Each person with a disability is linked with a community friend/ advocate who provides support to enable integration in the life of the community.
  • Agency activities e.g. regular network group gatherings and outings that expose each person to a variety of new activities and opportunities for them to develop new skills and form new friendships. Other opportunities follow as a result of these friendships.
  • Careful preparation and planning prior to community venture to reduce the anxiety of the person with a disability to ensure a positive experience for everyone involved – person with a disability, advocate and the other people in the community.
  • Group leaders and advocates work together to identify appropriate community activities for people with disability to be involved in, taking into account one’s degree of readiness.
  • Information about appropriate community services, facilities and events are provided regularly through the network group gatherings and newsletters to advocates/ families.

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Standard 6

Examples of evidence for Standard 6

All agencies

  • The way people with disability are referred to in agencies promotional material and reports
  • Public speaking at conferences, lectures and professional gatherings to promote a positive image of people with disabilities
  • Observations of the practices used by the advocacy agency in undertaking its work
  • Examples of issues raised with service providers and systemic advocacy agencies

Agencies undertaking individual advocacy

  • Examples of activities and issues that the agency engages in that support the valued status of people with a disability
  • Examples of referrals of issues to systemic advocacy agencies

Agencies undertaking systemic advocacy

  • Periodic reports of systemic advocacy activities

Agencies undertaking citizen advocacy

  • Examples of activities service users and advocates are involved in that promote the intrinsic value and the valued status of people with disability– while recognising that the citizen advocates and the person with a disability make their own decisions outside of the control of the funded agency
  • Observation that valued status is covered in citizen advocate orientation

Evidence examples indicated by advocacy agencies

A number of agencies suggested the following examples:

  • ‘Mission Statement’ or ‘Statement of Purpose’ of the advocacy agency
  • Promotional material, reports, issues advocates for/ against
  • Observations of the practices used by the advocacy agency in undertaking its work

Other examples:

  • Demonstrated advocacy efforts to include people with disability in valued roles in work, education and recreation
  • Strengths based approach in casework model
  • Reports and reviews of training programs or community education participation
  • Client evaluations about community education/development programs,
  • Direct case advocacy to support the participation of individuals in their community
  • The production of self advocacy tools, such as ‘how to’ publications or items like the BCA Identity Card, which promotes both the perception and reality of independence
  • Facilitating member meetings and conferences for peer support and positive role modelling
  • Online mailing lists for peer support, positive stories and self advocacy
  • With support, guidance and back up the service user is encouraged to take on some of the advocacy tasks themselves
  • evidence of steps/ actions agreed and/or taken towards this goal
  • Client advocacy plan (‘legal advocacy’)

Self

  • Training provided in response to consumes needs and interests, service focussed on client’s identified goals

Systemic

  • Media and communications, such as press releases, newsletters and radio shows which positively promote people with disabilities
  • Public speaking at conferences, lectures and social gatherings to promote a positive image of people with disabilities
  • Policy development and high level lobbying as a result of feedback from members on issues affecting their independence and dignity
  • Disability awareness training provided to organisations to promote the needs of people with disabilities
  • Quarterly reports of systemic advocacy programs

Family

  • Vision and mission statements and other documentation
  • Examples of activities agency engages in that encourage this standard

Citizen

A number of agencies suggested the following examples:

  • The person’s aspirations promoted by the way the advocate talks and relates to the person (6.1)
  • How the Citizen Advocate promotes the person with intellectual disability in the community
  • Citizen advocate involves the individual in their life, where appropriate, which will broaden their social and support networks and thereby increase their opportunities to achieve a variety of valued roles
  • Agency’s location, activities and promotional images to promote valued status
  • Establishment of one-to-one relationship with unpaid citizen is a valid way of promoting the valued status of people with a disability (who might otherwise be seen in a negative light by a devaluing society)
  • Established policy on valued status
  • New Citizen Advocates are orientated and supported to develop and act on a vision with/ for their protégé that will promote the participation of their protégé in activities designed to enhance their confidence, skills and personal well being and allow them to establish a variety of valued roles in society

Other examples:

  • The longevity of the relationship with the advocate.
  • the way Citizen Advocates can adapt to their own changing circumstances (or those of the person with intellectual disability) without it affecting their commitment to the person with intellectual disability.
  • All established Citizen Advocates are reminded through the newsletter, through support meetings and during follow along, to be alert to the possibilities of enhancing their protégés image in every possible way in the community
  • Advocates look for opportunities to encourage and support their protégé in the maintenance of established skills, abilities, aspirations and resilience and the development of new skills
  • All Citizen Advocates are orientated and encouraged to support their protégé to advocate for themselves where possible and appropriate.
  • Staff are also very conscious that any Citizen Advocates recruited should have valued roles in society which will reflect well on their protégés.
  • The agency makes a considered and conscious effort to avoid associating people with disabilities with any negative images or stereotypes which might devalue them and aims to provide a societal model for the promotion of the intrinsic value of people with disabilities.
  • Evidence of support for Self Advocacy Groups
  • The agency recognises that a person’s own self-worth may be dependent on how well he/ she fits into roles that are valued by the community.
  • Each person with a disability is encouraged, through the advocate, to participate according to his/her ability.
  • Activities of the agencies e.g. when people with disabilities are introduced to new activities the advocate encourages them to ‘have a go’ and ‘test the water’ within that supportive environment. As the person’s confidence develops encouraged to participate in similar activities in the wider community, particularly where those activities are valued by other members of the community.
  • Effort made to identify the types of activities that a person enjoys and for which he/ she displays a degree of competency.

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Standard 7

Examples of evidence for Standard 7

All agencies

  • Documented complaints policy and procedures
  • Established practices and policies for investigating and resolving complaints – cover both internal and external complaints resolution mechanisms, including the Complaints Resolution and Referral Service (CRRS)
  • Observations and file review of the processes used in investigating and resolving complaints
  • Established practices and policies for promotion of complaints mechanism
  • Reviews of complaints mechanism involving service users to ensure mechanisms are appropriate to potential complainants
  • Staff attributes to complaints and disputes
  • Service user feedback about the complaints mechanism
  • Complaints register

Evidence examples indicated by advocacy agencies

A number of agencies suggested the following examples:

  • Established complaints policy
  • promotion of mechanism for making complaints that is appropriate to potential complainants

Other examples:

  • Documented complaints process, also available in alternative formats as necessary
  • Knowledge provided of external complaints processes
  • Complaints policy and procedure made available on sign up (7.1)
  • communication with other agencies to ensure service user has support to make complaints about their agency (7.1)
  • Service users heard and responded to in professional manner, all issues treated as important and relevant (7.2)
  • complaints procedure followed in timely manner (7.3)
  • All issues or complaints taken seriously and referred to appropriate person for investigation (7.1)
  • Offer of an alternative advocate when available (7.1)
  • Tool for quality improvement, allowing concerns to be raised anonymously (7.2)
  • Clearly documented procedures for complaints handling and resolution, including timeframes and appeals/ review mechanism (7.2)
  • Clients provided with the agency’s Client service charter, which informs them of their rights, services available etc.
  • Maintenance of a Complaints Register;
  • Examples of dealing with a grievance (paper trail)
  • Minutes of meetings to resolve a grievance
  • Clients have no fear of retribution in making a complaint
  • Agencies seek to resolve issues in a timely manner.

Self

  • complaints procedure given to all clients in plain English/ pictorial framework
  • Encourage involvement of support people
  • Complaint received with attitude of service improvement (7.2)
  • Time frame for response to complaint given (7.3)

Family

  • Complaints policy and procedure in place and updated regularly
  • Clients have input into the complaints and disputes policy of the agency

Citizen

A number of agencies suggested the following examples:

  • Established complaints and disputes policies and procedures (that clearly outline independent complaints mechanism)
  • Policies and procedures actively applied (7.1, 7.3)
  • The individual, or where this is not appropriate, a family member or guardian, is given appropriate version of policies and procedures (e.g. plain English, multi-lingual, audio)
  • Service users, or where this is not appropriate, a family member or guardian, is informed who to speak to in raising a complaint (7.1)
  • Citizen Advocates support their protégés in raising raise complaints.

Other examples:

  • Policies and procedures are transparent
  • Staff and Board encourage people to complain if unsatisfied with the program
  • Newsletters and other general correspondence outline complaint mechanisms
  • People with an intellectual disability and their advocates encouraged to raise
  • Agency emphasizes that complaints will not result in retribution of any kind.
  • Any complaints are be taken seriously and investigated within an agreed time-frame.
  • All incidents are handled promptly and discreetly to reach a resolution.
  • If the complaint cannot be resolved internally, an independent negotiator will be brought in.
  • Issues and concerns are usually dealt with informally as part of the fortnightly network group review. If further action is needed, the group leader liaises with an agency staff member and a course of action is determined.
  • Complaints and dissatisfaction voiced handled with respect and confidentiality.
  • Fortnightly Review Sheets are used to record any changes that the advocates notice in their friend’s demeanour or any issues the person is facing at the time. On their own Review Sheet, Group Leaders keep a record of issues that are raised and dealt with at network group level.
  • Group Leaders are encouraged to inform staff of any ‘differences that are occurring in the lives of their friends with disabilities or in the relationships between advocates and friends. These matters are then recorded on a central file that can be accessed at a later date for reporting purposes or for tracking a rise in dissatisfaction

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Standard 8

Examples of evidence for Standard 8

All agencies

  • Documented agency aims and objectives
  • Established practices and policies for promotion and communication of agency aims and objectives with service users and stakeholders
  • Reviews of agency management systems involving service users – including documented annual internal audits and continuous improvement plans
  • Clear governance arrangements
  • Established practices and policies for performance and risk reporting to the governing body
  • Documented policy on agency independence
  • Agency management and staff can provide practical examples of how they operate to ensure they are as free as possible from things that conflict with the best interests of people with disability
  • Evidence of the involvement of people with disability involvement in all aspects of the quality system (e.g. participation in internal audits)
  • Minutes of management committee meetings
  • Documented roles and responsibilities of management committee office bearers

Evidence examples indicated by advocacy agencies

  • Fully developed policies and procedures
  • Policies and procedures indicate scope and limitation of the agencies
  • Evidence of training/ policy and procedure manuals for employees, volunteers and Board members
  • Annual governance training for Board members and staff
  • Participation of stakeholders in the Strategic Plan encouraged
  • Systems in place to monitor and review management and advocacy systems.
  • These issues (of the standard) should be part of an organisation’s strategic plan
  • Written information and brochures are clear and accessible to the target group (8.1)
  • Information storage and retrieval, policies, procedures and relevant information for service users should be accessible and useful to people with a disability first and foremost (8.2)
  • Minutes of Board meetings and AGMs
  • Monthly financial Reports, quarterly financial reports to FaHCSIA
  • Minutes and Reports of annual planning days
  • Annual audits reporting on quality improvement
  • Client feedback
  • Rigorous staff recruitment processes
  • Appraisal processes
  • Performance reports and plans
  • Documenting service management systems, policies and rocedures (‘legal advocacy’)

Self

  • Objectives available in plain English (8.1)
  • policies, procedures and training on conflict of interest (8.3)

Family

  • training for managerial staff and Board/ Committee in governance and management practices
  • vision and mission statements or other documentation
  • agencies do not undertake any direct disability service provision
  • agencies’ and Board’s and Committee’s structure demonstrates understating of conflict of interest and importance of independence from direct service delivery

Citizen

A number of agencies suggested the following examples:

  • Documents including statement of aims, policy and procedures manual, agency’s constitution, citizen advocacy handbook for advocates, guides for protégés
  • The agency’s aims [and objectives and limitations] clearly stated in documentation e.g. Policies and Procedures, Mission Statement, Constitution, Strategic Plan, manual, Handbooks, Annual Reports etc
  • Internal and external evaluation procedures in place (8.2)
  • Quality management practices and procedures in place and documented [procedures in place for anyone entering the Program in a management capacity be it Board or staff] (8.2)
  • The agency abides by founding principles of Citizen Advocacy including Advocate and Program Independence as the basis for minimising conflict of interest.
  • Annual self-regulating review processes for the Board (8.2); or Biannual Board of management composition audits
  • Long-term planning incorporating means for development (e.g. of program staff and Board) (8.2)
  • Annual reviews of: programs aims and objectives; policies and procedures
  • Board of management manual and Board of management roles and responsibilities for all new members
  • Stated policy, using ethical guidelines, regarding prior employment history of prospective employees, where there may be a potential for conflict of interests with clients of the advocacy agency

Other examples:

  • internal program review; annual program planning; quality improvement audit; participate in annual disability services assessment
  • Orientation covers understanding of conflict of interest
  • Established policy for program management
  • Stated policy of how conflicts of interest are managed at the level of the Committee of Management/ Board of Directors
  • Stated policy on conflict of interest issues that may arise in situations where more than one person with a disability is involved, e.g. where 2 people with disability are in an intimate relationship, and advocacy issues arise that affect the relationship
  • Stated policy on appropriate relationships for advocacy agency employees with clients and workers in the service provider sector for clients
  • Processes for continuous re-evaluation of staff and activities ensuring opportunities for improvement procedures to be put in place e.g. training and self assessment
  • Training by those experienced in delivering good citizen advocacy is invited in by the Board whenever available, finances permitting
  • Board members have opportunities, and are encouraged, to take part in evaluations of other programmes to study their practices, their strengths and weaknesses and the consequences of these
  • Annual board reviews are conducted, in which the Board evaluates the agency’s performance in all areas over the past year, assesses progress on past goals and formulates new ones.
  • An annual Match review is conducted, during which board members can become more familiar with matches and provide guidance to staff in improving the quality of matches;
  • Board members are encouraged to attend training on SRV and PASSING to become more aware of the bleakness of situation of many people with disability and thence inspire them to deliver a more effective service
  • The agency is careful not to ally itself in any way with, or even to have an implied association with, any service provider which provides a direct service to the agencies clients, to minimise any conflict of interest.
  • The agency maintains appropriate cover for Public Liability, Professional Indemnity and Volunteer Accident Insurance.
  • effort to ensure there is at least one qualified ‘First Aider’ in each network group at any one time, the agency provides opportunities for a number of volunteers to complete a Senior First Aid qualification each year.
  • Policy that explicitly states the requirements of ‘Duty of Care’ carefully balanced against the ‘Dignity of Risk’ that enhances personal growth.
  • A Volunteer Handbook provides all program participants with relevant information that they may need to fulfil the requirements of their role and to ensure the highest possible standard of ‘behaviour’ in their relationship with their friend with disability.

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Standard 10

Examples of evidence for Standard 10

All agencies

  • Agency promotional material that makes it clear the extent, if at all, the agency provides training and support
  • Established practices and policies for supporting people with disability where they want to self-advocate

Agencies undertaking self-advocacy

  • Established practices and policies for developing the capacity of people with disability to self-advocate

Agencies undertaking citizen advocacy

  • Established practices and policies for developing the capacity of protégés to assist people with disability meet their advocacy objectives

Agencies undertaking family advocacy

  • Established practices and policies for developing the capacity of family members to assist people with disability meet their advocacy objectives

Evidence examples indicated by advocacy agencies

  • empowering individuals to do as much as possible for themselves, and show effective advocacy processes so they could self advocate in the future
  • Evidence of training programs
  • Feedback of clients and participants of training sessions
  • Evidence of accessibility of information
  • Examples of clients and/ or volunteers being supported as consumer reps.
  • developing information kits could be useful
  • Supporting and encouraging services users to learn self advocacy skills built into service provision
  • The organisation demonstrates clear understanding of the values, skills and competencies required
  • Identifying training as part of appraisal processes

Self

  • self advocacy skills developed through identification of individual goals, relevant training, involvement in management
  • clients consulted about training topics
  • focus on development of a full understanding of rights, responsibilities and consequences
  • utilisation of other training options relevant to individuals goals
  • policies acknowledge that all people can learn to self advocate to some degree with appropriate support given to enable this
  • appropriate training opportunities provided

Systemic

  • Evidence of training programs
  • Feedback of clients and participants of training sessions
  • Evidence of accessibility of information
  • Examples of clients and/or volunteers being supported as consumer reps
  • ongoing consumer input into strategies and activities

Citizen

Numerous agencies noted that, consistent with contractual obligations, no training for self-advocacy is provided. One agency suggested the standard would be more appropriate as ‘...supported to self-advocate and linked into self advocacy groups’. Agencies also noted the potential impact of the standard on resources – some agencies may not be able to provide support and training.

However, a few of the agencies outlined the following

  • orientation guides advocates not to be socially over-protective and to guide, encourage and support their protégés to exercise their rights and speak up for themselves [or be as independent as possible], should this be possible and/or appropriate
  • Established Citizen Advocates are supported in follow along to maintain and develop the capacity to self-advocate in any protégés who are able
  • The agency does not provide specific self advocacy training, but such ‘training’ happens on an informal basis as advocates guide, encourage and support their friends with disabilities to express their needs and desires in whatever way they are able.
  • Advocates work at developing the trust and confidence of their friends with disability before encouraging them to participate in community activities that are ‘valued’ by other members of the community. When the people with disability are seen in valued roles, they enhance their own standing within the community.
  • Advocates strive to develop a sense of ‘self-pride’ in their friends with disabilities by ensuring they are appropriately dressed when out and about in the community and that their standards of personal hygiene and behaviour are such that other members of the community will not be offended in their presence.

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Standard 11

Examples of evidence for Standard 11

All agencies

  • Current list of all people who have an employment relationship with the advocacy agency
  • Position descriptions of all paid and unpaid staff that describe skills and competencies needed for the advocates role
  • Established practices and policies for recruitment & induction that ensure paid and unpaid staff have the necessary skills and competencies for their position, including relevant qualification (where appropriate)
  • Annual staff appraisals conducted
  • Training and development plans for all staff

Agencies undertaking citizen advocacy

  • Independent evaluations of practices for developing the capacity of citizen advocates to assist people with disability meet their advocacy objectives

Evidence examples indicated by advocacy agencies

A number of agencies suggested the following example:

  • Consideration is given to what ongoing training may be necessary (11.1 and 11.2)

Other examples:

  • agency ensures advocates have minimum level of training and monitor this (11.1 and 11.2)
  • Agency’s staff recruitment policy and procedure.
  • recruitment and selection procedures
  • induction (subject to budget constraints)
  • opportunities given to visit other agencies
  • Skill registers of employees and volunteers
  • Position description on recruitment reflect skills and what is needed for the advocates role (11.1)
  • Skills developed on an ongoing basis (11.1)
  • Documentation of opportunities provided for training/ skills development
  • Budget allocations made for training and appropriate pro bono assistance sought (legal advocacy)
  • Policies and procedures including for staff recruitment, employment and training and staff supervision and appraisal (legal advocacy)

Self

  • recognises the particular skills/life experience that people with intellectual disability bring to the service, and employs them whenever deemed suitable. The agency also recognises their needs and ensures appropriate support and training

Systemic

  • Skill registers of employees and volunteers

Family

  • Budget line item for training for staff and Board or Committee
  • Recruitment processes indicate commitment to skill and competency development

Citizen

A number of agencies suggested the following examples:

  • Staff supported to attend workshops and national citizen advocacy events (11.2)
  • Staff opportunities to attend values based training (11.2)
  • Established policy for staff recruitment, employment and training, procedures and reviews
  • Staff encouragement and given opportunities to visit other Citizen Advocacy Programs, be involved in their evaluation [programmes to study their strengths and weaknesses and the consequences of these]

Other examples:

  • Staff encouraged to visit other citizen advocacy programs and be involved in their evaluation (11.1 and 11.2)
  • Established staff selection protocol
  • Annual staff appraisals conducted
  • Staff given continuing training opportunities and other training opportunities arise as needed
  • Staff are encouraged to attend training on SRV and PASSING (11.2)
  • Staff regularly avail themselves of various opportunities for free training, e.g. Dementia, Communication with People with Disabilities, Negotiation Skills etc.
  • Training by those experienced in delivering good Citizen Advocacy is invited in by the Board whenever available, finances permitting
  • Staff members are in frequent contact with other CA programmes for advice and suggestions;
  • Qualifications prior to appointment [and demonstrated experience at a level that will ensure they are able to carry out their role of recruiting, training and supporting volunteer advocates].
  • Skills and experience through workplace mentoring
  • Rigorous screening procedures are in place to ensure the quality of volunteers who are offered placements as advocates for vulnerable people with disabilities.
  • Orientation and on-going training provided for all employed staff and volunteers of the agency.
  • The Executive Director oversees an annual ‘Performance Development’ process designed to enhance the level of competency of all employed staff. Where a need is identified, staff are encouraged to partake in further Professional Development training.
  • Network group leaders gather with their volunteer advocates on a fortnightly basis for a review session that is focused on the progress (or otherwise) of both the friends with disability and the advocates. Where issues are brought to the surface, the group leader provides guidance and support.
  • If the matter cannot be adequately dealt with at group level, the matter is referred to one of the PAS support staff who work with the individual or group until a satisfactory outcome is achieved.
  • Staff and volunteers are offered opportunities to participate in relevant professional development training that is available in the community.

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Standard 12

Examples of evidence for Standard 12

All agencies

  • Staff knowledge and skills in recognising and report criminal activities, abuse and neglect
  • Agency management and staff can provide practical examples of how they act to prevent abuse and neglect – including seeking out people with disability who are abused or neglected and who would not normally come to the attention of other agencies [e.g. outreach programs]

Evidence examples indicated by advocacy agencies

A number of agencies suggested the following example:

  • staff have knowledge and skills in recognising human rights indicators, and reporting criminal activities, abuse and neglect [evidence could be established through interviews]

Other examples:

  • Agency aware of the appropriate legislation
  • Agencies should encourage the Federal government to ratify the UN Charter and systemically encourage legislation and activities that reflect this charter’s intent.
  • Links with appropriate agencies (12.1)
  • Appropriate training to enhance knowledge and understanding (12.2)
  • complaints register
  • legal client database, including data on legal advocacy activities undertaken (legal advocacy)

Self

  • Staff training
  • Appropriate action taken in cases
  • Participates in suitable systemic advocacy, and research projects providing input from people with intellectual disabilities

Family

  • Documents demonstrating commitment to this standard
  • Staff training in processes for reporting breach of the standard
  • Orientation for new staff

Citizen

A number of agencies suggested the following examples:

  • Outlined in the advocate orientation and/or orientation handbook (12.1)
  • Relevant material published in newsletters [and media] and discussed with advocates (12.2)
  • Established policy for protection of human rights and freedom from abuse
  • Agency seeks out people with disability who are abused or neglected and who would not normally come to the attention of other advocacy agencies [e.g. outreach program] – a unique and powerful response to the recognition of the vulnerability of people with disabilities to abuse and the knowledge that this is frequently hidden from, and invisible to, the public
  • The very presence of a concerned and vigilant Citizen Advocate in the life of a vulnerable person has the power to prevent abuse and/or discrimination.

Other examples:

  • Additional agency policies related to the ‘Recruiting, Screening and Training of Volunteers’ and ‘Duty of Care and Dignity of Risk
  • The agency adopts stringent procedures for the recruiting, screening and training of all potential volunteer advocates detailed in their policies.
  • Outreach projects targeting people in vulnerable situations
  • Orientation and training, newsletter, handouts and videos, guest speaker presentations
  • An Advocate Associate has been recruited with specialist expertise in Disability Discrimination.
  • people with disabilities who are vulnerable or abused are carefully matched with concerned, resourceful Citizen Advocates who have the appropriate attitudes, understanding and skills to prevent the abuse and neglect of their protégés
  • Newly matched Citizen Advocates are encouraged, supported and guided by the office to provide effective advocacy for their protégé to ensure the abuse and neglect does not continue;
  • Any indication of abuse or neglect which surfaces during follow-along by the staff with established Citizen Advocates is discussed and the advocates are encouraged and supported to take action to ensure the abuse and/or neglect is prevented
  • The agency office recruits, trains and maintains a ‘pool’ of unpaid Crisis Advocates who are on hand to attend to urgent abuse or neglect of protégés who have not yet been matched with a Citizen Advocate, or whose advocate is unable to attend to such issues immediately for any reason.
  • Should it be deemed necessary, in order to effectively protect a protégé with a decision making disability from abuse or neglect, Citizen Advocates are supported to take out formal guardianship of their protégé
  • All new Citizen Advocates are clearly orientated regarding the legal and human rights of people with disability and the urgent need to speak up in order to uphold these
  • Citizen Advocates are oriented to remind service providers, should this be necessary, of the rights of people with disability and of their protégé in particular
  • New Citizen Advocates are oriented to remain constantly alert and vigilant to any indications of abuse and neglect and are supported to take action immediately should this be necessary to uphold their protégé’s rights
  • The agency consistently promotes the legal and human rights of people with disability in the literature it disseminates to the public
  • Citizen Advocates are available after hours to provide advocacy if this is necessary.
  • Volunteers who take on the additional responsibility of network group leadership are required to undergo more extensive training.
  • The two leaders of each network group are responsible for overseeing the relationships that develop between the advocates and people with disability in their network group. They are obligated to report to the Executive Director if they have any concerns at all about a particular relationship.
  • Enrichment training is provided at regular intervals to ensure that advocates have the necessary understanding and skills to be able to identify and prevent abuse and/or neglect of their friend with disability.
  • The agency provides one-to-one advocacy support for people with intellectual disability who are vulnerable and at risk of exploitation from other members of the community.
  • Any indication of abuse or neglect is reported immediately to the Executive Director of the agency and procedures are activated to further investigate the situation.
  • Where abuse or neglect has been known to occur, the advocate is supported through the process of reporting it to the relevant authorities.
  • All volunteer advocates are constantly reminded, through their network group gatherings, of the need to promote and uphold the legal and human rights of vulnerable people with disability.

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General evidence examples

A number of agencies did not propose evidence related to each specific KPI, but suggested evidence that could be used generally in structuring the evidence guidelines.

Evidence (predominately for individual advocacy)

  • An Advocacy Plan which details strategies for the achievement of consumers’ goals and the addressing of barriers is developed in partnership with consumers.
  • Plans are signed off by consumers
  • relevant statistical data
  • exit evaluation surveys by clients (as a performance indicator)
  • Issues presented by service users usually are resolved within a short period.
  • Goals are established to reflect consumers’ needs and personal goals.
  • Options given to service users so they can make informed decisions.
  • Communication Plans are developed to address updated individual needs, and these plans are reviewed on a regular basis
  • Advocates and service users work until the issues are resolved to the service user’s wishes.
  • Service users provided with information about their rights.
  • The agency promotes disability awareness issues through community education, consumer training sessions and the annual celebration of the International Day of People with a Disability.
  • Specific policies and procedures related to the Standards and KPIs
  • Written file note kept for all requests for assistance. Reasons noted for any refusal of service
  • Advocates are required to identify any potential conflict of interest they may have with particular clients. Any conflicts identified and actions to redress the conflict will be noted in the client file.
  • Register of complaints, which includes details of follow up action
  • Strategic and Business Plans
  • Staff files including training plans.
  • Case files, which includes supporting documents, consent forms, agreements etc.

Self

  • One agency suggested the evidence guidelines for Business Services with some minor changes would be applicable to advocacy services e.g. client rather than worker/ employee (and apply to KPIs 1.1, 1.2, 2.2, 2.3, 3.1, 4.1, 4.2, 7.1, 8.1, 8.2, 11.1, 11.2, 12.1, 12.2)
  • Issues presented by service users usually are resolved within a short period.
  • A Plan of action may or may not be developed in partnership with the consumers and the consumers carry out the majority of the actions, with the aim to empower consumers to self advocate.
  • Advocates provide options with sufficient information to support those options.
  • Communication Plans are developed to address updated individual needs and those plans are reviewed on a regular basis
  • Advocates and service users work until the issues are resolved to the service user’s wishes.
  • Advocates make referrals and provide consumer training sessions.
  • Consumers provided with information about their rights.
  • The agency promotes disability awareness issues through community education, consumer training sessions and the annual celebration of the International Day of People with a Disability

Citizen advocacy

  • Advocacy Plans
  • Entry Documentation
  • Access to policies and procedures, as currently expected from Disability Service Providers
  • Consumer Information through: Handbooks, Information Kits, Brochures
  • Interviews and documented results to assess whether beneficial outcomes resulted from advocacy

Systemic advocacy

A number of agencies referred to difficulties in evidence collection for systemic advocacy (particularly within the same framework as individual advocacy).

One agency suggested that, in light of these difficulties, a different structure for providing evidence might be appropriate. The structure could look at 1) issue being addressed 2) proposed action plan 3) strategies employed 4) outcomes/milestone achievements, and would be informed by a checklist of evidence indicators, for example, the one outlined below.

For outputs:

  • Evidence of written action plan
  • Media coverage of issue
  • Meetings with key stakeholders in the issue
  • Forums/workshops conducted to promote and progress the issue
  • Campaign materials produced
  • Direct action events – protests, demonstrations etc.
  • Other (never underestimate creativity in this area)

For Outcomes:

  • Policy position changed or improved
  • Reduction in demand for individual advocacy in relation to this issue
  • Strategic relationships/partnerships established
  • Milestones achieved (particularly as this work can take years to achieve the desired outcomes.

Other agencies suggested the following evidence:

  • Agencies could be required to record progress notes in relation to their systemic advocacy activities.
  • The agency liaises with relevant peak bodies if state or national issues are involved.
  • Goals are established to reflect the change or changes of rules, systems or legislations that are desired.
  • An action plan which details strategies for the achievement of the goal is developed in partnership with consumers.
  • Communication Plans are developed to address updated plans and they are reviewed on a regular basis
  • Advocates and consumers work until issues are resolved to consumers’ wishes.
  • Service users are provided with information about their rights and relevant legislation.
  • The agency promotes disability awareness issues through community education, consumer training sessions and the annual celebration of the International Day of People with a Disability.

Disability services Queensland

Some of the evidence used in Queensland standards includes:

  • Procedural guidelines outline the criteria for selecting people who will receive advocacy and describe the process for identifying needs and involving people (and/or their representatives) in the development of advocacy strategies.
  • Documented procedures for information dissemination and communication that assist the person who needs advocacy to engage people of their choice in the planning process.

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Support from FaHCSIA to ensure that the Disability Advocacy Standards and KPI’s are accessible to people with disability

A significant proportion of the agencies made suggestions as to how FaHCSIA could assist with the accessibility of the standards and KPIs. A number of the suggestions were mentioned by several agencies:

  • Develop information in various accessible formats to all people with disabilities (including intellectual disabilities and print disabilities) (printed, audio, online, Braille)
    • One agency offered for the documents to be scrutinised by a group of their members with an intellectual disability (9)
    • Another agency suggested responses of the blind and vision impaired could be sounded out at their national conference (25)
    • Another agency suggested providing funding so they can make available literature in appropriate formats showing how the agency adheres to the standards and KPIs (11)
    • Another agency suggested use of pictures to communicate information about the standards (36)
  • Plain English version of the standards, possibly with illustrations (to ensure people with intellectual disabilities and limited capacity can understand them)
    • One agency offered to assist FAHCSIA in this and in developing suitable illustrations. The agency has produced a set of 11 Standards Posters for its office, using photographs to illustrate each standard, which clients find more interesting (20)
    • Another agency also offered assistance (26)
  • Ongoing consultation face to face, and ongoing opportunities for discussion/ feedback (2, 8, 12, 14, 29)
  • Website funding
    • A couple agencies suggested funding for their websites (13, 27), one indicated the funds would make a sound file of the standards available of their site
    • Another agency suggested the standards be available on a website that all advocacy agencies would promote to consumers and other stakeholders (24)
    • Availability of the standards in electronic format on websites that can be read by screen readers – as not all agencies have websites, FAHCSIA could make this available (26)
  • Resources to promote the standards
    • Might include booklets or posters available from FaHCSIA’s website. DSQ have developed resources and these may be useful rather than replicating other modes (2)
    • Generic materials provided e.g. advocacy sector posters and pamphlets, signature /logo (16); a standard brochure for use across the program that sets out what expectations, rights and responsibilities are in place for people with disability using the advocacy support (27)
    • Develop an Information Package in appropriate formats for people with disabilities to be disseminated by advocacy agencies (24)
  • Funding for information sessions or workshops/ presentations , particularly in regional and sub-regional areas (6, 24)

Other suggestions were:

  • Mentors to assist agencies in planning and implementation stages (2)
  • promote clarity in advocate’s role (2)
  • Community open days – supporting the agency to attend more community open days and fairs (13)
  • Reporting processes to ensure access for people with disabilities to the standards (21)
  • Training package FaHCSIA could develop a standardized national consumer training package to be delivered/ presented regularly by disability agencies to their consumers and other stakeholders (initial training for all agencies provided by FaHCSIA) (24)
  • Multilingual standards available
  • Communication channels one agency indicated willingness to assist FAHCSIA to promote the Standards and KPIs through their communication channels including radio and mailing lists (25)

Recommendation 7: That FaHCSIA develop a set of resources to ensure the Disability Advocacy Standards and KPIs are accessible to people with disability. Resources should include:

  • The standards in various accessible formats, including Braille, audio and Plain English
  • The standards in electronic format, for example, on FaCHSIA’s website
  • Posters and/or pamphlets regarding the Standards.

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Attachment 1: Suite of Consultation Papers

CHANGES TO THE NATIONAL DISABILITY ADVOCACY PROGRAM CONSULTATION PAPER

OBJECTIVES & PRINCIPLES

INTRODUCTION

The intent of the Objectives and Principles is to support and guide the change process by providing:

  • A mechanism for the Australian Government to communicate its intended outcomes for the program which also captures some of the priorities identified by the disability advocacy sector.
  • A structure to guide the changes to the program and the implementation of the Budget measure to ensure that the needs of people with disability, the disability advocacy sector and the Australian Government are met.

OBJECTIVES FOR CHANGE PROCESS

To enhance the efficiency of the NDAP and the effectiveness of funded agencies in order to:

  1. Meet the advocacy needs of people with disability.
  2. Develop the capacity of NDAP funded agencies to respond to the advocacy needs of people with disability.
  3. Meet the performance and accountability needs of the Australian Government.

PRINCIPLES FOR CHANGE PROCESS

In order to meet these objectives, the changes to the NDAP will be based on the principles below.

For people with disability

  1. People with disability receive advocacy support appropriate to their needs (i.e. culture, disability type, gender) to address and prevent disadvantage including instances of discrimination, abuse and neglect.
  2. People with disability receive advocacy support that is timely to address and prevent instances of disadvantage including discrimination, abuse and neglect.
  3. People with disability have increased access to individual advocacy services.

For NDAP funded agencies

  1. NDAP funded agencies are supported to increase their capacity to respond to the advocacy needs of people with disability.
  2. NDAP funded agencies with specialist expertise (i.e. expertise in servicing cultural groups, particular disability types etc) are supported to share this knowledge with the disability advocacy sector.
  3. NDAP funded agencies are supported to deliver advocacy accountably and to continually improve quality.

For FaHCSIA

  1. FaHCSIA works in partnership with NDAP funded agencies to implement the NDAP changes.
  2. FaHCSIA supports collaboration between NDAP funded agencies as part of the NDAP changes.
  3. FaHCSIA draws on the knowledge and expertise of people with disability and the disability advocacy sector to guide the NDAP changes.

NEXT STEPS

FaHCSIA will be seeking agreement about the proposed Objectives and Principles from its funded advocacy agencies and disability peak bodies at the information and consultation sessions taking place in February and March 2008.

Should your agency wish to provide FaHCSIA with additional feedback, please send your comments by Friday 2 April 2008 to:

E-MAIL disabilityadvocacy@facsia.gov.au (preferred method)

POST FaHCSIA Advocacy Reforms & Management Section, Disability Policy & Coordination Branch, TOP-CE3 Box 7788 Canberra Mail Centre ACT 2610

FAX 02 6244 8499

Responses limited to two pages are appreciated. Thank you for your feedback.

ADVOCACY MODELS – WORKSHEETS

CITIZEN ADVOCACY

Summary of Feedback

A number of citizen advocacy agencies raised concerns about the characteristics of the model provided in FaHCSIA’s consultation paper that relate to friendship. The following description has been developed based on feedback received from citizen advocacy agencies and the definition provided by the International Citizen Advocacy Safeguards Group in 1992.

General Description

Citizen advocacy seeks to support people with an intellectual disability by matching them with volunteer advocates on a one-to-one basis. Citizen advocates are encouraged to represent the interests of a person with a disability as if they were their own and be free from conflict of interest. Citizen advocates are supported by a paid coordinator who manages the citizen advocacy office. Some of the matches made may last for life.

Functions

  • Seeks out people with an intellectual disability who are isolated with no family or community supports and networks.
  • Educates people with disability about their rights.
  • Recruits, trains and provides ongoing support (i.e. ‘follow-along’) to volunteer advocates.
  • Matches volunteer advocates to people with an intellectual disability (also called protégés).
  • Influences community attitudes towards people with disability.

Treatment or Prevention?

Both. Citizen advocates work with people with disability to treat specific instances of discrimination, abuse and neglect as they occur. Citizen advocates also seek to prevent discrimination, abuse and neglect from occurring through maintaining an ongoing relationship with a person with a disability.

Who Undertakes the Advocacy?

Volunteer advocates who are matched up on a one-to-one basis with a person with an intellectual disability.

What is the Advocates Role? Is it Paid or Voluntary?

The advocate’s role is to support the person with a disability on a long term or ongoing basis. The advocate may advocate on behalf of the person with a disability or provide support to enable the person with a disability to advocate for themselves.

The advocate is a volunteer and the coordinator of the citizen advocacy office, who supports the advocate, is a paid worker.

Who is Assisted?

A person with an intellectual disability on a one-to-one basis (i.e. each advocate is matched up with a single person with a disability).

INDIVIDUAL ADVOCACY

Summary of Feedback

There was general agreement about the characteristics of the individual advocacy model that were provided in FaHCSIA’s consultation paper.

General Description

Individual advocacy seeks to uphold the rights and interests of people with all types of disabilities on a one-to-one basis by addressing instances of discrimination, abuse and neglect. Individual advocates work with people with disability on a short-term and issue-specific basis.

Functions

  • Works with people with disability requiring one-on-one advocacy support either by referral or by direct contact being made by a person with a disability.
  • Develops a plan of action (sometimes called an individual advocacy plans) in partnership with the person with a disability that map out clearly defined goals.
  • Works through the individual advocacy plan in partnership with the person with a disability.
  • Educates people with disability about their rights.
  • Influences community attitudes towards people with disability.

Treatment or Prevention?

Primarily treatment. Individual advocates work with people with disability to address specific instances of discrimination, abuse and neglect as they occur. Individual advocacy also has a secondary preventative impact by assisting people with disability to better understand their rights and developing their capacity to advocate on their own behalf.

Who Undertakes the Advocacy?

Formal individual advocacy is undertaken by a paid advocate employed by an advocacy agency. Informal individual advocacy is undertaken on a voluntary basis by a family member or a friend.

What is the Advocates Role? Is it Paid or Voluntary?

The advocate’s role is to work with a person with a disability on a short-term or issue-specific basis to address specific instances of discrimination, abuse and neglect. The individual advocate will act on behalf of the person with a disability and also support the person with a disability to advocate on their own behalf.

Where individual advocacy support is formal, the advocate is employed by the advocacy agency to advocate on behalf of the person with disability. Where individual advocacy support is informal, a family member or friend advocates on a voluntary basis on behalf of the person with a disability.

Who is Assisted?

A person with a disability on a one-to-one basis. Paid individual advocates can support more than one person with a disability at a time.

FAMILY ADVOCACY

Summary of Feedback

A number of responses recommended combining family and parent advocacy models to remove confusion. The broader description of family advocacy was felt to be more appropriate as family members, other than parents, may also advocate on behalf of the family member with disability. These other family members may include siblings, grandparents and members of the extended family. It was also recommended that since the target group of the NDAP is people with disability, the terminology ‘parent advocacy’ may create confusion as to who the client of an advocacy service actually is.

General Description

Family advocacy works with parents and family members to enable them to act as advocates on behalf of a family member with disability. Family advocates work with parents and family members on a short-term and issue-specific basis. Family advocates work within the fundamental principle that the rights and interests of the person with disability are upheld at all times.

Functions

  • Works with a parent or family member requiring advice and advocacy support either by referral or by direct contact being made.
  • Develops networks of parents and family members of people with disability to support the advocacy efforts of parents and family members.
  • Educates a parent or family member about the rights of people with disability.
  • Influences community attitudes towards people with disability.

Treatment or Prevention?

Primarily treatment. Family advocates works with parents and family members on a one-to-one basis to address specific instances of discrimination, abuse and neglect as they occur.

Family advocacy also has a preventative effect through the development of networks of parents and family members to share information, ideas and strategies.

Who Undertakes the Advocacy?

The parent or family member of a person with a disability.

What is the Advocates Role? Is it Paid or Voluntary?

A paid advocate provides advice and support to a parent or family member of a person with a disability. The parent or family member then advocates on a voluntary basis on behalf of a person with a disability.

Who is Assisted?

The parent or family member is directly supported by a family advocacy agency to advocate on behalf of a person with a disability. Family advocates can support more than one parent or family member at a time.

Family advocacy may also assist family members if the interest of the person with a disability is aligned with the interests of the family.

SELF ADVOCACY

Summary of Feedback

There was general agreement about the characteristics of the self advocacy model that were provided in FaHCSIA’s consultation paper.

General description

Self advocacy supports people with disability (predominantly people with an intellectual disability however there are a number of NDAP funded agencies that provide self-advocacy to people with other types of disability) to advocate on their own behalf or on a one-to-one or group basis.

Functions

  • Develops the personal skills and self-confidence of people with disability to enable them to advocate on their own behalf.
  • Educates people with disability about their rights.
  • Influences community attitudes towards people with disability.

Treatment or Prevention?

Primarily prevention. Self advocacy agencies work with people with an intellectual disability on a one-to-one or group basis to educate them about their rights and support them to advocate on their own behalf. By supporting people with an intellectual disability to advocate on their own behalf, they are better able to recognise and address specific instances of discrimination, abuse and neglect as they occur.

Who Undertakes the Advocacy?

The person with a disability on their own behalf.

What is the Advocates Role? Is it Paid or Voluntary?

The advocate is paid by the advocacy agency to support people with disability to advocate on their own behalf.

Who is Assisted?

A person with a disability on a one-to-one or group basis. Paid advocates that work in a self advocacy agency can support more than one person with a disability at a time.

SYSTEMIC ADVOCACY

Summary of Feedback

A small number of agencies provided feedback regarding the characteristics of the systemic advocacy model. This feedback has been incorporated into the following revised description of systemic advocacy.

General Description

Systemic advocacy seeks to influence or secure positive long term changes that remove discriminatory barriers to ensure the rights and interests of groups of people with disability are upheld.

Functions

  • Pursues positive changes to legislation, policy and service practices in partnership with groups of people with disability, advocacy agencies and other relevant organisations.
  • Educates people with disability about their rights.
  • Influences community attitudes towards people with disability.

Prevention or Treatment?

Both. Systemic advocates seek to address discriminatory barriers and attitudes to produce long-term positive changes for people with disability.

Who Undertakes the Advocacy?

Systemic advocates and policy officers that are employed by advocacy agencies and disability peak bodies.

What is the Advocates Role? Is it Paid or Voluntary?

The advocate is paid by the advocacy agency to seek long-term positive changes for groups of people with disability.

Who is Assisted?

Groups of people with disability.

LEGAL ADVOCACY

Summary of Feedback

It is proposed that legal advocacy be identified as a formal model of advocacy. Legal advocacy is about people with disability receiving legal advice and representation from a lawyer or other suitably skilled individual who has knowledge of disability and the legal issues that impact people with disability. This specialist assistance is generally not available through the legal system.

General Description

Legal advocacy seeks to defend the rights and interests of people with disability on a one-to-one basis through the Australian legal system.

Functions

  • Provides legal representation for people with disability as they come into contact with the criminal justice system.
  • Pursues positive changes to legislation for people with disability.
  • Educates people with disability and their families about the legal system and their rights.
  • Influences community attitudes towards people with disability.

Prevention or Treatment?

Predominantly treatment however legal advocates may also work in partnership with systemic advocates to push for broader legislative and policy change.

Who Undertakes the Advocacy?

A lawyer or individual with appropriate legal knowledge.

What is the Advocates Role? Is it Paid or Voluntary?

The legal advocate is paid by the advocacy agency to represent the person with disability in a legal environment or assist the person with disability to understand their legal rights.

Who is Assisted?

A person with a disability on a one-to-one basis.

NATIONAL DISABILITY ADVOCACY PROGRAM QUALITY IMPROVEMENT CONSULTATION PAPER

DISABILITY ADVOCACY STANDARDS & KEY PERFORMANCE INDICATORS

INTRODUCTION

The 2007-08 Australian Government measure provides funding for the introduction of an independent third-party Quality Assurance system for advocacy agencies funded under the National Disability Advocacy Program (NDAP).

A key feature of the system is the development of a set of Disability Advocacy Standards and Key Performance Indicators (KPIs) which agencies will need to be certified against as a future condition of funding. The revised implementation timetable provides agencies with two and a half year years to achieve certification.

The purpose of these Standards is to introduce a minimum set of performance requirements for NDAP funded agencies. The Standards aim to establish what is expected of funded advocacy agencies by government and the department. The KPIs represent an outcome that needs to be demonstrated or measured in order to meet each Standard.

The Disability Advocacy Standards have as their basis the 1993 National Disability Services Standards which were developed in the context of the Commonwealth State Territory Disability Agreement (CSTDA). The National Disability Services Standards are a core set of Standards applicable to all CSTDA funded disability services, including advocacy.

DEVELOPMENT OF DRAFT DISABILITY ADVOCACY STANDARDS & KPIs

In 2006 two consultative bodies were created to develop the draft set of Disability Advocacy Standards and KPIs. FaHCSIA would like to thank the members of the NDAP Reference Group and Consultation Committee for their work in developing the Draft Disability Advocacy Standards and KPIs.

This set of Disability Advocacy Standards provided at Attachment A for comment comprises 11 Standards and 24 KPIs and replaces the 101 supporting standards which currently apply to non-employment services.

TESTING OF STANDARDS & KPIs

FaHCSIA recognises advocacy is different to service provision and that the Disability Advocacy Standards and KPIs must be:

  • easily understood by agencies and consumers
  • meaningful across the different advocacy models
  • achievable and able to encourage continuous improvement.

The draft Disability Advocacy Standards and KPIs will be tested for their appropriateness during two trials of the new Quality Assurance System for the NDAP during 2008 and 2009 (see the Fact Sheet 1 – Revised Timetable for further information).

WORKING WITH DIFFERENT ADVOCACY MODELS – INTRODUCTION OF EVIDENCE GUIDELINES

The NDAP currently provides funding for six different models of advocacy. FaHCSIA appreciates that each model operates differently and that the Disability Advocacy Standards and KPIs need to be appropriate for each model.

In order to ensure that the Disability Advocacy Standards and KPIs can provide an effective performance framework, FaHCSIA is proposing that the Standards and KPIs be ‘generic’ across the different models and that a set of Evidence Guidelines accompany each set of Standards and KPIs which are specifically tailored for the different advocacy models.

The intention of this approach is to promote flexibility and innovation in how advocacy support is delivered, rather than being prescriptive about KPI’s for each of model of advocacy and potentially restricting continuous improvement.

QUESTIONS TO CONSIDER

  1. Are the generic Disability Advocacy Standards and KPIs appropriate for the work of your agency?
  2. Does your agency support FaHCSIA’s approach to introduce specifically tailored Evidence Guidelines for each of the different models of advocacy?
  3. If yes (to above question), can you please provide some examples of the types of evidence appropriate to your model of advocacy?
  4. How can FaHCSIA work with your agency to ensure that the Disability Advocacy Standards and KPI’s are accessible to people with disability?
  5. Is your agency interested in participating in the Quality Assurance trials?
    (please note, that participation for all agencies cannot be guaranteed).

PROVIDING FEEDBACK

Your comments are sought in response to the questions above. Responses limited to five pages are appreciated. Please send your responses to this Consultation Paper by close of business Friday 2 May 2008 to:

E-MAIL disabilityadvocacy@facsia.gov.au (preferred method)

POST FaHCSIA Advocacy Reforms & Management Section, Disability Policy & Coordination Branch, TOP-CE3 Box 7788 Canberra Mail Centre ACT 2610

FAX 02 6244 8499

Thank you for your feedback.


Attachment A: Draft Disability Advocacy Standards and Key Performance Indicators
DISABILITY ADVOCACY STANDARDS KEY PERFORMANCE INDICATORS (KPIS) EXAMPLES OF EVIDENCE & ISSUES TO CONSIDER
Standard 1: Accessing Advocacy

Each person with a disability who is seeking the support of an advocate has access to an agency on the basis of relative need and available resources.
KPI 1.1 The agency adopts applies and promotes non-discriminatory entry rules in respect of age, gender, race, culture, religion or disability, consistent with the contractual obligations and purpose of the agency.

KPI 1.2 The agency’s entry and exit procedures are fair and equitable and consistently applied.

KPI 1.3 People with disability are informed about how decisions about access and prioritisation are made.
Issues to consider include:
  • How will this Standard and set of KPIs work for agencies that deliver systemic advocacy?
  • How will this Standard and set of KPIs work for agencies that deliver family advocacy given that advocates work with parents and /or family members and not directly with the person with a disability?
  • How will this Standard and set of KPIs work for agencies that deliver citizen advocacy given that coordinators work with the advocates and not directly with people with disability?
Standard 2: Individual Needs

Each person with a disability receives advocacy that is designed to meet, in the least restrictive way, his or her individual needs and personal goals.
KPI 2.1 Advocacy outcomes are negotiated and agreed to by the person with a disability and reflect their needs and personal goals.

KPI 2.2 All advocacy activities reflect and respond to an individual’s goals and needs.

KPI 2.3 In meeting the needs of a person with a disability, the advocacy agency will seek to minimise conflict of interest or to deal with it transparently if it is unavoidable.
Issues to consider:
  • As above for systemic, family and citizen advocacy.

Examples of evidence:
  • Citizen advocacy: demonstrated evidence about how the best interests of people with disability are determined when paid coordinators work directly with volunteer advocates.
  • Family advocacy: demonstrated evidence about how the best interest of a person with a disability is determined when advocates work directly with family members of the person with a disability.
  • Individual, legal and self advocacy: demonstrated evidence that advocacy plans and activities have been developed in partnership with people with disability.
  • Systemic advocacy: demonstrated evidence that people with disability have been consulted prior to systemic advocacy actions being undertaken on their behalf.
  • All models: agency operational policies include conflict of interest procedures.
Standard 3: Decision-making & Choice

Each person with a disability has the opportunity to participate as fully as possible in making decisions about the advocacy activities undertaken.
KPI 3.1 People with disability are supported to make their own decisions about the advocacy activities they require.

KPI 3.2 The advocacy agency acts upon the choices made by the person with a disability. Where a person with a disability has impaired decision making capacity, ethical guidelines will be used to inform decisions about advocacy activities.
Issues to consider:
  • As above for systemic, family and citizen advocacy.
Standard 4: Privacy, Dignity & Confidentiality

The right of people with disability to privacy, dignity and confidentiality is recognised and respected.
KPI 4.1 The advocacy agency complies with the Information Privacy Principles of the Privacy Act 1988 in order to protect and respect the rights of people with disability. The advocacy agency does not disclose personal information about people with disability without their informed consent.

KPI 4.2 The advocacy agency demonstrates respects for each person with a disability accessing support.
 
Standard 5: Participation & Integration

Each person with disability is supported and encouraged to participate and be involved in the community.
KPI 5.1 Through advocacy, opportunities for participation and involvement in every aspect of the community are promoted.

KPI 5.2 Where appropriate, the advocacy agency takes action to introduce, influence or produce systemic change in the community.
 
Standard 6: Valued Status

Each person with disability has the opportunity to develop and maintain their own advocacy skills that enable him or her to achieve valued roles in the community.
KPI 6.1 Through advocacy, the abilities, aspirations and resilience of people with disability is promoted.  
Standard 7: Complaints & Disputes

People with disability are encouraged to raise, and have resolved without fear of retribution, any complaints or disputes he or she may have about advocacy agency.
KPI 7.1 The advocacy agency encourages the raising of complaints by people with disability regarding any areas of dissatisfaction with the advocacy agency.

KPI 7.2 People with disability have no fear of retribution in raising complaints.

KPI 7.3 The advocacy agency seeks to resolve complaints or disputes raised by people with disability.
 
Standard 8: Agency Management

Each agency adopts quality management systems and practices that optimise the advocacy outcomes for people with disability and facilitates continuous improvement.
KPI 8.1 The advocacy agency has clearly stated aims and objectives that communicate the scope and limitations of the agency to people with disability and other relevant stakeholders

KPI 8.2 The advocacy agency has management systems in place that facilitate quality management practices and continuous improvement.

KPI 8.3 The advocacy agency is structured and operates in such a way that it is as free as possible from the interests that conflict with people with disability.
 
 
Standard 10: Training & Support

People with disability are supported to self-advocate through the provision of effective and relevant training and support.
KPI 10.1 The advocacy agency develops the capacity of people with disability to self-advocate Issues to consider:
  • As above for family and citizen advocacy.
Standard 11: Staff, Recruitment, Employment & Training

Each person employed by advocacy agency has relevant and appropriate skills and competencies.
KPI 11.1 The advocacy agency ensures that staff have the relevant skills and competencies.

KPI 11.2 The advocacy agency provides opportunities for the appropriate and continuing training and skills development for each staff member.
Issues to consider:
  • The issue of where advocates can source appropriate training and the financial impact of accessing training needs to be considered in the evidence guidelines.
Standard 12: Protection of Human Rights & Freedom from Abuse

The advocacy agency acts to prevent abuse and neglect and to uphold the legal and human rights of people with disability.
KPI 12.1 The advocacy agency takes all practical and appropriate steps to prevent abuse, neglect and discrimination of people with disability.

KPI 12.2 The advocacy agency upholds and promotes the legal and human rights of people with disability.
 

Please note that Standard 9 of the National Disability Service Standards relates to conditions and wages for people with disability working in employment services. As this does not apply for advocacy agencies, the number of the Standards been amended to reflect this.

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Attachment 2: List of agency submissions

(1) ADACAS

(2) Rights In Action Inc.

(3) Disability Advocacy Network Inc. (note response was to the principles)

(4) Illawarra Citizen Advocacy

(5) Disability Advocacy and Complaints Service of South Australia Inc. (also refer to submission 26)

(6) Southwest Advocacy (SWAA)

(7) Regional Information and Advocacy Council (RIAC)

(8) Northeast Citizen Advocacy Inc.

(9) Westernport Speaking Out Inc., Frankston, Victoria (see also, submission 9)

(10) Southern Citizen Advocacy & Citizen Advocacy Inner East

(11) Ability Incorporated Advocacy Service

(12) Citizen Advocacy South Australia Inc.

(13) Indigenous Disability Advocacy Service

(14) Citizen Advocacy Perth West

(15) Individual submission, not representing an agency

(16) Gippsland Citizen Advocacy Inc

(17) Combined Advocacy Groups Queensland

(18) Midland Information Debt and Legal Advocacy Service Inc.

(19) National Ethnic Disability Alliance

(20) Self Advocacy Sydney Inc.

(21) Side By Side Advocacy

(22) People with Disabilities (WA) Inc.

(23) Advocacy for Inclusion ACT

(24) Disability Advocacy Network Inc. (response to the standards and KPIs

(25) Blind Citizens Australia

(26) Disability Advocacy and Complaints Service of South Australia Inc. (also refer to submission 5)

(27) Action for Community Living

(28) Sussex Street Community Law Service – Individual Disability Advocacy Service

(29) Disability Rights and Advocacy Service inc. Victoria

(30) Disability Justice Advocacy

(31) Citizen Advocacy, Sunbury and Districts

(32) Institute for Family Advocacy and Leadership Development Assoc. Inc.

(33) Personal Advocacy Service

(34) Independent Advocacy SA Inc.

(35) Office of the Public Advocate

(36) Villamanta Disability Rights and Legal Service

(37) Westernport Speaking Out (note: submission regarding advocacy models, submission 9 addressing the standards and KPIs)

(38) Sunshine Coast Citizen Advocacy

(39) Disability Services Queensland

(40) Brain Injury Network of South Australia Inc

(41) DEAC

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Content Updated: 8 November 2012