Independent Advocacy and the NDIS
(A paper to consider the role of Independent Advocacy when there is a National Disability
Insurance Scheme)
30 June 2012
For further information please contact:
Andrea Simmons
Chief Executive Officer
Disability Advocacy Network Australia (DANA) Ltd
Telephone: (02) 6154 1983
Email: Andrea.Simmons@dana.org.au
Copyright © 2012 Disability Advocacy Network Australia (DANA) Ltd
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Table of Contents
Introduction ................................................................................................................................ 3
Policy Context .............................................................................................................................. 3
United Nations Convention on the Rights of Persons with Disabilities ............................................... 3
National Disability Advocacy Program ............................................................................................... 3
National Disability Strategy ................................................................................................................ 4
Productivity Commission Inquiry Report into Disability Care and Support ........................................ 5
Historical Context .............................................................................................................................. 7
National Disability Agreement ........................................................................................................... 8
Definitions of Advocacy ............................................................................................................... 9
What is the Significance of Independence? ................................................................................. 10
Why is Independent Advocacy Support Necessary ..................................................................... 11
What do Independent Advocacy Agencies do? ........................................................................... 12
Self Advocacy, Family Advocacy and Citizen Advocacy ................................................................... 13
Legal Advocacy ............................................................................................................................... 13
Individual Advocacy ........................................................................................................................ 13
Systemic Advocacy ......................................................................................................................... 14
How will Advocacy for Individuals change with an NDIS ............................................................. 15
What about Advocacy for Individuals will remain the same with an NDIS? .................................. 16
How will an NDIS affect Systemic Advocacy? .............................................................................. 18
Disability Support Organisations and Advocacy ......................................................................... 19
Future Advocacy Administration and Funding ............................................................................ 22
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Introduction
The following paper describes the disability policy framework in Australia and the role of
independent advocacy within this framework. It goes on to describe the way in which the framework
is likely to change with the introduction of the National Disability Insurance Scheme (NDIS) and the
way in which an expanded independent disability advocacy program will assist the Government to
meet its overall disability policy objectives.
In essence this paper identifies that government policy is directed to meeting Australia’s
international obligations under the United Nations Convention on the Rights of Persons with
Disabilities (UNCRPD) and to ensuring that people with disabilities are able to fulfil their potential as
equal citizens. It shows that ready access by people with disabilities to independent advocacy
support is a necessary system element for achieving these policy objectives because it supports
people with disabilities to act, directly or through an advocate, in their own interests from a position
of increased power and knowledge. It also operates as a protective mechanism in the lives of those
people with disabilities who face the most significant barriers to effectively communicating their
needs and wishes and it acts as an overall societal safeguard illuminating and seeking improvement
in those aspects of our services, systems and society that are failing people with disabilities.
Key to enabling independent advocacy to effectively fulfil its intended purpose of promoting,
protecting and defending the rights, interests and well being of people with disabilities is to create a
system structure that entrenches the independence and freedom from conflicts of interest of
disability advocacy at program, governance and operational levels.
Policy Context
United Nations Convention on the Rights of Persons with Disabilities (CRPD)
In July 2008 the Australian Government ratified the CRPD. The CRPD binds States parties to ‘ensure
and promote the full realisation of all human rights and fundamental freedoms for all persons with
disabilities.’ To this end States Parties undertake, amongst other things, ‘(a) to adopt all appropriate
legislative, administrative and other measures for the implementation of the rights recognised in the
present Convention...’ and ‘(c) to take into account the protection and promotion of the human
rights of persons with disabilities in all policies and programmes...’1
National Disability Advocacy Program (NDAP)
The funding of agencies to deliver advocacy support for people with disabilities is a measure taken
by Australian Governments to assist in the promotion, protection and implementation of the rights
recognised in the CRPD. The objective of NDAP is that ‘People with disability have access to effective
1
United Nations, Convention on the Rights of Persons with Disabilities (CRPD), 2006, Article 4
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disability advocacy that promotes, protects and ensures their full and equal enjoyment of all human
rights enabling full community participation...’2
NDAP provides advocacy support through a variety of models aimed either at assisting people with
disabilities to assert their individual rights and interests or at achieving long term improvements in
the rights and interests of people with disabilities collectively.3 The latter model is referred to as
systemic advocacy. When acting systemically and on behalf of people with disabilities, advocacy
agencies are regarded by the United Nations for the purposes of Article 4 paragraph 3 of the CRPD
as representative organisations for people with disabilities.4 As such, advocacy organisations have an
important role to play in the development and implementation of legislation and policies to
implement the CRPD.5
National Disability Strategy (NDS)
A key measure taken by the Australian Governments in 2011 for the implementation of the CRPD
rights is the NDS. The NDS ‘will help ensure that the principles underpinning the Convention are
incorporated into the policies and programs affecting people with disability, their families and
carers…’6 The NDS lays out a vision shared by all the then Australian Governments for ‘an inclusive
Australian Society that enables people with disability to fulfil their potential as equal citizens…..’7
The NDS drew on the findings of the ‘Shut Out’ report, the report of a Consultation conducted by the
National People with Disabilities and Carer Council in 2008-09.8 This report indicated that issues of
rights and discrimination were raised in 39 per cent of submissions, that people with disabilities
reported experiencing discrimination in every aspect of their lives,9 and that 31 per cent of
submissions contended that action is required to ensure greater protection of rights.10 The
suggested actions to be taken included ‘increasing the number of and funding for advocacy services
for people with disabilities’, allowing advocacy groups to bring cases to the Human Rights
2
Australian Government Department of Families, Housing, Community Services and Indigenous Affairs,
National Disability Advocacy Program – Program Guidelines, Part C Services and Support for People with
Disability Program: Application Information for National Disability Advocacy Program, 2010, p. 5
3
Australian Government Department of Families, Housing, Community Services and Indigenous Affairs, NDAP –
Program Guidelines Part C, 2010, p. 17
4
This is confirmed by the United Nations Development Group / Inter-agency Support Group for the CRPD Task
Team, Including the rights of persons with disabilities in United Nations programming at country level, A
Guidance Note for United Nations Country Teams and Implementing Partners, 2010, which says at p.6 that
that Governments should enhance participation of people with disabilities and their representative
organisations by involving ‘organisations that represent men, women and children with all types of disabilities ,
including groups representing people with a single impairment, advocacy groups as well as umbrella
organisations and those in remote and rural areas, so as to ensure that consultations are representative.’
5
United Nations, CRPD, 2006, article 4, paragraph 3
6
Council of Australian Governments, National Disability Strategy 2010-2020, Commonwealth of Australia,
2011, p. 9 and p.16
7
Council of Australian Governments, 2011, p. 8
8
National People with Disabilities and Carer Council, Shut Out: The experience of people with disabilities and
their families in Australia – National Disability Strategy Consultation Report, Commonwealth of Australia , 2009
9
National People with Disabilities and Carer Council, 2009, p. 14
10
National People with Disabilities and Carer Council, 2009, p. 17
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Commission on behalf of groups of individuals and enlisting advocates to ensure the effectiveness of
person centred approaches and appropriate outcomes for people with disabilities.11
It is not surprising, then, that the NDS highlighted the role of disability advocacy in enabling and
supporting people with disabilities, on both an individual and systemic level, to safeguard their rights
and overcome barriers that impact on their ability to participate in the community.12
The NDS has six broad outcome areas. Outcome 2, under the heading of ‘Rights protection, justice
and legislation,’ reads ‘people with disability have their rights promoted, upheld and protected.’ The
NDS, in respect of this outcome area considers policy directions and actions that ‘seek to promote
awareness and understanding of the rights of people with disability, improve responses to people
with disability in the justice system, ensure their safety and enable them to participate fully in the
economic, civil and social life of our nation.’13 Disability advocacy agencies are identified by the NDS
as forming part of the Government’s commitment to achieving this Outcome.14 Support for
independent advocacy to protect the rights of people with disability is also identified as an area of
future action.15
Senator McLucas, in her ‘Parliamentary Secretary Foreword’ to the recently released Quality Toolkit
for the National Disability Advocacy Program said: ‘A well administered, quality assured, disability
advocacy sector will be crucial to support Australia’s human rights framework and the achievement
of broader disability reforms outlined in the National Disability Agreement, the National Disability
Strategy, the United Nations Convention on the Rights of Persons with Disabilities and a National
Disability Insurance Scheme.’16
Productivity Commission Inquiry Report into Disability Care and Support
Outcome area 4 of the NDS focuses on people with disabilities, their families and carers having
access to the specialised supports they need to live independently and actively engage in their
communities.17 The areas for future action include considering ‘new approaches to long term
disability care and support, including responses to the Productivity Commission Inquiry’.18
The Productivity Commission Inquiry Report into Disability Care and Support was released on 10
August 2011. In undertaking its Inquiry the Productivity Commission considered many submissions
that addressed the issue of advocacy support for people with disabilities and directly questioned
DANA about matters arising from these submissions.19 It made a number of strong statements in
support of the role and value of individual and systemic advocacy in the context of the proposed
National Disability Insurance Scheme (NDIS). The Commission said:
11
National People with Disabilities and Carer Council, 2009, p. 17
Council of Australian Governments, 2011, p. 8
13
Council of Australian Governments, 2011, p. 36
14
Council of Australian Governments, 2011, p. 40
15
Council of Australian Governments, 2011, p. 41
16
Australian Government Department of Families, Housing, Community Services and Indigenous Affairs
(FaHCSIA), Quality Toolkit for the National Disability Advocacy Program, 2012
17
Council of Australian Governments, 2011, p. 47
18
Council of Australian Governments, 2011, p. 52
19
Productivity Commission, Draft Report on Disability Care and Support, Transcript of proceedings at Perth on
Wednesday, 20 April 2011, at 8:54 am, pp. 930-933
12
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‘Both independent advocacy and systemic advocacy will continue to play an important role under the
proposed NDIS. The independence of individual advocacy organisations will allow them to represent
the interests of the most vulnerable people in the disability system, whose concerns may be
otherwise overlooked...... Part of this role will entail helping people express concern or make a
complaint about the quality of service provision, either to service providers themselves, or to local
area coordinators as well as the NDIA [National Disability Insurance Agency] directly. Beyond this,
individual advocacy will also play an important role in ensuring that the assessment processes
properly recognise people’s needs, as well as providing a safeguard with DSOs [Disability Support
Organisations] and local area co-ordinators [LACs].
Similarly, systemic advocacy will play an important role in promoting system wide quality of service
provision through: uncovering system failures; petitioning for widespread change; disseminating
information of best practice to service providers; promoting public awareness of disability issues; and
promoting the interests of particular groups such as CALD, indigenous and women with a disability.’20
The Productivity Commission went on to say that:
 the key feature of good advocacy is that no interest is countenanced other than that of the
person themselves21
 individual advocacy is integrally linked to systemic and other forms of advocacy22
 neither systemic, nor individual advocacy are well suited to a user pays system so
independent advocacy should continue to be block funded23
 organisations funded to provide advocacy, in order to avoid any conflict of interest, should
not also be funded through the NDIS, as DSO’s or service providers, or directly by the NDIA
at all24
 the NDIA should not directly fund advocacy support however there may be merit in the NDIA
contributing additional untied funds to the existing advocacy programs25
It then recommended in Recommendation 10.4 that:
‘The Australian Government, through the Department of Families, Housing, Community Services and
Indigenous Affairs should continue to provide funding for general advocacy by non-government
organisations, with no involvement by the National Disability Insurance Agency in this funding role.
State and territory funding of disability advocacy groups should continue.’26
DANA is of the view that the Productivity Commission has taken a good first step in the direction of
understanding the role and function of independent advocacy when there is an NDIS. Importantly it
has identified clearly that advocacy is not suited to a user pays model and that independence from
service provision and the NDIA (and by analogy the National Injury Insurance Scheme [NIIS]) is a key
design consideration for the reformed system.
With this in mind, but without consideration or analysis of the relative merits of possible
independent alternatives, the Productivity Commission appears to have opted for a no change
scenario in relation to the administration and funding of advocacy. Perhaps the Productivity
20
Productivity Commission 2011, Disability Care and Support, Report no.54, Canberra, pp. 507-508
Productivity Commission 2011, p. 524
22
Productivity Commission 2011, p. 524
23
Productivity Commission 2011, p. 524
24
Productivity Commission 2011, p. 525
25
Productivity Commission 2011, p. 525
26
Productivity Commission 2011, p. 525
21
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Commission viewed such an analysis as too far removed from the work of designing an NDIS.
Alternatively it may have considered it not possible to decide on the most appropriately
independent administrative mechanism for independent advocacy until the administrative
framework for the NDIS and NIIS is settled. Either way there is clearly a case for a more detailed
consideration of this issue.
In addition to the continuation of funding for independent advocacy organisations, the Productivity
Commission in its Inquiry Report recommended that the NDIA have its own LACs and fund DSOs.
Some of the functions envisaged for these roles seem, at first glance to have similarities to, or
overlap with each other and with those of advocacy agencies. On closer investigation, however, it
can be seen that where the functions are similar, they are performed in each role in different ways,
to different degrees, applying different skills and responding to a different set of accountabilities.
This is discussed later in this paper.
LACs are intended by the Productivity Commission to:
 provide a local/regional point of contact and advice for people with disabilities in their dealings
with the NDIS, oversight the delivery of their services and collect service performance
information
 liaise with other government services on behalf of people with disabilities
 assess the capacity of a person to use self-directed funding, and assist in the development of
spending plans
 manage a limited pool of funding to address emergency respite and other special circumstances
 negotiate, if requested, with service providers in the event of a dispute or complaint27
DSOs are envisaged by the Productivity Commission as being available to people eligible for Tier 3
individualised supports to:
 provide personal planning services beyond what is available from the LAC
 help them to get the best value from their allocated self-directed funding
 help them develop the skills and confidence to practically exercise choice
 provide them with information about the available support services
 assemble ‘packages’ of supports from specialist and mainstream providers
 undertake administrative tasks associated with their self directed funding28
 facilitate community capacity building29
 assist in resolving minor service issues and providing information about complaints processes
and advocacy organisations30
Historical Context
So far this paper has sought to contextualise advocacy within the human rights framework adopted
though ratification of the CRPD. It is important to understand, however, that today’s advocacy has a
long history and draws from a range of ideological movements and societal influences31:
27
Productivity Commission 2011,
Productivity Commission 2011,
29
Productivity Commission 2011,
30
Productivity Commission 2011,
28
p. 413
p. 416
p. 417
p. 421
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


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the Judeo/Christian teachings directed to safeguarding and protecting those in need32
the Hegelian/Marxist promotion of equity and egalitarianism
societal recognition of the self serving characteristics of human organisations and their
tendency towards ‘decay, mediocrity and worse...’33
the 1940’s and 50’s parent rejection of institutional living for their sons and daughters with
disability34
the articulation of some influential principles within human services35
the self help movement’s focus on skill development to enable independence, control and
inclusion36
The National Disability Advocacy Program (NDAP) was ‘established after the introduction of the
Disability Services Act 1986 with a mandate to provide advocacy services independent of direct
service provision that would protect and promote the rights of people with disabilities. The program
is an integral part of the rights protection framework which includes the Disability Discrimination Act
1992 as well as bodies such as the Human Rights and Equal Opportunity Commission, Offices of Legal
Aid, the various offices of Public Advocate/Public Guardian and Ombudsman Offices....’37 At the time
advocacy was regarded by the Federal Government as being needed to assist the significant process
of change being embarked upon through the Disability Services Act, and as recognition that the life
experience of people with disabilities was commonly associated with oppression, discrimination and
disadvantage. 38
National Disability Agreement (NDA)
Advocacy for people with disabilities today is funded and administered, jointly by the
Commonwealth and the States under the NDA, as a specialist disability service. For NDA purposes a
specialist disability service is probably one which falls in the category of services described in Item 8
of the NDA agreed outputs as follows:
‘(a) services that provide skills and supports to people with disability to enable them to live as
independently as possible;
(b) services that assist people with disability to live in stable and sustainable living
arrangements;............and
(d) services that assist families and carers in their caring role.’39
31
W Wolfensberger, A Balanced Multi-component Advocacy /Protection Schema, Association Resources
Division Canadian Association for the Mentally Retarded, 1977, pp. 3-6
32
For example see Proverbs 31:8-9 ‘Speak up for those who cannot speak for themselves, for the rights of all
who are destitute. Speak up and judge fairly; defend the rights of the poor and needy.’
33
Wolf Wolfensberger, 1977, p. 4
34
E Cocks & G Duffy, The Nature and Purpose of Advocacy for People with Disabilities, Centre for the
Development of Human Resources, Social Research and Development Monograph No.4, 1993, p. 39
35
E Cocks & G Duffy, 1993, p. 40 provides as examples Normalisation, The Least Restrictive Alternative, The
Dignity of Risk, The Developmental Principle/Model and Social Role Valorisation.
36
E Cocks & G Duffy, 1993, pp. 40-41
37
Social Options Australia; Evaluation of the National Disability Advocacy Program Final Report; FaHCSIA,
2006, p. 10
38
J Cross & L Zeni, Safeguarding Advocacy for People with Disabilities in Australia , A report to the Disability
Advisory Council of Australia, 1993, p. 14
39
Council of Australian Governments (COAG), National Disability Agreement, 2009, p. 4
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There can be little doubt that independent advocacy agencies fall within the descriptions at a), b)
and d) above and are regarded by people with disabilities as a necessary specialist disability support.
As part of the NDA, all governments:
‘agreed to create a service system which enhances the social and economic participation for people
with disability and supports their families and carers. The agreed policy directions to achieve this are
to:
(a) improve provision of the skills and opportunities to enhance the capability of people with
disability to participate in social, economic and community activities;
(b) ensure services are person centred and provide timely access to supports based on
assessed needs;
(c) identify, plan and respond to the development and support needs of people with disability
at an early stage and at key life transition points; and
(d) support the role of families and carers including strengthening their informal support
networks.’40
The work of advocacy organisations funded under the NDA make a significantly contribution to the
governments’ implementation of each of these policy directions. This will be addressed in more
detail later in this paper.
Under the NDA the various governments have agreed to ‘consider improvements in administration
of advocacy services, with a focus on improving service delivery and access to advocacy services for
people with disability.’41
Definitions of Advocacy
The term ‘Advocacy’ is derived from the Latin verb vocare, which means ‘to call or speak’. When
joined with the prefix ad, it becomes ‘to speak on behalf of or in favour of’42.
English language dictionaries commonly define advocacy in terms similar to the following: ‘The act of
pleading or arguing in favour of something, such as a cause, idea, or policy; active support.’43
The definition of advocacy used by NDAP throughout the life of the Program has been something
like:
‘In broad terms, advocacy for people with disability can be defined as speaking, acting or writing with
no 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 noone else’s; being primarily concerned with their fundamental needs; and remaining loyal and
accountable to them in a way which is empathetic and vigorous.’ 44
The DANA definition of advocacy, below, has been derived taking all of the above into account.
40
Council of Australian Governments, 2009, p. 8
Council of Australian Governments, 2009, p. 9
42
M Kendrick, Advocacy as Social Leadership, The International Journal of Leadership in Public Services, vol. 4
issue, October 2008, p. 63
43
The American Heritage®, Dictionary of the English Language, 4th edn, Houghton Mifflin Company, 2009,
viewed 30 June 2012, http://www.thefreedictionary.com/advocacy
44
Australian Government Department of Families, Housing, Community Services and Indigenous Affairs, NDAP
–Program Guidelines Part C, 2010, p. 9
41
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We have also defined what we mean by independent so that a reference in our paper to
independent advocacy will be distinguishable from the incidental advocacy support provided by
services as an adjunct to or offshoot from their general service provision.
‘Advocacy’ is taking action to promote, protect or defend the rights, interests or well-being of a
person or group.45
‘Independent’ means freedom from influence by agencies or government entities with responsibility
for the provision of supports and services to people with disabilities. (Consistent with the
Productivity Commission view detailed above)
What is the Significance of Independence?
Disability advocates are compromised in their capacity to effectively advocate for people with
disabilities if they, at the same time, have interests to serve that are in conflict with those of people
with disabilities. This is because the more powerful interests of service providers and government
agencies usually prevail.
Service provider interests will conflict with those of people with disabilities whenever a service is to
be the object of advocacy because:
 service providers have similar interests to each other and so are constrained in their
advocacy against other services for things that may apply equally to them; and
 service providers need good working relationships with other services to carry out their
work effectively and so are constrained in the strength of their advocacy against other
services.
Service provider interests will conflict with those of people with disabilities whenever the NDIA or
NIIS is the object of advocacy because services will rely on the goodwill of these government
agencies for their block (Tier 2) funding, for their eligibility to receive individualised funding and for
LAC or NIIS equivalent recommendations to people with disabilities.
DSOs are proposed to perform many important services for people with disabilities including
planning, brokering, administering and managing and will receive both block and individualised
funding. They will therefore be subject to the same conflicts of interest identified above for services.
The NDIA and NIIS will be conflicted in also providing or funding advocacy for people with disabilities
whenever a decision, policy or process of the NDIA or NIIS is called into question and when the
service provider subject to advocacy is one that they have promoted to people with disabilities,
directly funded or quality approved.
Disability advocates thus seek structural arrangements for advocacy provision that avoid these
conflicts occurring and allow them to advocate solely in the interests of people with disabilities. The
structural arrangements that have long been thought of as important involve:
45
Lobbying is generally understood to be a form of advocacy directed to influencing the actions of the
members of a legislative body.
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

ensuring that the agencies that deliver advocacy support do not also provide disability
services; and
ensuring that advocacy agencies are funded and administered by a part of government that
is unlikely to be subject to disability advocacy.
Why is Independent Advocacy Support Necessary?
Australian Governments fund services and supports for people with disabilities to enable them to
achieve economic and social participation and to enjoy choice, well-being and the opportunity to live
as independently as possible.46 The capacity to take action, to effectively promote, protect and
defend your rights and interests is a necessary enabler for each of these goals. It is necessary for
things as simple as remedying an overcharge on a phone bill and for things as complicated and
emotionally challenging as taking action to address or prevent a situation of abuse. Our systems of
redress for wrongs done to people take for granted that those affected will have the personal and
fiscal resources to take up the issue with the relevant person or body and, if necessary, to push it
through a plethora of complaints mechanisms to a successful conclusion, engaging with suitable
professional support as needed along the way.
If someone does not have the personal resources to do this and does not have family or friends able
to take on the role, then independent advocacy support is required. When the issue concerned is
complicated, intractable or challenging, advocacy support from someone knowledgeable about
advocacy and about the subject matter is required. If it is not readily available then only the most
skilled, knowledgeable and empowered or well supported (by families or friends) people with
disabilities will have their issues addressed.
People with disabilities are more likely than the rest of the population to be in a poor position to
advocate for themselves, more likely to lack family advocacy support and more likely to face
complicated, challenging or intractable challenges to their rights and well-being. This situation arises
from the interaction people’s disabilities with their environment and societal factors. It is particularly
the case for those who are reliant on the services of others for their most basic needs;47 those who
lack effective communication, negotiation or comprehension skills and those who lack knowledge
about their rights and how to exercise them.
For these same reasons people with disabilities are more likely than the rest of the population to
experience abuse, neglect, injustice and a denial of their basic human rights and fundamental
freedoms.48 This is a universal phenomenon and was part of the driver for the development of the
UNCRPD. The international community recognised that, despite broad acceptance of the general
46
Council of Australian Governments, 2009, p. 4
‘...people with disabilities are often denied the friendships, educational opportunities, information and self
esteem to stand up for their rights and get their opinion heard’. J Cross & L Zeni, 1993, p. 13
48
See for a variety of examples National People with Disabilities and Carer Council, 2009 and the Disability
Representative, Advocacy, Legal and Human Rights Organisations, Australian Civil Society Shadow and Baseline
Report to the UN Committee on the Rights of Persons with Disabilities, 2012
47
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International Human Rights Instruments,49 intended to apply to everyone without distinction of any
kind, ‘persons with disabilities continue to face barriers to their participation as equal members of
society and violations of their human rights in all part of the world.’50
‘Advocacy identifies and draws attention to mistreatment, injustice and oppression. It seeks to ensure
that injustice is exposed and practices that are unacceptable are discontinued. Advocacy aims for
people with disabilities to be afforded the same benefits and opportunities as are available to other
citizens and continually strives for a fairer society for all people with disabilities’. 51
Advocacy is a safeguarding mechanism which gives people with disabilities the means by which to
‘challenge the societal devaluation they experience, the discrimination, the limitations of
opportunity and the inadequacy of our society’s response to people with disability and their
family.’52
What do Independent Advocacy Agencies do?
Through NDAP, advocacy agencies are funded to carry out advocacy activities according to six
different models. Most advocacy agencies are funded by the Commonwealth or the States and
Territories to deliver a variant on one or more of these models. The six models are now reasonably
well established and understood within government. They were the subject of extensive
consultation and refinement over a number of years resulting in a Report by Jenny Pearson in 200953
which explained in some detail how they work. NDAP funded agencies agree through their funding
Agreement to deliver one or more of these models of advocacy54 and to submit to quality assurance
processes that consider evidence (specific to their form of advocacy55) of compliance with the
Disability Advocacy Standards. The models of advocacy are described slightly differently in different
documents however they are generally understood as follows:





Individual Advocacy, where a person with disability is supported to exercise their rights on a one
to one basis
Self Advocacy, where people with disabilities are supported to advocate on their own behalf
Family Advocacy, which supports family members to advocate with and on behalf of a family
member with disability
Citizen Advocacy, which matches a person with disability with a community member who makes
a commitment to stand beside the person as their advocate over the longer term
Legal Advocacy, where a legally trained advocate supports a person with disability on a one to
one basis to address legal issues
49
United Nations, The Universal Declaration on Human Rights, 1948; United Nations, International Covenant
on Civil and Political Rights, 1976 and United Nations, International Covenant on Economic , Social and
Cultural Rights, 1976
50
United Nations, CRPD, 2006, Preamble, paragraph (k)
51
J Cross & L Zeni, 1993, p. 13
52
J Cross & L Zeni, 1993, p. 12
53
Jenny Pearson & Associates Pty Ltd, Research of the Models of Advocacy funded under the
National Disability Advocacy Program - Final Report, 2009
54
Commonwealth of Australia, Terms and Conditions - Standard Funding Agreement: For Agreements entered
into from 11 May 2011, Schedule Version 3.5, July 2011, Item B 3.8
55
(FaHCSIA), Quality Toolkit for the National Disability Advocacy Program, 2012, p. 45 and Attachment 5.
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Systemic Advocacy which seeks changes to legislation, policy and service practices to benefit a
significant number of people with disabilities
Self Advocacy, Family Advocacy and Citizen Advocacy
These models all focus on reducing the susceptibility of an individual with disability to abuse,
neglect or injustice by working to ensure that they and/or other people in their lives are ready and
able, with the necessary advocacy knowledge and skills, to advocate for them should the need arise.
These three models also involve the advocacy agency providing the advocate (self, family or citizen)
with information and advocacy advice when requested on individual advocacy matters. They have
the benefit of enabling many issues to be resolved quickly and effectively, with minimum disruption
to key relationships and before anything of a serious nature occurs.
Legal Advocacy
This model applies professional legal skills coupled with specialised disability knowledge to individual
advocacy matters. As such it is a legal variant on the Individual Advocacy model.
Individual Advocacy
The individual advocacy model operates reactively on issues that are brought to the advocacy
agency by a person with disability or someone acting on their behalf. Referrals are commonly made
by government officials or service providers who recognise the need for independent individual
advocacy support. In most cases, they will refer on only those issues that are difficult to resolve or in
which they have a conflict of interest. Where everything is going well for a person with disability and
their relationships with their families, service providers and local communities are respectful and
sustaining they do not seek individual advocacy support. Thus individual advocacy operates
primarily as a trouble shooter or circuit breaker in difficult situations where there are no easy
answers.
The individual advocacy model commonly involves an advocate working with a person with disability
to identify:
 their advocacy issue/s and any relevant information
 what the person wants to achieve
 the strategies available to address the issue
 the likely outcomes from using a particular strategy
 the strategy/s that the person wishes to pursue
 who will do what and when
When the agreed actions have been taken, the advocacy work involves a review of what has been
achieved and a consideration of what more needs to be done following the same process as before.
The intention is that the advocacy work is issues based and short term; and that the person with
disability is supported and enabled, as far as possible and to the extent that they choose, to be the
decision-maker and to self advocate. Thus the agency advocate will, at different times, act as
representative of, assistant to, or behind the scenes supporter of, the person with disability.
[13]
Individual advocacy thus supports the person with disability to make decisions and exercise control
over both the advocacy process and the outcomes achieved.
The range of issues addressed through the work of individual advocacy organisations is broad. NDAP
funded agency performance reports to The Department of Families Housing Community Services
and Indigenous Affairs (FaHCSIA) until June 2009 provided useful information about the kinds of
issues addressed. Some agencies continue to collect and publically report this information56. An
example of the range of issues addressed though individual advocacy is found in the Disability
Advocacy section of the Advocacy Law Alliance Annual Report 2010/1157.
Advocacy Issues
abuse/neglect
accommodation
discrimination or rights
education
employment
%
3.7
12.8
8.8
6.6
1.9
equipment
finances
health
1.5
10.6
3.8
Advocacy Issues
independent living
legal
physical access
recreation, social or family
service (gaps, access, policy, reduction
or complaints)
transport
vulnerable/isolated
other
%
5.9
16.9
1.2
1.9
15.3
1.6
6.6
1.2
The CRPD Shadow Report58 and the Shut Out Report59 provide examples of the kinds of matters that
advocacy agencies become involved in alongside people with disabilities.
Systemic Advocacy
Systemic advocacy seeks changes to legislation, policy and service practices to benefit a significant
number of people with disabilities. It takes up, on a regional, state or national level, rights and wellbeing issues for people with disabilities that are not suited to individualised solutions.
Advocacy agencies seek systemic change on behalf of people with disabilities:



when a systemic barrier prevents the successful resolution of a number of individual
advocacy matters; and/or
on the advice of a consumer representative committee established to provide advice in this
area and/or
at the direction of a governing board with a majority of people with disabilities
Every NDAP funded agency that carries out systemic advocacy will, in the next 18 months, for quality
assurance purposes, be required to provide evidence of how people with disabilities are involved in
their systemic advocacy decision-making.60
56
For example ACT Disability, Aged and Carer Advocacy Service (ADACAS), Annual Report 2010-2011, 2011 p.
20; Advocacy Law Alliance Inc. Annual Report 2010-2011, 2011 pp. 9-10, viewed 30 June 2012,
http://advocacylaw.org.au/wp-content/uploads/ALA-Inc-Annual-Report-Audit-short-form.pdf
57
Advocacy Law Alliance Inc. Annual Report 2010-2011, 2011 pp. 9-10, viewed 30 June 2012,
http://advocacylaw.org.au/wp-content/uploads/ALA-Inc-Annual-Report-Audit-short-form.pdf
58
Disability Representative, Advocacy, Legal and Human Rights Organisations, 2012
59
National People with Disabilities and Carer Council, 2009
[14]
How will Advocacy for Individuals change with an NDIS?
With the NDIS61 DANA would expect to see:62

people with disabilities growing in their desire to address rights and well-being issues in their
lives because they are becoming accustomed to exercising power over their lives and because
they begin to see a different picture of what their life might be
Example: A man, for twenty years of his adult life, has lived with his parents (his legal guardians).
When he receives his NDIS entitlement he wants to use it to move to the other side of the city to
live closer to his work and his workplace colleagues. He wants advocacy support to deal with his
parent’s total opposition to the move and their refusal to allow the DSO to work with their son to
plan for and manage the move.

people with disabilities growing in their confidence to self-advocate i.e. requiring more self
advocacy support and less representational support
Example: A woman, now in her 50’s, has through her life, required significant levels of support to
manage her personal care needs and had multiple experiences of abuse and neglect at the
hands of service providers. Prior to the NDIS, she asked her advocate to look for avenues of
resolution that did not involve her confronting her abuser or in any way threatening her
relationship with her service provider. With the NDIS and an ongoing entitlement to support, for
the first time she may feel free to challenge any abuse or neglect directly, by reporting the
perpetrators to the appropriate authorities, refuting their version of events and seeking justice
for herself and others in a similar position. She will now want advocacy support to enable her to
speak up effectively and safely.

a shift in the kinds of disability service issues to be addressed, with a lesser focus on service
access issues and a greater focus on dealing with contractual and consumer rights issues
Example: The NDIS will entitle a person with disability to choose their services from a range of
providers or individuals. The ongoing relationship between the person with disability and the
service provider will be defined by the nature and terms of the service or employment agreement
entered into. An agreement of this kind will give rise to legal rights and responsibilities. If a
relationship turns sour, significant and complicated issues can occur. Where the service provider
is a large organisation, it will have specialised complaints handling teams ready to respond.
Where the service is provided by an individual as an employee of the person with disability the
individual will have Union support. The person with disability will likewise want support from an
advocacy specialist to assist them to exercise their rights as consumers, employers and service
users.
60
Australian Government Department of Families, Housing, Community Services and Indigenous Affairs,
Disability Services Standards (Advocacy Standards) (FaHCSIA) Determination 2012
61
In the form recommended by the Productivity Commission, 2011
62
The examples in this section of the paper are derived from the experiences of advocates, working alongside
people with disabilities who have had the additional freedom, personal power and responsibilities associated
with managing or directing an individual support package or a compensation payout.
[15]

a shift in the kinds of issues to be addressed, with a lesser focus on disability specific issues and a
greater focus on using the support to engage in mainstream activities. This is because the
absence of necessary specialist disability support is a preliminary barrier to broader economic,
community and social inclusion of person with disabilities. If this barrier is removed, other
barriers will become more visible and require advocacy knowledge, skills and involvement to
resolve
Example: A boy with both intellectual and physical disabilities is excluded from involvement in a
nature studies project his class is working on because the project requires traversing rough
terrain. Prior to having an NDIS entitlement the boy could not access a suitable wheelchair for
the purpose. When the NDIS package is used to secure the loan of a rugged terrain wheelchair,
the teacher continues to exclude the boy because his involvement would require a change in the
way the project activities are conducted. The boy’s parents want advocacy support to try to
address this situation without damaging their son’s relationship with his teacher.

People with disabilities growing in their desire to make choices consistent with their interests
because they see the NDIS entitlement and flexibility offering them a greater likelihood of being
able to get a reasonable outcome.
Example: A woman has worked for many years in a supported employment service and has a goal
of ultimately working in a large hotel. She has been unable to achieve this because her service
provider/employer resisted unbundling her support dollars and downplayed her skills. With her
NDIS entitlement and self advocacy support she is now a better position to convince her family
and friends, her NDIS LAC, her DSO and a potential new employer that this is achievable and she
has the DSO and financial resources to make it happen.
What about Advocacy for Individuals will remain the same with an
NDIS?
Significant numbers of people with disabilities will continue to face major barriers to expressing and
implementing their wishes and be lacking in family support for this purpose. These people will
continue to need the support of individual advocates to ensure that their needs and wishes are
respected and addressed to the same extent as those with strong personal or family advocacy
resources.
There will continue to be public pressure to reduce taxes and hence to reduce the entitlement of
people with disabilities to ongoing support. Individual advocates will continue to assist individuals
with disability to make their case for a reasonable level of entitlement and support.
Polices and processes adopted by Government and service providers will continue to
disproportionately disadvantage certain individuals. Individual advocates will continue to assist
affected people with disabilities to make the case for an alternative approach that meets their
individual circumstances. In doing so, advocates assist in identifying and addressing system gaps.
Government and service workers will continue to make mistakes that they are unwilling to recognise
and correct. Individual advocates will continue to assist in the process of bringing errors to the
attention of the relevant authorities and seeking redress and rectification for affected individuals.
[16]
This work commonly has the effect of stopping small issues becoming significant problems,
preventing substantial damage to individuals and saving time and money in the long run.
Funding bodies will maintain a preference for ever increasing levels of control at the expense of
flexibility and autonomy for the person with disability.63 This is because inevitably some
individualised arrangements will come to public attention because they do not work well and
governments will respond with increasing regulation to manage the perceived risk. Individual
advocates will continue to assist the person with disability to assert their autonomy and right to
individualised self directed services.
Government and service workers will continue to bring to their work the same prejudices and
misunderstandings that are held in the broader community and many will come with an unhelpful
history of exercising control over people with disabilities. Independent individual advocates will
continue to model respectful ways of providing services and support to a person with disability and
make available information about alternative power sharing arrangements.
Individuals with disability will continue to be disadvantaged when their interests are in conflict with
those of their service provider, particularly if the service provider is a large organisation with
substantial resources and if it is not easy for the person with disability to move elsewhere. Individual
advocates in these circumstances will continue to assist in redressing the power, information and
skill imbalance.
People with disabilities will continue to experience multiple and many-faceted issues that are
incapable of resolution without the involvement of a variety of people and agencies (from across
government and the service system), each with their own scope of operation and limitations.
Individual advocates will continue to stand beside people with disabilities in such situations to insist
that the people and agencies with the potential to make a difference remain involved until
appropriate solutions are found.
Government funders and service organisations will continue to engage in quality assurance
processes that involve the consumers of their services. Individual advocates will continue to support
people with disabilities to engage effectively in these processes64 so that the processes are more
likely to lead to better service quality from a consumer perspective.
People with disabilities will continue to face barriers to effective inclusion and the realisation of their
rights in many areas of their life. Individual advocates will continue to support people with
disabilities to effectively assert their rights whenever they experience injustice, exclusion or
discrimination because of their disability.
People with disabilities who do not qualify for individualised supports through an NDIS will continue
to be unable to access necessary disability supports and so seek advocacy assistance and personally
tailored information to address rights, well-being and inclusion issues.
63
D Schwartz, Crossing the River, Creating a Conceptual Revolution in Community & Disability, 1992
64
See, for example, Joint Accreditation System of Australia and New Zealand,
Procedure Number 18 – Requirements for bodies providing audits and certification of disability
employment organisations, Issue No 3, 2008, pp. 3, 9 & 24
[17]
People with disabilities, their families and allies will continue to need information tailored to their
particular purposes about the rights and entitlements of people with disabilities and about advocacy
strategies that have previously been successful. They will also continue to need specifically targeted
training and advice to support their advocacy efforts.
For the reasons detailed above many people with disabilities will therefore continue to want the
support of an independent advocate (family member, citizen or paid) and/or access to information
personalised to suit their circumstances:







during eligibility or assessment processes
to challenge the merits of a decision
to challenge the validity of a procedure or process
when an issue or conflict arises with the funding body or specialist disability service provider
to resolve rights or well-being issues
to effectively engage in service quality processes
when an issue arises with a mainstream provider or system
This will be true even though a DSO or NDIA case manager may offer support because that support
will be incidental to their primary function, will probably not bring with it highly developed advocacy
skills or knowledge and will not reliably be partisan to interests of the person with disability due to
competing government and service interests.
How will an NDIS affect systemic advocacy?
It is anticipated that a properly funded NDIS should lead to a reduction in the requirement for
systemic advocacy to secure specific disability supports for those people who are identified as being
eligible for Tier 3 supports. It is not clear however whether the support situation will improve under
an NDIS for the very significant numbers of people with disability who will not qualify for Tier 3
supports but will still require a level of assistance to manage the ordinary activities of daily life.
Systemic advocacy will also continue to be required to address, on a systems level, many of the
same issues that have been identified above in relation to individual advocacy. It will therefore be
needed to:






ensure that all people with disability are able to access necessary supports and services
counter external forces seeking to reduce the public contribution to disability support
Identify and respond to gaps in the supports provided
Promote support options for people with disabilities that comply with the CRPD
Address the barriers to rights realisation, economic participation and social inclusion for
people with disabilities across all parts of society
Counter the tendency of governments to continually increase control over the expenditure
of public monies
[18]
DSOs and Independent Advocacy
Below, reproduced in it’s entirely, is the Productivity Commission Table 9.265 which provides a
comparison between the roles of LAC’s and DSO’s. A further column has been added to enable a
direct comparison of their roles with that of independent advocacy agencies. Not addressed here
but equally important is that independent advocacy organisations have similar roles to play
alongside people with disabilities in their interactions with the NIIS and in other government,
business and community spheres.
The key roles, described in Table below, of LAC’s ( administering NDIA funding in accordance with
NDIA policies and processes) and DSO’s ( assembling, brokering, administering and managing
packages of support) will commonly require LACs (as funder) and DSOs (as service provider) to give
priority to agency interests over those the person with disability. This means that their advocacy
support will be limited to matters incidental to the performance of their key roles and to matters
that do not conflict with their organisational interests. Additionally, they will bring predominately
administration and governance (LACs), planning and management (DSOs) knowledge and skills to a
situation rather than advocacy and justice knowledge and skills.
65
Productivity Commission 2011, p. 421
[19]
Role or
Function
Local area coordinator
(NDIA)
Disability Support
Organisation
Independent Advocacy
Assessment
As the key NDIA point of contact
with the person, their early
involvement (visits, learning about
the person, providing early guidance
and advice) will help inform the draft
assessment package.
Helps the person think more
broadly about the supports they
will need, and their life aspirations
(allows the person to approach the
NDIA assessment better prepared).
Planning
Immediate service planning,
including providing information and
advice on available supports;
indicators of quality; available local
community supports, resources and
activities to fulfil needs or
aspirations; and how to access other
government supports.
No role
Where needed, assist with short
and longer-term planning, focusing
on life possibilities, succession
planning etc. Will tend to be wide
ranging, iterative and require
creative solutions. (Some not-forprofits do this now.) NDIS-funded
where need has been assessed.
Additional funds provided as part
of the entitlement may be used for
brokerage if the NDIA assesses that
need. For others, hire DSOs on fee
for- service basis.
If the person wants self-directed
funding administration to be done
by the DSO, costs should be met
from the person’s cashed out
individual package
On request provides support (independent and partisan) to
the person to express their needs and wishes during the
assessment process.
On request supports (with advocacy skills and knowledge) the
person to challenge the validity or merits of an assessment.
On request supports the person to express their views in NDIA
Quality Improvement processes.
Conducts systemic advocacy to improve the assessment
process and outcomes for people with disabilities.
On request supports (with advocacy skills and knowledge) the
person to assert their right to be the decision-maker in the
planning process, for example, where any disagreement arises
with the LAC, guardian or the DSO.
On request supports the person to express their views in NDIA
and DSO Quality Improvement processes.
Conducts systemic advocacy to improve the planning process
and outcomes for people with disabilities.
On request supports (with advocacy skills and knowledge) the
person to take action in relation to concerns about the quality
of the brokerage that is provided.
On request assists/supports the person to express their views
in DSO Quality Improvement processes.
On request supports (with advocacy skills and knowledge) the
person to challenge decisions taken by others that prevent or
limit them in self directing their funding.
On request supports the person to express their views in
quality improvement processes connected with self-directed
funding policy and processes.
Systemic advocacy to improve government policy and
processes in relation to self directed funding.
On request supports (with advocacy skills and knowledge) the
person to claim equivalent rights to others across all aspects
Brokerage
Administration
of
self-directed
funding
packages
Provides guidance on suitability for
the person, and undertakes
compliance checking
Community
access
Operates on an individual level
through planning and assessment as
May be block funded to offer
community brokerage, community
[20]
and inclusion
described above
capacity building and community
awareness (chapter 4)
Regulatory
oversight
Would pass evidence of breach of
service standards or other service
problems to LAC
Resolution of
disputes
between
service
providers
and NDIS
participants
Periodic checks on people,
(according to degree of
vulnerability).
Contact point for complaints and
breach of standards (as LACs would
be the major source of information
for NDIS participants about service
providers). Able to initiate
investigation against service
providers, or pass to Office of
Inspector–General
Would seek to resolve more serious
conflicts. Has access to past
information on both person and
provider and authority to initiate
further investigation if necessary (or
to involve Office of Inspector–
General)
Where needed, may be involved in
resolving minor issues concerning
services the DSO has helped
organise, or in advising people how
to take their complaint further,
including how to contact advocacy
services
On request supports (with advocacy skills and knowledge) the
person throughout the entirety of any dispute with a service
provider.
Assist in
transitioning
from
one service
provider
to another
Can provide information, advice and
support to people transitioning (if
required). Where transitions occur
due to quality problems, LAC would
advise Office of Inspector-General
(see below).
People with a longstanding and
positive relationship with a DSO
may be most comfortable with
their advice and assistance in
transitioning. DSO would keep LAC
informed.
On request provides support (independent and partisan) to
the person to express their needs and wishes during a
transition process.
[21]
of the life.
Conducts systemic advocacy activity directed at rights
protection and promotion and community inclusion.
On request supports (with advocacy skills and knowledge) the
person to effectively present their viewpoint and supporting
evidence in any complaints process.
On request supports the person to express their views in
quality improvement processes connected with complaints
handling schemes.
Conducts systemic advocacy to improve the quality and
effectiveness of complaints processes in delivering positive
outcomes for people with disabilities.
Future Advocacy Administration and Funding
Having clearly established the role of independent advocacy into the future it then becomes important to
consider how this is best provided and to what level. To some extent the level of advocacy support required
in the future depends on how well the established system of services and support responds to the needs,
rights and interests of people with disabilities. This is difficult to estimate ahead of time, before it is known
what the system will look like, how well it will be funded and the extent to which it provides for consumer
control and service individualisation.
What is known, however, is that there is a vast pool of unmet need for advocacy support at present and
that agencies in some locations report prioritising to such an extent that people with very serious issues are
turned away in favour of those with survival level issues. We know also that advocacy support is even more
important at times of system change: to ensure that the experiences and knowledge of the people most
affected by it are able to influence the change process and the overall outcomes; and so that the
unintended impacts of previously untried policies and procedures and any system gaps are quickly
identified and addressed on an individual and system level. Additionally we have identified above, ways in
which the demand for advocacy is likely to grow and change in the proposed new system.
This all points to a need to ensure that the accepted models of independent advocacy support are
available on request to people with disabilities and their allies throughout the country to safeguard the
rights and well-being of people with disabilities entering the new system and to assist in the
implementation of the NDS. Currently, not all forms of advocacy support are equally available to people
with disabilities in all locations. The mapping exercise recently undertaken by FaHCSIA will hopefully point
to the gaps and limitations in the current availability of the different models of advocacy across the
country. A gap analysis, when added to the information provided in this paper, can then pave the way for a
sensible discussion about how to address the unmet need for independent advocacy support in this
country.
This paper has shown the important contribution that independent advocacy makes, as one of the suite of
disability specific NDA funded supports, to enabling people with disabilities to achieve the NDA objectives
of an enhanced quality of life and valued community participation. It has also shown that independent
advocacy will continue to be important,66 for these purposes when we have an NDIS and NIIS and that its
‘independence’67 is critical to its effectiveness. For this reason the minimum level of funding dedicated to
independent advocacy support should be a defined percentage of the NDIS and NIIS (and any other
disability specific) funding pools. This funding should however be administered by a government agency
that is at arms from the NDIS or NDIS.
For some time DANA has argued that the work of administering the government funding program for
independent advocacy support for people with disabilities should be carried out by a national statutory
authority. This authority, operating free from the influence of the NDIS or NIIS, would take receipt of the
defined percentage (discussed above) of the insurance (and any other disability specific) monies and
distribute it to independent advocacy agencies through direct funding arrangements.68
66
For people who fall within Tier 2 or Tier 3
From service providers and from the NDIS and NIIS
68
As recommended in Productivity Commission 2011, p. 524 because advocacy work undertaken is in the nature
of a public good with potential to benefit many people with disabilities.
67
[22]
The authority would also take responsibility for





Promoting the value and importance of independent advocacy
Advocacy sector planning and development
Management of core recurrent advocacy funding perhaps via State based officers
Oversight of the Performance Reporting and Quality Assurance Framework for advocacy providers
Research in relation to advocacy practice, administration and demand
If the proposal to create a National Statutory Advocacy Authority is not accepted, the next best alternative
would be for independent advocacy funding to be administered by one of the following:


A Commonwealth Department that is not linked to the NDIA or NIIS
State Departments not linked to the NDIA, the NIIS or to other services commonly subject to
advocacy.
In making this decision and in designing an Advocacy Program for the future it will be important to have
regard to the intended governance arrangements for the NDIS and NIIS, the implementation plan for the
NDS and the key principles identified in DANA’s 2010 paper ‘A Proposal for A New Administrative and
Leadership Framework For Disability Advocacy’ as follows:
1. ‘Government should provide core recurrent advocacy funding on the basis that independent
advocacy is a fundamental and essential support for vulnerable people with disabilities.
2. Program administration and funding should be separate from political or government influence
because advocacy is commonly directed against government agencies or services provided under
government funded programs.
3. To minimise the possibility or the perception of conflict of interest, advocacy support should be
provided only by dedicated advocacy organisations that do not also undertake service provision.
4. Individual advocacy support should be available in a variety of forms to all people with disability.
5. Systemic advocacy capacity should exist in each state/territory to respond to the range of issues
that impact on the rights, interests and needs of people with disabilities.
6. Specialist advocacy support and advice should be available across Australia for specific population
groups and where specific advocacy knowledge is required.
7. Advocacy organisations should be formed in consultation with and remain connected to local
communities.
8. Advocacy organisation funding should provide for advocacy development...
9. Advocacy organisation funding should provide for the development of relationships with key
organisations and agencies...
10. Advocacy organisation funding should be at a level to ensure the viability and sustainability of the
organisation...
11. Government funding for the Advocacy Program should respond to the unmet need for
advocacy...’69
This publication has been prepared by the Disability Advocacy Network Australia (DANA) Ltd for the Australian
Government, represented by the Department of Families, Housing, Community Services and Indigenous Affairs.
The views expressed in this publication are those of Disability Advocacy Network Australia (DANA) Ltd and do
not necessarily represent the views of the Australian Government.
69
Disability Advocacy Network Australia (DANA) Ltd, A Proposal for A New Administrative and Leadership Framework
For Disability Advocacy, 2010, p 19, viewed on 30 June 2012, http://dana.org.au/submissionspublications/submissions/
[23]