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Appendix 10 Report on performance in implementing the Commonwealth Disability Strategy

The Commonwealth Disability Strategy (CDS) requires Government agencies to report progress in achieving inclusion and participation by people with a disability in Commonwealth Government policies, programs and services in their annual report. This appendix reports the Department’s performance in its policy adviser, regulator, purchaser and provider roles against the performance indicators established by the CDS.

General performance (relevant across all roles)

The Department supports equity of access to all its policies, programs and services to ensure that people with a disability are empowered and able to access the services required to achieve economic and social participation.

All relevant policy announcements/media releases, submissions to the Department, grant program guidelines and publications adhere to plain English principles and are available in accessible formats on the Department’s website. Where appropriate or on request, interpreting services are used to translate information materials into other languages and formats, including Braille and audio.

The Department’s website incorporates contact details for the National Relay Service/TTY under its contact section and all contact centre staff are aware of procedures to follow if callers need assistance.

From January to June 2009 the Department commissioned an independent consultant, recommended by the Australian Government Information Management Office (AGIMO), to conduct independent audits for accessibility of all key departmental websites. Departmental websites available for archival purposes only were not within the scope of the audit project. All audited websites were found to conform to the minimum government guidelines with a number of sites exceeding the minimum accessibility requirements. All web development for the Department’s sites is done in accordance with and tested against World Wide Web Consulting (W3C) standards for accessibility.

The Department’s Service Charter 2008–10 places a high value on ensuring our clients have equal access to relevant information. The Department responds promptly to any requests and to any concerns raised by members of the public about the accessibility of material.

Policy advisor role

The Disability sector is a prominent portfolio stakeholder and during 2008–09 the Government made it a priority for consumers to have a strong voice and protections in the emerging environment. In its policy development and program design, the Department recognises that people with disabilities face additional barriers when it comes to participating in everyday life. Through its objectives to improve broadband, broadcasting and communications service availability, reliability, quality and affordability the Department’s work has the potential to provide people with disabilities with new opportunities for increased social and economic participation.

The Department’s involvement in the establishment of ACCAN has strengthened consumer representation in respect of disability issues. ACCAN will be an Expert Advisory Committee on disability issues in the communications sector and provide a strong voice for consumers in policy and industry code of practice development.

During 2008–09, the Department provided funding to 17 consumer representation organisations through its section 593 Telecommunications Consumer Representation and Research Grants to enable their attendance at meetings of the Communications Alliance’s Consumer and Disability Councils. The Department also collaborated with Telecommunications and Disability Consumer Representation (TEDICORE) on organising the Signposts for Change: People with Disabilities and Telecommunications Forum attended by 32 representatives of the disability sector.

Table 4.13 Consideration of the needs of people with disabilities in policy development
Performance Measures	2008–09 Results
Percentage of new or revised policy/program proposals that document that the impact of the proposal was considered prior to the decision making stage.	The Department’s processes and templates for the development of new policy or the revision of existing policy and preparation of Cabinet submissions include mandatory consideration of the impact of proposals on different community groups.
Percentage of consultations about new or revised policy/program proposals that are developed in consultation with people with disabilities.	In developing and reviewing policy and legislation the Department routinely consulted widely with interested parties and designed consultation processes that supported the participation of those most affected and provided time for people to comment on policies and proposals. At the Signposts for Change: People with Disabilities Forum accessibility was assured through provision of wheelchair access, Auslan interpreting, live captioning, materials in accessible formats, access for the vision impaired and hearing loops.
Percentage of new, revised or proposed policy/program announcements available in a range of accessible formats.	All relevant policy announcements/media releases, submissions to the Department, grant program guidelines, were made available in accessible formats on the Department’s website. During 2008–09 the Department also produced audio files (available as a CD and on the Department’s website) as well as 10 braille copies of the National Broadband Network Regulatory Discussion Paper, 20 braille copies of the ABC SBS discussion paper and eight braille copies of the Independent Disability Equipment Program Feasibility Study for people with a vision impairment. The terms of reference for the Independent Disability Equipment Program Feasibility Study Forum were provided in rtf format on USB flash drives to all vision impaired participants.
Time taken in providing announcements in accessible formats.	The Department responds promptly to any requests or concerns raised by members of the public about the accessibility of material.

Regulator role

In line with Government Policy, the Departmental Regulatory Plan is available on the Department’s website in an accessible format. Plain English principles were followed in all publications, including explanatory legal material in Acts, Regulations and Instruments, available on the Department’s website.

All legislative instruments made, are posted on the Federal Register of Legislative Instruments (FRLI). All documents on FRLI are accessible on ComLaw (a publicly available website managed by the Attorney-General’s Department) and published in multiple formats.

Table 4.14 Timely delivery of information in accessible format
Performance Measures	2008–09 Results
Percentage of publicly available information on regulations and quasi-regulations requested and provided in accessible electronic formats; and accessible formats other than electronic.	No requests received.

Purchaser role

All open tender processes were available online, with all tender documentation available in PDF format for security reasons. Information on how to request tender documentation in alternative formats was included in all tender documents.

All of the Department’s grant/funding program guidelines were available online (generally in html format).

The Department’s standard contract terms and funding deeds required compliance with relevant legislation including the Disability Discrimination Act 1992. Draft contracts were supplied with all standard requests for tender.

Table 4.15 Reflecting the needs of people with disability in Commonwealth purchasing
Performance Measures	2008–09 Results
Percentage of publicly available purchasing specifications requested and provided in accessible electronic formats and accessible formats other than electronic.	No requests received.
Percentage of processes for purchasing goods or services that directly impact on the lives of people with disabilities that are developed in consultation with people with disabilities.	All purchasing specifications of goods and services that directly impact on the lives of people with disabilities incorporate accessibility requirements. For example the Request for Tender in relation to the supply, installation and demonstration of a high definition set top box to eligible households in the Household Assistance Program stated that a high priority will be placed on ensuring that the set-top box supplied is suitable for the elderly and people with disabilities.
Percentage of purchasing specifications for goods and services that specify that tender organisations must comply with the Disability Discrimination Act 1992.	All tender specifications for goods and services advise that tender organisations must comply with the Act. The Department’s standard templates and tools used to generate non-standard tender documentation contain clauses to this effect.
Percentage of contracts for the purchase of goods and services that require the contractor to comply with the Disability Discrimination Act 1992.	All contracts entered into by the Department for the purchase of goods and services contain provisions requiring the contractor to comply with the Act. The Department’s standard contract templates and tools used to generate non-standard contracts contain provisions to this effect.
Established complaints/grievance mechanisms, including access to external mechanisms, in operation.	The Department’s complaints/grievance mechanisms include: Feedback processes are outlined in the Department’s Service Charter (see Provider role) The Department’s website also provides information about how citizens are able to resolve complaints about services provided by the broadband, broadcasting and communications sector where the Department’s responsibilities are limited to policy and regulatory roles. In these circumstances consumers are encouraged to resolve their complaint with the relevant service provider and to escalate to the Telecommunications Industry Ombudsman or the Australian Communications and Media Authority as appropriate.

Provider role

The Department measures client satisfaction through an annual Client Service Survey. More information about the survey is reported in the ‘Performance Review’ section of this report.

The Department has effective internal audit and evaluation programs which test policy and procedural compliance and performance and examine opportunities for improvement in the Department’s administration and communication of its programs. More information about these activities is reported in the ‘Management and Accountability’ section of this report.

Table 4.16 Customer service to people with disabilities
Performance Measures	2008–09 Results
Evidence of quality improvement and assurance systems in operation.	The 2009 Client Service Survey demonstrated statistically significant improvements in the Department’s website, administration of funding programs, providing further contact information in written correspondence, courtesy and politeness, technical competence and complaints handling. Client satisfaction with the Department’s sensitivity to diversity decreased slightly from 97 per cent in 2008 to 96 per cent in 2009 however the proportion of clients rating the Department’s sensitivity to diversity as good or excellent increased from 77 per cent to 79 per cent. In 2009, the Department commissioned an independent consultant to audit the accessibility of Departmental websites from January to June 2009. During this period, websites for the Department, the Senator the Hon Stephen Conroy, Stay Smart Online, the Online and Communications Council, the Regional Telecommunications Review and NetAlert were found to comply with all relevant checkpoints and standards. The Department’s E-security Education Package—available online at www.staysmartonline.gov.au—was also audited and found to comply with all relevant checkpoints and standards. All web development for the Department’s website was undertaken in accordance with and tested against World Wide Web Consulting (W3C) standards for accessibility.
Established service charter that adequately reflects the needs of people with disabilities in operation.	The Department’s Service Charter 2008–2010 complies with Department of Finance and Administration’s ‘Client Service Charter Principles’ and addresses accessibility and diversity issues, through the provision of a wide range of contact options, and through clearly set out service standards that include sensitivity to diversity issues. The Charter applies to clients in the Department’s policy advisor, regulator, purchaser and provider roles.
Established complaints/grievance mechanisms, including access to external mechanisms, in operation.	The Department’s Service Charter 2008–2010 alerts clients to an electronic feedback form on the Department’s website and outlines arrangements for contacting the Department to resolve complaints including escalation of complaints to supervisors and the Client Service Manager where appropriate. The Charter also provides the Commonwealth Ombudsman’s contact details. In the Department’s Client Service Survey, three per cent of clients indicated they had lodged a complaint with the Department with 52 per cent of those clients stating they were satisfied with how the complaint was handled. This compares with 25 per cent satisfaction with complaints handled in 2008. The survey did not identify whether any of the complaints concerned discrimination or accessibility. Three formal service complaints were received by the Manager Corporate Strategy and Performance Reporting as the Client Service Manager in 2008–09. In each case as the complaint was the initial contact between the complainant and the Department it was referred to the relevant program area for resolution. All cases were resolved to the satisfaction of the client and none of the complaints concerned discrimination or accessibility.