Vision Australia Submission

26 February, 2008

Senator the Hon Joe Ludwig, Minister for Human Services Manager of Government Business in the Senate Senator for Queensland

Via email: Minister@humanservices.gov.au CC: Jacky.Fogerty@humanservices.gov.au

Dear Minister Ludwig,

Vision Australia appreciates this opportunity to comment on the effectiveness of the Job Capacity Assessment and Job Capacity Account services in meeting the needs of people with barriers to employment. We would like to thank you for consulting with Vision Australia in our dual capacity as Australia’s largest blindness and low vision service provider, and as an organisation which has both a specialist disability employment network service and two supported employment services.

We certainly agree with your perspective that:

“to be socially included, people must be given an opportunity to secure a job, as well as to access the services they need, to connect with others, to deal with personal crises such as ill health, and to have their voices heard.”

Your consultation around these programs is timely as Robyn McKenzie, Executive Officer of Blind Citizens Australia, and I met with staff from your Department in December to discuss concerns particularly around job capacity assessment and its applicability for people who are blind or have low vision.  During the discussion with the DHS staff Robyn and I drew attention to several aspects of the assessment process which are causing difficulty and sometimes even withdrawal from the process, for jobseekers who are blind.  I have addressed these below under the specific areas you raised in your letter for comment.

• Job Capacity Assessment Guidelines, particularly as they relate to assessment and referral practices;

Vision Australia struggles to see how the current JCA interview and referral process adds value for the majority of our client group –  jobseekers who are blind or have low vision.  The process can actually become a barrier to clients successfully seeking employment – they are fearful of losing their benefits and the system is often so bureaucratic, that jobseekers can give up the idea of voluntarily seeking employment through our Disability Employment Network (DEN) service.

In the past, people with a disability were able to either be referred directly by Centrelink to a specialist disability employment provider or could even go directly to that service which then sought approval from Centrelink prior to commencing employment related services.   Under the current arrangements jobseekers with a disability “must” go through the JCA process even if they are a long standing client of an organisation such as Vision Australia or they voluntarily seek employment as an existing DSP (blind) recipient.  This confuses clients and they often think that Vision Australia is responsible for the unnecessarily complicated JCA process.

Clients often have no understanding of what is happening to them, or why, when they go through the JCA and Centrelink referral process.  We are commonly confronted with clients who are told that their Disability Support Pension (DSP) Blind will be reviewed as part of the process even though they are totally and permanently blind.

The documentation and forms required in commencing and during the JCA process are also generic in nature and have successfully scared off some voluntary jobseekers.

It takes an average of two months for clients to commence a service, due to the overly extensive assessment process they need to go through.  Clients have to prove their disability, undertake a Job Capacity Assessment and agree to a review of their pension.  Many clients are lost during this overwhelming process.  Given that the majority of Vision Australia’s clients are already assessed as eligible for DSP Blind, and that these clients would access the program as voluntary participants, it would make sense that this should make them automatically eligible for the DEN program.  The more rigorous assessment processes could be reserved for people not in receipt of Disability Support Pension.

• The appropriateness and range of the qualifications necessary for Job Capacity Assessors to undertake assessments of people with different disabilities, including those with a mental illness;

In our experience the job capacity assessors generally lack knowledge about the capacity to work of people who are blind, have low vision or are deafblind.  We also find that they have little awareness about specialist employment service provider organisations such as Vision Australia.  This has been exacerbated by the requirement that jobseekers must access a JCA within their local area.  Under previous arrangements Vision Australia’s employment staff were able to establish effective working relationships with one or two key JCAs who then developed some expertise in blindness and vision impairment.  This strategy is no longer allowed.

It is not uncommon for us to receive a high number of inappropriate referrals – several per week – due to the inexperience of the JCAs with blindness and low vision and lack of knowledge of Vision Australia as a specialist DEN provider.  This is not an unexpected situation given that blindness and vision loss is a low incidence disability and JCAs would only be seeing one in the many of hundreds of jobseekers they are assessing who happens to be blind or has low vision.

• The quality of information recorded during the assessment process, including whether this is sufficient to assist agencies making decisions on income support and/or employment assistance;

In discussing this element with Vision Australia’s employment services staff they were unanimous in saying that the JCA process provides them with little or no information they could use to better assist the jobseeker.  They also feel that there is an apparent lack of awareness by JCAs and some Centrelink staff about the system and procedures of referral and benefits.  In some instances this has led to clients of Vision Australia being misinformed about their entitlements and/or having benefits withdrawn.

Other elements of concern are that some job capacity assessment reviews are simply done using medical records with no actual interview with the jobseeker, and there is a requirement for medical information to be current.  We believe that there is little faith in a system which is supposedly about assessing work capacity where there is no contact between the jobseeker and the JCA.

A key concern for many of Vision Australia’s clients is that given they are permanently blind or have an irreversible sight loss that they are required to obtain a current medical report.  Many of our clients have not been to an eye specialist for many years and have no relationship with a doctor who could provide a report.  It seems unnecessary to require such a report from someone who has a permanent and irreversible disability.

• The appropriateness of arrangements to ensure attendance at Job Capacity Assessments;

It is not uncommon for Vision Australia’s employment staff to support clients to access job capacity assessors and to support clients to attend JCA interviews even though the client may not be linked to Vision Australia as an employment client.  This is particularly the case given that the jobseeker is not referred to an employment service until they have gone through the job capacity assessment. 

It can also be quite onerous for a person who is blind or has low vision to physically access a range of sites.  We often find that in working with clients who want to become jobseekers that they are reluctant to physically go to a Centrelink office to commence the jobseeking process even though we support them to complete the required forms.  Most of the reluctance is around having to go to an unfamiliar place, the Centrelink office, and then knowing they will need to locate the JCA office to attend an assessment.

Our staff has also experienced significant difficulty contacting JCAs about referrals even though that is expected of the JCAs.  An example recently was where a JCA made an inappropriate referral to our service, the jobseeker had no vision impairment, and the JCA was only contracted one day per week.  This experience was not an isolated incident as there appears to be a real problem with continuity and availability of JCAs.

• Key strengths of the current arrangements and any lessons for the future, from your knowledge of current and past arrangements in Australia and internationally.

While we have not had a generally positive experience of the job capacity assessment process we fully understand the principle behind the program.  We strongly believe that there needs to be a form of assessing capacity to work and to best determine which level of employment service a person should be referred to.  We are of the view however that people who are blind or have low vision are best served by providers that have specialist knowledge of the practical and functional affects of blindness and sight loss.

In Vision Australia’s experience we find best success where the jobseeker has an opportunity to develop work related skills and is job ready before launching into the jobseeking phase.  Overall the JCA process, in our opinion, neither provides job related skills nor effectively assesses job readiness from the perspective of the practical implications of blindness.

Vision Australia recently undertook significant research into employment for people who are blind or have low vision.  I have attached the overview of the study and findings.

We are keen to work with you, and other Departments which have some responsibility around employment policy and implementation.  .  In that regard, Vision Australia is eager to meet with you and your Department to discuss the findings of our employment research and the issues you have raised in your consultation.

Kind regards,

MICHAEL SIMPSON General Manager Policy and Advocacy