Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697637951849.pdf (Australia)
Purpose, intent and adequacy of the Disability Support PensionSubmission 27 1.1 About Catholic Social Services Victoria (CSSV) CSSV is the peak body for 44 member agencies delivering a wide range of Catholic community and social services to over 200,000 people every year across the State of Victoria.

A list of our member agencies is at Attachment 1 to this submission.
Our shared Christian mission is to love and serve our disadvantaged neighbours in the light of the human dignity they bear as persons made in God’s image, no matter how difficult the circumstances they may face.

Inspired by Jesus Christ’s life, death, healing and teaching ministry, we and our member agencies are called to hear and stand with the poor and marginalised, and to work for a just, equitable and compassionate society.
Further information about CSSV is available on our website: www.css.org.au Several of our member agencies are engaged in focused care, support, provision of accommodation and advocacy for people with a disability, including those experiencing mental illness.

We are particularly grateful to Sacred Heart Mission, St John of God Accord, The St Vincent de Paul Society in Victoria and VMCH for generously assisting us with particular expertise and data to inform this submission.
1.2 Catholic approaches to the concept of disability The liberating principles of Christ and Catholic Social Teaching promote the common good — that no part of society can flourish if other parts of society miss achieving their gifts.

Rather than engaging in a one-way exchange relationship with people with disability, we believe that they are a gift to the community, not a burden.

They remind us that we all have inestimable value and great vulnerability.
But consulting with our member groups shows that even with mechanisms in place such as the DSP and despite the big steps forward through the NDIS there are still many people with a disability and their families who miss out on supports they are entitled to, or need to participate fully in social and economic life.
CSSV strongly affirms all efforts to improve both quality and quantity of personal, familial and systemic supports so that those with disabilities can express their God-given dignity and rights and ‘be helped to participate in every dimension of family and social life at every level accessible to them and according to their possibilities.”1 This is broader than just providing charity and services.

It requires society to ensure access to and participation in a full community life.
As Pope Francis has also said: “Many persons with disabilities feel that they exist without belonging and without participating.

Much still prevents them from being fully enfranchised.

Our concern should be … to ensure their ‘active participation’ in the civil and ecclesial community.

(Fratelli Tutti, 2020, 98).


1 Pontifical Council for Justice and Peace, Compendium of the Social Doctrine of the Church, 2004, para 148, at http://www.vatican.va/roman curia/pontifical councils/justpeace/do cuments/rc pc justpeace doc 2006052 6 compendio-dott-soc en.html 2 Purpose, intent and adequacy of the Disability Support PensionSubmission 27 Legally blind lawyer and theologian Dr Justin Glyn SJ, who authored the Catholic Social Justice Series No.
83 in 2015 reminds us that those with a disability are: “’Us’ Not ‘Them’”.2 He provides a definition for understanding disability: “Many of us would see our impairment as the mental or physical lack of function or form, for example optic nerve damage, which we experience.

Our disability, on the other hand, would be the interrelation between the impairment and the social and physical environment that prevents us enjoying life to the full”3.
He argues that “impairments are simply points on the spectrum of enfleshment of the image of God”, and impairment highlights the fact we are interdependent as a community, and that our different gifts within the community supplements the weaknesses and limitations of others, and that all of us are limited in some way, and all of us have something to give.
Mechanisms such as the DSP are one way that we as a society share mutual support of each other, is one material way of working towards full participation of life in Australia, and should be approached from this grounding if they are to be truly useful.

2 Recommendations 1.


The Disability Support Pension be considered as a responsive financial base that someone can live reasonably from, that works in the context of other additional supports made available depending on the particular impairment of an individual 2.
The Government set fair and reasonable DSP eligibility requirements and fast processes that take into account the complexity of individuals’ situations, comorbidities and impairments, and generally better reflect the complexity of fluctuating conditions or illnesses, rapid onset of disease, and injury from accidents 3.

Greater collaboration is pursued between Federal agencies to reduce the burden of the multiple assessments currently required for people with disabilities 4.
Reform Australia’s welfare system through the establishment of an expert review panel to examine and make recommendations on the adequacy of all welfare payment rates, including pensions.

Increase the rate of the DSP 5.

The DSP should be able to be held flexibly to meaningfully support trial and temporary participation in the workforce.

The DSP should act as a safety net that can be relied upon and be responsive to income from other streams without people being removed from the pension 6.
Assessments should be streamlined and the ‘burden of proof’ should be reduced 2 Justin Glyn, “’Us’ Not ‘Them’”: Disability and Catholic Theology & Social Teaching, Australian Catholic Bishops Conference 2019.

3 Justin Glyn, “’Us’ Not ‘Them’”: Disability and Catholic Theology & Social Teaching, Australian Catholic Bishops Conference 2019.

2 Purpose, intent and adequacy of the Disability Support PensionSubmission 27 7.
The Federal Government should partner with State Governments and the broader social services sector to build the 500,000 affordable and social housing units needed by 2026.

This will enable people with disabilities and who receive the DSP to be securely housed 8.

Accessible transport and responsive mobility allowances should be made readily available to all who are on a DSP 9.
The Government invest, alongside other employers, in programs which can assist in making workplaces accessible and the barriers to employment for people with disabilities reduced as far as possible 3 Introduction This submission is aimed at complementing the submissions written for this inquiry by organisations such as Catholic Social Services Australia and the National Council of the St Vincent de Paul Society, who both have broad knowledge of the support given and issues seen by Catholic social services and communities throughout Australia.
The content is derived largely from consultation with a number of our Victorian member organisations who work with people with disabilities as well as a range of supporting literature and previous work done by Catholic Social Services Victoria and like-minded organisations.

This submission brings a Catholic service- based perspective before the inquiry, and should be read and understood alongside the direct testament of people who live with disabilities.
We note that this inquiry is ongoing alongside a review being run by the Department of Social Services4 into the suitability of the Impairment Tables currently utilised to assess for the eligibility for a Disability Support Pension (DSP).

We urge the committee to seriously consider the issues raised by stakeholders that are noted in the Impairment Tables Review Issues Paper.

A relevant section of this paper is included as Attachment 2 to this submission.
People with disabilities bring about a richer society for us all.

Mechanisms that overcome barriers and support participation in all aspects of interdependent community and social life allows all people, including people with impairments be meaningfully connected and allow for the active sharing of different perspectives and life experiences, and assist us all to appreciate life in our shared society.
Being clear on the role of the Disability Support Pension: as a responsive financial base that someone can live reasonably from, that works in the context of other additional supports made available depending on the particular impairment of an individual, is one substantial and practical way society can increase the opportunity for fuller participation of people living with a disability, and enrich us all as a community and society.
4 https://engage.dss.gov.au/review-of-the-disability-support-pension-dsp-impairment-tables/ 3 Purpose, intent and adequacy of the Disability Support PensionSubmission 27 4 Eligibility Although about one in six (4.4 million) Australians have a disability 5, about 750,000 people received the DSP as at 20196.
There has been an overall decrease in people receiving the DSP over the past ten years, and there is shared concern from our members that many who should be in receipt of the DSP are being excluded, as well as a cohort of people who believe the application process to be overwhelming and therefore do not engage at all, as well as individuals who find the process of applying so onerous they are unable to begin or navigate it effectively.
The Guardian recently reported that some 100,000 disability support [pension] applications are made each year, but those who manage to complete job search requirements before applying make up a tiny fraction of overall claims.

About 30% of claims are granted each year, down from about 70% in 20117.
In 2019, a spokesman for Social Services Minister Anne Ruston said in a statement that the impairment tables used to assess eligibility are a big part of the reason for the reduction in numbers who are eligible for the DSP.

"The former Labor government amended the tables used to assess work-related impairment for DSP, which has significantly contributed to the decline in the number of Australians entering that payment.
"8 These changes have had significant impact on many, and workers and organisations with long standing commitments to supporting people with disabilities consistently have found the process of applying and eligibility criteria to be overly rigid and therefore overly exclusionary — and this means they have been ultimately detrimental to the welfare of many individuals who live with an impairment.

Attachment 2 details some of the changes to the eligibility process over the past years.
Many of these changes have impinged on the ability of individuals who would benefit from the DSP to secure it.

This inquiry is an opportunity for the Government to set fair and reasonable eligibility requirements that take into account the complexity of individuals’ situations, comorbidities and impairments, and ensure more people who need the support of the pension are able to access it.
Our members stated that there are many assessment demands placed on people with disabilities at different points in their life for all kinds of reasons, there could be greater collaboration and work done between Federal agencies which would allow less assessments that an individual is put through.
5 https://www.aihw.gov.au/repo rts/disability/people-with-disability-in-australia/contents/summary 6 https://www.aihw.gov.au/repo rts/disability/people-with-disability-in-australia/contents/inco me-and- finance/income-support 7 https://www.theguardian.co m/australia-news/2020/oct/01/nearly-14000-australians-with-disability-made- to-live-on-40-a-day-for-18-months-before-receiving-pension 8 https://www.abc.net.au/news/2019-09-12/disability-support-pension-applicants-diverted-to- newstart/11486164 4 Purpose, intent and adequacy of the Disability Support PensionSubmission 27 5 Adequacy of the DSP There is broad consensus from our members who provide services to people on a DSP (be them via the NDIS, or through more general community programs funded through other revenue streams, or homelessness services) that the level of income provided by the DSP is generally inadequate.
It should be increased.

Being on a limited income, substantially less than the minimum wage, means limited participation in society by people with disability, and this is a negative for all of us.

The current rate of the DSP means that individuals are often forced to seek support from crisis and other services on an ongoing basis to meet daily living requirements.
CSSV’s member organisation Vinnies Victoria noted that the highest cohort of callers to their community support ‘conferences’ (who mainly provide material aide, food, clothing, assistance with bills and other ‘everyday living’ needs and support) are those who are on a DSP – material aide and crisis support is often regular – about one third of total callers to the charity for the last financial year.
They have also seen that when there is an extra payment – such as the Economic Support Payment of $750 which was made recently, there is a significant drop in calls from DSP recipients.

This indicates a general issue of rate of pay being not enough to provide for everyday needs.
A typical scenario of someone living in supported accommodation as provided by a social services agency during our consultations is as follows: - - - 50% of an individual’s DSP can be taken by an organisation to provide food and bills etc., 25% (plus rent assistance allowance) is taken for rent, 25% (approximately $15.50 per day) of the DSP is left for a person for all day to day expenses – medications, leisure activities, special occasions, group activity fees, sport etc.
One organisation noted that they receive many requests for the waiving of fees associated with activities, due to the incredibly limited disposable income of people on the DSP.

This either comes at direct cost to the organisation or someone is unable to participate.

In this relatively ‘ideal’ and supported situation, the rate of the DSP provides an extremely modest budget that precludes recipients from many of the joys afforded to many Australians.
In Victoria, some people with disabilities live in privately run ‘Supported Residential Services (SRS)’ which are regulated in Victoria by the Human Services Regulator located in the Department of Families, Fairness and Housing.

“Each SRS determines the services it offers and its fee structure”9 and these SRS providers have been reported to typically take at least 90%, if not closer to 100%, of an individual’s DSP.
Many individuals who live in these places have co- morbidities, and due to the financial costs, have little if any disposable income to allow them to participate in life outside of their basic living requirements, and are very much reliant on their provider.
If someone is single and is living alone, or has children, or is in the private rental market, or has a disability that makes it difficult to use public transport or similar, or has other life complexities or co-morbidities as well as a disability, the current DSP rate of pay, at best, provides a significant and often detrimental restriction to the kinds of usual activities, diet and accommodation afforded to many Australians, and at worse, places someone in receipt of the DSP in abject 9 https://www2.health.vic.gov.au/ageing-and-aged-care/supported-residential-services 5 Purpose, intent and adequacy of the Disability Support PensionSubmission 27 poverty, homeless or at risk of homelessness, and in ongoing need of crisis support and emergency relief.
Rather than making a particular recommendation on the dollar amount that the DSP should be, CSSV supports CSSA’s recommendation there should be a reform of Australia’s welfare system through the establishment of an expert review panel to examine and make recommendations on the adequacy of all welfare payment rates, including pensions.
This panel should also consider overhauling the assessment criteria to better reflect the complexity of fluctuating conditions or illnesses, rapid onset of disease, and injury from accidents.

6 A need for more flexibility of the pension in regards to employment Employment is not always suitable for people with a disability, or those who are in receipt of a DSP.

However, employment is one substantial way positive participation in broader society takes place, and many people with disabilities work.
If the DSP was more flexible in its approach to employment income and eligibility, more people could feel safe to try out different roles, or engage in seasonal or casualised work.

The aim should be to reduce the daunting prospect of having to re-apply to the DSP, given that the current application process is considered demanding, stressful, time consuming, and overly rigid.
For those people with a disability who are able to work, the DSP could act as a solid and confidence-building platform that allows people to try out and trial roles or jobs that may be suitable.
The adversity and difficulty of the process of getting on the pension in the first place, and the seeming impossibility to be able to get back on the pension if a job doesn’t work out or it turns out isn’t suitable in the longer term, is a significant problem and was perceived as a potential barrier to participating in the workforce.
The arbitrary ‘Program of Support’ requirement was raised as an issue by members, and comorbidities or the impact of multiple impairments did not seem to be considered in the process of medical exemption for the job search requirement – “To avoid the 18-month job search requirement, they must have one stable condition that is so severe it warrants 20 points on these [impairment] tables out of a possible 30.
Those who are judged as having 20 points but across various conditions rather than one must first “demonstrate that they have tried to improve their work capacity”, according to the government”.10 If a supported and clear eligibility process is established, grounded in the principle that the DSP is a mechanism for greater participation in all aspects of society for an individual, and the pension remained as a flexible support and back up if work or employment was no longer made available or was no longer feasible due to a person’s impairment, people with certain disabilities could be more engaged in the workforce – and the DSP could be a key part of allowing them to be supported in this element of participation in society.
10 https://www.theguardian.co m/australia-news/2020/oct/01/nearly-14000-australians-with-disability-made- to-live-on-40-a-day-for-18-months-before-receiving-pension 6 Purpose, intent and adequacy of the Disability Support PensionSubmission 27 Our understanding is that the Disability Employment Service system will be reviewed.
It makes sense that the Government should invest alongside other employers at making workplaces accessible and the barriers to employment for people with disabilities reduced as far as possible.

Having a more flexible DSP could be one part of this, and having more overt incentives and financial support made available for employers to assist in addressing structural adaption and accessibility and addressing workplace culture to ensure attitudes of inclusion are normalised, is another.
7 The intersection of complex needs A disability is sometimes only one of the complexities that someone is dealing with – there is often an intersection of complexities surrounding someone with disability – sometimes someone lives with more than multiple impairments, or they have other illnesses that are made more difficult to live with particularly because of disability.

Different impairments may be ongoing, but debilitating symptoms come and go, depending on other factors.
These complexities should be taken into consideration when thinking through the eligibility and adequacy of the DSP allowance – people need to be understood within the unique context of their lived situation to be best supported.

There are general issues/problems/illness that contribute to the overall costs of living: medication expenses etc.

that are possibly amplified by an impairment.


The limited current rate of DSP can often mean that individuals and families are living hand to mouth, due to the limited and fixed income and the other complexities and costs related to living with a disability.

These stresses can further compound and increase the likelihood of other complicating factors.

People on the DSP are highly represented in the proportion of people who need Specialist Homelessness Services.
In its most recent Specialist Homelessness Services Annual Report released in December 2020, the Australian Institute of Health and Welfare (AIHW) indicates that 3.1% of clients had an NDIS package at the start of their support period and that 14.7% of clients aged 15+ had the Disability Support Pension as their main income11 The same report stated that these individuals required assistance with challenging social/behavioural problems (20%) and assistance for trauma (16%) more often than the general SHS population (12% and 13% respectively).”12 Consideration should be given to the complexity of each individual’s situation, and the DSP should be able to be responsive, as impairments cover a wide range of areas, and particularities are important to acknowledge and respond to.
7 Assessment Member agencies reported that there is a general sense of dissatisfaction of clients who have ongoing and permanent disability have to prove their disability at regular intervals to Centrelink 11 https ://www.aihw.gov.a u/reports/homelessness-servi ces/shsc-data-cubes/contents/specialist-homelessness-services- col l ection-shsc-data-cubes 12 https ://www.aihw.gov.a u/reports/homelessness-servi ces/specialist-homelessness-services-annual- report/contents/clients-with-disability 7 Purpose, intent and adequacy of the Disability Support PensionSubmission 27 or other agencies.
This puts a burden on families and friends, and can be a source of significant stress for persons with disabilities.

While there are some disabilities that may improve with time and different technologies or therapies, and there are supports that can assist with learning to manage various disabilities that will improve the quality of life and be useful to an individual, agencies stressed that this won’t mean that an individual will no longer be disabled, or necessarily become work ready.
Justification for the DSP for many diagnosis is simply an added burden and unnecessary, and can be harmful to many who have permanent disabilities.

8 Transport Members advocate that accessible and affordable transport is of vital importance to participation in society for people with disabilities, and the limited mobility pension is often insufficient.
It is our understanding that a mobility pension (which has a cap) can be attached to the DSP but also can be included as a part of a NDIS plan, which has greater flexibility in overall monetary terms.
While appreciating that there should be fair and reasonable contribution from individual with disabilities to transport costs, with the DSP being well under the minimum wage, this gives little flexibility to individuals who might have significant social anxiety or other needs related to their disability to make a decision about appropriate transport.
In regional centres, or rural communities, or in certain suburbs of urban areas, public transport is limited and ability to afford and run a car is particularly important.

Lack of transport options or inability to afford appropriate transport can directly contribute to social isolation.
This is the case for people comorbidities who are accessing specialist homelessness services: “Clients with severe or profound disability were “more likely to need assistance with transport (27%)13” and as reported by social service providers who provide day services and the like – affordable and appropriate transport is a general barrier to participation for a broad set of people with disabilities.
Transport, and the ability to afford different modes of transport, should be carefully considered when thinking about the appropriate consideration of a mobility allowance or overall amount of DSP.

In 2017, there were 18.8 million cars registered in Australia14 – it is safe to say a car is considered normal to own.
Owning a car may not be appropriate or necessary for people with impairments, however, this figure would indicate a community standard that owning a car is a normal thing, and meaningful participation in many aspects of life in Australia require access to a car.

Transport options provided by either the NDIS or as an attached allowance for the DSP should take this into consideration.
9 Concerns of Financial Abuse General concerns included the observation that there could be , especially in an NDIS service 13 https ://www.aihw.gov.a u/reports/homelessness-servi ces/specialist-homelessness-services-annual- report/contents/clients-with-disability 14https://www.abs.gov.au/AUSSTATS/abs@.nsf/Lookup/9309.0Main+Fea tures131%20Jan%202017?OpenDocu ment 8 Purpose, intent and adequacy of the Disability Support PensionSubmission 27 environment, some specific safeguards put into place for people on a DSP to protect them from financial abuse.
CSSV Members reported knowledge of instances, both suspected and validated, where people on the DSP were being financially abused.
This vulnerability was seen by some to be increased in recent years, as the NDIS has potential for carers and others to make decisions for the person who is in receipt of the DSP to easily leave a program should they seek or gain the support of workers who may come to be familiar with their situation, and there isn’t the ability for these workers to follow up with individuals once they have left, or have been removed, from a program of care.
10 Accommodation Vulnerability Purchasing a home, or even renting on the private rental market, is out of reach for many individuals who receive a DSP.

Our members and a number of reports tell us that many on a DSP are reliant on charities, material aid and crisis support to get by, and can be at risk of homelessness.

Greater investment in social housing is required to ensure that those on a DSP have the option to live in a safe and secure home.
Despite the incredible injection of funds by the Victorian State Government into building more social housing through their ‘Big Housing Build’, the need far outstrips this investment.

The Federal Government should partner with State Governments and the broader social services sector to build more social housing, given that Australia will need 500,000 new social and affordable homes by 202615.
By having consistent and affordable rent in secure long term social housing, alongside other supports, people who receive the DSP will have a greater opportunity to participate in all of the many great things life in Australia can offer.

11 Conclusion The DSP should be positioned as a platform for participation.

The eligibility requirements for the DSP should be broadened, and comorbidities, and multiple impairments should be able to be flexibly considered.
The rate of the DSP should be set by a newly established expert review panel who could make recommendations on the adequacy of all welfare payment rates and pensions.

Linked with services provided by the NDIS, and other community supports, the DSP could be a powerful mechanism to ensure that as a society we live true to the spirit of ‘us’ not ‘them’, which will enrich us all.
15 http://everybodyshome.com.au/our-campaign/mo re-so cial-and-affordable-homes/ 9 Purpose, intent and adequacy of the Disability Support PensionSubmission 27 Purpose, intent and adequacy of the Disability Support PensionSubmission 27 12.2 Appendix 2: Catholic Social Services Victoria Member Organisations The Following is an excerpt from the Department of Social Services 2020 Impairment Tables Review Issues Paper pages 11 – 1216 Changes Made to DSP since the Introduction of the Impairment Tables in 2012 Since the introduction of the current Impairment Tables on 1 January 2012, there has been a number of significant policy changes to DSP assessment and qualification criteria.
These changes are briefly explained below: DSP reviews for recipients aged under 35 From 1 July 2014, eligibility reviews were introduced for DSP recipients aged under 35 years, who were granted DSP between 1 January 2008 and 31 December 2011 (prior to the introduction of the revised Impairment Tables).

This measure also included review of a person’s evidence of participation in a Program of Support (POS).

The POS reviews component of the measure commenced on 5 January 2015.
Compulsory participation requirements From 1 July 2014, DSP recipients aged under 35 years with an assessed work capacity of eight hours or more a week were required to undertake a compulsory work focussed activity such as education and training, or engagement with a job service provider.
DSP reduced portability From 1 January 2015, DSP recipients travelling overseas can only continue to receive payment for a maximum of four weeks overseas within any 12-month period, unless they have been granted indefinite portability.

A recipient’s payment will cease if they remain overseas for more than four weeks.
Introduction of Government-contracted Doctors and removal of the Treating Doctor’s Report A revised assessment process for DSP was announced as part of the 2014-15 Mid-Year Economic and Fiscal Outlook and fully introduced from 1 July 2015.

The new process introduced the requirement for a Disability Medical Assessment by a Government-contracted Doctor (GCD), and replaced the Treating Doctor’s Report with the requirement for claimants to provide raw medical records in support of their claim.
This revised assessment process requires a claimant to lodge supporting medical evidence for the assessment of their claim, rather than the previous process of the treating doctor completing a template form titled Treating Doctor’s Report.

This information is used by Job Capacity Assessors and GCDs during their assessment of a person’s claim, along with, typically, a face-to-face assessment with the claimant.
The changes to the assessment process were implemented transitionally from January 2015 and initially only applied to certain DSP claimants under 35, beginning with claimants aged under 25 who lived in capital cities.

It was rolled out to all new DSP applicants from 1 July 2015.
16 https://engage.dss.gov.au/wp-content/uploads/2021/06/D21-536572-4168-DSS-Impairment-Tables-Review- FA-Accessible-.pdf page 11-12 11 Purpose, intent and adequacy of the Disability Support PensionSubmission 27 Existing Feedback Stakeholders have previously raised the following issues with the Department of Social Services.
          The criteria for a medical condition to be Fully Diagnosed, Treated and Stabilised (FDTS), The criteria for a ‘severe impairment’ can be difficult for people with episodic and fluctuating conditions, The assessment of co-morbidities under the Impairment Tables, The costs of gathering the required medical information, The potential gaps in the current Impairment Tables when it comes to the assessment of some medical conditions, The complexity of the claim process for DSP, The Program of Support requirement, The use of Government-contracted Doctors (GCDs), The challenge for people living in remote and regional areas to gather the required medical evidence.
12 Purpose, intent and adequacy of the Disability Support PensionSubmission 27