National Disability Authority

1. Monitoring implementation of the NDA’s Code of Practice on accessibility of public services and information provided by public bodies National Disability Authority

2. Background to the Report: Section 8 (1) (2) (d) of Part II of National Disability Authority Act, 1999, requires the NDA to “monitor the implementation of standards and codes of practice in programmes and services provided to persons with disabilities and to report to the Minister thereon”.

3. Background to the Report: Section 30 (1) of Part 3 of Disability Act, 2005 states that: “The Minister may request the National Disability Authority (“the Authority”) to prepare and submit to him or her draft codes of practice for public bodies relating to the matters referred to in sections 26 to 29” of the Disability Act.

4. Method: • … Questions • Approach: Timelines … annually? … when to start? • Methodology: Almost 570 bodies .. visiting each for spot checks impractical on an annual basis • Models and Guidance: e.g. the U.K.’s Disability Rights Cmsn’s compliance notice approach

5. Method: • Independent research by Goodbody Economic Consultants indicated that: • Given our legislation, a supportive and developmental model of monitoring would be best (a ‘lots done, more to do; how can we help’ vs. ‘Oi! Sort it!’ type approach) • Given the number and range of bodies to be monitored and NDA’s resources, a self-report postal survey would be likely to prove the most practicable and effective methodology

6. The Questionnaire: Questionnaire follows structure and provisions of the Code Complaints Best Practice Key Challenges Developed in consultation with all key stakeholders 73 formal submissions

7. Final Response Rates: The finalized questionnaire was circulated for completion to 568 bodies. We received completed returns from 203, giving a final return rate of 35.0% from a diverse range of bodies from all parts of the country. This rate of return allows us to be 95.0% confident that the information we have gathered is reflective of the public sector overall. Other quality assurance strategies: identification and follow up of key non-responders.

8. 15 Key Positive Findings: • All survey respondents showed awareness of the Code’s requirements (qualifications and apologies rather than inappropriate n/a’s and objections) • All survey respondents reported having taken at least some initiatives to improve accessibility • 70% reported completing a formal access audit review of significant aspects of their services • Many of those that have not, intend to do so in the near future • 84% reported developing and implementing action plans to address issues raised in their access reviews and audits • 84.5% reported ensuring the availability of appropriate expertise in relation to accessibility matters

9. 15 Key Positive Findings: • 55.5% reported regularly consulting with people with disabilities in relation to accessibility matters and having learned some important lessons in so doing • 71.5% reported having at least one access officer • 66.4% reported that their access officers have received training and many indicated their association with important accessibility initiatives across their organisations • 72% reported having a procedure on how to make arrangements to assist a person with a disability to access their services, if requested and all survey respondents indicated at least some assistance initiatives to date

10. 15 Key Positive Findings: • 60.5% of bodies with their own website reported having them audited for accessibility and almost half of these were AA or AAA level compliant • 82.5% reported having a procedure in place for written complaints under the Disability Act - and making this known to customers • 8.5% of survey respondents reported having received complaints under sections 26, 27 and 28 of the Disability Act • 55.5% reported appointing inquiry officers to handle complaints received under the Disability Act • Many survey respondents report very commendable, ‘best practice’ initiatives in improving the accessibility of the information and services they provide

11. 3 Key Negative Findings: • Less than half of survey respondents reported having policies and procedures in place to ensure the provision of information in accessible formats, when requested • Less than half of survey respondents reported having policies and procedures in place to ensure that goods and services supplied to them are accessible to people with disabilities • A number of survey respondents report that they are experiencing significant challenges in trying to improve accessibility

12. Conclusions: • Regarding the 35.0% of public bodies that made returns: • ample evidence of awareness and commitment • many important achievements • a small number of important areas of under-achievement, requiring particular, urgent attention • some notable examples of best practice • Regarding the remaining non-responders: • possible lack of completeness or confidence in implementation and compliance achieved at the time of the Survey? • some new organisations will require time to address accessibility issues

13. Recommendations: • Arranging formal access audits and reviews and developing action plans • Ensuring appropriate expertise and consultation with people with disabilities in relation to accessibility matters • Appointing and training of access officers under the Disability Act, 2005 • Developing procedures on making arrangements to assist a person with a disability • Developing policies and procedures on providing accessible information • Arranging website accessibility auditing with a view to achieving AAA compliance • Developing policies and procedures on accessible procurement • Promoting of accessibility initiatives undertaken • Implementing effective, accessible complaints management systems • Making use of NDA supports to help meet challenges experienced in trying to improve accessibility.

14. Our final comments: • The NDA would like to: • encourage all public bodies to continue to progress the accessibility agenda within their organisations • remind public bodies of the various supports we have made available to them.