Strengths:

• The strategy title and its values of Equality, Participation and Choice place the framing of the strategy firmly in a rights-based context. In particular, the emphasis on engaging Disabled Person’s Organisations in policy/decision making, and the highlighting of disabled people’s right to self-determination and meaningful choices about their lives is welcome.
• The framing of the strategy as closely aligned with the UN Convention of the Rights of Disabled Persons (UNCRPD) is welcome. The principles of the strategy are borrowed from the UNCRPD Article 3.
• The stronger emphasis on a whole of government approach, coupled with clearer structures to support and oversee implementation is a positive step forward and addresses a major criticism of the previous strategy. This includes clearer accountability on lead and collaborating departments for strategy commitments documented, a ‘Programme Plan of Action’ to support implementation produced every two years, and a range of collaborative structures outlined to oversee and support implementation + increase DPO engagement. The establishment of a new unit in the Department of the Taoiseach will attempt to drive a more cohesive approach to implementation.

Concerns:

• The Strategy’s commitments are often aspirational, and in many areas, there is little detail in what concrete actions will be undertaken to achieve them. This is deliberate in that the Strategy proposes that more concrete actions will be contained in the associated ‘Programme Plans of Action’ which will be released every two years, with the first within three months of now. So, the impact of the strategy will ultimately rely on how well these commitments are translated into actions within those Plans, making it difficult to get too excited just yet.
• While DPOs are highlighted as central to delivery of the strategy, many are under-resourced, and they are many disabled-led organisations who could with support to develop their governance structures qualify as a DPO. We hope to see some detail on how DPOs will be supported to contribute (direct funding and capacity-building) within future Plans of Action.
• While the introduction of the strategy highlights that its “success will require the wholesale integration of Universal Design principles”, we believe that this could have been more strongly translated into related commitments in every pillar. While some actions attempting to advance a universal design approach are referenced under commitments 2, 8, 11, 12 and 22, there are two pillars with no immediately evident actions for same – ‘Employment’ and ‘Wellbeing and Health’.

Note that our mission relates to tertiary education and so our analysis of this pillar comes through that lens.

Strengths:

• AHEAD is pleased to see Action 2.6 with allocated responsibility to DFHERIS and its focus on using “Universal Design approaches to foster inclusion across all programmes”. However more clarity is required in the Action Plan such as how the department can support implementation of the ALTITUDE Charter.
• The commitment under Action 1.12 to expand the roll out of courses for people with intellectual disabilities initially funded under Path 4 phase 2 is a welcome development.
• The focus on continuing development of “flexible options and pathways which support and recognise the diverse needs of learners” (1.11) chimes with our calls more flexible grant funding mechanisms across tertiary study which recognise for example the urgent need to recognise the impact of disability, and the AHEAD/NDPAC call for the development of more dedicated pathways to postgraduate study for disabled learners.
• Strong commitments to improving guidance (2.3) and transition-planning (2.4) for disabled people are evident and welcome.
• A much-needed commitment from the state to work with the FET and HE sector and invest in tackling the shortage of ISL interpreters through provision of accredited training programmes.

Concerns:

• Actions are weighted towards early childhood, primary and secondary level education, and appear less ambitious and less defined in the FET and higher education areas.
• Given that AHEAD views the inconsistent application of disability supports across FET and HE, and the pressure on disability support services stemming from rising numbers not being matched by rising funding pots as amongst biggest issues in the sector, actions concerning the reviewing and bolstering of disability support in tertiary education are not strong enough in our opinion. The strategy makes a commitment to “identify which educational supports best meet the needs of disabled students in third level” and build “a system of relevant supports for disabled students that will support them to reach their potential at third level”, but little else is referenced.
• No specific reference is made to increasing participation in postgraduate and PhD study, an area of persistent under-representation in tertiary education according to AHEAD research.
• Although we welcome the general commitment in the executive summary tackle the added cost of living with a disability through more holistic cross-governmental action, AHEAD would have liked more emphasis and detail on what targeted measures will support this, such as how the government plans to introduce the non-means tested Cost of Disability payment outlined in the Programme for Government.

Strengths:

• Commitment for the civil and public services to lead by example is welcome, in particular the actions relating to “review and enhance disability inclusion policies and practices” (4.1), “expand the number and range of work placement opportunities with mentoring support” (4.2) such as the AHEAD WAM programme, and “promote inclusion with the development of innovative recruitment, assessment and assignment practices” (4.3) in the public sector are a welcome move. These actions locate the barriers to employment primarily in the system in line with the social/human rights model of disability.
• Overall reforms to Disability Allowance outlined are a vital step forward. The commitment to “reform the Disability Allowance Payment and remove anomalies in the means test” (6.2) and to “make it easier to regain Disability Allowance if employment ceases” (6.4), and to “review the retention of secondary benefits where disabled people take up employment and move off a Department of Social Protection payment” (6.5) have the potential to make a huge impact. However, more detail will need to be provided in the forthcoming Action Plan and the actions arising should be progressive in nature.
• Actions targeting private sector employers such as to “provide practical information on how to hire, retain and promote a disabled employee” (5.1) and to “undertake research with employers in identifying enablers and obstacles to employing disabled people” (5.8) are welcome. However, more detail will need to be provided in the forthcoming Action Plan about how this is achieved, support as supporting the private sector implementation of the AHEAD/Employers for Change WIDE Framework.
• Establishment of a “ministerial-led forum which will include engagement with relevant disability stakeholders in order to raise awareness of supports and discuss issues related to the employment of disabled people” (5.5) provides a potentially important new structure for engagement with disabled people and private sector employers.

Concerns:

• While the commitment for public sector to lead by example is welcome, no increased targets for disabled people in public sector employment have been set.
• The strategy places most of its emphasis on accessing employment, and contains little focus on career advancement and progression to leadership roles.