National Council for the Blind of Ireland

Pre-budget Submission 2018

July 2017

NCBI Pre-Budget Submission 2018Contents

The impact of sight loss.........................................................................1About NCBI – National Council for the Blind of Ireland.........................2Sight loss figures...................................................................................3NCBI’s recommendations for budget 2018...........................................3

Department of Employment and Social Protection.............................3Department of Health.........................................................................5Department of Enterprise and Innovation...........................................9Department of Transport, Tourism and Sport...................................10Department of Housing, Planning and Local Government...............13Department of Education and Skills.................................................14Department of Communications, Climate Action and Environment..15

The Impact of Sight LossRegardless of time of onset, sight loss impacts on all aspects of an individual’s life and that of their family; income / employment, health, mobility, transport, housing, education / training, technology requirements, relationships, self-confidence, and therefore a holistic approach is required to address the physical, psychological, financial and technological impacts and needs that arise as a result of sight loss.

On this basis NCBI is outlining in our pre-budget submission for 2018 recommendations and asks of individual government departments. In addition to this, we are recommending more coordination across government departments that would result in more conjoined policies and services, which would inevitably result in better outcomes for people with sight loss (and all who live with disability), many of whom struggle to make ends meet and to have their most basic of needs met and their rights recognised as citizens.

The Way Forward

As we embark on a new Disability Inclusion Strategy and we sit on the cusp of ratification and subsequently implementation of the UNCRPD,

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NCBI is fully committed to collaborating and working in partnership with government departments towards putting in place policies and systems that will reflect moves towards compliance and adherence to current and future legislation, directives, and the CRPD itself. Together we will begin to address the many ways in which people with disabilities, including those who are blind and vision impaired, are denied their rights in many aspects of life in Ireland. This pre-budget submission sets out NCBI’s recommendations for beginning that process by effective, efficient and targeted allocation of resources and collaboration across government departments.

About NCBI – National Council for the Blind of IrelandAt NCBI, we are working every day with people of all ages, from young babies to those reaching their 100th birthday. The majority of people we work with actually have some remaining vision, while a small percentage are completely blind.

We understand the impact of sight loss – the fear people may feel when they are having difficulty seeing road crossing signals or the upset when struggling to do things like reading, writing, or recognising people’s faces; the worries families have about their loved ones living alone safely; the dreams and hopes that parents have for their children born with low vision, sometimes coupled with other complex needs and their need for support through the pathway of their life to having their child’s needs met as they grow up.

NCBI offers emotional and practical help so that people can live their lives fully with confidence and independence, now and into the future.

Sight Loss Figures

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51,718 people with significant sight loss. Work with 8,000 each year.

NCBI

NCBI’s Recommendations for Budget 2018Department of Employment and Social ProtectionMinimum Essential Standard of LivingResearch carried out recently by NCBI and Vincentian Partnership for Social Justice found that the Minimum Essential Standard of Living (MESL) for a single adult with vision impairment costs €44.54 (18%) more on a weekly basis than for a single adult in the main MESL budgets for the general population [1].

Therefore, NCBI welcomes the commitment in ‘A Programme for a Partnership Government’ to support “an increase in the Disability Benefit and Allowance, Carer’s Benefit and Allowance, and Blind Person's Pension”.

There are anomalies between Disability Allowance and Blind Pension which need to be addressed. Some people with impaired vision are in receipt of Blind Pension whilst other people with sight loss are in receipt of Disability Allowance. The greatest anomaly between Blind Pension and Disability Allowance is disregarded means. See table below.

Blind Pension Disability Allowance

Disregarded means €20,000 €50,000

Recommendations

1. Increase Blind Pension and Disability Allowance by €20 a week.

2. Address the anomalies between Disability Allowance and Blind Pension and increase the disregarded means for Blind Pension to €50,000.

Welfare to EmploymentThere are a number of barriers for people with impaired vision in relation to moving out of welfare and into employment. Some of these barriers are outlined below:

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The transition period from benefits to employment and back again

is problematic for many people with sight loss.

There is confusion around what employment services are available and the extent to which they have capacity to work effectively with people with sight loss.

NCBI has had experience of some applications for Workplace Equipment / Adaptation Grant being granted and others being refused. There does not appear to be consistency in responses to applications.

There is confusion within the Department regarding people on Disability Allowance and Blind Pension and in relation to Blind Welfare Allowance, which is causing considerable concern and reduced income for some.

Recommendations

1. Implement recommendations of “Make Work Pay” 2017.

2. Make the Workplace Equipment / Adaptation Grant and the Personal Reader Grant available to public sector employees and Section 39 organisations.

3. Ensure that the Workplace Equipment / Adaptation Grant is administered consistently.

4. All job activation schemes should be disability-proofed. 5. Services need to be integrated – welfare, employment, HSE and

other departments need to work collaboratively. 6. Engagement is essential between NCBI and Intreo services on

barriers to accessing employment services which include limited transport options to get to Intreo offices, accessibility of Intreo buildings, the service itself, and information available.

7. All Intreo staff should receive training in working with people who are blind and vision impaired and increase their knowledge regarding the technological and other practical solutions to perceived difficulties in employment of a person who is blind or has impaired vision. NCBI, as the national sight loss agency, should deliver this training and should be resourced to do so by the Department.

8. The National Advocacy Service needs to be resourced and expanded so that it is actually available and accessible for people with disabilities, including people who are vision impaired or blind.

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Department of HealthAs part of the National Vision Coalition, NCBI is committed to the development of a National Vision Strategy in partnership with the Department of Health to ensure a clear, efficient and effective pathway from assessment though treatment and rehabilitation services for people who experience sight loss.

Funding NCBI ServicesAs the primary funder of NCBI’s front line services (currently through the HSE), the Department of Health should ensure that NCBI, the national sight loss agency, is fully resourced to address the identified needs of people who are blind and vision impaired through professionally trained specialist staff based in accessible locations and one single national budget.

Recommendations

1. Restoration of funding allocation to NCBI by at least 16%, which reflects funding reduction since 2008, which would enable NCBI to respond to current and future growth in numbers of people experiencing sight loss in line with the increasing population of older people.

[2.] One single national budget for NCBI to facilitate equal access to services across the country.

2.[3.] See appendix for more recommendations.

Aids and Appliances: technologyRecent research by NCBI [1] shows that individuals with vision impairment are faced with large up-front expenses to pay for essential assistive technology. An individual on a low income or a person who has recently had to give up work as a result of acquiring vision loss (or deterioration of an eye condition) should not be expected to pay up front high costs, upwards of €800 at a minimum, for basic accessibility requirements that are directly associated with sight loss. Often, people have to go without these most basic of requirements which would enable them to move on with their lives in spite of sight loss because the Technical Aids Grant in their area is either non-existent or has such a long waiting list that it may as well not be there.

Vision loss (which can become part of anyone’s family at any time) is an unplanned visitor into people’s lives. It results in people having to adapt

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and learn new ways of doing things as well as develop strategies and mechanisms for coping with the change. Assistive technologies are not luxury items but are instead essential for enabling those with vision impairment to complete their education, gain or retain employment, and to live in their community.

NCBI’s “Out of sight” survey found that 72% of participants with sight loss said that access to assistive technology would enhance their choices and opportunities [2].

Despite the clear significance of assistive technology for those with vision impairment in general, funding for assistive technology in Ireland, in comparison to other countries, is fragmented and uncoordinated. HSE discretionary funding for assistive technology has also been greatly reduced and in many HSE areas the funding stream has disappeared completely.

Recommendations

1. Introduce an Assistive Technology Passport [3]. This is a record of an individual Assistive Technology user's equipment, training and funding history. It is owned by the person and offers them autonomy over their assistive technology needs. It would travel with the person, across school, college and work. It would allow them to have freedom of movement throughout the country on par with everyone else without fear of losing funding, IT supports or training on the assistive technology they use.

2. A central agency should be mandated with responsibility for ensuring delivery of a comprehensive infrastructure to include the coordination of the Assistive Technology Passport process, information provision, and model of service delivery that will serve the needs of citizens’ with disabilities for Assistive Technology solutions [3].

3. Fair and equal access to assistive technologies for people across the country.

4. Each HSE region should adopt standardised criteria for approving low tech magnification aids, as an entitlement under the GMS (General Medical Service). Currently each region employs different criteria for the awarding of magnification or low vision aids. This creates unnecessary stress for those who require the aids for fundamental tasks such as reading and writing. It is vital that any

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residual vision a person has is optimised to maximise their quality of life and independence.

5. Long canes which are essential for people with little or no vision to move around safely and independently (and symbol canes to indicate vision impairment to others) should be available to those who need them, free of charge from the State. Currently NCBI requires €20,000 per annum of fundraised income to provide one cane per year and is of the opinion that canes should be funded by the State.

6. NCBI requests an increase in Lottery funding to help fund NCBI projects that support social inclusion for people with impaired vision.

7. Census figures from 2016 show that there is an increase of 19% in the number of those over 65 years [4]. As the population ages, so will the incidence of age related sight loss. NCBI requires additional funding in order to cope with an increase in demand for our services.

Aids and Appliances: EyewearRecent research found that people on low incomes are spending €5.74 per week on specialist prescription glasses / lens’s and high spec sun filter glasses, without which many people severely affected by glare cannot leave the house [1]. High spec (sometimes prescription) sunglasses are an essential item for an individual with vision impairment as daylight can affect a person’s eye condition and often causes pain and incapacity to see anything.

Recommendations

1. Include high spec sunglasses/filters and specialist spectacle lenses for those with vision impairment within the definition of aids and appliances.

2. For every second set of high spec lenses and sunglasses received, a second (back-up pair) should be provided to mitigate against the high risk of accidental damage and to reduce for the State the cost of reassessment.

Personal Assistants and Support ServicesNCBI welcomes the commitment in ‘A Programme for a Partnership Government’ to review State structures and delivery to respond to the introduction of personalised budgeting tailored specifically to the needs of the individual. A personalised budget would go somewhat towards

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responding to the fact that personal assistants and support services are becoming increasingly necessary to enable people with sight loss to do the ordinary things of everyday life such as shopping, transport, participating in community, health and well-being, attending appointments and engaging with public services. Lack of funding has reduced access to assistance, transport, and support services significantly. Without a renewed commitment to a properly resourced personal assistant service that is available to and inclusive of people with sight loss, people who are blind and vision impaired will continue to have great difficulty engaging in education and employment opportunities, living independently, or participating in their communities.

The personal assistant service plays a key role in the lives of many people with disabilities in Ireland. There is a growing demand for this service and people with impaired vision are losing out due to unavailability of a personal assistant service to respond to the needs of our particular cohort of people.

A recent NCBI study [2] found that 48% of respondents with vision impairment said that “access to funding for a personal assistant to enhance capacity to do the things you want / need to do and access to a call up service (to help people to get out to do the things that are important to them) would enhance life choices and opportunities”.

Recommendations

1. NCBI calls on the Department of Health to support the HSE in extending the current PA service to include people with sight loss.

2. Fund personal assistant services for people with sight loss regardless of where they live, which addresses the specific and different requirements of a person who is blind or vision impaired.

3. NCBI should co-ordinate this service with government funding.

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Department of Enterprise and InnovationRates of Employment amongst People with Sight Loss

Barriers to Accessing EmploymentThe main obstacles for people with vision impairment in relation to employment are the negative attitudes they face and lack of awareness about the possibilities and options for overcoming the effects of sight loss and people’s capacity to work effectively.An NCBI survey found that 82% of participants with sight loss do not believe that people with impaired vision have the same employment opportunities as their fully sighted peers. 25% said they have experienced discrimination in relation to employment - 64% in accessing employment and 48% while in employment [2]. Declaration of disability on application (or not) can also pose a significant dilemma for applicants with disabilities. The main reason for not declaring prior to interview is fear of unconscious bias which may be based on lack of awareness on the part of employers.

Other barriers to employment for people with impaired vision include limited availability of / access to assistive and mainstream technology required for employment, lack of transport from home to a potential work location.

Recommendations

1. Information needs to be provided to employer’s regarding grants available to accommodate employees with disabilities.

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UK: 41%

Australia: 36%

Canada: 33%

Ireland: 16%

2. The Workplace Equipment / Adaptation Grant and the Personal Reader Grant should be made available to people with sight loss who work in the public sector or Section 39 organisations.

3. Introduce a Transport to Work Scheme which would make available affordable transport to and from work for those who are unable to drive a car. This would remove one of the major barriers for people with sight loss taking up or remaining in employment.

4. Funding should be made available for awareness campaigns that showcase the capacity of people with sight loss when reasonable accommodation is in place and assistive technology and enabling supports available.

5. Establish a policy initiative that states where a person meets the criteria for a position and declares they have a disability, an interview should be guaranteed. This would enable the applicant to know that declaration of disability would be safe and not responded to negatively. It would give the potential employer an opportunity to increase their understanding of how things can be done and expose them to the possibilities and options that enable a person with a disability to contribute to a workforce.

6. Making funding available for IT training and skills development to be delivered by NCBI to prepare people with sight loss for online engagement with public services from 2018 onwards.

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Department of Transport, Tourism and SportTransport ServicesNCBI welcomes the Government’s commitment in ‘A Programme for a Partnership Government’ to invest in “making public transport services more accessible for people with disabilities including the provision of audio announcements on train and bus services to aid people who are blind and vision impaired”.

People who are blind or vision impaired cannot drive and therefore public transport is their only means of transport. Accessible public transport is vital for independence. Availability goes hand in hand with accessibility. Many people, particularly outside main cities, are trapped in their homes or very restricted in their capacity to access public services or engage in social, educational political, recreational activities, or employment because it is not possible for them to travel within their own county!

Recommendations

1. NCBI recommends a complete review and revamp of the transport services in Ireland in order to increase public transport availability to everyone including people with impaired vision.

2. All public transport should operate audible announcements both within carriages / coaches and at stations / platforms to enable those with insufficient vision to have access to the same basic information as the sighted population – i.e. destination of the train, tram or bus and location of next stop / station.

Free TravelThe free travel scheme is something that is valued by those who can avail of it and needs to be retained. The current criteria for eligibility is causing a difficulty for some people who cannot see enough to obtain a driver’s licence and yet do not fulfil the criteria for eligibility – they therefore fall between two stools.

Recommendation

1. Eligibility criteria for access to the free travel scheme should be changed to include those with a long-term eye condition which renders their level of vision insufficient to meet criteria for a drivers licence.

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TaxisOne of the main impacts of sight loss is lack of capacity to drive a car and for many journeys people need to make, public transport is simply not available. This results in significantly higher use of taxis by people with sight loss, even among those on very low incomes. A recent focus group ‘consensus based research’ with people who live with vision impairment identified taxis as the most expensive service being used by people with impaired vision.

Recommendations

1. NCBI is seeking a commitment that people in receipt of free travel due to sight loss will not face cuts in the course of any review.

2. Public transport, where it exists, is the only means of transport for a person who is blind or vision impaired but there are many locations in which it is not available and where there is a public transport service, it sometimes does not include the route to and from the places that people need to go. A subsidised taxi transport scheme should also be introduced for this cohort of people. In some jurisdictions, a subsidised taxi system is available. Some examples include: London’s ‘Taxicard’ system, Chicago’s Taxi Access Program and Australia’s Multi-Purpose Taxi Program.

Rail TravelMany trains and train stations continue to present significant barriers for people who are blind and vision impaired. In addition to the ongoing lack of audible announcements, with unstaffed stations around the country, people with impaired vision are faced with uncertainty as to the availability of a member of staff to offer assistance on and off the train. People have to give 24 hours’ notice of travel, if they require assistance, and NCBI finds this situation unacceptable.

Recommendations

1. Allocate funding to upgrade (or staff) unmanned train stations to ensure that people with disabilities have full access to travel whenever they chose, just like everyone else.

2. All trains to have audible announcements that are functioning switched on and maintained to operate correctly.

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3. All stations to be fully accessible to persons with impaired vision, i.e. audible announcements of the destination and platform of all trains in advance of and as they enter the station.

Buses: Recommendations1. All buses / coaches to have audible announcements that are

functioning and reliable for all journeys. 2. All buses and coaches to be fitted with cameras to enable

monitoring of alignment with kerb edges and reduce the risk of persons with impaired vision sustaining injury as they embark or disembark the bus.

3. Monitoring and review of all accessibility features and procedures that have been put in place to facilitate equal access and consequences for misuse or non-compliance by employees of transport companies.

Trams: Recommendations1. All trams to have audible announcements that are functioning and

reliable for all journeys. 2. Audible announcement of the destination of “the tram” as it enters

and stops at the platform. 3. Monitoring and review of all accessibility features and procedures

that have been put in place to facilitate equal access and consequences for misuse or non-compliance by employees of transport companies.

Electric VehiclesIn “A Programme for a Partnership Government” the Government states that it "want(s) Ireland to become a leader in the take-up of electric vehicles. We will establish a dedicated taskforce involving relevant government departments, agencies, industry and representative groups, to work on this goal and to set ambitious and achievable targets".

Recommendation

1. NCBI to be a full member of the taskforce to ensure that the needs of people with sight loss are represented and considered in relation to provision of an Alert Vehicular Acoustic Systems (AVAS) that cannot be switched off.

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Department of Housing, Planning and Local GovernmentPeople with sight loss are perceived as particularly vulnerable, walking many places often with the use of a cane or guide dog or having to travel slowly to safely use residual vision while moving around. This group of people are dependent on public transport and rely on local authorities to ensure their physical safety by maintaining public footpaths and spaces, highlighting edges of steps, installing and maintaining audible signals on traffic lights, tactile paving to indicate where traffic light crossings are located, and having appropriate lighting in public spaces.

Recommendations

1. Local authorities need to be resourced and subsequently obliged to facilitate full access, inclusion, and participation of people with sight loss including moving about safely and having access to public and community amenities.

2. Access features including those listed above must comply with legislation and directives and must be resourced to do so as well as monitored on an ongoing basis.

3. Local authority / social housing must take into consideration the specific needs of persons who are blind or vision impaired when allocating accommodation.

4. Vulnerability of persons who are blind or vision impaired must be taken into account when housing is being allocated.

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Department of Education and SkillsNCBI recognises that the overall broad concept of mainstreaming in primary and secondary schools has been well embedded through the work of the Department however, sometimes the practical application of the concept is lost through lack of attention to detail (and resources) with the individual child. In addition, at a local level, schools often develop meaningful working relationships with the not-for-profit sector (who are providing support services to children in education) but these relationships need to be supported at a national level.

It is clear that educational plays a critical role in preparing people for employment. Although children with vision impairments are achieving academically at primary and second level, they are not gaining the social and life skills at the same rate as their sighted peers. This leaves them at a distinct disadvantage when it comes to competing for employment.

NCBI sees education and literacy as fundamental enablers of independence and participation in society and as the foundation stone for higher participation rates in the employment market. We note the research by AHEAD [5] which gives details of the disability profile of total student population in 2013 to 2014. Only 2.8% of student population at third level have a vision impairment and while the total numbers of students with disabilities rose by 4% year on year, the number of students with vision impairments actually fell by 10% - the second fall in consecutive years.

This shockingly low and decreasing participation rate of people with impaired vision in higher education is a great concern to us. Having consulted with many colleges and interested bodies, NCBI has learned that many colleges currently struggle with this issue. We believe that the absence of a specialised service producing accessible materials in the format chosen by the student themselves is a contributory factor in the low participation rates.

Recommendations1. NCBI recommends that the Department, at a national level, put

polices in place that ensure the development of meaningful working relationships between schools and the not-for-profit sector (who are providing support services to children in education) in order to maximize potential outcomes for children.

[2.] NCBI recommends that funding is made available for the production of all course content at primary, secondary and third

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level in the accessible formats of a student's choice, from the beginning of the academic year. This will enable greater participation of people who are blind and vision impaired in higher education and ensure that the needs of students with vision impairments are accommodated throughout their education. The availability to all children at each level of education the technology that they require to participate fully in the education system and achieve their potential.

2.[3.] The introduction and use of an advocacy type resource would be an invaluable resource to parents who are often forced into a relationship of both advocate and parent with the educational system.

3.[4.] An holistic approach to education, that recognises the equal importance of both the academic and social developmental needs of children with disabilities, should be adopted. NCBI recommends the introduction of an expanded core curriculum for children with vision impairment to address this. This would include the required compensatory skills such as mobility, digital literacy and low vision skills and could be provided in co-operation with the not-for-profit sector in a structured and co-ordinated way. It is also necessary that training and appropriate resourcing for specialist subjects, such as Braille maths, Braille music and assistive technology, is provided. Particular attention needs to be paid to transition periods within the educational system and ensure that preparation and progress is structured.

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Department of Communications, Climate Action and EnvironmentEU Web Accessibility DirectiveRight now, numerous websites, apps and e-learning platforms are inaccessible to screen reading software. The new EU Web Accessibility Directive will significantly improve the accessibility of online public services.

Recommendations1. Government needs to prepare for the implementation of EU Web

Accessibility Directive (next 18-24 months). 2. Continue to prioritise funding for digital skills development for

people who are blind and vision impaired particularly as public services will require this for access when they go on line.

Audio descriptionThe current targets for audio description (AD) in Ireland are too low and are considerably out of sync with the UK.

Channel 2015 target 2018 target CommentRTÉ 1 & 2 1.75% 2.5% - 11,000 hours of

programme. - 494 hours AD – 4.5% - Includes 82 hours of children’s programmes.

RTÉ Junior

2% 5% - Target not being met.- Infrastructure not in

place.- Upgrade due in 2017.

UK - 10%- Many broadcasters

provide 20% audio description.

RTÉ 1 and 2 have a target of 2.5% audio description for 2018 and RTÉ Junior has a target of 5%. In the UK, the audio description target is 10% but many broadcasters provide 20% audio description.

In a recent NCBI survey, 51% of people who are blind and vision impaired listed the availability of more audio described television

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programmes as a priority in improving their ability to participate in cultural and social life [2].

The challenges that affect television in general, such as streaming, also have an impact on the viewing of people who are blind or vision impaired. The availability of audio described programming on UK channels and through streaming (Netflix and Amazon) means that people who are blind or vision impaired in Ireland are choosing other channels to view content in a way that is accessible to them.

Even when programmes are audio described by RTÉ, they may not be made available in that way by providers like Sky and Virgin, whereas almost all of Netflix and Amazon’s offerings are automatically available with audio description.

RTÉ programmes with audio description are not made available with audio description on the RTE player, unlike the BBC iPlayer, which includes audio description.

Recommendations1. Increase audio description targets. NCBI feels that a target of 10% by

2020 is achievable and necessary if we are to catch up with our UK counterparts.

2. Ensure compliance across platforms (such as the RTE Player). 3. There should be accessibility of the entire experience – from website

to app to programme. 4. There should be greater awareness among providers like Sky, Virgin,

and eir on ensuring provision of RTÉ audio description programming. 5. The accessibility of set-top boxes should be fully considered. 6. Education and awareness among people who are blind and vision

impaired on how to access audio description content should be taken on board.

7. Consult with NCBI in relation to implementing these recommendations.

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References[1] NCBI and the Vincentian Partnership for Social Justice (2017) Minimum Essential Standard of Living (MESL) for a single adult with vision impairment (Unpublished).

[2] NCBI (2016) Out of Sight Campaign: A report on the Access Priorities of people who are blind and vision impaired in Ireland – Accessed at http://www.ncbi.ie/ncbi-research/out-of-sight-campaign-access-survey-2/)

[3] Enable Ireland and Disability Federation of Ireland (2016) Assistive Technology for People with Disabilities and Older People: A Discussion Paper – Accessed at http://www.enableireland.ie/report-0)

[4] Census (2016) Census 2016 Results: Profile 3 – An Age Profile of Ireland – Accessed at: http://www.cso.ie/en/csolatestnews/pressreleases/2017pressreleases/pressstatementcensus2016resultsprofile3-anageprofileofireland/.

[5] AHEAD (2017) Numbers of Students with Disabilities Studying in Higher Education in Ireland 2015- 16 – Accessed at https://www.ahead.ie/userfiles/files/shop/free/Rates%2015-16%20Online.pdf.

Appendix Restoration of Pay

In the last few years cuts in HSE funding resulted in pay cuts for NCBI staff as was the case in other section 39 organisations. In order to continue to provide high quality services for people with sight loss we need to retain highly qualified staff. To do this we need to be in a position to offer pay rates that are in line with section 38 agencies. If this does not happen, section 39 organisations will lose specialist, skilled and experienced professionals and only be in a position to attract and retain less qualified staff. As a consequence we will be forced into delivering lower grade services. It is NCBI’s belief that people with sight loss should have access to the same quality of (staff delivered) services as those who use section 38 and HSE services.

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‘’Pay restoration on same basis as S38 organisations is required if we are going to retain and attract suitably qualified staff to support service provision into the future.

There is a real risk that the current division in pay rates between S38 and S39 organisations which has opened up since April 1st 2017 will lead to diminution in capacity of organisations to retain professional staff, which in turn compromises the standards of service excellence we aim to provide. If left uncorrected, this situation will compromise future ability to provide even basic services.

The April 2017 pay restoration in S38 organisations has started to further open up a salary & conditions differential, which is unfair to staff working in S39 organisations who already have a much reduced pension provision as against those working in S38 organisations.’’

Recommendations

1. There needs to be a restoration of pay for NCBI (a Section 39 organisation) staff and a commitment to parity with professional grades in the HSE going forward to ensure continuity of service capacity and retention of quality standards.

2. NCBI recommends that Section 39 organisations are treated the same as Section 38 organisations in terms of pay restoration.

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