PVI Feedback on the NZ Disability Strategy, September 2025

PVI provided feedback to Whaikaha – Ministry of Disabled People on the draft refresh of the NZ Disability Strategy. Below is a short summary of our feedback, or you can download the full feedback (at the bottom of the page).

DISABILITY STRATEGY – CONDENSED FEEDBACK SUMMARY

Key Gaps Across All Sectors

  1. Exclusion of Complex and High Needs Individuals
    • Actions largely target mild/moderate or single-area disabilities.
    • Intellectual disabilities, non-verbal children, and multi-disability individuals consistently absent.
  2. Lack of Funding, Enforcement, and Accountability
    • Most action points are aspirational or guidance-based.
    • No mandatory measures, enforceable obligations, or timelines for implementation.
    • Consultation feedback is not linked to tangible outcomes.
  3. Insufficient Integration Across Sectors
    • Education, employment, and health actions are siloed.
    • Limited linkage between school, post-school transitions, and workforce participation.
    • Digital infrastructure gaps undermine implementation (e.g., health accessibility records, learning support coordination).
  4. Disconnected from Lived Experience
    • Parents and whānau report strategy appears “outsider-written” or AI-generated.
    • Whānau and child voices largely absent in design and execution.
  5. Structural Barriers Ignored
    • BOTs, employers, housing providers, and health institutions lack accountability.
    • Ableism, stigma, and service inflexibility remain unaddressed.
    • Māori and Kaupapa Māori contexts underrepresented, especially in education and health.

Sector-Specific Recommendations

Education

  • Mandatory, funded professional development for teachers, TAs, and BOTs.
  • Include complex and high needs learners in all programs.
  • Embed transition planning from school to tertiary education and employment.
  • Ensure accountability for inclusive practice, particularly for ORS-funded children.

Employment

  • Include complex, intellectual, and multi-disability individuals in all employment actions.
  • Address systemic barriers, ableism, and employer accountability.
  • Link initiatives to education and school-to-work transitions.
  • Implement measurable outcomes and monitoring for all disability types.

Health

  • Embed whānau and child voice throughout health services.
  • Fund accessible, inclusive health services and digital infrastructure.
  • Include all disability types, including intellectual and complex needs, in workforce planning.
  • Support disabled people in frontline, professional, and leadership roles, not only peer support.
  • Ensure accountability and monitoring of health system improvements.

Housing

  • Fund and enforce accessible new builds and home modifications.
  • Cover all disability types, including intellectual and complex needs.
  • Separate housing provision from disability service delivery where appropriate.
  • Embed monitoring and accountability for housing providers.
  • Prioritize disabled people and whānau needs over bureaucratic rules.

Overall: Parents and whānau report a consistent lack of practical, funded, enforceable actions across sectors. The disability strategy currently risks being aspirational “vibes” without real-world impact, especially for high needs and complex disability populations. Immediate attention to accountability, cross-sector integration, and lived experience inclusion is essential.

DISABILITY STRATEGY FEEDBACK (SUMMARY)

SectorKey Gaps / IssuesRecommendations
Education– Focus on mild/moderate disabilities; complex/high needs children absent
– Teacher training insufficiently mandatory, ongoing, or targeted
– BOTs not held accountable for inclusion
– Transition to tertiary education/employment missing
– Fund mandatory, on-the-job professional development for teachers, TAs, and BOTs
– Include complex/high needs learners in all programs
– Embed transition planning from school to work and tertiary education
– Ensure school accountability for inclusive practices
Employment– Focus on physically disabled, single-area disabilities
– Intellectual and complex disabilities excluded
– Overemphasis on awareness campaigns; systemic barriers ignored
– No accountability for employers
– Include all disability types, including complex/intellectual needs
– Address systemic ableism and barriers
– Link employment initiatives to education and transition programs
– Implement measurable outcomes and monitoring
– Support meaningful career progression, not just entry-level roles
Health– Whānau and child voices largely absent
– Digital infrastructure gaps (NHI, accessibility needs) impede action
– Frontline roles for disabled people under-supported; focus on peer support roles
– Intellectual and complex disabilities ignored
– Embed whānau and child voice in all health actions
– Fund accessible, inclusive services and digital infrastructure
– Include all disability types in workforce planning
– Support frontline, professional, and leadership roles
– Implement monitoring and accountability mechanisms
Housing– Generic actions; no funding for new builds or modifications
– Intellectual and complex needs absent
– Slow, inflexible processes (e.g., Kāinga Ora)
– No separation between housing provision and disability services
– Fund and enforce accessible housing and modifications
– Include all disability types
– Separate housing provision from service delivery where needed
– Embed monitoring and accountability
– Prioritize disabled people and whānau needs over bureaucratic rules
Justice– Complex/high needs, intellectual, and non-verbal disabled people largely absent
– Workforce lacks mandatory disability competence, Deaf competence, trauma-informed and supported decision-making training
– Frameworks aspirational, under-resourced, unclear timelines
– Lived experience and whānau input not consistently included
– Include all disability types in justice actions
– Mandate workforce training in disability competence, Deaf competence, trauma-informed and supported decision-making
– Fund, resource, and enforce safeguarding frameworks
– Embed lived experience and whānau input throughout policy, design, and monitoring
– Implement culturally safe approaches for Māori and whānau

Cross-Sector Observations

  • Complex, high needs, and intellectually disabled individuals are consistently excluded.
  • Actions are aspirational, lacking funding, enforcement, and accountability.
  • Consultation perceived as disconnected from lived experience; AI/writing concerns reported.
  • Parents report frustration with repetitive, non-impactful consultation processes.
  • Cross-sector integration (education → employment → health → housing) is weak.

You can read the full submission here:

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