Sightsavers’ submission to the International Development Committee on FCDO & Disability Inclusion

September 2023  

About Sightsavers

Sightsavers is an international development organisation which works with partners to eliminate avoidable blindness and promote equality of opportunity for people with disabilities in around thirty low and middle-income countries and at a regional and global level. Our programmes also include working to ensure quality inclusive education, strengthen health systems and eliminate neglected tropical diseases (NTDs). 

Summary

1. The FCDO has made important progress on disability inclusion since the first IDC inquiry on disability and development. However, there have also been major challenges over this time period and much work still needs to be done to reach its objectives.
2. The FCDO’s Disability Inclusion and Rights Strategy (DIRS) provides a strong framework for disability inclusive development and reflects a high-level of ambition. However, we have three main areas of concern which we have outlined in more detail below: i) insufficient mechanisms for delivery and implementation ii) increased need for accountability and iii) insufficient human and financial resources. These factors risk the ambition set out by the FCDO in the Strategy not being realised.
3. The FCDO should improve the quality, disaggregation, and transparency of data to enable better tracking and accountability of ODA spend and programming.
4. The cuts to ODA are impacting disproportionately on the poorest and most marginalised communities and people across the globe. Examples from Sightsavers disability programming which experienced cuts are outlined in more detail below. It is critical that lessons are learnt from the cuts and the mechanisms put in place to improve decision making around allocation of resources.
5. The FCDO should build on their experience on disability inclusive development and step up to playing a more visible leadership role in global processes and forums.

The adequacy of FCDO’s new disability and inclusion rights strategy as a framework for approaching disability inclusive development

On balance, the FCDO’s Disability Inclusion and Rights Strategy (DIRS) provides a strong framework for approaching disability inclusive development and, if implemented, could drive significant change on disability inclusion.

The Strategy builds upon, and in many ways is more ambitious than, previous versions. It commits the FCDO to working across development and diplomacy, has a strong focus on intersectionality and rights, brings in areas such as health[1] and climate for the first time, and has positive commitments to meaningfully engaging organisations of people with disabilities (OPDs).

However, while the Strategy is a strong and ambitious document, we have concerns around the extent to which it contains sufficient mechanisms for implementation. For example, the Minimum and Higher Standards from the previous Strategy have been removed. The ‘Equalities Continuum’ could be an important alternative way of ensuring implementation of the DIRS by providing a framework for action and situating disability inclusion within broader implementation mechanism. However, there seems to be a lack of clarity on how this will be implemented in practice and how it will support implementation of the Strategy. We recommend the Committee asks for further information about implementation of the Equalities Continuum in relation to disability inclusion.

One of the key mechanisms for implementation of the DIRS is an internal Delivery Plan which accompanies the Strategy. However, we have concerns that the current indicators in the Delivery Plan are too vague to fully monitor progress across thematic areas and instead is a more appropriate way of highlighting examples of good practice. We recommend that the Delivery Plan is strengthened with clear baselines, milestone and targets.

In terms of accountability, the FCDO has established an External Disability Inclusion Board which meets several times a year. While the Board is useful and has had some important discussions, the structure of the Board and information provided to it means it is unable to really hold the FCDO to account on delivery of the Strategy. We recommend that accountability for delivering the Strategy is strengthened, including commissioning an external evaluation at its mid-point.

Our concerns around the extent to which the DIRS is driving mainstreaming can be seen in the lack of mention of the DIRS and insufficient consideration of disability in the FCDO’s International Women and Girls Strategy (WGS). The DIRS will only be successful if its objectives are integrated across other strategies and taken on by other teams. We recommend that the FCDO takes further measures to raise awareness of the Strategy across the organisation and considers identifying Senior Champions, as this has been effective in the past.

Critically, the DIRS and the Delivery Plan cannot galvanise action without appropriate resourcing. The FCDO should pay great attention in efforts on implementation that adequate resources are being allocated for disability inclusion across thematic areas. This could include using mechanisms such as payment by results of the basis of disability inclusion, as done previously with success.

Another mechanism for implementation is ensuring that partners know disability inclusion is a priority and ensuring it is included across all programme documents. For example, it is important that the ambition of the strategy is transferred into Terms of References when new programmes are developed and that disability is specifically referenced. The FCDO’s explicit inclusion of disability within the Terms of Reference for the WISH Programme led to the inclusion of a disability partner within the Consortia and, as MSI set out in more detail in their submission this has had a transformational impact on the programmes and MSI’s work more broadly.

The FCDO Disability Inclusion team is a committed team with good individuals working within it, however it has struggled with capacity issues in recent years. The team plays a critical mainstreaming role and the FCDO should ensure they have sufficient human and financial resources to implement the Strategy.

The adequacy of FCDO’s spending on disability-inclusive programmes and the impact of cuts to ODA programmes on people with disabilities

There is limited data from which to fully assess the adequacy of FCDO spending on disability inclusion. Available data, from the OECD DAC disability marker[2], gives some indication of the extent to which programming is disability inclusive indicating that 24% of the UK's ODA and 41% of the FCDO’s ODA is ‘disability inclusive’[3]. This is a positive increase from 2020 where there appeared to be a drop in the percentage marked as inclusive[4].

This indicates some level of mainstreaming and is positive compared to other donors and where the UK would likely have been 5 or 10 years ago (where comparable data is not available). However, we suggest that the FCDO sets specific targets for the percentage of programmes marked as disability inclusive against the OECD DAC disability inclusion marker in specific sectors and also assess the extent to which ODA is both gender equitable and disability inclusive.

The FCDO should be commended for its leadership on the creation and adoption of the DAC marker and we recognise that they have taken important steps to improve the quality of the data. However, questions remain about quality and we expect that this represents an overestimation. We recommend the FCDO takes further steps to improve the quality of the data reported against the disability marker.

It should also be noted that due to the nature of the marker this does not mean that all of this funding is disability inclusive but that some larger programmes may have small elements of disability inclusion[5]. We understand that the FCDO tracks the percentage of these programmes that are thought to be disability inclusive, but does not publish this data. We recommend the FCDO publishes this data. This could be done in a timelier way than the official DAC data requires, which would enable better tracking and accountability.

The data also shows only 0.3% of programmes are marked as 'principle’ against the marker, which broadly translates as disability specific within the FCDO’s stated approach. Given the commitment to the twin-track approach the FCDO should assess whether this is sufficient and set a target for the percentage of ODA that should be disability specific.

Furthermore, in the design of programmes, specific funding should be included to ensure the meaningful participation and consultation of people with disabilities and their representative organisations and to ensure accessibility and reasonable accommodation. Some donors, such as Australia, have had success in providing a specific fund that teams can use for mainstreaming. While this has been pushed back against by the FCDO in the past it would be useful to consider whether this would support the UK’s efforts.

Another critical element of adequacy is being able to assess the extent to which people with disabilities are reached through the FCDO’s programmes and we remain concerned that this not always the case. For example, last year the Independent Commission for Aid Impact’s (ICAI)[6] found that the FCDO is unable to track the number of children with disabilities reached by the UK’s education programmes and that therefore overall results are unclear. We recommend that the FCDO makes further efforts to strengthen the use of disaggregated data in programmes and that where data is disaggregated this is used to inform programmatic and funding decisions.

This should sit as part of efforts to improve data more broadly. The UK is a champion of the Inclusive Data Charter but has not yet published a revised Action Plan. The UK should publish a revised Inclusive Data Charter Action Plan which sets out how the UK will improve data collection within its own work and support partners.

Another consideration in understanding whether financing is adequate is understanding the extent to which the FCDO’s overall portfolio is promoting disability inclusion. We share the IDC’s concerns in the Extreme Poverty report[7] about the extent to which investments in areas like trade and investment ‘trickle-down’ to people with disabilities. We recommend that as part of its approach to achieving disability-inclusive development, and more broadly leaving no-one behind, the FCDO assesses the overall portfolio of ODA spend and ensures a sufficient percentage goes to sectors which can promote equality, such as education, health and social protection. Where programmes are targeting economies more broadly there should be specific attention given to ensuring this takes place in a way which promotes equitable development and does not entrench inequalities.

Impact of the cuts

As the Committee and the recently published Equalities Impact Assessment highlights, large ODA reductions will disproportionately impact on people with disabilities.

Examples from Sightsavers disability programming show some of the challenges around the cuts: 

Disability Inclusive Development Programme (DID)

The FCDO’s flagship Disability Inclusive Development (DID) programme for which Sightsavers is the consortium lead, has received significant annual budget cuts starting from 2020 to 2024. Late budget communications from FCDO impacted on planning and relationships with partners.

Cumulatively, these have required us to close projects early, slow-down implementation and cut research and learning activities resulting in the ending of the Institute of Development Studies’ involvement. This compromised our research and learning portfolio, which are essential components to inform evidence-driven programming, policy making and effective ODA spending.

These cuts have obviously impacted on people with disabilities, their representative organisations that we work with, as well as government partners in the country in which we operate. It is critical that FCDO rebuilds this trust and credibility that has been broken with partners due to the continuous requests to re-plan and re-budget.

The FCDO should look to mitigate the impact of the cuts by embedding learning from the DID programme across its work more broadly and considering how evidence can be used to inform the design of mainstream programming.

Women’s Integrated Sexual Health Programme (WISH) and Partnership for Learning for All in Nigeria (PLANE)

The WISH programme is the FCDO’s flagship Sexual and Reproductive Health and Rights programme and includes a crucial component to improving access for people with disabilities. Throughout the duration of the programme, there have been multiple budget cuts which have affected the consortium’s ability to deliver effective and responsive SRHR programme interventions. The submission from MSI Reproductive Choices provides more details on the cuts to the WISH programme. The cuts to the disability element of WISH, while difficult, were proportionate with the rest of the programme. However, this decision was mainly driven by the consortium lead and although supported by the FCDO it was not a requirement.

In the Partnership for Learning for All in Nigeria Education programme (PLANE), however, budget cuts fell heavily and disproportionately on the disability inclusion components of the programme risking poor outcomes for programme participants and making our continued involvement untenable. We recommend that when decisions are being made about cuts to programmes the FCDO is explicit in its guidance to partners that this should not disproportionately impact people with disabilities.

Overall, we remain concerned that disability inclusion was not sufficiently considered when making decisions, as explored by the IDC previously. While the proposed FCDO-Treasury “star chamber” to provide more pre-scrutiny of budgetary decisions is a welcome development, the FCDO should conduct and publish Equalities Impact Assessments as a matter of policy. Equalities Impact Assessments should also be used to guide decision making on equalities issues, rather than to solely report the impact on equality.

A return to spending at least 0.7% of GNI on ODA as soon as possible will also be critical to ensuring the most marginalised do not fall further behind.

The FCDO’s work to encourage and facilitate the participation of relevant advocacy groups, in developing its strategy and approach

There have been good examples of consultation with OPDs, including in the development of the DIRS. Disability specific programmes funded by the FCDO have strong components of participation and co-creation. It is positive that the FCDO has launched an OPD Engagement and Consultation Guide. The FCDO should encourage take-up of the guide across all staff, departments and partners.

However, meaningful engagement and participation has not been institutionalised within the FCDO. The DIRS Delivery Plan mentions that engagement with people with disabilities will be done “where possible” or “where disability inclusion is relevant to the outcome of the programme.” This weakens FCDO’s commitment to mainstreaming inclusion and may send the wrong message to staff about when consultation or engagement is relevant. We recommend the FCDO supplement their guidance and good practice in disability specific programmes with clearer institution wide approaches to consultation and engagement. 

The extent to which other ODA-spending departments are ensuring that their ODA expenditure is inclusive of people with disabilities

Based on OECD DAC disability marker data, other government departments are reporting much less of their ODA as disability inclusive or not using the marker.

Despite stating in response to the 2019 inquiry that DFID was working with “other governments departments to ensure all ODA-spending departments include the disability inclusion policy marker within their programme data” there is still a limited number of Departments using the marker – presenting significant measurement challenges. We recommend that the UK uses the disability marker across all ODA departments.

The Committee has previously highlighted the importance of cross-government co-ordination on disability inclusion and while in the past some progress was made it is not clear whether this has continued. We recommend that the UK government adopts a co-ordinated approach to disability inclusion within its international cooperation and engagement.

The role of the UK in disability inclusion within the global humanitarian and development community

The UK has played an instrumental role in influencing others to do more on disability inclusion, including through hosting the first Global Disability Summit, influencing the World Bank’s work on disability inclusion and being an early supporter of the Global Action on Disability Network (GLAD).

While the UK is still active in disability globally and has some strong engagement, we are concerned that this has been deprioritised in recent years and the UK are not seen to be pushing disability as significantly within global processes and with other development actors. It is essential that the UK re-establishes its place as a visible global leader on disability inclusion. While the departmental merger and cuts have undermined the UK’s position more broadly,[8] the bringing together of development and diplomacy can be maximised to mitigate these impacts. For example, the FCDO could do more to use diplomatic efforts to encourage ratification of the Convention on the Rights of Persons with Disabilities. The UK should also use diplomatic efforts to influence on systematic financing of the UN Disability Inclusion Strategy (UNDIS), building on the UK’s work in this area.

More broadly, the FCDO should develop a clear influencing plan which sets out ambitious priorities for influencing on disability inclusive development and foreign policy. This should explore the range of mechanisms at the UK’s disposal and will be critical to implementing their strategy.

Further examples where the UK and FCDO could be well-placed to offer leadership include the following:

Inclusive Data

The 2019 voluntary national review (VNR) data recognised that the UK has made strides in building the capacity of national statistical systems and promoting data disaggregation however this work has not been referenced more recently in high level documents such as the International Development Strategy[9]. The UK should ensure that it is prioritising supporting the development of inclusive data systems. All support for censuses and surveys should include support and capacity building on disability data.

Education

With children with disabilities constituting one the most likely groups to be excluded from school,[10] building on previous activities, the UK could play a leading role in supporting countries to strengthen inclusive public education systems as the mechanism for meeting their commitments to education.

The UK has made progress in driving global education efforts. This included hosting the replenishment of the Global Partnership for Education and making education a central component of its G7 presidency. The UK could make more consistent and prominent use of its positioning on girls’ education to influence on disability inclusive education.

We recommend that the UK works with G7 members and low-and middle-income countries to develop an inclusive and tangible plan to achieve the Declaration on Girls Education and global targets set. More detail should be publicly announced which sets out how G7 investment is being used to reach girls with disabilities.  As the UK led the efforts for G7 endorsement of the declaration, it has the responsibility to continue to lead and co-ordinate efforts towards its realisation for children with disabilities.

Health

The UK has played a key role in advancing health equity for persons with disabilities as co-sponsor of the 2021 World Health Assembly Resolution on the Highest Attainable Standard of Health for People with Disabilities (WHA74.8)[11]. The UK should ensure continuing leadership and support of action globally to implement WHA74.8 and to ensure implementation of the recommendations of the WHO global report on health equity for persons with disabilities[12] which has followed from this, including through the WHO Governing Bodies and the UK’s implementation of its new Global Health Framework: working together towards a healthier world (GHF)[13].

Safeguarding issues within disability inclusion that should be prioritised in FCDO’s work tackling sexual exploitation and abuse in the aid sector

People with disabilities are at increased risk of harm, compared to people without disabilities and face extra barriers to accessing reporting or other safeguarding mechanisms. The FCDO has a strong safeguarding strategy[14] and it is positive that they accepted most recommendations from the Committee’s report on tackling the sexual exploitation and abuse of aid beneficiaries[15].

The FCDO has done important work around disability inclusion and safeguarding and so is well positioned to lead in this area. Through our work with governments, it is clear that inclusive safeguarding policies are not in place. The FCDO could do more to advocate for disability inclusive safeguarding policies with governments.

Integrating disability inclusive safeguarding is particularly important for programmes dealing with Sexual and Reproductive Health (SRHR) and Gender Based Violence, as survivor support services are often inaccessible for girls and women with disabilities. We therefore recommend that the FCDO integrates disability inclusive safeguarding into all projects, with a particular focus on ensuring that Gender Based Violence and SRHR programming contain specific actions and financing on inclusive safeguarding.

FCDO’s learning from other approaches and global work on disability inclusion

Bilateral and multilateral donors are increasingly creating disability inclusion strategies. Although these strategies respond to the specific policy context it is important that they learn from each other and the UK could do more to learn from other approaches.

As mentioned above, one component of the FCDO-funded Disability Inclusive Development programme is generating evidence, research and learning on what works and doesn’t for disability inclusion. One element of the programme is the Disability Inclusion Helpdesk[16] which provides research and advice to the FCDO on disability inclusion. This is a critical resource and we recommend that this is maintained in future. We would also recommend conducting a review to strengthen FCDO’s uptake of the technical expertise provided by the Helpdesk.

The FCDO also provides funding for the Global Action on Disability (GLAD) Network Secretariat. GLAD’s Working Groups provide valuable fora for FCDO’s learning. At the Global Disability Summit 2022, the FCDO committed to fund the GLAD Network until March 2024. We would recommend that the FCDO provides continued funding to the GLAD Network, whilst also reviewing the network’s strengths and opportunities.  

The UK also funds the UN Partnership on Persons with Disabilities (PRPD) which is a critical UN fund that funds multi-agency programming on disability inclusion. The PRPD is an important mechanism for programming on disability inclusion but also plays a critical role is supporting learning and the development of good practice. The UK should continue to fund the PRPD and ensure that it engages fully with the learning opportunities that this presents.

FCDO’s progress in implementing the Committee’s previous recommendations, and the commitments made at the Global Disability Summit

The Committee has played an important role in supporting DFID and the FCDO’s progress on disability inclusion. DFID and the FCDO have integrated many of the commitments from the 2014 and 2019 inquiry over time. However, the IDC’s comment that ‘the disability inclusion and rights strategy 2022–2030 must feed into all the Department’s development work, or it risks becoming an empty promise’[17] still holds true.

Specific areas for the Committee to follow up on from previous inquiries include:

• The Committee previously made recommendations on the Minimum Standards from the previous strategy – we were concerned that this approach was dropped in the latest strategy, although we were provided with reasoning around the new FCDO structure. The Committee could explore though the extent to which alternative approaches are supporting the roll out of a minimum level of competency and work on disability inclusion across FCDO offices and the extent to which this is measured.

• The Committee has previously recommended increasing disability specific spend. Although this is difficult to assess the available data suggests that this is likely not the case. As referenced above, we would suggest that the FCDO has a target for disability specific spend. 
• In response to the 2019 inquiry DFID set out that all new business cases, terms of reference and annual reviews will consider disability inclusion and that new programmes will collect and use disability disaggregated data in their logframes. We are concerned that this is still not happening and programme documents are not consistently including disability, especially logframes. Our analysis of this is also hindered by reduced transparency since the merger, which is critical for monitoring and accountability.
• In response to the previous inquiry DFID highlighted that they regularly review business cases to assess the extent to which these are disability inclusive – the Committee could seek to understand the process that takes place in the FCDO and whether recommendations are needed in this area.

Global Disability Summit

The UK’s hosting of the inaugural Global Disability Summit (GDS) in 2018 was a positive step demonstrating commitment in this area, and promising commitments were also made at the GDS in 2022. However, the sense of urgency and scale of the work needed to deliver on commitments is missing and we can already see that in practice, some have not been fulfilled. This includes commitments to the Women and Girls Strategy, as above.

As previously outlined, not all commitments made at the Summit are reflected in the Delivery Plan, leading to a lack of co-ordination and accountability across all commitments. A more comprehensive Delivery Plan would support better delivery of all commitments.

As with the DIRS, the cumulative budget cuts will also compromise progress towards many of the commitments made at the GDS, such as the commitment to extend the WISH programme and work with OPDs, both of which have now faced significant budget cuts as detailed previously.

We also recommend that the UK continues to engage in the development of subsequent Summits, to ensure they develop as a useful space for ongoing commitment to disability inclusion. This could also be done through its funding of the GDS Accountability Mechanism and GLAD membership. Ahead of the 2025 Summit the UK should consult widely on the development of its commitments.

For more information please contact Hannah Dawson, Policy Officer - Inclusion and Gender hdawson@sightsavers.org or Ross Gilligan, Multilateral and Parliamentary Adviser rgilligan@sightsavers.org

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              Sightsavers submission FCDO and Disability Inclusion | October 2023