Within the European Union and the Organisation for Economic Co-operation and Development (OECD), approximately one in seven people is categorized as disabled, and in many countries the number claiming financial support due to disability is increasing. Most governments recognize the many benefits of integrating people with disabilities into the workforce and have programs to address this need. The level of government spending, the social importance of the programs, and the risks inherent in such programs (for example, the difficulty of establishing eligibility for support) make this an important area for scrutiny by SAIs.
A recent survey on programs that integrate people with disabilities into the workforce was completed by 26 European SAIs in preparation for a discussion on this topic at the VII EUROSAI Congress in Krakow, Poland, in June 2008 (see the report on p.18). The National Audit Office of the United Kingdom led the theme with support from the SAIs of Estonia, Iceland, Sweden, and Switzerland. This article summarizes the results of the survey as well as the conclusions and recommendations reached at the conference.
Promoting the Professional Integration of People with Disabilities
The OECD has classified programs to support working-age people with disabilities as integration based (helping people to find and keep jobs) or compensation based (providing financial assistance as an alternative to work). According to the results of the survey completed by 26 European SAIs, job search assistance and training accounted for the highest number of participants in government programs, and training accounted for the highest government expenditures. The discussion paper reported that most governments have a strong commitment to integrating people with disabilities into the workforce, citing as the primary motivating factors the right to work of people with disabilities and the additional social benefits to individuals and the community. Other reasons given include constitutional mandates prohibiting discrimination against people with disabilities (Germany), demographic developments in labor law and the employment market (Austria), and the desire to provide an improved quality of life for people with disabilities (Malta). Improving the economy and reducing benefit expenditures were considered less important. As a reflection of their desire to provide support, many governments have adopted targets for integrating people with disabilities into the workforce. About 60 percent of the 26 SAIs that responded to the EUROSAI survey reported specific quantitative targets in their countries. All of the SAIs reported that the rate of employment among the people with disabilities is lower than the rate of employment in the population as a whole—for example, 30 percent lower in Switzerland, 40 percent lower in Ireland and the Netherlands, and 65 percent lower in Poland.
SAI Audits of Programs to Integrate People with Disabilities into the Workforce
Across the EUROSAI region, SAIs have undertaken a wide range of work to audit programs to support people with disabilities. There are some clear differences in the audit work of different SAIs. The situation in different countries appears to vary depending on the legal definitions of disability, the role of central and local governments in delivering support to unemployed people with disabilities, the objectives of the SAI and its audit mandate, and the priority attached to these programs.
Of the 26 SAIs that responded to the EUROSAI survey, 23 had done some audit work directly or indirectly linked to disability. Of these, 20 had done financial audits of the accounts of entities providing state support to people with disabilities, and 13 SAIs had done performance audits. The focus of these audits included the overall set of programs and schemes provided by government, the role of sheltered workshops, subsidies for employers, job assistance support, and the role of training in helping people with disabilities develop skills. The most important factor driving SAIs to carry out these audits is the amount of resources expended.
Audits have enabled SAIs to determine whether funds are being spent as intended. For example, in Poland, the SAI’s audit of programs providing tax relief for employers of people with disabilities found that only a small part of the funds were spent on statutory objectives related to rehabilitation. Instead, the money had been spent on such things as electricity charges and investments. In Germany, the SAI reported that government and social insurance bodies had provided funding for facilities and projects designed to assist people with disabilities into work for which there was no demand or which operators of the facilities could have funded themselves.
Audits can highlight significant weaknesses in program performance. For example, in the United Kingdom, the SAI’s work showed that Remploy factories, which provide sheltered employment, were struggling to be productive, with funding per head in some businesses being disproportionate to the average salary paid. In Norway, the SAI reported a steady decrease in the number of new recipients of disability pensions who had tried vocational rehabilitation before being granted their pensions (only 1 in 7 applicants in 2000) and recommended that the ministry be more ambitious in raising performance.
SAIs can highlight shortcomings in relevant legislation and the way it is implemented. In the Ukraine, the SAI’s compliance audit work drew attention to the legal uncertainty and lack of a clear program for supporting people with disabilities into work. The fund providing social protection for persons with disabilities had not ensured the proper implementation of the budget program, which led to an inefficient use of funds. About one third of loans to other organizations over the last 10 years appeared to be high risk, jeopardizing returns to the government.
The work of SAIs has also shown the impact of administrative procedures on vulnerable people. In Germany, the SAI reported an excessive delay from the time a person with a disability applied for assistance until suitable integration measures were initiated. The Icelandic SAI identified a lack of fully qualified employees to care for people with disabilities and stated that the service provided did not always follow relevant laws and regulations. The SAIs of Sweden and the United Kingdom both identified insufficient quality in the individual action plans prepared for people with disabilities going through assistance programs, jeopardizing the value of the support provided.
Recommendations from the EUROSAI Congress
While auditing programs that promote the professional integration of persons with disabilities, SAIs have encountered a range of challenges, including poor quality or incomplete data, difficulties in auditing an area involving medical judgments about eligibility, organizational complexity in the way some programs are delivered, and difficulties in assessing the impact of interventions to help people find work.
Participants in the EUROSAI congress identified a number of recommendations to address the difficulties inherent in audits of programs. These include the following.
In planning their future audit work, SAIs should take account of the particular materiality, risk, and sensitivity inherent in programs to promote the professional integration of people with disabilities. Because of sensitivities associated with this area, both public interest and program risks are often quite high. There is some evidence that at the political level, governments may set overly ambitious targets that are higher than anything previously achieved and are unrealistic or unachievable. There are often increased risks to delivering such programs; for example, it is difficult to challenge legacy systems.
In some circumstances, normal expectations of performance (e.g., in sheltered employment) are tempered by a recognition of wider social benefits from helping people with disabilities. As a consequence, auditors have to use particular skill and judgment in assessing performance, particularly if their work could lead to conclusions that certain programs constitute poor value for money. In practice, SAI audits have confirmed that these difficulties and other factors increase the risk that programs will fail to deliver their intended benefits. Indeed, some audits have found programs to have significant weaknesses and very limited success.
When planning and carrying out their work, SAIs should consider obtaining the views of service users or their representatives. Service users or their representatives can provide SAIs with firsthand information on how effectively programs are working, the quality of the employment opportunity and experience (which is not always measured by providers), and proposed developments in policy and administration. These views can be obtained through surveys and by contacting groups representing people with disabilities. In taking such actions, however, auditors need to ensure that they retain their objectivity and independence and are able to evaluate particular services without becoming advocates for those services in the political arena.
Where SAIs’ statutory remit permits, they should make full use of the opportunities for collaboration with other inspectors, but SAIs must ensure the accuracy and completeness of data provided by third parties. Auditors in some jurisdictions cannot audit work programs on their own and need to collaborate with other organizations to discharge their duties. In many jurisdictions, work programs are delivered by nongovernmental bodies, such as charities or other private sector entities. In these circumstances, the role of the SAI in the audit of programs can be more difficult. The auditor may need to gain a detailed understanding of a system that involves a high number of small organizations or a long delivery chain.
SAIs should encourage governments to adopt good administrative practices. Because of the high level of funding used for work programs for people with disabilities, SAIs have a responsibility to ensure that funds are spent as intended and not directed into other activities. Audits by SAIs have often found that administrative arrangements put in place by governments are not fully effective. SAIs should encourage governments to introduce clear legislation and regulations, design robust and transparent decision-making arrangements for assessing a person’s eligibility for programs, and maintain clear and accurate records of support provided to individuals.
SAIs have a role in encouraging governments to improve the information they collect on program outcomes (such as the extent to which participants find and retain jobs) and ensuring that programs are designed in ways that allow for the evaluation of success. Many SAIs found data reliability to be a problem. In some cases, the number of participants in any given program could not be determined; in other cases, data were not available. Where multiple organizations are involved in delivering services, different datasets may need to be cross referenced or combined to gain an overall understanding of the programs. Such work can be time-consuming and difficult. In addition, the difficulties in tracking what happens to people after they have completed work programs are likely to make assessments of program effectiveness very difficult.
SAIs should consider whether they need specialist skills and support in assessing programs for people with disabilities. Eligibility for programs and support arrangements for people with disabilities often center on an assessment of disability, which is usually carried out by medically qualified staff. Auditors cannot question the medical judgments on which decisions are made about eligibility for disability support or admission to a work program. Nevertheless, auditors will need to have a good understanding of the relevant medical decisions and the classifications of people with disabilities and must find ways of assessing whether a strong decision-making process is in place. To do this, specialist assistance in carrying out the audit may be needed.
Because of the difficulty in making judgments about programs to support people with disabilities, SAIs should pay particular attention to obtaining sources of evidence that can further corroborate findings and conclusions. Where making an audit judgment is difficult—for example, where it is not feasible to determine how the medical profession is applying eligibility criteria—it is important to seek other evidence. For example, information showing trends of usage or participation can often be an indicator of a problem in applying eligibility criteria. Such evidence is often more objectively verifiable than other sources.
In scoping work in this broad and complex area, SAIs should look for indicators from a variety of sources to identify areas to focus on in their work. SAIs have found that certain indicators can help to reveal trends or problem areas within programs. For example, a high level of benefit appeals, repeat enrollments of individuals within training and skills programs, or the return of a high number of people to a reliance on benefits may indicate areas of risk or unintended or unforeseen consequences of program implementation. The audited entity may not necessarily have all of the information needed. Other entities, such as nongovernmental organizations, will often be a valuable source of relevant information on whether programs are providing sustained employment for people with disabilities.
SAIs have an important role to play in auditing how governments spend money to assist people with disabilities to gain and retain work. Overall, European SAIs are assisting governments to make the most of their resources by highlighting inefficiencies, the incorrect use of funds, and poor performance. SAIs share many common challenges in completing this work, including the complexity of the methods for delivering these programs, the difficulty in measuring program success, and the lack of available data. As a result, opportunities to learn from the experience of colleagues and the techniques they have used in developing their audit approaches are extremely beneficial. We hope that the dialogue begun at the recent EUROSAI congress will help to promote additional sharing about work in this important area.
For additional information, contact the U.K. National Audit Office at