Australian Human Rights Commission Submission to the Committee on the Rights of Persons with Disabilities – 25 July 2019 (b) Support measures for people ineligible for the NDIS 29. The Commission recognises the importance of the Information, Linkages and Capacity Building (ILC) element of the NDIS, as a mechanism to support all people with disability, their families and carers, regardless of whether they are eligible for the NDIS. ILC services provide information about, and referrals to, community and mainstream services (including health, education, transport, justice and housing). 30. However, the broad remit and lack of funding for ILC has led to a lack of clarity about the purpose of the program and reduced effectiveness. As recommended by the Productivity Commission, Australian governments should clarify the role of ILC and the level of funding required to ensure its effectiveness, before it is fully rolled out in 2019–20. 25 Recommendation 10: The Australian Government clarify the role of the Information, Linkages and Capacity Building of the NDIS and the level of funding required to ensure the effectiveness of the program. (c) NDIS monitoring and evaluation 31. The Commission is concerned that an overarching performance reporting framework for the NDIS has not yet been developed. The Commission notes that the Productivity Commission recommended that the NDIS use the same performance framework as the framework developed for the new NDA.26 32. A performance framework must involve the ongoing and active participation of people with disability and their representative organisations in the evaluation and monitoring of the NDIS. Recommendation 11: The Australian Government act upon the recommendations of the Productivity Commission to ensure effective monitoring and evaluation of the NDIS that actively involves people with disability and their representative organisations. 4 Specific Rights 4.1 Equality and non-discrimination (CRPD art 5, CO 14-15, LOI 5) 33. The duty to make reasonable adjustments under the DDA is narrower than the reasonable accommodation duty provided by the CRPD and explained by the Committee in General Comment No. 6 (2018). Under the 10