A/HRC/34/26 protection in a cross-cutting way for all rights and areas of life;35 and (c) explicitly cover all persons with disabilities, including children, indigenous people, women and girls, hard-ofhearing persons, deaf persons and people with psychosocial disabilities. 69. In particular, legislation should set out explicitly the obligation to provide reasonable accommodation with regard to all rights as immediately enforceable,36 stating that denial of reasonable accommodation constitutes discrimination on the basis of disability. States could make an arbitrary denial of accommodation punishable by law. 37 States should furthermore regulate the criteria for the provision of reasonable accommodation,38 identifying the entities responsible and addressing the specific context of implementation. The implementation of reasonable accommodation calls for flexible policies, clear guidelines and protocols, specific resources and the efficient and timely management of funds in order to respond immediately to requests for it. In the United Kingdom of Great Britain and Northern Ireland, the public Access to Work programme provides grants to cover the costs of reasonable accommodation incurred by employers who hire persons with disabilities. New Zealand has allocated public funds to the provision of sign language for specific situations, and has formulated guidelines for the implementation of reasonable accommodation. 70. States must develop policies to prevent the exclusion of persons with disabilities and to combat discrimination against them,, in particular multiple and intersectional discrimination based on disability, age, gender, indigenous background and rural isolation, ethnicity, Afro-descendant origin or migrant status, among others. In particular, social protection schemes should include older persons with disabilities, for instance by ensuring coverage of disability-related costs when transitioning to retirement. Policies should also prevent discrimination among persons with disabilities; for example, disability-related services and benefits should be provided irrespective of the cause or kind of impairment. 39 Along these lines, policies should envisage budget allocations and markers for women with disabilities and for children with disabilities. For example, in Togo, the Fond national de finance inclusive explicitly targets women with disabilities, facilitating their access to funding. The European Disability Strategy (2010-2020) includes several provisions on children with disabilities. 71. States must also ensure the proper monitoring of compliance with legislation and policies on equality and non-discrimination, including the provision of reasonable accommodation. Discrimination against and the stereotyping of persons with disabilities can be rooted in customs and beliefs, including those held by public officials. Monitoring should have an enhanced focus on the situation of the most marginalized (such as persons with albinism, in certain contexts, and those with psychosocial disabilities). Persons with disabilities should have access to information and simple and effective remedies to assess governmental action. 72. Monitoring bodies operating under article 33 (2) of the Convention should have sufficient powers to carry out investigations and impose sanctions on public or private bodies that commit acts of discrimination,40 and could indeed serve as an effective alternative means of recourse for persons with disabilities to obtain redress without 35 36 37 38 39 40 16 CRPD/C/GAB/CO/1, para. 13 (a). CRPD/C/DEU/CO/1, para. 14 (b). CRPD/C/UKR/CO/1, para. 10. CRPD/C/MEX/CO/1, para. 52 (e). CRPD/C/HRV/CO/1, para. 8. CRPD/C/ECU/CO/1, para. 15.

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