NDIA Accountability Project

Protecting choice and inclusion for people with disability in regional communities

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From: IMPACT Community Services
Date: November 2025

Executive Summary

IMPACT Community Services urges the review to protect choice and inclusion for people with disability in employment and education. Retaining the Australian Disability Enterprises is critical to ensuring autonomy, psychological safety, and cost-effective support for those with high support needs, while education policy must safeguard flexible learning environments. Our recommendations strengthen the Disability Discrimination Act (DDA) and support diverse pathways to participation.

1. About IMPACT Community Services

IMPACT Community Services has operated in the Bundaberg region since 1978, supporting the most vulnerable people to improve their lives through employment, training, and social services.

  • We have run IMPACT Recycling and Collections, a Material Recovery Facility (MRF), since 2001, providing sustainable employment opportunities for people with disability. During this time, we have worked closely with Bundaberg Regional Council to prevent full mechanisation of the MRF to ensure continuous employment options for people living with disability in the Bundaberg region.
  • We currently employ 30 supported employees under the Supported Wage System (SWS), with varying degrees of disability. Across the workforce, the average productivity is just under 50%, with 93% of employees above 30%.
  • IMPACT works collaboratively with local high schools to create tailored work experience options for young people with disabilities to promote joining the work force once completing schooling.
  • We also administer Inclusive Employment Australia (IEA) contracts into other regional Queensland communities, creating pathways for people facing barriers to employment.

Our aim is to create choice, inclusion, and opportunity for people with disability in regional communities.

2. Our Position on Supported Employment and Australian Disability Enterprises (ADEs)

IMPACT strongly supports ADEs as a vital mechanism for inclusion and empowerment.

  • Choice and Flexibility: All supported employees choose to work with us in an ADE employment model and decide how many hours they undertake, reinforcing autonomy and dignity.
  • Psychological Safety: Removing our ADE would cause significant psychological harm for employees, including trauma from losing a safe, structured environment and sense of purpose.
  • Community Impact: Supported employment enables participation in community life; our employees have achieved milestones such as buying homes and cars, demonstrating independence and inclusion.
  • Family Wellbeing: Supported employment provides respite for carers, reducing stress and improving family dynamics.
  • Cost Efficiency: Our model operates on a 1:5 support ratio. If supported employees were in open employment settings, they would require 1:1 support, making it five times more expensive under the NDIS.

3. Risks if ADEs are Removed

  • Loss of employment for people with high support needs.
  • Increased isolation and reduced community participation.
  • Psychological harm and trauma from losing safe workplaces.
  • Greater pressure on families and carers.

4. Equity and Choice in Education

IMPACT also supports equity and choice in educational settings for students with disability. We believe the DDA should protect the right to learn in environments that meet individual needs, not impose a one-size-fits-all approach.

  • Tailored Support: Students should receive adjustments and resources that enable them to achieve their highest potential.
  • Inclusive Pathways: Integration into mainstream schooling should be encouraged where appropriate, but supported options must remain available for those with complex needs.
  • Flexibility: Education policy should recognise that inclusion is not about location alone; it is about meaningful participation and outcomes.

5. Risks if Choice in Education is Removed

  • Students with complex needs may experience educational failure and disengagement if forced into mainstream settings without adequate support.
  • Increased psychological distress for students and families when appropriate learning environments are unavailable.

6. Our Recommendations

  1. Introduce a Positive Duty: Employers should proactively prevent discrimination while maintaining flexibility for supported employment models.
  2. Clarify Reasonable Adjustments: Clearly explain what reasonable adjustments mean, make sure they apply in both work and education, and consider people who face multiple challenges like disability combined with gender or cultural factors.
  3. Continue the Supported Wage System as a legitimate option under the DDA.
  4. Recognise diversity in employment models. ADEs should complement, not compete with, open employment and social enterprise options. Individuals should have dignity of choice and be supported to choose what model of employment suits their unique and individual needs.
  5. Award Reform: a. Remove Grades A and B from the Supported Employment Services Award. b. Set the starting point at Grade 1 (20%), rather than the current 12.5% minimum, to ensure fairer wages. c. Give wage assessors more control and authority on Award grades when completing assessments.
  6. Do not fully eradicate sub-minimum wage, as doing so would limit employment opportunities for people with very limited capacity who still want to work.
  7. Strengthen enforcement mechanisms within the SWS framework to ensure best practice and prevent misuse.
  8. Require exhaustion of industry grievance mechanisms before DDA complaints are accepted, to avoid unnecessary litigation and protect viable employment models.
  9. Support inclusive education spaces. IMPACT collaborates with local schools and sees stronger outcomes when education and employment pathways are integrated.

7. IMPACT Case Studies

Case Study 1 - Stability and Success Through Supported Employment: SE1 lives with a physical disability and works full-time under SWS with 99% productivity (Grade 5).

Despite attempts at open employment, SE1 could not maintain long-term employment and chooses SWS for stability and access to essential concessions.

Case Study 2 - Cost Efficiency and Long-Term Inclusion: SE2 has an intellectual disability and works full-time under SWS with 30% productivity for 14 years. Open employment would require 1:1 support, costing the NDIS five times more than the current 1:5 ratio within an ADE.

Case Study 3 - Rebuilding Confidence After Open Employment Challenges: SE3 has ASD and works part-time under SWS with 41% productivity. After repeated failures in open employment, SE3 regained confidence through supported employment in an ADE and is now preparing for future open employment opportunities.

Closing Statement

IMPACT Community Services urges the Review to protect choice and inclusion for people with disability. ADEs are not segregation; they are a pathway to dignity, purpose, and community participation for those who need it most. We believe these recommendations strengthen the DDA’s ability to protect rights while supporting diverse pathways to inclusion.