Submission to the

Joint Standing Committee on the National Disability Insurance

Scheme

on the

Subject: Market Research Findings regarding NDIS Employment Provider Responsiveness and Professional Job Carving

Submitted by

Louise Christel Marie Camille Kaestner

Disclosure of GenAI use ……………………………………………………………………………………………… 2

Introduction ……………………………………………………………………………………………………………….. 2 Terms of Reference Addressed …………………………………………………………………………………….. 3

The Barrier: Accessing Professional Employment Support ………………………………………………. 3 Methodology: Provider Outreach Research ……………………………………………………………………. 4

Results and Findings …………………………………………………………………………………………………… 4 Discussion: Systemic service gap …………………………………………………………………………………. 4

Recommendations to the Committee …………………………………………………………………………….. 5 Conclusion ………………………………………………………………………………………………………………… 5

Disclosure of GenAI Use

As a neurodivergent individual with a comorbid diagnosis of CPTSD, I use GenAI as assistive technology to bridge the gap between my unique method of communication and neurotypical/non-disabled communication standards. The GenAI tool used to help structure and polish the language of this submission is Google Gemini and Perplexity. I have maintained data privacy protocols throughout this process.

Introduction

I am a current NDIS participant, accepted onto the scheme in 2024. One of my employment goals is to find and keep a job. As a person born with ASD and who developed PTSD in childhood, I have experienced long-term instability in employment, including repeated exploitation and difficulty securing sustainable work.

I’ve found that conventional recruitment systems, including applicant tracking systems and standard interview processes, disadvantage applicants whose communication style or employment history do not fit a linear or neurotypical pattern. As a result, my skills and experience, developed through life experience, volunteering and study, are not always assessed on an equal basis.

The Disability Discrimination Act 1992 prohibits indirect discrimination in employment and recognises that reasonable adjustments may be required to enable people with disability to participate in work on an equal basis. Western Australian guidance also states that employers must make reasonable workplace adjustments, and that these adjustments may include modifying work tasks to support a person with disability to work productively and safely. In that context, job carving and job customisation are practical examples of reasonable adjustment because they can reduce procedural barriers and align a role with a participant’s strengths and support needs.

In April 2026, I contacted 21 NDIS employment providers in good faith, based on their public commitments to inclusion, service and participant support. Despite outlining my strengths, needs and goals, I received little meaningful engagement. My research therefore

Terms of Reference Addressed

ToR 1: Non-compliance and sharp practices.

I provide data suggesting that some providers systematically ignore or filter out professional enquiries in favour of high-turnover, entry-level placements.

ToR 2: Impacts on participants.

I outline the psychological and economic harm caused by repeated non-response, particularly for participants with CPTSD, and explain how this can prevent economic participation. Silence/non-response is a form of relational trauma.

ToR 3: Adequacy of government policies.

I present evidence of a market gap that persists despite the Government’s stated commitment to participant choice and control and employment outcomes.

ToR 4: Required reforms.

I propose accountability measures to help ensure providers respond to all participant enquiries, regardless of perceived profitability.

The Barrier: Accessing Professional Employment Support A major barrier identified in this research is the limited capacity of some NDIS employment providers to support professional participants. Existing service models often appear to favour high-volume, entry-level placements and may not accommodate the more nuanced job carving or job customisation required for skilled roles.

For a professional participant, this can be disempowering, along with reducing choice and control. Job carving or customisation is not a favour but a reasonable adjustment for a person with disability who has demonstrated merit but faces barriers in conventional recruitment processes. Applicant tracking systems and standard interviews can privilege social presentation over capability, which may amount to indirect discrimination.

NDIS employment providers also tend to rely on standardised service models designed around billable hours, including discovery, job search planning, job development and negotiation and post-employment support. In one case, I received a response that included material focused on personal hygiene, literacy and numeracy, despite having clearly identified myself as a professional participant.

The 3-hour profitability barrier highlights a mismatch between provider funding models and the needs of participants seeking a gradual return to work. For a person managing CPTSD and ASD, a low-hour engagement may be the safest and most sustainable way to begin employment. However, my research suggests that some providers treat this as administrative inconvenience rather than as a legitimate support need.

The pattern of non-response itself functioned as an access barrier because it prevented meaningful entry into the service pathway. Despite clear, professional and legally literate outreach, the limited response suggests that some providers use administrative gatekeeping to

Methodology: Provider Outreach Research

I constructed a fact-based, legally grounded email to demonstrate my research skills and legal literacy. I sent this email to the general inboxes of multiple NDIS employment providers and followed up with their management and leadership to maximise the chance of a response.

I also reviewed the wording carefully to ensure the tone was appropriate and professional. The email is available upon request and set out my funding status, professional value proposition, proposed carved role and employment terms, legal basis, portfolio and accountability notice.

Results and Findings

Total Providers Contacted: 21
Non-Responsive (No contact made): 15
Did not respond (Initial contact, then stopped responding): 3
Referrals Out (Declined to provide service): 2
Out of Office: 1
Success Rate: 0%

Discussion: Systemic service gap

My outreach to 21 providers produced no successful engagement, which suggests a significant service access gap for participants seeking professional-level job customisation. Despite the legal obligations of the Disability Discrimination Act 1992 and the Western Australian Equal Opportunity Act, there appears to be a clear market gap for professional participants.

Providers appear to be commercially incentivised to prioritise low-skill, high-turnover placements. This can exclude high-performing neurodivergent professionals who require nuanced job carving. The resulting neglect may push skilled individuals into deskilling and welfare dependence, which is inconsistent with the NDIS goals of economic participation and choice and control.

The pattern of non-response is not merely an administrative lapse. It may amount to a sharp practice that effectively blocks access to the professional employment market.

Recommendations to the Committee

Mandatory Professional Competency Training: The NDIS Commission should mandate certified education for employment provider staff, specifically focused on communicating with and advocating for professional participants. This training must include competency in job negotiation, professional job carving and understanding the legal obligations of Reasonable Adjustments for skilled roles.
Establishment of a Professional Participant NDIS Framework: Design and implement a new, specialised employment framework specifically for participants with university degrees, professional experience or demonstrated professional-grade skills. This framework should bypass generic entry-level Discovery models and instead provide funding for high-level recruitment advocacy and professional consultancy to bridge the Experience Paradox.
Mandatory response metrics: Introduce a duty to respond within the NDIS Practice Standards, requiring providers to acknowledge service enquiries within 5 business days and provide written reasons for any decision to decline service.
Professional service standards: Develop specific NDIS performance measures for professional job carving so providers are incentivised to support skilled participants seeking tailored employment pathways.
Audit of infantilising materials: Require the NDIS Commission to review and take action against providers that issue generic entry-level materials, such as basic hygiene pamphlets, to participants who have clearly identified themselves as professional participants.
Reporting non-response: Establish a clear mechanism for participants to report failure to respond as a form of non-compliance and service discrimination.

Conclusion

This research suggests that for professional neurodivergent participants with spiky profiles, The NDIS employment market is not currently fit for purpose. Of the 21 providers contacted, one provided a successful employment pathway, and the pattern of non-response and infantilising service delivery indicates that choice and control is not being realised for participants who do not fit a high-volume, entry-level service model.

I urge the Committee to treat this evidence not as a series of isolated administrative lapses, but as a serious failure of scheme integrity and a failure to uphold the rights of professionals with disability. Real inclusion requires more than marketing. It requires a regulated market that is accountable, responsive and capable of supporting the economic participation of people with disability across a range of support needs.

                 I can provide supporting evidence and findings on request.

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Market access barriers for professional participants with ASD and CPTSD