Impacts of Bill on NDIS employment supports (Provider advocacy)

Submission 798

Submission to the Senate Standing Committee on Community

Affairs

Inquiry into the National Disability Insurance Scheme Amendment

(Securing the NDIS for Future Generations) Bill 2026 Disability Employment Australia: critical analysis of impacts on participant-facing employment supports and the conditions providers need to invest in quality services

Executive summary Disability Employment Australia is the national peak body for disability employment. Our membership represents approximately seventy per cent of providers and more than ninety per cent of the national disability-employment caseload. Most of those organisations also deliver NDIS funded employment supports, including School Leaver Employment Supports and its successor

Capacity Building Employment Assistance, Specialised Supported Employment, Workplace

Assistance, Assistance to Access or Maintain Employment, and Employment Assessment and Counselling. The total NDIS employment-support market exceeds two hundred million dollars annually, with School Leaver Employment Support (SLES) alone representing an estimated one hundred and forty-five million dollar market across more than six hundred providers.

The NDIS was established on the foundations laid by the Productivity Commission’s 2011 Inquiry into Disability Care and Support, which set out the long-term case for a national insurance scheme on explicitly economic grounds. Employment was central to that case. The Commission argued that the Scheme’s return on investment would depend, in significant part, on its capacity to lift the economic participation of people with disability and their families, and on the application of insurance principles by which early investment in capacity-building would pay off over the life of a participant. More than a decade later, that analysis remains correct. It has, however, never been fully grasped, embedded, or operationalised within the Scheme’s design. Successive policy choices have treated employment as a discretionary plan goal rather than as a load-bearing pillar of the Scheme’s economic architecture. The result has been a weaker return-on-investment case than the Productivity Commission contemplated, and a narrower path to sustainability than the country requires. As Parliament now considers a Bill explicitly framed around long-term sustainability, the

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proper response is to recommit to that original insight, not to retreat from it through indiscriminate cost cutting.

DEA shares the Government’s objective of securing the NDIS for future generations, and supports those measures in the Bill that strengthen integrity and transparency. As drafted, however, the Bill substantially heightens the risk that participant-facing employment supports will become weaker, more fragmented, and harder to invest in, at the very moment the system needs them to be stronger. The Bill does this not because it singles out employment supports, but because its system level architecture has predictable, adverse effects on them. The new support-determinations power in section 34A permits Ministerial reductions in funding for groups of supports, including Assistance with Social, Economic and Community Participation (SECP) and Capacity Building – Daily Activities (CBDA), without any requirement to assess the impact on employment outcomes. The Explanatory Memorandum confirms an intended fifty per cent reduction in SECP and a ten per cent reduction in CBDA budgets in old framework plans, phased between October 2026 and September 2027. The tightening of “reasonable and necessary” in section 34 to supports arising “directly” from impairment, coupled with the new evidence hierarchies, makes it harder to fund capacity-building work where the link to employment is mediated by environmental or labour-market conditions. The plan-renewal mechanism in section 50A removes the annual planning conversation in which employment goals are typically refreshed. And the Bill is silent on the quality, design, performance management, and pricing of NDIS employment supports, doing nothing to address the documented under-performance of SLES and CBEA, or the fragility of the supported employment market revealed by recent provider distress.

The cumulative effect is to risk a smaller, lower-quality NDIS employment support market at exactly the time we need a larger and smarter one. Centre for International Economics modelling (funded by Job Support) found that NDIS participants in open employment cost the Scheme approximately seventeen thousand dollars per year less than comparable participants who are not working. Bankwest Curtin Economics Centre estimated that a ten per cent increase in the employment of people with disability would lift national output by sixteen billion dollars per year. Reducing capacity building budgets without redesigning employment supports therefore undermines both NDIS sustainability and Australia’s broader economic potential, and inverts the very logic on which the Scheme was originally built.

1. About this submission DEA has led the disability employment sector for more than twenty-five years. Since 2023, we have lodged a continuous program of submissions and policy papers engaging with the design, pricing, market conditions, and outcomes of participant-facing employment supports across the Disability Employment Services program, the new Inclusive Employment Australia program, the National Panel of Assessors, Ongoing Support, NDIS-funded employment supports, supported employment in Australian Disability Enterprises, and the broader foundational-supports architecture.

What is clear about that body of work, comprising some fifteen substantive submissions since August 2023, is the consistency of its themes. Across submissions on the NDIS Review, the design of IEA, foundational supports, the Disability Discrimination Act review, the Review of the NDIS Practice Standards, supported-employment reform, pre-budget priorities, election platforms, and most recently the IEA Performance Framework and Ongoing Support Model, five propositions recur. Each

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is anchored in the Productivity Commission’s original framing of employment as a central economic engine of Scheme success, and each illustrates how that framing has been progressively diluted in implementation.

1. Employment is a foundational, life-course outcome and a human right. Our 2023 NDIS Review submission argued that employment is too often siloed from broader plan-making. Our submission to the Thriving Kids inquiry referenced the “polished pathway” (Inclusion Australia) that channels young people with intellectual disability into day centres and segregated work in the absence of high expectations. Our submission to the Disability Discrimination Act review framed employment as an Article 27 right under the Convention on the Rights of Persons with Disabilities. These submissions converge on a simple point: employment must be designed into the system from the earliest planning conversations, not retro-fitted later.

2. NDIS-funded employment supports are too often ineffective and fragmented, and require redesign rather than retrenchment. Our submissions on the draft List of Supports, on supported-employment reform, and on the Review of the NDIS Practice Standards have consistently shown that current arrangements permit providers with no employment expertise to deliver employment-focused supports, that activities are often indistinguishable from generic community-access programs, and that outcomes for participants are poor.

3. Providers need stable, evidence-based pricing, long contracts, and transparent performance frameworks in order to invest in quality. Our Reimagining DES Pricing Report, our Pre-Budget Submission, our Election Platform, our Review of the IEA Procurement, and our most recent submission on the IEA Performance Framework all converge on this point. A regulatory regime that demands quality without funding it, or that disrupts contracts without managing transition, produces thin markets, workforce decay, and exit by quality providers.

4. IEA and the NDIS must work together as a complementary ecosystem. Our 2024 submissions on the General Foundational Supports consultation and on the DSS DES reforms argued for a “smooth curve of change” rather than a “jagged transformation”, with clear hand-offs between the NDIS and IEA, and explicit recognition of where supports should be universally available rather than individually funded.

5. Market stewardship, not just market enforcement, is essential. Our Supported Employment Reform Paper, our submission on the IEA procurement, and our DDA submission have argued for relational contracting, transformation funding for providers managing change, individual transition planning for affected workers, and active Commonwealth stewardship of fragile sub-markets.

These five themes provide the lens through which DEA examines the Bill.

2. Eight provisions of the Bill that affect participant- facing employment supports

The National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations)

Bill 2026 introduces a broad package of changes across five Schedules. The Explanatory

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Memorandum frames the Bill as a response to two key vulnerabilities, unsustainable cost growth and fraud, and as a vehicle for implementing the 2023 NDIS Review and the 2024 Registration Taskforce. It says the Bill will help meet National Cabinet’s January 2026 commitment to reduce annual cost growth to between five and six per cent, or lower.

DEA’s analysis identifies eight provisions of the Bill that most directly affect participant-facing employment supports and the conditions for provider investment.

2.1 Section 34A: support determinations reducing funding for groups of supports

Proposed section 34A permits the Minister, by legislative instrument, to determine a percentage (lower than one hundred per cent) by which a funding-component amount for a specified group of supports is reduced while the determination is in force. Subsection 34A(5) states clearly that the determination has effect even if the result is that funding for a reasonable and necessary support is less than its total cost. The Explanatory Memorandum is explicit about the intended first uses of this power: a fifty per cent reduction in SCCP budgets and a ten per cent reduction in CBDA budgets, phased between October 2026 and September 2027.

The implications for employment supports are significant. The category Assistance with Social, Economic and Community Participation contains line items widely used to fund employment-related capacity building, including community-access work that scaffolds eventual transitions into employment. Capacity Building – Daily Activities funds the development of independent living, communication, and self-management skills that are necessary preconditions for open employment. The Agency has previously advised providers to ‘use up’ this category while waiting for a review when a participant’s employment journey shifts and additional funds are needed e.g. additional funds for work experience placement or new job support whilst waiting for ‘change of circumstance review’. This means it functions as a ‘fall back’ so a participant doesn’t miss an opportunity. “Finding and Keeping a Job” capacity-building supports also sit within the architecture the Bill empowers the Minister to cap or reduce. Yet the Bill does not require the Minister to assess whether a reduction in a group of supports will diminish participants’ capacity to access employment, or undermine provider viability for employment-focused services. The Minister must “have regard to the safety of participants” but is not required to consider their economic participation.

Employment for people with disability is already fraught with multiple barriers, and any disruption to supports could have irreversible consequences, not only for participants but also for the broader economy. We must prioritise continuity of support and grandfather existing employment funding.

2.2 Section 33(2EA): maximums for funding, intensity, and worker-to-participant ratios

Proposed section 33(2EA) permits the Minister to specify a maximum amount of funding, a maximum intensity of support, or a maximum ratio of worker to participant for any support or class of supports. Subsection 33(2EB) requires those maximums to be respected in working out funding component amounts. The Explanatory Memorandum confirms that the caps may apply regardless of whether they meet the actual cost of supports.

Maximums on worker-to-participant ratios are particularly significant for Specialised Supported Employment and for evidence-based employment supports such as Individual Placement and Support, Customised Employment, and Project SEARCH, all of which rely on intensive one-to-one or low-ratio coaching. A blanket maximum ratio that does not differentiate between programs aligned with evidence-based practice and those that operate as a series of vacation-care activities risks driving the system toward the lowest-quality option, exactly the outcome our submission on the

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Review of the NDIS Practice Standards sought to prevent. Such ratios must also account for differences in regional and remote areas where different ratios should be maintained.

2.3 Section 34(1)(aa), (1A) to (1K): “reasonable and necessary” tightening

Item 31 of Schedule 1 amends section 34(1)(aa) to require supports to arise “directly from an impairment or impairments”, rather than simply “from an impairment”. New subsections (1A) to (1K) impose a hierarchy of evidence. Published, peer-reviewed and generalisable research must be considered before participant-level outcome evidence; informal and family supports must be preferred unless their unsustainability or material risk of harm is demonstrated; and “value for money” must be assessed against comparable lower-cost supports.

These are reasonable policy ambitions in the abstract. For NDIS-funded employment supports, however, they create three specific problems.

First, employment outcomes are mediated by environment. A capacity-building support for a young person with intellectual disability, for example a supported internship modelled on Project SEARCH, works precisely because it connects intrinsic capacity to environmental opportunity. A test of “direct” causation invites a narrower interpretation that excludes such supports, even though they are the precise evidence base the Bill otherwise claims to value.

Second, the peer-reviewed evidence hierarchy disadvantages newer practice. Evidence-based employment supports such as Customised Employment, IPS for psychosocial disability, and the Supported Employment Quality Framework have a robust international evidence base but limited Australian peer-reviewed literature. Subsection 34(1F) permits the CEO of the NDIA to be not satisfied where there is limited or no peer-reviewed research, even where outcome evidence exists. This discourages the very innovation the Explanatory Memorandum elsewhere claims to want.

Third, the presumption of informal supports does not apply well to employment. Subsection 34(1K) requires the CEO to consider relying on family, carers, and informal networks before funding supports. Employment is precisely the domain where informal substitution most often entrenches low expectations. Our 2023 NDIS Review submission, and our submission to the Thriving Kids inquiry, made this case at length.

2.4 Section 50A: plan renewals and the loss of an annual planning conversation

Proposed section 50A renews each old framework plan for twelve months by force of law, replicating the prior plan and applying any Ministerial determination under section 34A and any indexation. Crucially, the new plan does not require a new statement of participant supports, and the making of the new plan does not involve the making of any reviewable decision.

For employment supports, the Plan Review conversation has historically been the moment at which an “employment statement” can be added, refreshed, or expanded, a recommendation DEA has made consistently since our 2023 NDIS Review submission. The Bill removes that conversation for every renewed plan, while reducing funding for the categories in which employment-related capacity building lives. This is a structural anti-employment outcome that we do not believe Government intended.

2.5 Section 48A: controls on unscheduled plan reassessments

Section 48A restricts reassessment requests to participants and nominees, and only where there has been a “significant change” arising from a change in functional capacity or in living, education, work,

Submission 798

or informal-support arrangements. The Bill explicitly recognises work arrangements as a trigger, which is welcome.

The Bill goes further, however, by preventing support coordinators and other intermediaries from making reassessment requests on behalf of participants. NDIS employment providers, and IEA providers working alongside them, are often the first to identify the need for additional supports to maintain employment: post-placement transport, behavioural support during a probationary period, or assistive technology, for example. The Bill should make clear that participant-led requests assisted by their support coordinator or employment provider remain valid, and that “work arrangements” is interpreted broadly to include progression in employment, redundancy, or changes to hours.

2.6 Sections 17A, 17B and 3: the Scheme’s objectives and principles

Items 60 to 65 of Schedule 1 amend the objects and principles of the Act. New section 17B sets out scheme-sustainability principles, including that the National Disability Insurance Scheme is to fund supports for participants to meet disability support needs that arise directly from impairments.

Strikingly, neither section 17A nor 17B contains any reference to economic participation, employment, or work, even though section 4(11) of the parent Act describes the role of the NDIS in promoting the social and economic participation of people with disability. The 2019 NDIS Participant Employment Strategy committed to a target of thirty per cent of working-age participants in employment by 30 June 2023, a target that was missed (twenty-three per cent at last public report) and not refreshed. Subsequently, the target was revised down to make it look more achievable. The omission of employment from the new objects is more than a drafting choice. It is the latest in a series of design decisions that have progressively removed employment from the centre of the Scheme’s purpose, despite the Productivity Commission’s original insistence that economic participation was integral to the Scheme’s case. Reinserting employment as a Scheme principle would correct that drift, and would do so at the very moment that Inclusive Employment Australia, the supported-employment reform process, and the foundational-supports architecture all depend on employment being central.

2.7 Section 45C: pricing decisions transferred to the Minister

Schedule 3 transfers pricing decisions from the NDIA Board to the Minister, following the Annual Pricing Review, and creates a transparent legislative pricing instrument. DEA supports the principle of ministerial accountability for pricing. The Bill is silent, however, on the criteria the Minister must consider beyond Agency advice. As our analysis of DES pricing has demonstrated, indexation lag alone produced two-thirds of the real-terms cuts to DES funding between 2018 and the start of the current contract. The same pattern of indexation lag in NDIS employment supports would render evidence-based practice unaffordable. The Bill should require the Minister, in setting prices, to consider provider viability, indexation, workforce capability, and innovation, and to publish the evidence base for each Annual Pricing Review.

3. Why the Bill’s design risks weakening participant- facing employment supports The “headline” reductions to SCCP (fifty per cent) and CBDA (ten per cent) attract attention, but the deeper problem is that the Bill changes the system conditions that determine whether NDIS

Submission 798

employment supports succeed or fail. Those conditions, comprising funding adequacy and structure, performance frameworks, procurement and contract stability, workforce capability, collaboration with employers, interactions with income support, and broader market stewardship, must each be in place for participants to receive high-quality employment supports. We address each in turn.

3.1 Funding adequacy and structure

DEA has consistently argued that funding must follow evidence, not the reverse.

The Bill’s combination of section 34A reductions, maximum-funding caps, and a new “reasonable and necessary” hierarchy creates the conditions for increasing funding inadequacy within the NDIS. Combined with the Explanatory Memorandum’s signalled fifty per cent and ten per cent reductions to SCCP and CBDA respectively, the cumulative downward pressure on the support categories within which employment-related capacity building sits is substantial. The architecture of the Bill provides no mechanism by which evidence about cost, workforce, or innovation can constrain that downward pressure. In a market in which workforce shortage is already acute, and in which smaller providers operate on net surpluses in the low single digits (or worse), the Bill’s pricing levers create a real risk that quality providers will exit, that quality will fall, and that participant outcomes will worsen.

3.2 Performance frameworks

In our 2025 submission on the Review of the NDIS Practice Standards, DEA argued that any provider can currently register to deliver employment-focused supports, even if they have no experience, are not operating from an evidence-based service-delivery model, and are not familiar with employment regulations. Providers are not required to demonstrate that activities are employment-related and beneficial, and many instances exist of employment-focused programs operating more like a series of vacation-care activities than an individualised, goal-oriented service.

DEA’s recommended response was to separate compliance from quality and embed a participant feedback mechanism, mirroring the IEA Performance Framework reforms. We also recommended stronger Practice Standards specific to employment supports, requiring providers to identify their service-delivery model and demonstrate outcomes against it. The Bill does not include any of these reforms. It is, therefore, an incomplete response to the NDIS Review and Royal Commission recommendations it cites: it strengthens regulatory powers without strengthening the standards those powers are deployed against in the employment space.

3.3 Procurement and contract stability

DEA’s August 2025 Review of the IEA Procurement provides one of the most detailed publicly available analyses of how public procurement can fail. The procurement disrupted around forty-two per cent of participants nationally, who were attached to providers leaving employment service areas. We projected that more than half the national caseload would transition to a new provider. Of one hundred and ten employment service areas, only forty-two of the top-performing all-cohorts providers were retained, little more than a third. As we wrote at the time: for providers, it takes years to build community connections, foster employer relationships, recruit and train good staff, and to perform well; it costs millions of dollars to shut down sites and open new ones, make staff redundant, and hire recruits.

These insights apply directly to the NDIS. The Bill enables, through separate instruments, a commissioned panel of plan managers from October 2027 and a commissioned support coordination function from July 2028. Each transition risks repeating the IEA disruption: losing high-performing providers, breaking long-standing participant relationships, and forcing substantial sunk-cost write

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offs by not-for-profit providers. The Committee should require the Government to publish detailed transition plans before any commissioning round commences, ensure providers receive at least six weeks’ tender window with full questions-and-answers close-off two weeks before submission, and pilot relational contracting approaches that move beyond “essay competitions” toward long-term, evidence-based relationships, as DEA has urged repeatedly.

3.4 Workforce capability

DEA’s Election Platform and Pre-Budget Submission both emphasise that the disability-employment workforce is in a precarious state. Average not-for-profit profitability in DES was around three per cent. More than one-third of DES providers terminated their contracts over the duration of the previous program. Workforce churn is high, driven by burnout and fatigue. The Bill’s expanded compliance burden, with civil penalties of sixty to three hundred penalty units across many provisions, adds to that burden.

Our proposed Professional Members Program, a sector-wide framework for continuous professional development with an annual continuing-professional-development points model, is one example of how the system could build workforce capability. The Bill should be paired with explicit Commonwealth investment in workforce capability for NDIS-funded employment supports.

3.5 Collaboration with employers

DEA has been a consistent voice for demand-side reform since our 2023 NDIS Review submission. We have argued that there has been strong and sustained attention on the “supply side” of disability employment, but scant regard has been paid to the equally important demand side. Put simply, employers are not doing enough to be inclusive.

The most rigorous available evidence on how to shift employer behaviour comes from the United Kingdom, where Professor Kim Hoque and colleagues at Warwick Business School have produced a sustained body of research on the limits of voluntary employer accreditation. Hoque’s evaluations of the UK’s Disability Confident scheme have shown that voluntary employer accreditation tends to produce symbolic compliance rather than measurable change in disability employment outcomes; large numbers of employers can be signed up without any commensurate movement in workforce composition. Hoque has also been a leading voice for mandatory disability workforce and pay-gap reporting in UK companies above a defined size threshold, arguing that the voluntary reporting frameworks introduced in the late 2010s have had little discernible effect, and that transparency obligations are now necessary if the gap is to close. The underlying logic, that exhortation without measurement does not produce structural change, generalises directly to the Australian setting.

DEA recommends the same trajectory for Australia. Our priorities for demand-side reform are mandatory disability prevalence and pay-gap reporting for employers above a defined size threshold; a piloted Disability Confidence Scheme designed from the outset to converge with mandatory reporting; and procurement preferences for inclusive employers. These measures sit outside the NDIS, but they are essential to ensuring any NDIS employment support lands in real jobs. As part of accepting the Bill’s sustainability framework, the Government should commit publicly to an integrated demand-side package alongside the supply-side restraint that the Bill imposes.

3.6 Interactions with income support settings

The Bill includes a new Part 9 making eligibility partly contingent on access to other service systems. It is silent, however, on the interaction with the Disability Support Pension (DSP), which DEA’s Supported Employment Reform Paper identified as a material disincentive to work. The current taper

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rate of fifty cents per dollar earned, combined with a two-year suspension period, creates structural barriers that reduce the effectiveness of employment supports for participants on DSP. DEA is part of a group (including Inclusion Australia, NDS, and Down Syndrome Australia) which has proposed reducing the taper rate to thirty cents per dollar earned and extending the suspension period to ten years. Modelling suggests this change could support between 2300 and 14,700 additional DSP recipients into employment each year, with a net economic benefit estimated at around two and a third billion dollars over a decade.

DSP reform is not a matter for this Bill directly. The Committee should note, however, that the Bill’s effectiveness in supporting employment outcomes depends materially on the broader income support architecture, and that the case for progressing DSP reform in parallel with NDIS reform is strong.

3.7 Market stewardship

The Bill substantially expands the Agency’s enforcement and compliance powers, but does less to strengthen market stewardship, the proactive role of government in shaping the disability employment market. The 2025 voluntary administration of the Bedford Group, Australia’s second largest disability employer with around 1400 affected supported employees, illustrated that supported-employment market viability cannot be assumed. Ministerial action ultimately enabled a sale, but the experience indicated that the architecture of the market has been under-tended.

The Bill’s sustainability framework, by contrast, is largely backward-looking: it controls cost growth rather than building investment conditions. DEA’s Supported Employment Reform Paper sets out an integrated alternative: managed transition with transformation funding, structural adjustment, individual transition plans for employees, NDIA market stewardship, and active Transformation Consultants for providers at risk. The Bill should be paired with a transparent statement of how government will steward the markets affected by its reforms.

4. The reform the Bill should be paired with: redesigning NDIS employment supports A central recommendation of DEA’s Supported Employment Reform Paper is to replace suboptimal NDIS employment supports with arrangements that combine high fidelity to evidence-based practice with funding sufficient to sustain that fidelity. Our preferred design is a targeted Foundational Support for people with intellectual disability and those on the autistic spectrum, with five design features: high fidelity to evidence-based practice, drawing on the Supported Employment Quality Framework, Customised Employment, Individual Placement and Support, and Project SEARCH; funding that incentivises fidelity and positive outcomes; a rigorous approach to data and performance management; clarity on its position in the system, including its relationship with IEA; and access to supported internships and to further education opportunities.

We recognise that a foundational support is not the only feasible mechanism for delivering these outcomes. An alternative, and one DEA considers worthy of serious consideration alongside the foundational-support model, would be to offer an enhanced service within Inclusive Employment Australia for NDIS participants. Under this approach, eligible NDIS participants would access IEA as their primary employment service, with additional funding made available where providers

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demonstrate fidelity to recognised evidence-based models such as Individual Placement and Support for psychosocial disability, or the Supported Employment Quality Framework for participants with intellectual disability. The additional funding would be conditional on independent fidelity assessment and tied to participant outcomes. This model has the advantage of consolidating expertise within a single specialist program, leveraging IEA’s planned Performance Framework, and avoiding the confusion and opacity that has characterised the SLES, DES, and NPA interface to date.

In DEA’s view, either pathway, a properly designed foundational support, or a fidelity-assured enhancement within IEA, would represent a substantial improvement on the current arrangements, provided each is matched by sustainable funding, a transparent performance framework, and active market stewardship. What the Committee should not endorse is the reduction of NDIS employment support budgets without a parallel commitment to one of these reform pathways. We urge the Committee to recommend that, in accepting the Bill, the Government commits publicly to a redesigned employment-support framework by 1 January 2028; that the redesign is co-designed with people with disability (including those with intellectual disability and autism), specialist providers, employers, and DEA; and that funding for the new program is locked in via a parallel instrument before any reductions to existing CBDA or SCCP employment-related supports take effect.

5. How DEA’s recommendations cohere with the Bill’s stated objectives We are conscious that the Government’s stated aims are to secure the NDIS for future generations and to reduce annual cost growth to between five and six per cent, or lower. DEA’s recommendations are not in tension with that aim. They are critical to its sustainable achievement, and they restore the centrality of employment to the Scheme’s economic logic that the Productivity Commission articulated more than a decade ago. Three propositions support this conclusion.

6. Employment is the most powerful long-term lever for NDIS sustainability. NDIS participants in open employment cost the Scheme approximately $17000 per year less than comparable participants who are not working. For a Scheme under cost-growth pressure, a saving of this magnitude per participant per year is among the largest available levers, and it compounds over the life of a plan. The fiscal case extends beyond the Scheme itself. DES was estimated to deliver a return of approximately fourteen dollars for every dollar invested, with a projected total fiscal gain of around ninety-three billion dollars against six and a half billion dollars of expenditure under the previous contract. Bankwest Curtin Economics Centre estimated that a ten per cent increase in the employment of people with disability would lift national output by sixteen billion dollars per year. The productivity dividend from inclusive employment is substantial, durable, and broadly distributed across regions and industries. Halving the disability employment gap by 2035 would translate into a multi-decade national productivity uplift. These are precisely the order-of-magnitude returns the Productivity Commission relied on in making the original case for the NDIS.

7. Reducing capacity-building supports without redesigning employment services undermines long-term sustainability. A regime that reduces capacity-building budgets without reforming employment supports will reduce participant outcomes and weaken the Scheme’s long-term financial position.

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Such an approach delivers short-term savings at the cost of long-term liabilities, contrary to the actuarial logic on which the NDIS was founded. The human consequences are evident in the “polished pathway” described by Inclusion Australia whereby young people with disability drift into segregated or non-vocational settings when employment supports fail. A system oriented toward high expectations, supported decision-making, supported internships, access to further education, and structured employer engagement produces better outcomes and stronger returns.

3. Provider investability is a precondition for achieving employment outcomes. The provider market is the delivery system through which all participant-facing reform must flow. Sustainable employment outcomes require a system in which providers can invest in workforce, relationships with employers, and evidence-based practice. This, in turn, requires pricing transparency, contract stability, and explicit market stewardship.

4. Implementation considerations and safeguards If the Committee recommends passage of the Bill in amended form, DEA suggests the following implementation safeguards be reflected in either the Bill, the NDIS rules, or supporting instruments.

5. Targeted carve-outs for employment-related supports. Any reduction under section 34A to Assistance with Social, Economic and Community

Participation, Capacity Building – Daily Activities, Finding and Keeping a Job, or Specialised

Supported Employment should be accompanied by an employment impact statement tabled in Parliament.

2. Grandfathering for participants with employment goals. Participants whose plans include active employment goals should be exempt from automatic funding reductions on plan renewal until a planning conversation about their employment trajectory has occurred.

3. A transparent pricing methodology. The Minister’s Annual Pricing Review should be accompanied by publicly available documentation of the pricing methodology and evidence base, including consideration of provider viability, indexation, workforce capability, and innovation.

4. Long contracts and relational commissioning. Any commissioned panel for plan management or support coordination should operate for a minimum of five years, with renewal based on outcomes rather than repeated re-tender.

5. Workforce capability investment. The Bill should be paired with Commonwealth investment in credentialing and professional development for NDIS-funded employment supports, building on the Centre for Inclusive Employment’s work and DEA’s Professional Members Program.

6. A demand-side commitment. Supply-side restraint should be matched by demand-side reform, including mandatory disability prevalence and pay-gap reporting for larger employers, a Disability Confidence Scheme, and procurement preferences for inclusive employers.

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7. Co-design requirements. Any rule or instrument made under sections 34A, 33(2EA), 34, 45C, or 50A that affects participant-facing employment supports should be co-designed with people with disability, specialist employment providers, and employers.

8. Conclusion DEA strongly supports the goal of putting the NDIS on a sustainable footing. This can only be achieved while strengthening, rather than weakening, Australia’s capacity to deliver participant facing employment supports.

Across our work, DEA have returned repeatedly to a single proposition: the NDIS was built on the Productivity Commission’s insight that employment is central to the Scheme’s economic success, and that insight remains correct. It has, however, never been fully grasped or operationalised. Every major design choice that has treated employment as peripheral, from underpriced and under stewarded employment supports, to the absence of employment from the Scheme’s objects, to the persistent fragmentation across SLES, CBEA, IEA, and Workforce Australia, has weakened the return on-investment case that the Productivity Commission originally made. As we cast our eyes to long term sustainability, the answer is to double down on that original idea, not to abandon it in a maelstrom of cutting.

Judged against that benchmark, the Bill as currently drafted gets two important things right: it confronts the unsustainability of the current trajectory, and it strengthens integrity. But it gets several critical things wrong for employment. It reduces capacity-building budgets without redesigning employment supports. It tightens “reasonable and necessary” in ways that disadvantage evidence-based, environmentally mediated employment supports. It removes the annual planning conversation in which employment goals are typically refreshed. It is silent on the practice standards, workforce capability, and demand-side conditions needed for participant-facing employment supports to succeed. And it strengthens regulation while weakening stewardship of an already fragile provider market.

The amendments and accompanying commitments DEA has proposed would correct these problems without compromising the Bill’s sustainability objectives. Taken together, they would advance those objectives, because a Scheme that supports more participants into open employment is a more sustainable Scheme, and a more productive country. We welcome the opportunity to work constructively with the Committee, DSS, the NDIA, the disability community, and employers to make this Bill the foundation of a renewed commitment to the original economic logic of the NDIS: a Scheme in which employment is not an afterthought, but the engine of its long-term success.