Submission 36 — Catholic Social Services Australia — NDIS Workforce

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GPO Box 1947     T 02 6285 1366•   ~  Catholic Social                                                                                Canberra ACT 2601   admin@cssa.org.au

Level 2 Favier House    www.cssa.org.au        Services Australia

51 Cooyong St Braddon ACT 2612   ABN 18 810 059 716   •

13 May 2020

Ms B Allan

Secretary

Joint Standing Committee on the National

Disability Insurance Scheme

PO Box 6100

Parliament House

Canberra ACT 2600

Dear Ms Allan

Please find attached our submission to the Joint Standing Committee on the National Disability Insurance Scheme Inquiry into the NDIS workforce.

Sincerely,

Dr Ursula Stephens

Chief Executive Officer

Catholic Social Services Australia

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~ Catholic Social

  • Services Australia Submission to the NDIS Workforce Inquiry of the

Joint Standing Committee on the National Disability

Insurance Scheme

May 2020

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Contents

Introduction …………………………………………………………………………………………………..4

Recommendations from this submission …………………………………………………………5

The National Disability Insurance Scheme ……………………………………………………….5

Workforce issues now ……………………………………………………………………………………6

Workforce in light of COVID-19 ……………………………………………………………………….7

COVID-19 economic measures ……………………………………………………………………..8

Access to Personal Protective Equipment …………………………………………………….9

Scenarios for the NDIS workforce post-pandemic …………………………………………….9

A return to Pre COVID-19 conditions …………………………………………………………….9

1.1 National Workforce Plan ………………………………………………………………………. 10

1.2 Disability Employment Pathways ………………………………………………………….. 11

Disruption to the NDIS Post COVID 19 ………………………………………………………… 13

Conclusion ………………………………………………………………………………………………….. 14

References ………………………………………………………………………………………………….. 15

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Introduction

Thank you for the opportunity to make a submission to the Joint Standing Committee on the National

Disability Insurance Scheme’s Inquiry into the NDIS Workforce. We acknowledge the significance and

timeliness of this inquiry, as the NDIS workforce is set to face increasing demand and challenges. In light

of the developing COVID-19 pandemic, the scope of our submission has changed significantly. Thus, we

will highlight both current issues within the NDIS workforce, and emerging issues induced by the

coronavirus crisis, before making recommendations based on potential scenarios post-pandemic.

Catholic Social Services Australia (CSSA) is the Catholic Church’s national body for social services. Our

organisation envisages a fairer, more inclusive Australian society that reflects and supports the dignity,

equality and participation of all people. CSSA works alongside an extensive national network of social

services providers to challenge, advocate and campaign for the development of just and compassionate

social and economic policies that will improve the lives people who are poor and vulnerable in Australia.

The membership network of CSSA is made up of around 50 Catholic social welfare organisations across

the country with more than half of our members delivering services to people with a disability. This

submission reflects our member agencies’ experiences with the NDIS, and their concerns with the

workforce problems associated with meeting the growing demands of the scheme.

The social service ministry, and by extension, the NDIS, is integral to the mission of the Catholic Church

in Australia. The Catholic Church, alongside other Christian Churches, have played an integral role in the

development of social services policies in Australia. Furthermore, Catholic social teachings outline the

importance of human dignity and the worth of each person. They also teach the importance of values such

as subsidiarity, where decision making and responsibility should be as close as possible to those most

affected by the decision, and solidarity, in which we recognise and celebrate the diversity of the human

family and responsibility for one another. These teachings closely align with the fundamental aims of the

NDIS and are integral to its workforce.

While committed to ensuring the success of the NDIS, CSSA and its members are very concerned about

the ability of the workforce to cope with the rapidly increasing demand for its services. The NDIS workforce

will need to employ a further 90,000 staff to meet the demands of the expected 480,000 participants when

the scheme is fully implemented (DSS 2019, 1). Furthermore, CSSA is very concerned about the impact

of COVID-19 on the NDIS workforce. It remains to be seen what impact COVID-19 will have on the NDIS

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workforce, but it is likely that there will need to be some changes post-pandemic to ensure that the scheme

fulfils its purpose of supporting all participants.

Recommendations from this submission

CSSA recommends that a number of steps be taken to address the issues prevalent within

the NDIS workforce and the increasing demand for its services. These include:  Prioritising the development of a national workforce plan that includes an awareness

raising campaign to attract and retain workers;  Providing the opportunity to enhance skills development within the workforce;  Re-examining the NDIS fee structure; and  Supporting pathways to meaningful employment for willing NDIS participants.

The National Disability Insurance Scheme

The NDIS is one of Australia’s most significant public policy initiatives. It was established in 2013 on the

basis of providing choice and control for people with a disability to access the support they need, when

and where they need it. The scheme allows participants to access funding for any support needs related

to their disability and to enable them “to participate in economic and social life” (NDIS 2013, 10). The NDIS

is based on the principle of choice, in which participants select which providers support them, underlining

the importance of self-determination and agency. The successful delivery of the NDIS is reliant upon a

skilled, committed and caring workforce.

The NDIS legislation was developed within the scope of Australia’s obligations under the United Nation’s

2006 Convention of the Rights of Persons with Disabilities (CPRD). The CPRD outlined that its purpose

was to “promote, protect and ensure the full and equal enjoyment of all human rights and fundamental

freedoms by all persons with disabilities” (UN 2006, 4). As a signatory of this convention, the Australian

government has committed to “take all appropriate measures” to ensure that persons with disabilities are

able to live without discrimination in Australia.

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The National Disability Insurance Scheme Act 2013 aims to “support the independence and social and

economic participation of people with a disability” and to promote the provision of high quality and

innovative supports that enable people with disabilities to maximise independent lifestyles and full inclusion

in the community” (Office of Parliamentary Council 2013, 4). At the core of these objectives is enabling

people with disabilities to live an independent life based on social and economic participation. This

independent life includes the ability to access meaningful employment.

Workforce issues now

The Department of Social Services has projected that there will be an expected 480,000 participants in

the NDIS when the scheme is fully implemented in 2020. In order to meet the needs of these participants,

the Department of Social Services (DSS) has estimated that the NDIS will need a further 90,000 staff (DSS

2019, 1). In 2019, the DSS found that the NDIS workforce consisted of approximately 100,000 full time

equivalent staff (DSS 2019, 1).

A 2017 Costings Report by the Productivity Commission highlighted that during the transition period to full

operation of the NDIS, 1 in 5 (net) jobs created in Australia will need to be in the disability sector (PC 2017,

319). The scale of this workforce growth dwarfs previous major national projects in Australia, placing the

government in uncharted waters. For instance, the rollout of the National Broadband Network required a

workforce increase of 25,000 staff and the Building the Education Revolution Program of 2007-2010

required 22,971 additional staff (DSS 2019, 1). The additional 90,000 staff required for the NDIS to meet

its demand when fully rolled out this year poses a very substantial challenge.

In addition to increasing the NDIS workforce, there are a number of issues that exist within the workforce

that need addressing. Firstly, staff within the disability sector do not receive remuneration that reflects the

challenging and demanding nature of their work. The majority of disability support workers are paid a little

over the minimum wage. In 2018, a study found that many NDIS staff experienced “difficulties earning

enough to pay their bills” (MacDonald et al. 2018, 87). The casualisation of the sector also results in

workers receiving less hours and unstable work. A workforce which does not feel adequately valued will

struggle to effectively carry out its role and will experience difficulty in attracting new staff.

The decline of permanent, full-time employees and the growing casualisation of the workforce is another

issue. From September 2015 to September 2017, the growth rate of casual workers in the disability

workforce was 26% per year, compared to only 1.3% per year for the permanent workforce (NDS 2018,

7). In 2018, the NDIS workforce comprised of only 6% fixed staff and 10% permanent full-time employees,

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compared to 38% permanent part-time and 46% casual staff (NDS 2018, 5). This is problematic as

workforce stability is essential to meet current and future demands. Further, workforce instability can result

in poorer outcomes for participants. Indeed, for many in the system, having established and reliable

support workers is crucial to their care.

Studies have found that workers in the disability sector experience high levels of stress and burnout. This

has been an ongoing issue that existed prior to the creation of the NDIS, and continues to this day. In

2011, the Productivity Commission found that stress and burnout, and the high “emotional and physical

demands” placed on staff resulted in high staff turnover (Productivity Commission 2011, 703). In 2010, it

was found that 13% of surveyed workers in the Australian disability sector listed “stress or burnout” as a

reason for leaving their occupation (Martin and Healy 2010, 148). In 2017, the Curtin University conducted

a study into the experiences of 12 disability support workers in Australia. They found that stress and

burnout were a very common experience amongst these staff, and that these conditions led to workers

experiencing difficulty in performing to their full potential (Judd et al. 2017, 1114-1115). Disability support

workers clearly continue to face a demanding working environment, and it is imperative that these staff

are better supported.

These issues in part explain the high staff turnover rate within the NDIS workforce. In June 2019, the

quarterly turnover rate for permanent staff in the disability sector stood at 5%, with the rate for casual

workers somewhat higher at 7% (NDS 2019, 58). This highlights the difficulty of retaining staff in the

disability workforce. High turnover also leads to higher costs in recruiting new staff. This further cements

the importance developing and promoting a sector in which its workforce feel valued and supported.

In the face of these findings, it is imperative that a national workforce plan is designed to meet the growing

demand  for workers  in the  disability support sector. Complacency and inadequate action on the

development of a sustainable NDIS workforce will undermine the scheme and directly impact those it

supports.

Workforce in light of COVID-19

The COVID-19 pandemic has introduced significant challenges to the NDIS workforce. As the current

situation is ongoing and developing it is difficult to determine the level of impact that this crisis will have on

the workforce. That said, many of the issues discussed in the previous section are being magnified during

the ongoing pandemic.

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Casualisation of the NDIS workforce has reduced the stability of the sector. Due to the COVID-19

pandemic, casual workers are at greater risk of losing their jobs as has been witnessed in other sectors.

Given that in 2018, the workforce comprised of 46% casual staff, a large proportion of the workforce is at

risk. However, it is critical that NDIS participants continue to receive support care during this crisis. The

sector’s demand for an additional 90,000 staff to meet the needs of a fully implemented NDIS will be further

challenged if workers are laid off during this pandemic.

COVID-19 economic measures

The Australian Government has introduced a number of employment measures to soften the economic

impact of the COVID-19 pandemic on the Australian economy. The most significant of these measures in

the context of this submission is JobKeeper. The JobKeeper payment of $1500 a fortnight is $20 above

minimum wage, which for many in the NDIS workforce is significantly greater than their current income

(Cassells and Duncan 2020). We see two issues arising from JobKeeper that may have a bearing on the

future NDIS workforce.

The NDIS has been particularly impacted by the cancellation of services during the COVID-19 pandemic.

The “fee for service” model operating across large parts of the NDIS leaves employers little capacity to

continue  to pay employees when demand  for services  falls. While the Australian Government’s

announcement on 21 March on changes to the NDIS were welcome, access to JobKeeper is, for many

employers, critical to the maintenance of their NDIS workforce. However the construction of the current

NDIS workforce complicates the accessibility to JobKeeper, and for some employees, access to

JobSeeker.

The JobKeeper Payment is designed to help businesses affected by the Coronavirus to cover the costs of

their employees’ wages, so that more employees can retain their job and continue to earn an income. It

has been described as an employer attachment payment. Casual employees are only eligible if they were

employed by an eligible entity on a regular and systematic basis for at least 12 months at 1 March 2020.

The eligibility requirement for casual employees, is problematic given the high level of casuals employed

within the NDIS. In the short-term there will be many casuals who will no longer be attached to the NDIS

because of their ineligibility to qualify for JobKeeper, which in our view will be problematic for the future

NDIS workforce. Conversely, a number of employees will receive more income because of their eligibility

to JobKeeper. The difficulty for the sector will be the financial impact the withdrawal of JobKeeper will have

on these individuals and the consequences of this on the employee’s decision to remain within the sector.

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Access to Personal Protective Equipment

The NDIS workforce has limited access to access to Personal Protective Equipment (PPE) due to the

extraordinarily high demand in the current situation. Hospitals are struggling with the limited supply of PPE,

with medical staff reportedly having to reuse facemasks (Knaus 2020). The CEO of the NDS, David Moody,

on 9 April 2020 stated that NDIS support workers were struggling to access protective equipment (Truu

2020). He noted that without adequate access to PPE, the challenge of “ensuring that there will be

sufficient workers to actually support people with a disability during the pandemic” is raised (Truu 2020).

The concern about contracting COVID-19 has seen in increase in staff cancelling their shifts. A further

increase in cancellations will test the system’s ability to deliver vital services, especially if there is a COVID

19 cluster within an entity or facility with NDIS participants.

The outbreak of the COVID-19 pandemic has posed a number of new challenges for the NDIS workforce,

as well as exacerbating the issues that previously existed within the workforce.

Scenarios for the NDIS workforce post-pandemic

It is still unclear what impact and challenges the current pandemic will present to the NDIS and its

workforce once the health challenges have been mitigated. If the situation returns to ‘normal,’ and the

NDIS sector emerges relatively unscathed, the critical issues, pre-COVID-19, facing the workforce will

need to be addressed. However, if there is a significant change to the disability sector following the

abatement of the pandemic, there will be many new and potentially more serious challenges facing the

workforce that will require system-wide reforms. In the following section, we will consider two different

post-pandemic scenarios, and their respective workforce issues.

A return to Pre COVID-19 conditions

If the disability sector emerges from the COVID-19 pandemic relatively unchanged, there are a number of

important issues that will need to be addressed. As discussed previously, these include insufficient

remuneration for staff, increasing casualisation of the workforce and the demand for 90,000 additional staff

by 2020. Further, the implications of the application of JobKeeper on the sector may see a decline in the

number  of casual employees  willing  to work  in the  sector,  especially should other employment

opportunities present themselves during the economic recovery period.

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CSSA believes that a national workforce plan should be established by the Australian Government to

address these issues. Furthermore, CSSA recommends the national workforce plan include a focus on

the development of stronger employment pathways for willing NDIS participants to gain meaningful, paid

employment within the NDIS itself.

1.1 National Workforce Plan

It is imperative that a national workforce plan is established for the NDIS to meet the projected demand

for workers in the system. CSSA believes that this workforce plan should be underpinned by innovative

strategies that attract new workers to the sector and enhance the development and retention of existing

staff.

Firstly, the NDIS requires a workforce plan that promotes the importance and value of the sector. A public

campaign that highlights the importance of working in the sector is necessary. This needs to showcase

the  life changing difference that disability support workers experience.  It is essential that the NDIS

workforce is built around staff who are passionate about the industry, and thrive in an environment where

they show compassion and care towards those they support. A public awareness campaign that

showcases the rewarding nature of the industry and the importance and value of the sector will be a step

in the right direction towards developing a workforce pipeline.

In the 2018-19 financial year, the Australian government spent a total of $140 million on advertising across

its departments and agencies (Department of Finance 2019, 12). The Department of Defence dominated,

spending $30 million on recruitment advertising (Department of Finance 2019, 11). Australian Defence

Force recruitment has received a total of $157.6 million over the last 5 years. It is CSSA’s position that

strengthening the NDIS workforce pipeline will require a similarly significant financial investment by the

Australian government to create a prominent public campaign to attract new staff to the disability sector.

As well as attracting new staff to the expanding NDIS workforce, it is also important to focus on retaining

staff. As outlined previously, the quarterly turnover rate for permanent staff in the disability sector in 2019

was 5%, with the rate for casual turnover at 7% (NDS 2019, 58). Factors such as high levels of stress and

burnout, and relatively low levels of remuneration contribute to this. To address staff retention it is essential

that staff are well managed and supervised. Greater focus needs to be placed on the training and

development of staff. More training and development opportunities need to be provided to the workforce

so that their skills and knowledge are regularly refreshed. In order to facilitate greater training and

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professional development, the fee structure for the NDIS needs to be revamped to enable providers to

offer employees access to more professional development opportunities.

Whilst skills and knowledge are critical to the delivery of NDIS services, values such as empathy and

compassion, and a commitment to making a better life for other people is also incredibly important. It is

essential therefore that the remuneration levels within NDIS are sufficient to attract employees with the

right skills and values as well as retain and reward those also already working in the NDIS.

A national workforce plan requires quality and innovation to continually refresh the system. It is not simply

enough to create a workforce pipeline. It is imperative to encourage and invite innovation in order to

stimulate the ongoing development of the NDIS workforce, and avoid stagnation. This could be achieved

by using new technology to address challenges faced by staff. For example, using technology to deal with

administration provides support workers the ability to focus more on the care and support of participants,

resulting in greater outcomes for both the workforce and those the NDIS supports. A survey in 2018 found

that only 46% of organisations providing services in the Australian disability sector believed that their

“information & service delivery system(s) work well for our staff and management” (Infoxchange 2018, 10).

This was well below the national average of 54% (Ibid, 10). This highlights that significant improvement

needs to be made in quality and innovation to refresh the use of technology within the NDIS workforce.

The Committee has already heard concerns raised about the NDIS fee structure and the impediments in

both the price and design in securing continuity of service to participants. Workforce development and

retention at provider level can only be achieved through a pricing structure which incentivises the

development and retention of staff. The current system does not. Further, governments must also look at

the disability sector as an industry and develop policies which will support a whole of sector approach to

developing a pipeline of employees that are willing and capable of serving NDIS participants now and into

the future. That investment must be more than simply providing education pathways. It must include the

funding of a workforce campaign.

1.2 Disability Employment Pathways

CSSA believes that it is imperative to create pathways to meaningful employment for people with a

disability willing and capable of working in the sector. Whilst the NDIS provides crucial support to

Australians with a disability, it also has the ability to provide willing participants an opportunity to gain

meaningful employment.

There are significant barriers to employment that exist for NDIS participants. Employers often consider it

“too difficult” to employ those with a disability, and when they do, they are often limited to “menial work”

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(NDIS 2019c, 8). Furthermore, even when they secure work, people disabilities are often underemployed,

with limited working hours (NDIS 2019c, 8). The OECD has found that people with a disability in Australia

experience twice the risk of poverty than those without a disability (OECD 2017, 32). Significant action

needs to be taken to drastically improve this disparity.

The aforementioned UN Convention on the Rights of Persons with Disabilities, on which the NDIS itself

was based, emphasises the importance of employment for those with a disability. Article 27 of the

convention recognises “the right of persons with disabilities to work, on an equal basis with others” (UN

2006, 19). This includes the right to the opportunity to gain a living by work freely chosen or accepted in a

labour market and work environment that is open, inclusive and accessible to persons with disabilities”

(UN, 2006, 19). Furthermore, the Convention states that “state parties” shall safeguard and promote the

realisation of the right to work…by taking appropriate steps, including through legislation” (UN 2006, 19).

In 2019, of the 300,000 Australians participating in the NDIS, 170,000 were between the ages of 15 and

64 years, and thus classed as of working age. Of this group, only 24% were employed in paid work (NDIS

2019c, 7). However, 31% of participants have a work related goal in their plan (NDIS 2019c, 7). Thus,

participants seeking work are subject to an unemployment rate of 23%, compared to the Australian

average in 2019 of 5.3% (Naufal 2019). The Australia Government’s new strategy aims to reach a target

of 30% of working age NDIS participants employed in paid work by June 2023 (NDIS 2019c, 12). Whilst

CSSA supports the Government in increasing opportunities for disability employment, these efforts must

not be tokenistic. A sophisticated approach is required that identifies opportunities for participants to gain

experience and skills to further their life and career ambitions.

There are widespread benefits in increasing the employment of NDIS participants, for both employers and

employees. For those with a disability, employment can provide them with a greater sense of identity and

independence, and have positive health benefits. Furthermore, it can give them an increased income,

resulting in greater financial independence and better living standards. In turn, this can reduce demand on

welfare and support systems.

Likewise, employing those with a disability can also benefit business and organisations, by providing them

with a diverse variety of skills, experiences and qualifications. Studies have found that people with a

disability are just as, if not more productive than their counterparts without a disability. Australian research

highlights that 86% of workers with a disability have average or superior attendance records, with 90%

displaying equal or superior productivity rates than their colleagues without a disability (Graffam et al.

2002, 251).

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Ultimately if the NDIS workforce emerges from the COVID-19 pandemic relatively unchanged, a focused

national workforce plan that aims to both attract and retain workers is essential for the NDIS to meet the

demands for an estimated 90,000 additional staff. Furthermore, quality and innovation are required to

continually refresh the system and ensure that it remains up to date so that the workforce can provide

essential support to all NDIS participants. In addition, increased support is required to ensure that all willing

NDIS participants can access pathways to meaningful, paid employment, which will provide longstanding

benefits for themselves and for their employees.

Disruption to the NDIS Post COVID 19

If the COVID-19 pandemic damages the capacity of the NDIS sector to support its 480,000 participants

then further efforts might be required to rebuild workforce capability within the NDIS.

Prior to the pandemic, the NDIS workforce required an additional 90,000 staff to meet the expected

demands of the scheme when it was fully rolled out in 2020. High casualisation of the workforce, may see

many disability support staff retrenched during the COVID-19 crisis. The Australian government will be

required to implement systemic reforms in order to rejuvenate the workforce back to its pre-pandemic

capacity, and boost it to the level required to support all the participants of the NDIS.

A recent Grattan Institute report suggests the unemployment rate in Australia could rise to between 10

and 15 per cent (Coates et al. 2020, 3). With levels of unemployment not seen since the last recession it

may appear counter-intuitive to suggest that there is increased urgency in developing and executing a

strong awareness raising campaign to attract and retain employees in the disability sector. The nature of

this economic shock is materially different to that which occurred during Global Financial Crisis (GFC). It

is our hope that governments will be reluctant to pursue austerity measures as many did during the GFC,

instead looking to stimulate the economy to deliver faster economic recovery and limit the prospects of

high and sustained levels of unemployment. If that is the case then those employees who have left the

sector will likely pursue other employment opportunities.

Positioning the disability sector as an employer of choice needs to begin before the recovery of the rest of

the economy. That is why CSSA is recommending that preparations for a strong awareness raising

campaign to attract and retain employees in the disability sector should be done as matter of priority.

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Conclusion

This submission seeks to highlight the challenges facing the NDIS workforce and presents a number of

recommendations to address these issues. In light of the COVID-19 pandemic, the challenges of attracting

and retaining staff may be exacerbated and amplified. That is why CSSA is recommending the prioritisation

of a national workforce plan that focusses on attracting new staff to the sector and retaining current staff.

A strong advertising campaign to raise awareness for the sector is essential to expand the workforce.

Furthermore, CSSA recommends that the NDIS provide greater opportunity to enhance skills development

within the workforce. The impact of the ongoing COVID-19 pandemic may prompt a re-examination of the

sector and its workforce. A key area for re-examination is the fee structure of the NDIS sector. Finally,

CSSA recommends that greater support is provided for pathways to meaningful employment for willing

NDIS participants.

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