Australians with disability are one of the groups at greatest risk from contracting coronavirus, as such they and many disability workers were identified and included in Phase 1a and 1b of Australia’s vaccination rollout.While vaccinations for Phase 1a and 1b began in February 2021, these phases have not been completed, leaving many people with disability at significant risk.

With the COVID-19 response firmly focused on vaccination rates, each jurisdiction across the country has introduced differing rules in terms of mandatory vaccination for specific groups of workers. The Delta outbreak of mid 2022 has seen many of the States and Territories introduce far reaching vaccine requirements for businesses and their workers. In the case of disability support providers and their employees, the requirements are not only complicated (and in some cases ambiguous) but also differ in each State and Territory. 

For months, Disability Peak Bodies and advocates including DIA, have been calling on the Commonwealth Government to set a national and consistent vaccination mandate for disability workers. National Cabinet has implemented similar mandates in the Aged Care and Health sectors; however, the disability sector has been left to navigate and deal with inconsistent and varying vaccination rules for our workforce.The Commonwealth Department of Health has noted that some people with disability are more likely to have comorbidity, leaving them especially vulnerable to the worst impacts of the virus, including death. 

DIA has trawled through the available information from each jurisdiction and has compiled a summary of the requirements and links to the various websites and pages of relevance. DIA also directs providers to seek clarification from the relevant jurisdiction authorities to any specific questions relating to vaccination requirements.

Summary Points:

  • There are vaccine requirements for workers in all States and Territories as of early December 2021 although they differ from jurisdiction to jurisdiction.
  • Where requirements are in place, any in-person supports would need to be provided by a vaccinated worker who complies with the jurisdictions requirements.
  • There are significant monetary penalties for both individuals and businesses who fail to comply with the relevant Public Health Orders.   

Commenting on the inconsistent approach to vaccine mandates, DIA’s CEO, Mr Jess Harper said:

“DIA urgently calls for the National Cabinet to develop and implement a nationally consistent disability worker vaccination mandate for approved vaccines. Such a mandate must specify detail any exemptions requirements and processes.

It is extremely difficult and costly for multi-jurisdictional and cross boarder organisation to meet and ensure compliance with such differing health orders and requirements. Whilst DIA understand that this is likely felt by many different industries and sectors, the Disability Sector is different in that its maximum prices for service are capped by the Commonwealth and as such there is no opportunity to recover these increased costs through normal commercial or market responses.”


As highlighted above, each jurisdiction in Australia has different rules covering mandatory vaccine requirements for workers across the economy, not just the disability sector. This added level of compliance complexity for business that operate across the country is incredibly frustrating and certainly brings into question the notion of “being together” in combating the impacts of the COVID-19 pandemic.


For Care Workers which includes disability residential services and supports delivered to NDIS participants in any setting, then:

    • In order to provide these services and supports in-person a worker will need to meet the following vaccine requirements:
    • From the 22nd October 2021 have received their first dose; and
    • From the 26th November 2021 have received their second dose.

Work premises is any place outside of the workers home where they are required to be for work purposes. 

If the worker is not able to provide the necessary evidence of vaccination by the above dates, the employer must ensure the worker does not perform work duties in contravention of the requirements. 

Fines to employers of up to $100,00 may apply if an unvaccinated worker is allowed to work in contravention of the requirements.

More information can be found on on the Victorian Government Website


The requirements in New South Wales stipulate two different “settings” that mention disability workers.

  • Workers providing disability supports at a government, non-government school or early education or care facility must;
    • Be fully vaccinated (both doses) from the 8th November.
  • For workers providing a disability service (all services funded / provided under the NDIS) must;
    • From the 25th October to 29th November have received at least their first vaccine dose; and
    • From the 29th November must have received both vaccine doses.
  • Workers providing “in-person” supports must be vaccinated as per the above dates and it is the employers responsibility to ensure that each worker provides the necessary evidence of vaccination. Monetary fines apply for non-compliance.

More information can be found on:

NSW Government Information – Disability Sector

NSW Vaccine Information for Workers


Vaccinations are required for workers in Residential and Non-residential community care services which include workers in the disability sector. The requirements are:

  • Workers to have had at least their first dose of vaccine by 1st December; and
  • Workers to have had their second dose by 31st December.

As per Victoria and New South Wales the onus of compliance is on the employer and monetary fines ranging from $20,000 to $100,000 may apply for breaches of these requirements. 

Interestingly, the Public Health Order stipulates that a worker cannot be excluded from the parts of a facility that are not providing primary health care (which includes a providers head office in the definition).

Therefore, for example, it may be possible for a RPMP who also engages in non-NDIS accounting services to have non-vaccinated workers conducting this service in a separate area of their site or office such as on a different floor.

More information can be found on:


For workers providing disability services and workers in Aboriginal communities and the community services sector, the following vaccine requirements apply:

  • To have received their first dose by 12th November; and
  • To have received their second dose by 24th December.

Similar to the other jurisdictions with vaccine mandates, there are monetary fines for non-compliance which can be up to $25,000 for businesses. To avoid non-compliance, workers providing supports in person must be vaccinated by the above dates. 

More information can be found on:


Disability support workers providing in-home and in community supports will need to be vaccinated by:

  • First dose by 15th November; and
  • Second dose by 13th December.

Again, there are heavy monetary fines for businesses that do not comply with fines up to $40,500 possible.

More information can be found on:


Workers in the disability sector are required to be vaccinated by the 15th December.

More information can be found on:




South Australia

For workers in the Disability sector, a first dose of COVID 19 vaccination needs to be adminstered before the 30th November and at least evidence of a booking for a second dose within the prescribed time limit after the first dose. 

More information can be found on:



Workers in the Disability sector providing High Intensity Supports must prove vaccination status by 21st November. 

More information can be found on:


Advice on Rights and obligations as an employer can be found on the Fair Work website.

DIA notes the fair work website which includes the below information:

Can an employer require an employee to be vaccinated?

Employers can only require their employees to be vaccinated where:

  • a specific law (such as a state or territory public health order) requires an employee to be vaccinated (see COVID-19 vaccinations: legislation and public health orders)
  • the requirement is permitted by an enterprise agreement, other registered agreement or employment contract (see Agreements or contracts relating to vaccinations), or
  • it would be lawful and reasonable for an employer to give their employees a direction to be vaccinated, which is assessed on a case-by-case basis (see Lawful and reasonable directions to get vaccinated).

One or more of these circumstances can apply when an employer is requiring an employee to be vaccinated. For example, an employer could rely on a state public health order that requires their employee to be vaccinated to give the employee a lawful and reasonable direction not to work unless they are vaccinated.”             Source Fairwork Website

If any provider requirea further information or advice, they should contact Fair Work Commission or seek their own legal advice.



As vaccination rates increase across Australia and governments continue to make plans to ease community restrictions – it is vital that people with disability are supported, in whatever way they require, to access vaccinations. 

You have an important role to play!

Support Coordination and Plan Management Providers have an extremely important role in supporting participants to understand the health orders within their State or Territory. Support Coordination and Plan Management Providers must themselves comply with the Health Orders with the States and Territories in which they operate.

There are a number of actions you can take today:

  • Talk about vaccination to the people with disability that you support;
  • Talk about any healths and their order requirements in their State or Territory;
  • Offer assistance, where needed, to access further information about vaccination health orders from reliable and trusted sources, such as the person’s GP and State or Territory Department of Health.

Further information is available on the Department of Health website, including Easy Read and Auslan resources

Vaccinations can be booked by visiting the Vaccine Clinic Finder or by contacting the National Coronavirus and COVID-19 Vaccination Helpline on 1800 020 080. The Disability Gateway is now also assisting people with disability that might need help to book a COVID-19 vaccine.



A lot of Intermediary Providers have requested clarification on their requirements around enforcing the health orders.

The State or Territory Health Orders, as referenced above, have been implementation on a State and Territory by State and Territory Basis, as such the enforcement of these Health Orders fall within the jurisdiction of the State that has implemented them (i.e. in, VIC Department of Health and VIC Police etc).

Enforcement, Investigation or Audit of suspected breaches of State and Health Orders are not activities within the role of Support Coordination and Plan Management Providers, including as a part of invoice claiming and funds disbursement. Where Support Coordination and Plan Management Providers become aware of or are alerted to such instances these should be reported to the appropriate State or Territory Police and/or Health Department.


If you have any COVID-19 vaccine related issues you wish to highlight directly to DIA, please email info@intermediaries.org.au and we will have one of our team contact you for further details.

DIA will continue to update the broader intermediaries sector with up to date information on the NDIS and related Disability and Intermediary issues and is able to  continue to do this because of the support of our members. DIA encourages Intermediary providers to consider joining DIA as a member, to ensure we can continue to support our members and the sector.