Submission No 107

INQUIRY INTO FOUNDATIONAL AND DISABILITY SUPPORTS AVAILABLE FOR CHILDREN AND YOUNG PEOPLE IN NEW SOUTH WALES

Organisation: Soul Dietetics and Supervision and Feed Me Nutrition Date Received: 18 September 2026

SUBMISSION TO THE SELECT COMMITTEE ON FOUNDATIONAL AND DISABILITY SUPPORTS AVAILABLE FOR CHILDREN AND YOUNG PEOPLE IN NEW SOUTH WALES

September 2026

Submitted by

Nicole Donnelly CEDC-D, APD Committee Member, Clinicians Network, National Centre of Excellence in Intellectual Disability Health Principal Dietitian, Soul Dietetics and Supervision, Maitland NSW

Laura Appel APD NDIS Registered Provider Principal Dietitian, Feed Me Nutrition, Shellharbour NSW

Acknowledgement

We acknowledge the Traditional Custodians of the lands, waters and seas across Australia on which we work and live. We pay our respects to Elders past, present and emerging and acknowledge the continuing connection of Aboriginal and Torres Strait Islander peoples to Country, culture and community.

We acknowledge that sovereignty was never ceded.

We recognise the enduring strength, knowledge and expertise of Aboriginal and Torres Strait Islander peoples. The voices, rights and needs of Aboriginal and Torres Strait Islander children, young people and families must be central to the design and delivery of foundational supports.

Recommendations

We recommend that the NSW Government:

1. Include private allied health providers, including Accredited Practising Dietitians (APDs), as eligible and appropriately commissioned providers within foundational support and early childhood intervention pathways.
1. Explicitly recognise dietetics as a relevant functional support for children with disability-related nutrition, feeding, growth, hydration and enteral nutrition needs.
1. Ensure children and families can access APDs as part of a multidisciplinary team (MDT) where clinically indicated.

Establish clear nutrition and feeding identification and referral pathways within routine child and family health services, with validated screening tools used where appropriate.
Establish clear referral pathways from GPs, child and family health nurses, paediatricians, Early Childhood Education and Care (ECEC) services and other relevant professionals to appropriately qualified APDs.
Preserve family choice of appropriately qualified provider, including private APDs, including where this provides timely, appropriate or geographically accessible care.
Fund telehealth, outreach and home-based service delivery where clinically appropriate, particularly for children and families living in regional, rural and remote areas.
Ensure funding and fee structures recognise the complexity of paediatric and disability dietetic practice, including clinical responsibility, expertise, preparation, documentation and care coordination.
Recognise multidisciplinary communication, joint assessment, case conferencing, care planning and professional consultation as necessary components of allied health practice and fund these activities appropriately.
Ensure changes to NDIS eligibility, access and planning are appropriately sequenced with operationally available alternatives so that children do not experience gaps in essential supports during the transition.
Develop outcome measures for foundational supports that consider functional participation, health, wellbeing, family capacity and access to everyday activities, rather than relying solely on clinical or diagnostic outcomes.
Ensure foundational support models are developed and implemented with children and young people with disabilities, families and carers, Aboriginal Community Controlled Organisations, practitioners and relevant community organisations.

About Soul Dietetics and Supervision and Feed Me Nutrition

Soul Dietetics and Supervision and Feed Me Nutrition are paediatric and disability private dietetics practices based in Maitland and Shellharbour, NSW, respectively. Together, we have 30 years of clinical experience.

Areas of practice include:

Complex feeding and mealtime support, including paediatric feeding disorder (PFD) and highly selective or restricted eating
Dysphagia and texture modification
Disability nutrition across the lifespan

Nutrition support for autistic children and young people and people with intellectual disability
Early childhood intervention and family-centred capacity building
Paediatric nutrition and growth, including undernutrition and nutritional deficiencies
Nutrition support for children and young people who are unable to meet their nutritional needs orally, including PEG (gastrostomy) and nasogastric (NGT) tube feeding
Nutritional management of complex medical and developmental conditions
Eating disorders and disordered eating, including anorexia nervosa, bulimia nervosa, binge eating disorder, avoidant/restrictive food intake disorder (ARFID) and other specified feeding or eating disorder (OSFED)
Clinical supervision for dietitians working in disability, paediatrics and eating disorders

Both practices support children and young people with developmental and disability-related health needs, including complex nutritional and feeding needs. Services are funded through the NDIS where eligible, limited Medicare pathways, insurance and private funding.

We provide services in the home, school, ECEC and community settings, as well as through telehealth and outreach to regional and rural NSW.

Private APDs are already part of the allied health workforce supporting children and families. They can work alongside public and community services and provide care in settings that are practical for families. Including this existing workforce in foundational support arrangements would increase capacity without requiring a new workforce to be established.

Introduction

Nutrition and feeding are an important part of children’s health, growth, development and participation. Children with disability and developmental concerns experience higher rates of feeding difficulties and nutritional risk and, when these concerns are present, may require dietetic support alongside other health, developmental and disability services.¹

Paediatric feeding disorder is recognised as a multidomain condition involving medical, nutritional, feeding-skill and psychosocial factors.¹ A child therefore requires input from a multidisciplinary team including APDs.

The Australian Government’s Early Childhood Targeted Action Plan focuses on improving support for children with disability, developmental delay or developmental concerns and their families and carers.² The National Best Practice Framework for Early Childhood Intervention provides a national framework for high-quality, evidence-informed support for children with developmental concerns, delay or disability and their families.¹²

The NDIS Review recommended a more connected system of mainstream services, foundational supports and individualised NDIS supports. In relation to children, Recommendation 6 proposes a continuum of mainstream, foundational and specialist supports for children with disability and developmental concerns.³

This is directly relevant to NSW.

Dietetics needs to be part of this system where a child’s nutrition or feeding needs require input.

Nutrition and feeding concerns can affect growth, health, participation and a child’s ability to engage in everyday activities and other therapies. Early dietetic input can identify nutritional risk, support families and carers, and work with other professionals to address feeding and nutrition needs in practical ways.

The current NDIS guidelines recognise nutrition supports, including supports involving dietitians, where the relevant criteria are met.⁴ This recognises that nutrition can be a disability-related support need. It does not, however, provide a pathway for every child who needs dietetic intervention.

Foundational supports provide an opportunity to address this gap, provided they are designed as part of a connected system rather than as another separate service pathway.

Role of private APDs within foundational supports

Private APDs already provide paediatric and disability dietetic services across NSW. We work alongside families, GPs, paediatricians, child and family health nurses, other allied health professionals, early childhood educators, support workers and other professionals.

Depending on the child’s needs, dietetic involvement may include:

assessing nutritional intake and adequacy
growth assessment and monitoring
identifying and managing nutritional risk
supporting children with restricted dietary variety
nutritional management of PFD and restrictive eating
nutrition management associated with complex medical conditions
nutritional aspects of dysphagia management
food and fluid modification in accordance with recommendations from relevant clinicians
enteral nutrition assessment and management
identifying potential micronutrient inadequacy
hydration assessment and management
constipation and other gastrointestinal nutrition management

family and carer education
capacity building with ECEC and school staff
support with mealtime routines and environments
communication and care planning with the child’s broader team.

Dietetics does not duplicate services provided by other allied health professionals. Where dysphagia or swallowing safety is a concern, assessment and management need to involve the appropriate clinicians. The dietitian’s role includes addressing nutritional and hydration requirements, considering food and fluid consistencies in line with swallowing recommendations, and managing enteral nutrition where required.

Systematic review and meta-analysis evidence supports intensive multidisciplinary intervention for children with severe paediatric feeding disorders. Nutrition was identified as one of the core disciplines overseeing care, alongside psychology, medicine and speech pathology/occupational therapy, supporting the inclusion of dietetics within multidisciplinary feeding care.⁵

Dietetics should therefore be available within foundational pathways when a child’s feeding or nutrition needs require input.

4. Responses to the Terms of Reference

4.1 TOR (a): The role of services and supports on a child’s overall development, health and

wellbeing

Nutrition affects a child’s growth, energy, physical development and ability to participate in everyday activities. Feeding difficulties can affect family life, mealtimes, social participation and attendance at childcare and school.

PFD provides a useful example because it recognises that feeding difficulties can involve nutritional, medical, feeding-skill and psychosocial factors.¹ This means that intervention may need to address the child’s medical and developmental needs, feeding skills, sensory or behavioural factors, family circumstances and nutritional intake.

Multidisciplinary intervention is particularly relevant for children with more complex feeding presentations. A systematic review and meta-analysis of intensive multidisciplinary intervention including dietitians for PFD found significant improvements in oral intake and mealtime behaviours across the studies reviewed.⁵

For dietitians, the role is not simply to advise families about healthy food. It is to assess and manage nutrition-related needs as part of the child’s overall care.

Case studies

Names and some identifying details in the following case studies have been changed or omitted to protect the privacy and confidentiality of the children, young people and families involved.

The clinical circumstances and issues described are representative of the types of presentations encountered in practice.

Case study: Sam

Sam is a school-aged child with multiple complex developmental and medical conditions, including Miller-Dieker syndrome, Lennox-Gastaut syndrome, Double Cortex Syndrome, global developmental delay, intractable epilepsy and central hypothyroidism.

Sam had inadequate oral intake and required PEG feeding. A private dietitian was involved through the NDIS to assess nutritional requirements, monitor growth, manage the enteral feeding regimen and provide ongoing nutritional support, including consideration of epilepsy-related dietary management where clinically indicated.

The dietitian worked with Sam’s family and broader multidisciplinary team and provided support in the home.

During the period of nutritional intervention, Sam’s family reported increased participation in physiotherapy and progression in physical abilities, including progression from being unable to stand to participating in sit-to-stand activities and walking across the room. Sam also increased participation in speech pathology and augmentative and alternative communication activities.

The case demonstrates the practical role nutrition and enteral feeding management can have within the overall care of a child with complex disability-related health needs.

4.2 TOR (b): Types of services and supports, effectiveness, availability and access

Children and families currently access dietetic and allied health services through NSW Health hospital and community services, non-government organisations, private providers, the NDIS where eligible, Medicare pathways where applicable and private funding.

Access varies considerably. Referral pathways, eligibility requirements, waiting times, geographical availability and funding arrangements differ between services and regions.

The current NDIS guidelines include nutrition supports, including supports involving dietitians, where the relevant NDIS criteria are met.⁴

This is an important pathway, but it does not cover every child requiring dietetic care. A child may have a clear nutrition or feeding need without meeting NDIS access requirements, may not yet have an NDIS plan, or may have needs that are more appropriately addressed through mainstream or foundational services.

Medicare provides a limited pathway. MBS item 10954 provides a dietetics health service for eligible patients with a chronic condition and complex care needs under specified care-planning arrangements. The service is limited to five services per calendar year for all allied health professionals.⁷

This provides an option for some families but is not a comprehensive pathway for children who require ongoing paediatric or disability dietetic care.

Recent NSW parliamentary work on access to early childhood health and development checks has also identified issues around access, workforce capacity, funding, early intervention, screening and the use of telehealth and other service models.6

Private APDs can help address some access barriers where they are appropriately commissioned. They can provide home-based services, telehealth and outreach and can work across health, disability, education and ECEC settings.

This is particularly relevant outside metropolitan Sydney. A child living in regional or rural NSW may have no local paediatric dietitian available through a public service, while an appropriately qualified private APD may be able to provide home visits, outreach or telehealth.

Families should not, however, have to rely on their ability to privately fund services to access necessary APD support.

Case study: James

James is a preschool-aged child with global developmental delay, probable autism and ADHD, chronic constipation, psychogenic polydipsia and oromotor dyspraxia.

James had significant food avoidance and restriction, high anxiety around eating and considerable family mealtime stress. James also met criteria for faltering growth.

Dietetic intervention was provided in the home using Responsive Feeding Therapy principles and was coordinated with speech pathology, occupational therapy and physiotherapy. Home-based intervention was important because James’s mother was caring for four children under six and regular travel to clinic was not practically sustainable.

Intervention addressed nutritional adequacy, food variety, constipation, mealtime routines and caregiver capacity.

Over the period of intervention, growth improved, dietary variety increased and constipation management improved. James’s mother also reported reduced mealtime stress and improved participation in preschool and other therapies.

This case highlights the value of providing intervention in the child’s natural environment and coordinating dietetic care with other professionals.

4.3 TOR (c): The role of diagnostic services, gaps and barriers, and measures to improve access

Nutrition and feeding concerns are not always identified through routine developmental or health assessments.

Families may first raise concerns with a GP, Child and Family Health Nurse, paediatrician, speech pathologist, occupational therapist or early childhood educator. Without clear referral pathways, children can move between services without timely access to the clinician best placed to address the concern.

Dietitians have an important role in identifying nutrition and feeding concerns that require further assessment and referral. A child may present with growth faltering, nutritional inadequacy, highly restricted food intake, constipation, dehydration risk, difficulties progressing textures, reliance on supplements or enteral nutrition needs. These concerns may be the first indication that further developmental assessment is required.

Validated screening tools may assist in identifying children who require further assessment. The Infant and Child Feeding Questionnaire (ICFQ) is a brief six-question screening tool developed to identify feeding concerns in infants and young children.8 The Pediatric Eating Assessment Tool (PediEAT) is a validated parent-report measure for children aged 6 months to 7 years.9

The choice of screening tool should take into account the child’s age, the purpose of screening, the setting, feasibility and cultural appropriateness. Screening should not replace a comprehensive clinical assessment by an APD.

We recommend incorporating nutrition and feeding into routine child and family health pathways, for example during developmental checks, with clear referral pathways to APDs for children who require further assessment.

Importantly, screening needs to lead somewhere. Identifying a feeding or developmental concern without an accessible referral pathway can leave families with additional information but no practical support.

4.4 TOR (d): Gaps and barriers to accessing early childhood intervention and their impacts

There is no consistent pathway through which children with disability-related nutrition and feeding needs can access dietetics as part of foundational early childhood intervention.

The main barriers we see in practice include:

Inconsistent inclusion of dietetics

Dietetics is not consistently included within early childhood intervention models, multidisciplinary teams or key-worker services. As a result, nutrition and feeding concerns may be identified late or addressed only after they have become more complex.

Limited access outside the NDIS

There is no consistent publicly funded pathway for ongoing paediatric dietetics for children who do not have access to relevant NDIS funding.

Medicare provides a limited pathway, including a maximum of five allied health services per calendar year under MBS item 10954 for eligible patients.⁷ However, the Medicare benefit is a rebate rather than full coverage of the cost of the service, meaning families are generally required to pay a co-payment or gap. These out-of-pocket costs can be a significant barrier to accessing services, particularly for families requiring ongoing allied health support.

Geographic barriers

Children living in regional, rural and remote communities may have limited access to paediatric and disability dietetic services.

Telehealth and outreach can help, but these models require sustainable funding. They also should not replace face-to-face care where it is clinically required.

Cost

When public or NDIS pathways are unavailable, families may need to self-fund dietetic services. This means access can depend on a family’s financial circumstances.

Waiting times and service capacity

When families are required to wait for publicly funded services, feeding and nutrition problems may continue while they wait. For some children, difficulties can become more established or complex over time.

Multidisciplinary collaboration

Nutrition and feeding care often involve several professionals. Joint assessments, case conferences, care planning, communication with schools and ECEC services and liaison with medical practitioners all require professional time.

These activities are not always adequately funded.

Impact on children and families

When nutrition and feeding needs are not identified and appropriately addressed, children may experience inadequate nutritional intake, restricted dietary variety, constipation, micronutrient inadequacy, growth concerns, dehydration risk and mealtime distress. These difficulties can also affect participation in childcare, school and community activities.

With timely access to appropriately funded nutrition and feeding support, many of these risks can be identified early and appropriately managed, reducing the likelihood of needs escalating and supporting children to participate more fully in everyday life.

Families can otherwise experience substantial additional stress, caring responsibilities and coordination demands when they are required to manage complex nutrition and feeding needs across multiple services or without adequate professional support. Appropriate funding for

dietetic and multidisciplinary support can reduce this burden by enabling families to access the right support at the right time, rather than relying on families to manage complex needs without sufficient support.

Case study: Emily

Emily is a preschool-aged child with global developmental delay, ADHD and chronic constipation who developed significant feeding difficulties following a choking incident.

Following the incident, Emily became increasingly anxious around food and regressed to accepting mainly pureed textures. There were also concerns about dietary iron intake and low fluid intake while attending daycare.

The dietitian completed a food and fluid assessment and provided nutrition advice addressing dietary adequacy, fluid intake, fibre and constipation. Parents and early childhood educators were also supported with practical mealtime strategies and education.

A joint session with speech pathology is planned to support safe progression of food textures and trial appropriate foods, with liaison with the daycare service also planned.

This case highlights the need for dietetic and speech pathology input to be coordinated, particularly when feeding difficulties involve both nutritional and swallowing or feeding-skill concerns.

4.5 TOR (e): Opportunities for cross-sector engagement and collaboration

Private APDs already work across health, disability, ECEC and education.

In practice, this includes:

joint visits with other allied health professionals
liaison with GPs, paediatricians, and other specialists
communication with early childhood educators and teachers
mealtime planning in ECEC settings
education for support workers and caregivers
nutrition and mealtime planning
case conferencing
multidisciplinary care planning
education and training for enteral nutrition
coordinating recommendations across home, school and community settings.

The National Best Practice Framework for Early Childhood Intervention identifies teamwork, participation, everyday settings and community-focused practice as important elements of high-quality ECI.11

Families should not be expected to coordinate all these services themselves. Foundational services should provide mechanisms for professionals to communicate and work together.

Aboriginal Community Controlled Organisations

Foundational support pathways should be developed with Aboriginal and Torres Strait Islander communities and Aboriginal Community Controlled Organisations.

Nutrition and feeding support needs to be culturally safe and responsive to local community priorities, family structures, culture and connection to Country.

Where services are provided to Aboriginal children and families, dietetic pathways should support collaboration with Aboriginal health services and other trusted community providers.

ECEC

APDs can support ECEC services with:

individual nutrition and mealtime planning
staff education
dietary management
enteral feeding planning where required
communication with families and health professionals
menu review
implementation of agreed feeding strategies.

Education

For school-aged children, dietitians may contribute to:

nutrition and mealtime plans
management of disability-related dietary needs
enteral feeding plans
staff education
liaison with families and treating clinicians
supporting participation in school activities involving food and meals.

Health

There should be clear referral pathways between GPs, child and family health nurses, paediatricians and APDs.

Multidisciplinary foundational support hubs

Where multidisciplinary or transdisciplinary foundational support hubs are established, dietetics should be an available discipline for children with relevant nutrition, feeding, growth, hydration or enteral nutrition needs.

Commissioning arrangements should include appropriately qualified private and sole-trader APDs, alongside other allied health providers, rather than limiting access to dietetics to services delivered directly by large organisations or government-funded providers. This would support greater choice and flexibility for families and enable children to access clinicians with the relevant expertise for their individual needs.

Funding models also need to recognise the time required for multidisciplinary care, including joint assessments, case conferences, care planning, professional consultation and communication between clinicians, families and other services.

4.7 TOR (g): Workforce issues

A sustainable foundational support system needs appropriately qualified clinicians with relevant skills and experience.

Paediatric and disability dietetics requires knowledge of nutrition, growth, feeding, developmental disability, enteral nutrition, gastrointestinal conditions, dysphagia-related nutritional management and family-centred practice.

APDs need access to appropriately skilled and experienced external clinical supervision and continuing professional development. This is particularly important for dietitians working with children and young people with complex disability, feeding, developmental and medical needs, where presentations can require specific knowledge and multidisciplinary collaboration. Access to high-quality supervision and ongoing professional development supports clinical competence, safe and evidence-informed practice, appropriate scope of practice and a sustainable workforce. Private practice is already part of this workforce. However, commissioning arrangements can make it difficult for small practices and sole practitioners to participate, particularly where requirements have been designed for larger organisations.

Commissioning requirements should be proportionate and should allow appropriately qualified individual practitioners and small practices to participate.

Broader disability-sector workforce and service viability also need to be considered when designing commissioning arrangements. The National Disability Services State of the Disability Sector Report 2024 identified significant financial and operational pressures across the disability service sector.10

Workforce planning should consider more than the number of clinicians. It should also consider:

APDs’ skills and experience
geographical distribution
service flexibility
home and community-based care
cross-sector work
access to clinical supervision
multidisciplinary capacity
sustainable remuneration for complex clinical work.

The NSW parliamentary inquiry into access to early childhood health and development checks has also identified workforce recruitment and retention, allied health capacity and funding for early intervention as relevant issues.6

A workforce strategy should therefore consider both workforce numbers and the distribution of skills.

Private APDs should be able to participate alongside public and not-for-profit providers where they can meet the required clinical and service standards.

Case study: Ben

Ben is a preschool-aged child with Trisomy 21, global developmental delay, intellectual disability and severe oropharyngeal dysphagia.

Ben initially required NG feeding and subsequently transitioned to PEG feeding, with a small amount of puree offered orally for quality of life.

Ongoing dietetic involvement has focused on enteral nutrition, growth and nutritional adequacy. The private dietitian worked closely with Ben’s other allied health clinicians, with these supports funded through the NDIS. This enabled the clinicians to communicate regularly, coordinate care and contribute their respective areas of expertise to support Ben’s nutritional, feeding, developmental and functional needs.

For a child with significant dysphagia, nutritional management needs to occur alongside appropriate assessment and management of swallowing and feeding safety by the relevant clinicians. Dietetic input helps ensure that nutritional and hydration requirements continue to be met and that enteral nutrition is appropriately managed, while close collaboration with the broader team supports consistent and coordinated care.

This case demonstrates the value of enabling families to access a private dietitian with appropriate experience who can work collaboratively with other allied health professionals. NDIS funding enabled this multidisciplinary approach, supporting communication and coordination between clinicians rather than requiring each area of need to be addressed in isolation.

4.8 TOR (h): Measures to implement the NDIS Review Final Report and Disability Royal Commission Final Report

The NDIS Review recommended a connected system of supports incorporating accessible and inclusive mainstream services, foundational supports and individualised supports funded through the NDIS.³

Recommendation 1 called for investment in foundational supports, including expanded supports for children with emerging developmental concerns and disability. Recommendation 6 proposed a continuum of mainstream, foundational and specialist supports for children under the age of 9 and their families.³

The Review also recommended better screening and earlier developmental checks to identify developmental concerns as early as possible and enable timely access to appropriate support.³

These recommendations are relevant to the design of NSW foundational supports.

Nutrition and feeding should be part of these pathways where children have relevant needs.

Children should be able to access skilled and experienced dietetic support according to their assessed nutrition and feeding needs rather than according to NDIS status alone.

The Disability Royal Commission’s Final Report made 222 recommendations addressing a wide range of issues, including human rights, inclusion and accessibility, mainstream and disability service systems, safeguards, and the experiences of people with disability.¹²

For foundational supports in NSW, implementation should therefore include:

genuine involvement of people with disability and families in design and evaluation
meaningful choice and control for children, young people and families, including choice of appropriately qualified providers
accessible and inclusive mainstream services
clear responsibility between mainstream, foundational and individualised supports
culturally safe approaches, including appropriate engagement with Aboriginal Community Controlled Organisations
accessible information and navigation
appropriate safeguards
continuity of support during system changes
workforce capability
mechanisms for professionals and services to communicate across sectors

Foundational supports should complement appropriate NDIS supports rather than duplicate or replace them.

Changes to NDIS eligibility or access need to be appropriately sequenced with operational mainstream and foundational services. Families should not lose access to necessary dietetic, feeding or other allied health support before an appropriate alternative is available, with sufficient capacity and appropriate funding in place.

Family choice and control should also be retained. Where an appropriately qualified private APD can provide timely and appropriate care, including home-based, telehealth or regionally accessible services, families should be able to access that provider where the service is appropriate and consistent with the relevant funding arrangements. Commissioning arrangements for foundational supports should therefore include appropriately qualified private and sole-trader providers, rather than limiting families to services delivered by larger organisations.

Transition arrangements are particularly important. A change in eligibility or funding should not result in a child being left without care while families wait for a new service or referral pathway to become available. Transitions should be planned around continuity of care, with sufficient lead time, service capacity and funding to ensure that children and families do not experience avoidable gaps in support.

Family choice and continuity

Foundational supports should be designed around children and families rather than around organisational boundaries.

Families often already have established relationships with clinicians who understand their child’s history, communication style, nutritional needs and broader care team. Losing that relationship because of a change in funding source can create additional assessment and coordination requirements and may disrupt care.

Where an appropriately qualified private provider is already supporting a child, transition arrangements should consider whether continuity of that provider can be maintained.

Proportionate commissioning

Foundational support commissioning should be accessible to small practices and sole practitioners where they meet the required clinical standards.

Requirements designed for large organisations can unintentionally exclude experienced clinicians who already provide services to children and families.

Commissioning should consider:

proportionate administrative requirements
reasonable contract arrangements

appropriate payment for face-to-face and non-face-to-face work
travel and outreach
telehealth
clinical supervision
professional consultation
care coordination.

Outcome measurement

Foundational supports should be evaluated using outcomes that are meaningful to children and families.

For nutrition and feeding services, relevant outcomes may include:

nutritional adequacy
growth and nutritional status
hydration
food and fluid safety
participation in mealtimes
participation in ECEC and school
reduced family mealtime stress
caregiver confidence and capacity
participation in community activities
successful coordination between services.

Outcome measures should not focus solely on diagnosis or the number of therapy sessions delivered.

Co-design and lived experience

Foundational supports should be designed and evaluated with children and young people with disability, families and carers, as well as disability representative organisations and practitioners.

This is particularly important for children who communicate in ways other than speech or who require significant support to participate in decision-making.

Avoiding another fragmented system

The purpose of foundational supports should be to improve access and coordination, not create another layer of disconnected services.

Families should have clear pathways between health, ECEC, education, community services, foundational supports and the NDIS.

A child should not have to repeatedly explain their circumstances to different services simply because responsibility has moved between systems.

5. Conclusion

Nutrition and feeding are part of children’s health, growth, development and participation.

Children with disability and developmental concerns have increased risk of feeding difficulties and nutritional concerns. When these needs are present, timely access to an appropriately qualified APD can be an important part of early intervention and disability support.

Private APDs are already providing support across NSW. We work in homes, ECEC settings, schools and community settings and provide telehealth and outreach where appropriate. We also work closely with health, disability, education and community services.

The cases described in this submission reflect some of the nutrition and feeding needs seen in practice, from enteral nutrition and growth management to restricted eating, constipation, feeding difficulties and caregiver support.

The evidence and policy direction underpinning the current reform agenda support a more connected system in which children can access mainstream, foundational and specialist supports according to their needs.³

Dietetics is one part of that system, but an important one for children whose nutrition and feeding needs affect their health, development, participation and family life.

We recommend that NSW foundational supports explicitly include access to appropriately qualified dietitians, including private APDs, where children have relevant nutrition and feeding needs.

Children should be able to access the support they need based on their functional needs, without being left without appropriate care because they do not have an individualised NDIS plan.

6. References

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Australian Government Department of Social Services. Early Childhood Targeted Action Plan [Internet]. Canberra: Commonwealth of Australia; 2024 [cited 2026 Sep 16].
NDIS Review Panel. Working together to deliver the NDIS: Independent Review into the National Disability Insurance Scheme. Canberra: Commonwealth of Australia; 2023 [cited 2026 Sep 16].

National Disability Insurance Agency. Nutrition supports including meal preparation [Internet]. Canberra: Australian Government; 2026 [cited 2026 Sep 16].
Sharp WG, Volkert VM, Scahill L, McCracken CE, McElhanon B. A systematic review and meta-analysis of intensive multidisciplinary intervention for pediatric feeding disorders: how standard is the standard of care? J Pediatr. 2017;181:116-124.e4. doi:10.1016/j.jpeds.2016.10.002.
Legislative Assembly Committee on Community Services. Improving access to early childhood health and development checks [Internet]. Sydney: Parliament of New South Wales; 2026 [cited 2026 Sep 16].
Australian Government Department of Health, Disability and Ageing. Medicare Benefits Schedule: item 10954, dietetics health service [Internet]. Canberra: Australian Government; 2026 [cited 2026 Sep 16].
Silverman AH, Berlin KS, Linn C, Pederson J, Schiedermayer B, Barkmeier-Kraemer J. Psychometric properties of the Infant and Child Feeding Questionnaire. J Pediatr. 2020;223:81-86.e2. doi:10.1016/j.jpeds.2020.04.040.
Thoyre SM, Pados BF, Park J, Estrem H, McComish C, Hodges EA. The Pediatric Eating Assessment Tool: factor structure and psychometric properties. J Pediatr Gastroenterol Nutr. 2018;66(2):299-305. doi:10.1097/MPG.0000000000001765.
National Disability Services. State of the Disability Sector Report 2024 [Internet]. Sydney: National Disability Services; 2024 [cited 2026 Sep 16].
Moore T, Imms C, Luscombe D, SNAICC authors, Bonyhady B, Dimmock K, Deane K, D’Aprano A, Kakoschke-Moore S. National Best Practice Framework for Early Childhood Intervention [Internet]. Canberra: Australian Government Department of Health and Aged Care; 2025 [cited 2026 Sep 16]. Commissioned by the Commonwealth of Australia, Department of Social Services.
Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability. Final report [Internet]. Canberra: Commonwealth of Australia; 2023 [cited 2026 Sep 16].