Submission No 89

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

Organisation: Sunshine Speech and Allied Health Date Received: 15 September 2026

Submitted by: Sunshine Speech & Allied Health Location: Ballina, Northern Rivers, NSW Contact: , Director and Certified Practising Speech Pathologist Date: September 2026

Introduction

Sunshine Speech & Allied Health (SSAH) welcomes the opportunity to provide a submission to the Select Committee on Foundational and Disability Supports Available for Children and Young People in New South Wales.

SSAH is a multidisciplinary private allied health service based in Ballina in the Northern Rivers of NSW. We provide speech pathology and occupational therapy services to children and families across a range of funding pathways, including the National Disability Insurance Scheme (NDIS), Medicare and private funding. Our clinicians work closely with families, early childhood education and care services, schools, support providers and other health professionals.

Our service has a strong focus on early identification, neurodiversity-affirming and family-centred practice, capacity building, multidisciplinary intervention and supporting children within the environments in which they live, learn and participate.

This submission responds particularly to Terms of Reference (b), (d), (e), (g), (h) and (i).

SSAH supports the intent of foundational supports and the development of Thriving Kids. There is significant opportunity to create a system in which families can access appropriate developmental support earlier, without requiring a diagnosis or navigating the complexity that has developed around NDIS access.

However, the success of this reform will depend heavily on how services are commissioned and delivered.

From the perspective of a regional allied health provider, there is a significant risk that a well-intentioned reform could inadvertently destabilise the existing paediatric allied health workforce, reduce continuity and family choice, duplicate infrastructure that already exists in communities, and create new access bottlenecks.

Our central recommendation is therefore that NSW should build Thriving Kids with the existing allied health workforce, rather than alongside or in place of it.

62 Tamar Street, Ballina NSW 2478 02 6610 9200 hello@sunshinespeechalliedhealth.com.au

Regional access and the importance of existing local capacity

Children in regional NSW already experience inequitable access to developmental and allied health supports.

The Committee’s interim report appropriately recognised the significant barriers faced by families outside metropolitan areas and recommended regionally tailored commissioning, workforce incentives, outreach, telehealth and other flexible service models.

SSAH strongly supports this direction.

However, regional workforce issues cannot be addressed simply by commissioning larger organisations to establish new teams.

In regional communities, the allied health workforce is finite. Private practices, community organisations, hospitals, schools, disability providers and other services are frequently recruiting from the same limited pool of clinicians.

A commissioning model that incentivises one sector to build an entirely new allied health workforce can therefore unintentionally remove clinicians from another part of the local system rather than increasing overall capacity.

The result may be improved access for one cohort but reduced access for children with higher support needs, NDIS participants, adolescents, adults or families accessing mainstream health services.

The priority should instead be to map, retain and utilise existing regional workforce capacity, alongside targeted investment to grow that workforce.

Private allied health must be part of the core Thriving Kids model

SSAH is concerned about the current distinction between commissioned non-government providers and private allied health providers.

DCJ currently advises that targeted supports will primarily be delivered by commissioned non-government organisations and NSW Government services. Private allied health providers may potentially participate through a future panel arrangement, including where there is a temporary capacity gap, specialist expertise is required or a region has limited workforce availability. DCJ has also advised that subcontracting with for-profit allied health providers under the initial procurement is intended to be time-limited while the commissioned provider develops internal capacity.

We respectfully suggest that this approach should be reconsidered.

Private allied health providers should not be viewed primarily as an interim workforce solution, overflow mechanism or source of specialist services while another organisation develops capacity.

They are already a substantial component of the developmental and early intervention system.

Many have established therapeutic relationships with children and families, infrastructure, clinical governance systems, experienced practitioners and strong relationships with local early childhood services, schools, medical practitioners and community organisations.

Replacing this capacity rather than incorporating it risks unnecessary duplication and workforce disruption.

A private allied health panel should therefore be a permanent and substantive component of Thriving Kids, with opportunities for suitably qualified providers to deliver funded supports directly where this is clinically and locally appropriate.

Provider eligibility should be based on clinical quality, safeguarding, evidence-based practice, governance and outcomes - not organisational structure or whether a provider operates on a not-for-profit or for-profit basis.

Family choice and continuity of care

The transition to foundational supports should not lose one of the important principles developed through disability reform: children and families should have meaningful involvement in decisions about who supports them and how support is delivered.

For young children in particular, relationships matter.

Effective early childhood intervention often depends upon trust between the child, family and clinician. For neurodivergent children, children with communication differences, children experiencing anxiety or children who have had difficulty engaging with services, establishing a safe therapeutic relationship can take considerable time.

Where a family already has an effective relationship with a suitably qualified clinician, the commencement of Thriving Kids should not automatically require that child to cease that relationship and begin again with a commissioned provider.

Continuity should be treated as an important clinical and service-quality consideration.

Family choice also protects against a system becoming overly standardised. Children with superficially similar developmental concerns can have very different communication, sensory, motor, regulation, feeding, functional and participation needs.

A strong system therefore requires access to a diverse provider ecosystem, including clinicians with different areas of expertise and different models of practice.

Supports must be needs-led, not restricted by arbitrary timeframes

SSAH supports targeted, goal-focused intervention and regular review of whether therapy remains beneficial.

However, the description of Thriving Kids targeted supports as assistance provided for a specific or time-limited period should be implemented cautiously.

Duration and intensity should be determined by a child’s functional needs, goals, developmental trajectory and family context rather than by a predetermined number of sessions or standard program length.

For some children, a short period of parent coaching, group intervention or consultation may be entirely appropriate.

Others may require more intensive individual intervention, multidisciplinary input or several periods of support across different developmental stages.

Foundational supports should therefore operate as a stepped and responsive system, rather than assuming that all children with low-to-moderate support needs require low-intensity intervention.

There must also be straightforward escalation pathways where assessment identifies that a child’s needs are greater than initially anticipated.

Early identification should occur where children already are

One of the strongest opportunities presented by Thriving Kids is to shift intervention earlier.

SSAH has direct experience partnering with early childhood educators to strengthen early identification. This has included educator training, developmental observation, screening pathways, guidance about when to seek speech pathology, occupational therapy or hearing assessment, support for conversations with families, referral pathways and ongoing consultation.

This kind of model can identify concerns before families reach crisis point or spend months trying to determine which service they should contact.

We strongly support expanding allied health in-reach into early childhood education and care environments.

However, allied health involvement should extend beyond conducting a screening or providing generic information. Clinicians need capacity to observe children within natural environments, coach educators and parents, contribute to assessment and clinical reasoning, and provide targeted intervention where indicated.

This requires genuine partnership between allied health, early childhood education, health services and families.

Avoid creating another complicated system for families to navigate

Families currently navigate multiple systems including NSW Health, the NDIS, Medicare, education, early childhood services and private allied health.

Thriving Kids should reduce this complexity, not add another layer.

Eligibility criteria, referral pathways, expected waiting periods, available supports, the interface with the NDIS and pathways when a child’s needs change should be publicly available and communicated in accessible language.

The Committee’s recommendation for a statewide “no wrong door” model is strongly supported.

A parent raising a developmental concern with a GP, early childhood educator, Child and Family Health Nurse, allied health professional or other appropriate service should be able to enter the pathway without repeatedly telling their story or independently coordinating referrals between disconnected services.

Similarly, clinicians need clear mechanisms for referral into and out of Thriving Kids.

Workforce sustainability and the true cost of allied health delivery

A sustainable foundational support system must recognise that allied health services consist of substantially more than face-to-face appointment time.

Safe and effective intervention may require assessment, documentation, clinical reasoning, planning, multidisciplinary collaboration, communication with educators and families, report writing, travel, supervision, professional development, safeguarding, clinical governance and outcome measurement.

Commissioning rates must realistically account for these functions.

Rates that only fund direct contact time will either result in providers subsidising essential clinical activity, reduced service quality or clinicians leaving the sector.

This is particularly important in regional areas, where services may also need to absorb additional travel, workforce recruitment, professional isolation and supervision costs.

Long-term funding certainty is also critical. Workforce cannot be sustainably recruited and retained where providers are operating through short-term contracts or uncertain commissioning arrangements.

Recommendations

SSAH recommends that the Committee’s final report call on the NSW Government to:

1. Establish private allied health as a permanent core component of Thriving Kids, rather than limiting private clinicians primarily to temporary capacity gaps, specialist services or transitional subcontracting.

2. Create a transparent allied health provider panel that enables appropriately governed private, not-for-profit and other community allied health providers to deliver funded Thriving Kids supports directly.

3. Preserve genuine family choice and continuity of care, including mechanisms allowing children to continue with an existing suitably qualified clinician where this is clinically appropriate.

4. Undertake regional workforce and service-capacity mapping before implementing commissioning decisions, to ensure Thriving Kids increases net allied health capacity rather than redistributing an already limited workforce between sectors.

5. Adopt regionally tailored commissioning models, recognising that approaches suitable for metropolitan Sydney may not be appropriate for communities such as the Northern Rivers.

6. Ensure intervention intensity and duration are clinically determined, with flexibility for individual therapy, group intervention, parent coaching, multidisciplinary care and episodic support rather than predetermined program limits.

7. Establish clear escalation and transition pathways between Thriving Kids, the NDIS, health, education and other services when a child’s needs or circumstances change, including safeguards against children falling between systems.

8. Expand allied health partnerships with early childhood education and care services, including funding for early identification, educator capacity building, screening, consultation, parent support and intervention within natural environments.

9. Fund the full cost of quality allied health delivery, including necessary indirect clinical work, multidisciplinary collaboration, travel, supervision, clinical governance and outcome measurement, with appropriate indexation and regional loadings where required.

10. Establish formal and ongoing co-design mechanisms involving frontline allied health practitioners and small-to-medium regional providers, alongside children, families, Aboriginal Community Controlled Organisations, disability organisations, educators and other stakeholders.

11. Measure Thriving Kids against meaningful outcomes, including functional participation, family experience, waiting times, continuity of care, equitable regional access and unmet need - not simply service volume or program completion.

12. Publish a clear statewide service map before major NDIS access changes commence, explaining eligibility, referral processes, available interventions, provider choice, interfaces with the NDIS and what occurs when a child requires greater or ongoing support.

Conclusion

SSAH supports the objective of creating a stronger system of early developmental support for children and families in NSW.

Thriving Kids represents an important opportunity to intervene earlier, reduce reliance on diagnosis as the gateway to assistance, strengthen the capacity of families and early childhood environments, and provide appropriate supports outside the NDIS.

Its success, however, will depend upon whether implementation reflects the realities of the communities in which it will operate.

In regional NSW, the existing private allied health sector is not peripheral to the early intervention system. It is an established part of that system.

The NSW Government should therefore seek to strengthen and integrate the workforce that already exists, rather than creating parallel structures that compete for the same clinicians or unnecessarily disrupt established relationships between children, families and practitioners.

The goal should not simply be to create a new program.

It should be to create an interconnected developmental support system in which families can access the right support, from the right professional, at the right time - regardless of where they live, how their service provider is structured, or whether their child has a formal diagnosis.

Sunshine Speech & Allied Health thanks the Committee for the opportunity to contribute to this inquiry and would welcome further consultation regarding the implementation of Thriving Kids and foundational supports in regional NSW.

Certified Practising Speech Pathologist Director Sunshine Speech & Allied Health Ballina, NSW