Submission
No 84

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

Organisation: Humanity Health Group
Date Received: 24 August 2026

Submission to the Select Committee Inquiry into Foundational and Disability Supports Available for Children and Young People in New South Wales

AUGUST 2026

Executive Summary

Humanity Health Group welcomes the opportunity to make a further submission to the Select Committee’s reopened inquiry. We support the intent of Thriving Kids and the broader foundational supports reforms. Properly designed, they can deliver earlier and easier access to support, strengthen the capability of families, and ensure children receive help in the everyday environments where they live, learn and play.

This opportunity is important and significant. Thriving Kids is the first phase of a new national foundational supports system for children with developmental delay, autism and other support needs. For a large cohort of people this provides a new opportunity for a pathway to important support. Delivered well, this can ease the pressure that currently pushes families toward the NDIS as the only avenue to help.

The risk is equally significant, and it lies in implementation. The NDIS experience has shown that ambitious reform can still produce fragmented, inconsistent and hard-to-navigate services when commissioning, workforce and continuity are not resolved at the design stage. Thriving Kids will be built quickly and at scale, which makes early design choices decisive.

Humanity Health Group’s central recommendation is that NSW adopt a provider-neutral, outcomes-focused commissioning model. Providers should be selected on demonstrated clinical quality, child safety, cultural capability, workforce scale and geographic reach, not on ownership type. Established for-purpose providers with accredited, clinically governed services should be able to participate as comprehensive Thriving Kids providers.

Continuity of care should be treated as a critical design principle. As eligibility settings shift between the NDIS and foundational supports, children already receiving allied health support must not experience a service cliff. Clear transition protocols and defined responsibilities across the NDIS, the NSW Government, providers, schools and early learning services are essential.

This submission makes six recommendations, spanning commissioning, comprehensive provider participation, continuity of care, rural and thin-market access, workforce and accessible delivery of services. Together, they are intended to help NSW capture the opportunity of Thriving Kids while avoiding the implementation risks that have limited the impact of earlier reforms.

About Humanity Health Group

Humanity Health Group is a national allied health organisation that delivers holistic, person-centred services for people of all ages and abilities. Its models of care are grounded from design in research and evidence, and are built to support people across the life course, from early childhood through to older age.

Humanity Health Group operates across the disability, health, workers compensation, employment and aged care sectors, delivering allied health, mental health, employment and rehabilitation, treatment and

assessment, corporate wellbeing and digital healthcare. These services are provided through a range of specialist brands, including Humanity Allied Kids, Humanity Allied Health, Generation Care, Assessment Squared and Back2Work Health Solutions.

Two of our brands are directly relevant to the inquiry. Humanity Allied Kids provides allied health services for children with developmental delay or disability, working through tailored plans, collaborative clinical input, family-centred support and a coordinated care approach that keeps the child and family at the centre. Assessment Squared delivers evidence-based early intervention assessments for children with developmental delays, including autism and other cognitive or intellectual disorders. Together our brands have a strong emphasis on capacity building through family systems approaches and collaborative care within the communities children live, learn, and play.

Humanity Health Group’s scale is directly relevant to the questions before the committee. We have a workforce of around 700 allied health professionals nationally, alongside significant work supporting vulnerable children, adults and families in NSW. We are an approved supplier under the NSW Government Specialist Allied Health and Behaviour Support Provider Scheme, and it invests in clinical supervision, applied research and workforce development, including the graduate pathways and supervision structures that a foundational supports workforce will depend on.

This combination of clinical breadth, workforce depth and geographic reach gives Humanity Health Group practical insight into the design choices that will decide whether Thriving Kids succeeds in practice.

Submission

Policy context: Thriving Kids and the foundational supports reform

Thriving Kids sits within a broader restructuring of how children’s developmental supports are funded and delivered in Australia. It is the first phase of a new foundational supports system, established under the National Agreement on Foundational Supports, which is intended to strengthen the layer of support that sits outside the NDIS.

Foundational supports are broadly grouped into general supports, available to the whole community, and targeted supports, positioned between mainstream services such as health and education and the more specialist, individually funded supports of the NDIS. Governments have committed $4 billion over five years to the first phase of foundational supports, with at least $1.4 billion of the Commonwealth’s contribution to be provided as direct funding to states for Thriving Kids services.

In NSW, state-delivered services are due to commence from 1 October 2026 and to reach scale from 1 January 2028. Significantly, this build-out is sequenced ahead of changes to NDIS access arrangements, which means the foundational supports system must be ready to receive children as NDIS eligibility settings tighten. The timing places a premium on getting continuity and capacity right from the outset.

The committee’s earlier work, and the NSW Government’s response to it, provide a clear foundation. The NSW Government response accepts, or supports in principle, a range of the committee’s recommendations, including on co-design, rural and remote access, system navigation, early intervention, workforce and family and carer involvement.

However, many of the decisions that will most affect children and families, particularly how services are commissioned, which providers can participate, and how continuity is protected during transition, remain to be settled through implementation and procurement. This submission concentrates on those key design choices, where the committee’s continued attention can have the greatest impact.

Key Submission Priorities

This submission is organised around five priorities. Each reflects an important design priority that is still open, and each carries a clear risk if it is resolved poorly and a clear benefit if it is resolved well.

Thriving Kids is a significant opportunity, and implementation will determine outcomes

Thriving Kids is a genuine opportunity to improve outcomes for vulnerable children and to relieve pressure on a stretched NDIS. Earlier, lighter-touch support delivered in everyday settings can prevent needs from escalating, reduce the number of children who require individualised packages, and give families practical help sooner.

The central lesson of the NDIS, however, is that the distance between policy intent and lived experience is closed or widened by implementation. Where commissioning, workforce and continuity are not resolved early, families encounter fragmentation, long waits, repeated assessments and unclear pathways, regardless of the reform’s stated goals.

Because Thriving Kids will be built quickly and at scale, the design choices made now, particularly on procurement, provider participation and workforce, will do more to determine outcomes than the policy’s objectives on paper. The committee’s role in scrutinising those choices is therefore critical.

Procurement must not arbitrarily exclude established for-purpose allied health providers

The most consequential near-term decision is how Thriving Kids services are commissioned. In a system being built at speed and scale, NSW cannot afford to narrow the available provider base on grounds unrelated to quality or outcomes. Providers should be assessed on demonstrated clinical quality, outcomes, workforce capability, child safety, cultural capability and clinical governance, not on their ownership structure.

A commissioning approach that excludes privately owned but for-purpose providers would risk unintended consequences. Risks of this approach include reducing the allied health workforce available to the new system when demand is rising; weakening service coverage in regional and thin markets that depend on providers with the scale to sustain delivery and disrupting established therapeutic relationships between children and their existing clinicians.

If such a significant share of allied health service providers are potentially excluded, this would reduce the system’s overall capacity to meet demand within the reform’s compressed timeframe.

NSW needs comprehensive providers, not only panel-based participation

How providers participate matters as much as whether they can. NSW should be able to commission providers with genuine multidisciplinary capability as comprehensive Thriving Kids providers, rather than restricting established organisations to ad hoc participation on a referral panel.

Panel-only models tend to fragment care. They can require families to assemble their own team from separate providers, repeat their child’s history at each new contact, and manage multiple assessments and appointments with no single point of accountability. The result is duplication, gaps, and fewer direct allied health hours reaching the child.

Comprehensive provision addresses these problems directly, and it reflects how Humanity Health Group already works. For children with multiple or changing needs, this integration is not an administrative convenience, it is what makes support effective. NSW should design commissioning so that this kind of comprehensive, coordinated model is available to families, not excluded by a panel-only structure.

Continuity of care must be a key design principle

The transition from the NDIS to foundational supports is the single largest source of risk for children already in the system. As eligibility settings change and re-assessments take place at an unprecedented scale, some children will move from individualised NDIS supports into Thriving Kids or universal services.

Without deliberate safeguards, these children face a potential service cliff, an interruption in therapy and support caused not by any change in their needs but by the system reorganising around them. Continuity should therefore be treated as a first-order design principle, not a matter left to chance during transition.

Government should consider clear transition protocols, continuity safeguards, and defined responsibilities across the NDIS, the NSW Government, providers, schools, early learning services and families, so that no child loses essential allied health support during the changeover. This directly responds to the committee’s own findings on fragmentation, unclear eligibility, difficult navigation and transition risk.

Rural, regional and thin-market access depends on workforce depth

Access in rural and regional NSW depends on the depth of the allied health workforce, and workforce depth depends in turn on which providers the system draws on. The Committee has already identified that families in rural and remote areas face longer waits, greater travel burden and, in some locations, an absence of qualified expertise.

Sustaining services in these markets is difficult and requires scale. Mobile delivery, telehealth, outreach, local partnerships, and the supervision and training needed to keep clinicians in regional roles all rely on providers large enough to carry the fixed costs involved. Excluding established providers from comprehensive participation would remove precisely the capacity that makes thin-market delivery viable, reducing regional access and making it harder to maintain clinically accountable services in the communities that already have the least.

NSW should therefore design Thriving Kids around the full available allied health workforce, and commission deliberately for rural and thin-market coverage, drawing on providers with the scale to sustain supervision, training, mobile delivery, telehealth and outreach.

Recommendations

Humanity Health Group makes the following recommendations. Each is directed at a design choice that remains open in the implementation of Thriving Kids in NSW.

1. Adopt provider-neutral commissioning: NSW should commission Thriving Kids services on the basis of outcomes, quality, clinical governance, workforce capability, child safety, cultural capability and geographic reach, rather than provider ownership type. This protects the workforce and service coverage the reform needs, and keeps the focus on the quality of support children receive.
2. Include comprehensive multidisciplinary providers: NSW should enable established allied health providers to participate as comprehensive Thriving Kids providers where they can demonstrate integrated, family-centred and clinically governed service models, rather than limiting

them to panel participation. This reduces fragmentation and increases the direct allied health support reaching children and families. 3. Protect continuity of care: NSW should develop and publish transition protocols for children moving between the NDIS, Thriving Kids, universal services and other supports, with explicit safeguards against interruption of essential allied health services. Continuity should be guaranteed by design, not left to individual negotiation during transition. 4. Build a rural and thin-market access model: NSW should commission deliberately for regional coverage, including mobile allied health, telehealth, outreach, travel support, thin-market loadings and regionally tailored arrangements, so that access does not depend on where a child lives. 5. Invest in workforce supervision and pipelines: NSW should recognise provider-led supervision, graduate pathways, allied health assistant models and internal clinical training as part of the foundational supports workforce strategy, drawing on the training capacity that established providers already hold. 6. Embed allied health in everyday settings: NSW should support delivery in the places children live, learn and play, including early learning, preschool, school, community and home settings, consistent with the developmental evidence and with families’ preferences.

Conclusion

Humanity Health Group supports the ambition of Thriving Kids and the foundational supports reform, and wants to see it succeed. Whether it does will depend on the implementation choices being made now. Provider-neutral commissioning, comprehensive provider participation, guaranteed continuity of care, deliberate rural and thin-market design, and a workforce strategy that draws on existing capacity would together give the reform the best chance of delivering for children and families.

Humanity Health Group would welcome the opportunity to work with the committee and the NSW Government on these design choices, and to contribute its clinical, workforce and service-delivery experience to the detailed implementation of Thriving Kids in New South Wales.