NDIA Accountability Project

Inquiry into foundational and disability supports available for children and young people in New South Wales

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Submission
No 129

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

Organisation: Independent Schools of NSW
Date Received: 18 September 2026

Independent Schools NSW

Biala School

Inquiry into foundational and disability supports available for children and young people in New South Wales

Inquiry into foundational and disability supports available for children and young people in New South Wales

Contents

Inquiry into foundational and disability supports available for children and young people in New South Wales

Independent Schools NSW

This submission has been prepared by Independent Schools NSW and reflects the views of the diverse range of Independent schools. Independent Schools NSW sought the views of leaders and teachers in NSW Independent schools.

For further enquiries or additional information relating to this submission, please contact:

Caraline Cloke
Head of Compliance & Policy
Compliance, Policy and Member Engagement
Independent Schools NSW
Email: redacted
Phone: (02) 9299 2845

Introduction

Independent Schools NSW, as the peak body representing the Independent schools’ sector in NSW, welcomes the opportunity to make this further submission to the Select Committee on Foundational and Disability Supports Available for Children and Young People in New South Wales.

Independent Schools NSW represents a large, diverse and growing educational sector. In 2026, there are 434 Independent schools in NSW operating across 580 campuses. These schools educate approximately 252,268 children, representing around 20 per cent of all students in the state, employ a workforce of approximately 41,000 people and provide families with choice in schooling options.

Independent schools are established to provide education underpinned by philosophical, cultural or faith-based approaches. Some schools have been established by community groups seeking to reflect the religious or cultural values of a community. Others promote specific educational philosophies or serve particular cohorts of students, including student with disability or students at risk of disengaging with education.

The diversity of Independent schools in New South Wales includes:

  • Schools that specialise in meeting the needs of students at risk or students with disability
  • Schools of educational philosophies such as Montessori and Rudolf Steiner schools
  • Schools constituted under specific Acts of Parliament, such as Grammar schools
  • Boarding schools and schools enrolling significant numbers of international students
  • Schools with religious beliefs including Islamic, Buddhist, Greek Orthodox, Lutheran, Presbyterian, Seventh-day Adventist, Baptist and Uniting Church schools
  • Community schools, including schools in Aboriginal communities.

Most Independent schools in New South Wales are established and governed independently on an individual school basis, although some schools with common aims and educational philosophies are governed and administered as systems.

Since 2000, enrolments in New South Wales Independent schools have grown by approximately 108,380 students, accounting for around 67 percent of the state’s student growth over that period. Almost three-quarters of Independent schools serve low to medium socio-economic communities and almost one in three are located outside metropolitan Sydney. Almost half of all Independent schools in New South Wales are small schools, educating fewer than 200 students.

The scale and complexity of disability related support needs in Independent schools is increasing. In 2024, around 51,700 students in NSW Independent schools were identified through the Nationally Consistent Collection of Data (NCCD) as receiving educational adjustments due to disability. The largest identifed categories were cognitive disability and social-emotional disability, with cognitive disability increasing from approximately 24,000 in 2023 to 27,000 students in 2024 and social-emotional disability increasing from approximately 15,4000 students to 16,800 students over the same period. Student requiring supplementary, substantial and extensive adjustments also increased between 2023 and 2024. This data reinforces that foundational and disability supports are not peripheral to schooling and that they are directly connected to the daily work of supporting student participation, learning and wellbeing.

Context

This submission responds to the NSW Government’s response to the Committee’s First Report which confirms that foundational supports for children will be delivered through the federally funded Thriving Kids program. It also confirms that Thriving Kids will focus on children aged eight and under with developmental delay and/or autism who have low-to-moderate support needs, together with their families, carers and kin.

Independent Schools NSW supports the broad direction of reform. Foundational supports that are preventative, family centred, equitable and accessible that align with the needs identified by schools and families. Earlier access to support, stronger coordination and greater emphasis on prevention and early intervention are necessary objectives. The Government’s support for Recommendation 11 and 12, together with its support in principle for Recommendations 2, 5, 6, 7, 8 and 14, provides a useful foundation for implementation.

The Government response should not, however, be read as resolving the issues identified by the Inquiry. Many of the most significant questions are left to future implementation, commissioning and design processes. A central concern is the extent to which the response relies on the future implementation of Thriving Kids as the principal answer to many of the issues raised by the Committee. Thriving Kids may become an important part of the support landscape, but it remains a targeted program for a defined cohort and is still in the early stages of implementation. It remains unclear whether a program focused on younger children with developmental delay and/or autism who have low-to-moderate support needs, can on its own, address wider structural issues including workforce shortages, geographic inequity, diagnostic delays, service fragmentation, family support needs, mental health related support needs and system navigation challenges.

Recommendation 11: Early intervention

Recommendation 11 responds to one of the most consistent themes arising from the Inquiry with the need to identify and address children’s support needs earlier. The Government has supported this recommendation and has indicated that Thriving Kids will operate as a dedicated early intervention program, supported by monitoring and evaluation and based on evidence informed community delivery models. This direction is sound. Early support can reduce escalation, improve participation and strengthen outcomes for children and families. However, prevention and early intervention will only be effective if early identification is matched by timely access to support. Identifying a child’s needs earlier and responding to those needs earlier are not the same thing.

Schools experience this issue directly. Concerns about development, communication, social participation, behaviour, learning progress, attendance and wellbeing often become visible in early childhood and school settings. Teachers and school staff are regularly among the first professionals to observe that a student may require additional support. Yet identification alone does not improve outcomes. If concerns identified in educational settings cannot be translated into timely assessment, intervention and ongoing support, schools may continue to manage much of the practical impact of unmet need while families navigate the system.

Early intervention also provides an opportunity for schools to partner with external providers before needs escalate. This aligns with the broader policy rationale that prevention is preferable to crisis driven response. A connected early intervention system should enable schools, families and external providers to collaborate early, with clear boundaries about roles and responsibilities. That would support schools to respond to student needs as part of a coordinated framework rather than in isolation.

Recommendation 12: System clarity

Recommendation 12 addresses another recurring concern raised throughout the Inquiry in the lack of clarity

regarding eligibility, service boundaries and pathways through the support system. The Government has supported this recommendation and has indicated that further information will be published as Thriving Kids services become available. This is essential. Families need to understand where to go, what their child may be eligible for and how different services connect. Schools also need clear information because they frequently assist families to understand the relationships between school based adjustments, external assessments, therapy recommendations, NDIS supports and community services.

A clear system map would provide more consistent advice regarding eligibility, pathways and available supports, including where families are seeking assistance outside the NDIS. It would also reduce the risk that schools are left providing informal navigation support without clear guidance or reliable referral pathways. A system map that only explains Thriving Kids will not be enough. The Government response confirms that no decision has yet been made regarding additional cohorts or services that may be delivered under foundational supports beyond Thriving Kids. This leaves unresolved questions about children who fall outside the target age range, children whose needs exceed the intended threshold of the program, children who require support across key transition points and children whose needs emerge later in childhood or adolescence.

These matters go directly to whether the broader concerns identified by the Inquiry are being addressed or deferred. Many students in Independent schools requiring significant adjustments may not fall within the current parameters of Thriving Kids. This includes older students, student with more complex support needs and students with social-emotional and mental health related support needs who require coordinated support to access and participate in education.

Recommendation 2: Co-design

Independent Schools NSW supports the Government’s commitment to ongoing engagement with children, families and services. However, consultation and co-design are not the same thing. Consultation gives stakeholders an opportunity to express views. Co-design gives stakeholders a meaningful role in shaping decisions. This distinction is important because many of the decisions that will determine whether foundational supports succeed have not been made. Commissioning arrangements, referral pathways, service integration, workforce planning, information sharing and evaluation frameworks will shape how children and families experience the system in practice. Engagement processes should be structured to ensure those affected by these decisions are able to influence them, not merely respond to them.

The Inquiry examined issues that extend across health, disability, education and community services. Co-design should reflect this reality. Families, children, young people, disability and health providers, community organisations, Aboriginal Community Controlled Organisations (ACCOs) and representatives from education sectors all have practical experience of how these systems interact. Their involvement should continue through implementation, not end once the design phase is complete.

Education has an important role within this process. If schools are expected to interact with commissioned providers, support referrals, participate in collaborative planning or host in-reach service models, then implementation should be informed by how schools identify need, work with families, implement adjustments and coordinate with external services.

Recommendation 5: Regional access

Geographic inequity remains one of the most persistent barriers to support access across NSW. The Government has supported Recommendation 5 in principle and has indicated that flexible and effective service approaches in regional, rural and remote areas and thin markets are among the national service principles for Thriving Kids. The response also notes that outreach, telehealth and other delivery modes will be considered, while travel subsidies are currently out of scope. Recognition of this issue is necessary, but the response

remains high level. Regional, rural and remote access challenges extend beyond the likely scope of Thriving Kids and include shortages in diagnostic services, allied health, psychology, early intervention and family support. Flexible service models may assist some families. Telehealth and outreach may also improve access in certain circumstances. However, these approaches do not resolve the deeper structural problems created by too few local providers, long wait times, limited specialist expertise and substantial travel burdens.

This has practical implications for regional Independent schools. In many communities, schools are among the most consistent and accessible services available to children and families. Schools often maintain long term relationships with families and are frequently where the consequences of delayed assessments, unavailable services.

Recommendation 6: Navigation

Recommendation 6 is directed to one of the most practical problems facing families, how to move through the support system without becoming responsible for coordinating it. The Government has supported this recommendation in principle and has indicated that access and referral touchpoints will be defined, information will be shared online and through existing community networks and access to Thriving Kids services will be made as simple as possible. This direction is positive, but a genuine “no wrong door” model requires more than information provision. The practical test is whether families can move between health, disability, education and community services without being redirected from one system to another or left to coordinate those systems themselves.

Education settings are centre to this issue. Schools may become a key access point for identifying students and connecting families with supports. For many children, concerns are first identified in schools or early learning services. Where this occurs, families should experience a clear and supported pathway into services, not a referral into another part of the system that they must navigate independently.

Recommendations 7 and 8: Cultural safety

The Government’s support in principle for Recommendations 7 and 8 is significant. Recommendation 7 calls for foundational supports to be co-designed, governed and delivered in partnership with ACCOs. Recommendation 8 calls for an equity and inclusion framework for culturally and linguistically diverse families. The Government response states that Thriving Kids services will be culturally safe, evidence based and responsive to the needs of families and communities across NSW, including Aboriginal and Torres Strait Islander children and families, culturally and linguistically diverse groups and rural and remote communities.

These commitments are essential, but the challenge extends beyond culturally appropriate service delivery. It requires systems that are culturally safe, trusted and designed in partnership with communities.

For many Aboriginal and Torres Strait Islander families, engagement with disability, health and education systems cannot be separated from the broader legacy of invasion, intergenerational trauma and experiences of racism and discrimination within government institutions. These experiences may contribute to mistrust of mainstream services and may affect whether families seek support, when they seek support and how comfortable they feel engaging with systems that assess, diagnose and make decisions about children.

Western concepts of disability may not align with the way all Aboriginal and Torres Strait Islander families and communities understand children’s strengths, needs and roles within family and community. Some Aboriginal and Torres Strait Islander languages and cultural frameworks do not map neatly onto the term “disability”. For some families, a child may be understood more holistically, with emphasis placed on who the child is, their relationships, strengths, needs and place in family and community rather than on a diagnostic label.

This has important implications for early intervention. Access cannot rely only on a family’s willingness to engage with mainstream assessment or diagnostic systems. It requires culturally safe pathways that recognise

different understandings of disability, avoid deficit based assumptions and build trust through relationships, self determination and community leadership. Partnerships with ACCOs and Aboriginal-led services are essential, but mainstream services that work with Aboriginal and Torres Strait Islander children and families must also be culturally safe.

These issues should not be treated as primarily regional or remote. While access challenges may be acute in some regional and remote areas, many Aboriginal and Torres Strait Islander children and families live in metropolitan communities and may experience barriers that are not geographic in nature, including cultural safety concerns, prior negative experiences with services, racism, discrimination and difficulties navigating complex systems.

Recommendation 14: Workforce

Workforce capacity will be one of the defining factors in whether foundational supports achieve their intended outcomes. The Government has supported recommendation 14 in principle and has indicated that the Department of Communities and Justice will work with service providers, industry bodies and NSW Government agencies to deliver sector and workforce transition activities to support the implementation of Thriving Kids. However, workforce shortages are not a future implementation risk. They are a current system constraint. Without workforce expansion, the system may become better at identifying and referring children without becoming better at providing support. Shortages already affect diagnostic services, early intervention supports, allied health services and specialist assessments.

This issue is heightened by the extent to which the Government response relies on Thriving Kids as the vehicle for reform. Introducing a new program may increase demand from an already stretched workforce unless practical measures are taken to build capacity. Workforce transition activities will not be enough if they do not address recruitment, retention, distribution and service availability, including outside metropolitan areas.

Schools experience these workforce shortages through longer waiting periods, reduced access to specialist advice and increasing pressure on teachers and learning support staff to respond to complex student needs without timely external support. This does not mean schools should replace the specialist workforce. It means workforce planning must consider how specialist services and education settings work together.

Recommendation 13: Education settings

Independent Schools NSW is concerned that the Government did not support Recommendation 13 which goes to the heart of whether foundational supports will operate as an integrated system or as a set of services located near existing systems. This recommendation proposed that foundational supports uphold children’s rights to support in learning and educational settings, including playgroup, early learning and school settings, through revised funding mechanisms, co-commissioned allied health supports, universal design for learning, educator capability building and integrated inclusion planning between education, health and disability systems. It is noted that the stated basis for the Government not supporting the recommendation is that Thriving Kids does not include revision of education funding mechanisms, although services may be delivered in some circumstances alongside schools and early learning services through in-reach models with appropriate governance.

Independent Schools NSW recognises that Recommendation 13 raises complex funding and governance questions. Even so, the decision not to support it leaves unresolved many practical issues that will determine whether children and families experience foundational supports as connected or fragmented. The Government response acknowledges schools as places where services may occur but gives much less attention to schools as partners in coordination, referral, planning and implementation. This creates a clear tension. If services are delivered alongside schools a range of key details will determine whether a child experiences support as

connected or fragmented. These include:

  • How referrals occur
  • How information will be shared
  • How external recommendations will connect with learning support procedures
  • How support will be coordinated across schools, providers and families coordinate support
  • How child safety, privacy and consent requirements will be managed

These are not merely administrative details.

The decision to not support Recommendation 13 may mean schools continue to carry significant responsibility for student support without corresponding access to integrated external services. Current evidence and practice in early intervention emphasise the value of support being provided in natural settings. For many school aged children, the school environment is one of the most important natural settings in which they learn, build relationships, regulate behaviour and participate in social life. The issue is not whether schools should become disability or health service providers. The issue is whether the interface between foundational supports and the education system has been designed clearly enough for the model to function.

Conclusion

Independent Schools NSW supports the development of foundational supports that are preventative, family centred, equitable and accessible. The Government response establishes a significant direction for reform through Thriving Kids and reflects many of the concerns identified during the Inquiry. The Committee should be cautious, however, about treating the future implementation of Thriving Kids as a complete response to the breadth of issues examined through the Inquiry. Thriving Kids may become an important component of the support landscape, but it remains targeted to a defined cohort and is still in the early stages of implementation. Many challenges considered by the Inquiry extend beyond that scope, including support for older students, students with more complex needs, students with social-emotional and mental health related disability and families requiring ongoing assistance.

The Committee should also continue to explore the relationship between foundational supports and education. Schools and early learning services are recognised in the Government response as possible settings for service delivery, yet there is limited detail about how the education system will be integrated into referral pathways, coordination processes, workforce planning, information sharing or evaluation. This is a significant omission because schools are central to children’s daily experience of learning, participation and wellbeing.

Thriving Kids should form part of a broader continuum of support that works in partnership with schools, health services, disability providers and community organisations. The success of foundational supports should ultimately be judged not be the establishment of a new program, but by whether children and families experience earlier support, clearer pathways, stronger coordination and better outcomes across the systems they rely on every day.