Submission
No 98
INQUIRY INTO FOUNDATIONAL AND DISABILITY SUPPORTS AVAILABLE FOR CHILDREN AND YOUNG PEOPLE IN NEW SOUTH WALES
Organisation: Allied Health Professions Australia
Date Received: 17 September 2026
Allied Health
Professions
Australia
Select Committee on Foundational and Disability Supports Available for Children and Young People in NSW
September 2026
This submission has been developed in consultation with AHPA’s allied health association members.
Allied Health Professions Australia
PO BOX 439, Carnegie VIC 3163
www.ahpa.com.au
About Allied Health Professions Australia and the allied health sector
Allied Health Professions Australia (AHPA) is the recognised national peak association for Australia’s allied health professions. AHPA’s membership consists of 29 national allied health associations and a further 10 affiliate members, each representing a particular allied health profession. AHPA collectively represents over 195,000 allied health professionals and works on behalf of all Australian allied health practitioners.
AHPA’s Disability Working Group (the Working Group) comprises policy and clinician representatives drawn from the range of AHPA’s members that provide services to people with disability including through the National Disability Insurance Scheme (NDIS). The Working Group is therefore informed by the views and experiences of both individual allied health professions and the allied health sector as a whole.
AHPA and its member associations are committed to ensuring that all Australians can access safe, evidence-based services to assist them to realise their potential for physical, social, emotional and intellectual development.
Overview
AHPA welcomes the extension of the Select Committee on Foundational and Disability Supports Available for Children and Young People in NSW inquiry and thanks the Committee for the additional opportunity to provide input. AHPA previously provided a response to this inquiry and appeared at a public hearing in 2025. This response is intended to build on that initial advice, while providing feedback about emerging issues.
Since our involvement in the initial inquiry, there have been considerable developments in relation to foundational supports and the broader disability ecosystem. That includes more substantial changes to the National Disability Insurance Scheme (NDIS), underpinned by new legislation, as well as the formal announcement and finalisation of Thriving Kids agreements between the Commonwealth and NSW along with other state and territory agreements. AHPA has been actively engaging with Commonwealth, state and territory governments to help inform the development of Thriving Kids and to understand more about how governments will be implementing new programs and services. With the formal commencement of Thriving Kids programs in most states and territories less than a month away, policy and program implementation approaches in NSW, and their impact on the allied health early childhood workforce, are starting to become clearer.
Allied health professionals play an integral role in supporting children with developmental delay and disability. Their scope of practice, training and expertise cover identifying developmental delay and disability; undertaking comprehensive assessments; prescribing and supplying assistive technology; building the capacity of families, carers and other professionals; and delivering tailored, evidence-based interventions that respond to each child’s needs and preferences, as well as those of their caregivers.
Whilst a national model for Thriving Kids has been agreed to, there remains a need to develop and implement a nationally consistent framework for access to allied health services, based on a consistent assessment approach; commissioning structures that support participation by private
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local providers; and careful consideration of how Education and Health-funded allied health supports complement the program.
An ecosystem of private early childhood allied health professionals currently support many children and their families in NSW. That workforce is unevenly and incompletely distributed despite significant investment by Australian governments to develop the allied health therapy market to deliver NDIS supports. The distribution and availability of that workforce is in significant question because of emerging policy guidance suggesting Commonwealth funding of allied health services through the NDIS will be reduced and given that the NSW government is largely not intending to include private allied health providers in their commissioning processes.
AHPA continues to call for foundational supports that enable all children and their families, carers or kin to have access to a wide range of inclusive, accessible, and evidence-based allied health services and supports at a level of volume and intensity to support developmental outcomes.
Our response below focuses on several key areas that must remain a priority in the design and implementation of Thriving Kids in NSW:
- Commissioning of targeted and other Thriving Kids supports in NSW
- Supporting a sustainable and accessible allied health workforce in NSW
- Reducing assessment duplication and access barriers for children and families seeking access to services
- The importance of mainstream early childhood and school-based supports
- Integration of best practice approaches for Thriving Kids services in NSW
Detailed response
Commissioning of targeted and other Thriving Kids supports in NSW
The expansion of the disability ecosystem to comprise not only NDIS-funded services delivered by NDIS providers, but a greater system of foundational supports co-funded and delivered by states and territories represents a major shift in who and how the delivery of services is funded. The Commonwealth government has made clear that early childhood foundational supports delivered under Thriving Kids are only one part of a growing requirement for future services to be established outside of the NDIS. The shift to exclude more people from the NDIS and instead rely on states like NSW to deliver supports in the form of foundational supports will fundamentally impact the volume of services that private providers will be able to deliver and how they participate in delivering services for people with disability.
When the NDIS was established, governments actively encouraged allied health professionals to transition into the NDIS market to serve people with disability. Many invested substantially in building private practices to deliver those supports, often in areas that might not otherwise have supported a sustainable allied health service without that funding source. Those businesses have contributed to delivering much more accessible and well-distributed supports, and comprise some of the most experienced providers of early childhood intervention in the country. However, NSW has clearly signalled that those private businesses have a very limited role in delivering Thriving Kids supports.
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The Thriving Kids commissioning model announced in NSW, largely excludes for-profit allied health providers from delivering supports through Thriving Kids. This exclusion appears to apply regardless of the provider’s size, experience or geographic reach. AHPA argues strongly that this approach will exclude some of the most experienced allied health practitioners in early childhood intervention from the program, break down established local service systems that are supporting families, and significantly reduce the pool of providers NSW can draw on.
Excluding private providers from Thriving Kids on the basis of their business structure rather than their capability, quality, or local presence is inconsistent with the rationale for their transition into the private sector in the first place and risks leaving significant workforce capacity on the sideline precisely when it is needed most.
AHPA recognises the complexity of the task before NSW and other state and territory governments. These changes require NSW to re-build planning and commissioning capability, to take responsibility for coordinating and connecting a complex mix of mainstream early childhood, education, health and disability supports, and to build a new ecosystem of programs. Large provider contracts often appear to offer a seemingly simple solution to a complex task. But that approach may overlook other challenges such as the readiness of those providers to provide an appropriately skilled workforce to deliver supports, the absence of well-developed local referral networks, and the impact on the availability and sustainability of other services that will continue to be needed for NDIS participants, albeit at smaller service volumes.
AHPA argues that there are opportunities to implement more flexible commissioning options that allow for private providers of different sizes to participate in direct or consortia-based commissioning approaches. The Commonwealth Primary Health Network program and the increasingly mature and more flexible commissioning approaches starting to be used for those programs provide potentially helpful guidance that NSW and other governments can draw on when developing and establishing their commissioning programs.i Implementing a more flexible and fit-for-purpose approach potentially increases initial complexity but may reduce gaps and ensure access to high-quality private providers of all sizes for children and families accessing Thriving Kids supports in NSW. The success of Thriving Kids in NSW, and the ongoing availability of high-quality disability supports regardless of funding source, depends on drawing on the best available workforce, not putting arbitrary limits on who can participate in commissioning processes.
Supporting a sustainable allied health workforce in NSW
The upcoming changes to the NDIS and Thriving Kids appear to already be impacting on access to allied health services, and the way in which the allied health sector delivers supports for children with developmental delay and disability. Allied health professionals report that reassessments of children receiving NDIS supports, along with reductions in funding of plans, is reducing access to services and pushing families and providers to seek other funding alternatives including private and charitable funding. These alternative funding approaches are unlikely to be sustainable in many areas, particularly areas experiencing greater financial disadvantage, and are reportedly already reducing demand for services in some areas.
As further NDIS reforms, and cuts to access and funding, are implemented, and as the Thriving Kids programs are established and children move to those programs, the viability of allied health practices will be increasingly at risk. Market exits, and reductions in service capacity, are already
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occurring and will continue to occur with the risk of creating new gaps in services and increasingly thin markets. In some cases, those changes may reflect a genuine lack of local need due to children and families gaining access to other services. But in most cases, there will be a direct impact on access to NDIS and, where businesses deliver mixed services across multiple funding programs, non-NDIS services for many Australians as those businesses find themselves unviable and needing to reduce capacity or close. Market exits or changes in access risk having a potentially significant impact on the children, families and other users of those services, particularly where alternate services may not be available.
AHPA notes that no governments appear to have shown significant work to model the impact of these changes on businesses, or to develop transition support resources and guidance that would allow businesses to pivot to other funding programs and areas of support need. While the Commonwealth has suggested that there is demand for other supports and services delivered by allied health businesses, including aged care and veteran’s supports, work has not yet been undertaken to establish where and what volume of supports are needed in a way that would allow providers to refocus clinical expertise and service focus where genuine needs exist.
A much more dedicated focus on workforce impact and workforce transition supports must be a priority for all governments if the allied health sector is to remain able to support children and families in Thriving Kids and continue to support other areas where there is unmet need. NSW will need to consider carefully how delivery of Thriving Kids and other disability programs can contribute to a viable system of disability supports for their residents and how complementary work will help mitigate the risk of unintended consequences on other areas of service delivery. Workforce transition supports will be essential to ensure that allied health services are able to make informed decisions about whether to build the capacity to deliver services in other funding programs and areas of clinical need.
AHPA notes that it has advocated to the Commonwealth to build transition supports for allied health providers but has not yet been able to secure funding to progress the development of those transition supports. AHPA understands that DCJ has indicated it intends to develop a sector and workforce transition plan. AHPA recommends a commitment of resources by NSW to support the establishment of a transition support program for providers in NSW and welcomes the opportunity for further discussions about how this could be delivered.
Reducing assessment duplication and access barriers for children and families seeking access to services
Children and families seeking access to services and supports in NSW need to undertake a range of different assessments to determine their needs and establish eligibility for supports across health, education, disability, and early childhood programs. Currently, processes to determine access to services and the types of assessments that may be needed vary considerably leading to potential duplication or unintended barriers to access for those seeking supports.
AHPA understands that some of the assessment and access processes are subject to further consideration and decision by governments. For example, current work being undertaken by the Commonwealth will determine who has access to the NDIS in future and how access eligibility is determined. AHPA also understand work is underway by jurisdictions to determine a process for establishing who will be eligible for Thriving Kids services, and which services they will need.
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Unfortunately, while it’s understood there are some attempts to share information between the Commonwealth Technical Advisory Group leading NDIS Access work and the jurisdictional group leading discussion around the development of Thriving Kids, AHPA is not aware of a firm commitment to align the development of requirements and processes for access and eligibility across systems. Without that, children and families risk being required to participate in multiple different processes with no clear pathway from NDIS assessment to Thriving Kids services, or vice versa.
AHPA argues strongly that work to develop access requirements and processes for Thriving Kids and the NDIS should be developed at the same time with as much overlap as possible in requirements, noting that the two programs will have some key differences in the information they require. This provides the best opportunity to create a more efficient and streamlined process for families seeking services for their child, reducing assessor workforce requirements and costs, and expediting access to appropriate programs in a more effective step-up and step-down system. While we support the need to move away from a diagnosis-based approach for establishing eligibility for Thriving Kids, there is also a clear need to reduce the cost, time, and accessibility barriers that children and families experience when different funding programs or schemes within the health, education, and disability ecosystem all require different assessments or evidence.
The importance of mainstream early childhood and school-based supports
The NDIS Review established the significant gaps in mainstream supports for children with developmental delay and disability. ii Education settings in particular were noted as having too high a dependence on external, individual NDIS-funded supports that may not be effectively integrated with the education environment, that may make the role of educators more difficult, and that may disrupt the usual flow of the education setting. Foundational supports were recommended alongside work to address barriers and improve the accessibility of mainstream education settings for children.
While NSW has provided guidance about how it is approaching the establishment of Thriving Kids programs, the role of Education-based supports and of allied health professionals working in education settings is still unclear despite education settings being a key natural setting where children develop and grow.
There are indications that some Thriving Kids supports across Australia may operate in education settings, particularly early childhood settings, however it is not clear how those supports will operate alongside other Education-funded services and how funding will be drawn from different programs to address the need for environmental adaptions, dedicated staff resourcing, and better integration of educators with other expert early childhood staff such as allied health professionals. The previous section also flagged the need for greater coordination in how access and eligibility assessments for services can be better streamlined across the ecosystem and this includes Thriving Kids, education settings, mainstream services and the NDIS.
AHPA strongly encourages NSW to provide clearer guidance about the work that it will do to improve the accessibility of Education-based supports, noting how integral education-based supports are for many children with developmental delay and disability. In particular, the role of allied health professionals, and how these mainstream education supports will be aligned with and complement Thriving Kids, should be more clearly articulated. AHPA and its members have
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undertaken policy work to support understanding of how this can be undertaken and welcomes opportunities to work collaboratively with the NSW government.
Integration of best practice approaches for Thriving Kids services in NSW
Australian governments have indicated a strong interest in, and need for, evidence-based approaches to the delivery of supports for children with developmental delay and disability. Despite that, AHPA notes ongoing uncertainty about how directly the Commonwealth-funded Best Practice Framework for Early Childhood Intervention and the tools and resources associated with the Framework will guide the development and delivery of Thriving Kids programs and services, including a model of allied health targeted support delivery.
For example, it’s not clear to what extent individualised needs, and best practice approaches to identifying and meeting those needs, will align with the level of resourcing and program structure of future targeted supports in NSW. There also appears to be a likelihood that key worker models will be implemented where a child has higher levels of need. This is despite the key worker model being only one of the collaborative models identified in the best practice framework.iii AHPA supports the findings of the evidence review and consultation that underpinned the Best Practice Framework, which showed that high levels of experience and clinical expertise are required by practitioners working in a key worker paradigm. These roles are not appropriate for early career professionals or those lacking a strong understanding of their own scope of practice. Evidence also shows that key workers must be well-integrated in a multidisciplinary team and should not work in standalone roles.
AHPA argues strongly that the Framework, and the associated evidence and resources associated with the tool, must guide program development and delivery of Thriving Kids across Australia. There could be opportunities to seek more targeted advice and guidance from the clinicians in the consortium who developed the Framework to guide program development.
AHPA also argues strongly that further consideration is needed about how other complementary funding sources such as Education and Medicare can play a role in addressing any resource limitations within the Thriving Kids program and ensure services for children and families genuinely meet their needs.
i Department of Health, Disability and Ageing. Final Report. Review of the PHN Business Model and Mental Health Flexible Funding Stream. June 2025. Available from: https://www.health.gov.au/sites/default/files/2025-12/primary-health-network-program-final-report.pdf ii Commonwealth of Australia, Department of the Prime Minister and Cabinet. Working together to deliver the NDIS - Independent Review into the National Disability Insurance Scheme: Final Report. 2023. Available from: https://www.ndisreview.gov.au/resources/reports/working-together-deliver-ndis iii Luscombe D, Moore T, Gavidia-Payne S, Bull K & Bhopti A. Teamwork in early childhood intervention: A practice brief for the National Best Practice Framework for Early Childhood Intervention. The University of Melbourne. Commissioned by the Commonwealth of Australia’s Department of Social Services. 2025. Available from: https://www.health.gov.au/our-work/national-best-practice-framework-for-early-childhood-intervention
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