ECIA VIC/TAS acknowledges the traditional custodians of the lands and pays respect to elders past and present. We pay respects to Aboriginal and Torres Strait Islander children, their families, and we commit to creating a future where every child is valued, safe and an empowered member of their community.
Recommendations
- Recognise early childhood as a unique developmental life stage and embed a developmentally responsive, family-centred approach throughout access decision-making.
- Provide timely and proportionate access, including streamlined pathways for children with clear significant and lifelong disability and avoiding a “wait and see” approach.
- Recognise the full range of evidence, including family experience, professional judgement and evidence gathered across settings and over time, while reducing duplication and unnecessary assessment.
- Build NDIA accountability into implementation, through workforce capability, cultural safety, family and sector participation, child-specific outcome monitoring and continuous quality improvement.
- Embed cultural safety and equity into access design co-designed with Aboriginal and Torres Strait Islander communities, culturally and linguistically diverse communities, people in rural, regional and remote areas, and families experiencing disadvantage.
- Make access communication accessible and transparent with decisions explaining; the evidence considered; how the eligibility criteria were applied; how the decision was reached; what the family can do if circumstances change; and what alternative supports are available. Information should be provided in accessible formats and with appropriate interpreting, communication and cultural supports.
- Streamline access for children with clear, lifelong disability through a proportionate and tiered access model so that children with clear evidence of significant and permanent or likely permanent disability are not required to undergo repeated or unnecessary assessments to establish eligibility.
- Create a genuinely connected system, with warm referrals and supported navigation between the NDIS, Thriving Kids, health, education and community services. Ensure pathways are easy to navigate and respond to changing needs throughout early childhood
About us
Early Childhood Intervention Australia Victoria/Tasmania (ECIA VIC/TAS) represent the Early Childhood Intervention Sector (ECI) with 500 members working with children 0-9 years with developmental concerns, delay or disability.
Our members are deeply connected to the communities they serve working in both metropolitan, rural and remote areas of Australia.
Our membership encompasses Early Childhood Education and Care, lower primary school and early childhood intervention sectors including:
- Early Childhood Intervention practitioners- allied health professionals and specialist teachers
- Early Childhood Education and Care educators and teachers
- Pre-School Field Officers in Victoria
- Students
- Parents/carers/kin
We advocate for equitable inclusion, belonging and participation in education, family and community life for all children, particularly those with developmental concerns, delay or disability.
ECIA VIC/TAS are committed to an interconnected ecosystem of support around a child and family, comprising education, health and disability portfolios.
We are committed to service provision that is aligned with evidence-informed practices, to deliver lifelong outcomes for children and families.
ECIA VIC/TAS strongly advocates that co-design with families, service providers, First Nations communities, CALD groups, and children themselves (where appropriate) must inform all stages of program design, implementation, and evaluation.
Executive Summary
ECIA VIC/TAS welcomes the opportunity to contribute to this consultation. Our response is informed by the experience of our members and the families and children they support. We support the intent of access reform to improve consistency, transparency and proportionality while reducing unnecessary evidence requirements and administrative burden. However, we strongly emphasise that a future access process must recognise early childhood as a unique developmental life stage. Development in the early years is rapid, variable and influenced by relationships, environments and opportunities for participation. Functional capacity can change significantly over relatively short periods, and the impact of an impairment may present differently across home, early childhood education and care, school and community settings.
The current NDIS early childhood approach recognises the importance of family-centred and strengths-based practice and participation in everyday environments. The future access process for children should build on these principles rather than introduce an access model that relies primarily on point-in-time assessment.
Guiding principles and Evidence
ECIA VIC/TAS supports the seven draft principles. Together, they provide a strong foundation for a future access process. However, their application must be adapted to recognise that early childhood is a unique stage of development linked to specific outcomes, in the lives of young children and their families.
Children with significant and lifelong disability should not have to repeatedly prove their eligibility
Children with clear, significant and lifelong disability should not be required to repeatedly demonstrate their eligibility for the NDIS. Where appropriate evidence has already established that a child has a permanent impairment and substantial functional impact, access should ongoing. Requiring families to repeatedly produce evidence places an unnecessary burden on families and clinicians and diverts resources away from supporting children. A proportionate access process should distinguish between situations where eligibility is clear and those where further information is genuinely required.
Access decisions must consider the family context
For young children, disability cannot be considered in isolation from the family and environment in which the child lives. The Person-Centred Principle, does not adequately represent a child in the context of family. Family circumstances should be considered in access decision-making, particularly where there are risks to child or family safety, family breakdown or the sustainability of informal supports.
This includes situations where:
- families are supporting multiple children with disability or developmental needs;
- a parent or carer also has disability-related support needs;
- families have limited informal support networks;
- caring responsibilities are placing significant pressure on family functioning; or
- the child’s support needs are contributing to risks to the safety or wellbeing of the child or family.
The access process should recognise that a child’s functional needs and the sustainability of the family supporting that child is interconnected. The principle of Person-Centred should be expanded to include family-centred where a child is the NDIS participant.
Strengths-based practice must be consistently applied
ECIA VIC/TAS welcomes the explicit commitment to strengths-based practice.
However, our members continue to observe inconsistency in how strengths-based and family-centred approaches are applied. We recommend that the NDIA invest in comprehensive capacity building and training for all staff involved in access decision-making so that these principles are consistently reflected in practice.
Access must respond to developmental change
Early childhood is characterised by rapid development. A child’s functioning and support needs can change considerably as they develop, participate in new environments and transition between settings.
The access process therefore needs clear and simple pathways for families to make a new access request when circumstances change. Families who have previously engaged with the NDIS or provided evidence should not have to start again from the beginning.
Similarly, plan structures and budgets need sufficient flexibility to respond to significant developmental and life transitions, including transitions into or between early childhood education, school and other environments.
Early intervention must not become “wait and see”
ECIA VIC/TAS is particularly concerned about approaches that require children and families to wait until functional difficulties become sufficiently significant before support is provided. The future system must avoid a “wait and see” or “wait and fail” approach. For children with significant disability or a clear trajectory towards significant and lifelong disability, early access to appropriate intervention should be enabled rather than delayed while families wait for further functional deterioration or for a child to fail to meet developmental expectations.
Early childhood professionals have specialist expertise in recognising developmental trajectories. Their professional judgement and evidence should be considered alongside formal assessment results. There must be a clear pathway for children with significant disability to access the NDIS without being required to cycle through lower-intensity systems before they can demonstrate a level of impairment that was foreseeable.
Professional evidence and clinical judgement must be valued
The professionals who work with children and families over time have an important role in describing functional capacity and support needs.
This may include:
- paediatricians and other medical specialists;
- allied health professionals;
- early childhood intervention practitioners;
- early childhood educators;
- specialist teachers;
- early childhood partners; and
These professionals can provide information about the child’s functioning over time and across settings, including information that may not be evident during a single assessment.
ECIA VIC/TAS recommends that the NDIA clearly articulate what assessment and screening evidence will be accepted and how professional evidence will be weighted. This would enable families and practitioners to gather appropriate evidence without unnecessary duplication.
Communication must be accessible and transparent
Families need clear explanations of access decisions, including why a child has been found ineligible and what options are available next. Information should be provided in formats that families can understand, with interpreters, visual supports and other communication adjustments available when required.
Families should not have to wait for their next appointment with their ECI practitioner to understand a letter from the NDIS, particularly where that letter contains a time-limited requirement for action.
Transparent communication is fundamental to equitable access.
Establish a proportionate assessment model
ECIA VIC/TAS supports a tiered approach in which the level of evidence required reflects the complexity of the access decision. For children with clear, significant and lifelong disability, evidence from appropriate specialists and professionals demonstrating permanent impairment and substantial functional impact should be sufficient for streamlined access. Additional functional assessment should only be required where it is genuinely necessary to resolve uncertainty. Importantly, the assessment process must not create a financial barrier to access. Families should not have to pay for multiple assessments, diagnostic or functional, simply to establish eligibility.
Cultural safety and equity
The access process must work effectively for:
- Aboriginal and Torres Strait Islander children and families;
- culturally and linguistically diverse communities;
- children and families in rural, regional and remote areas; and
- families experiencing social and economic disadvantage.
Assessment tools and processes should be culturally responsive and developed with the communities they will serve.
Should any principles be added, removed or changed?
ECIA VIC/TAS recommends the addition of an explicit principle:
Early Childhood as a unique life stage.
The access decision-making process should recognise early childhood as a unique developmental life stage. It should account for the dynamic nature of children’s development, the influence of family and environmental contexts, and the importance of timely intervention. Decision-making should consider children’s functioning and participation across everyday environments and recognise the expertise of families and professionals who know the child well.
The existing principles are relevant to all people with disability, but they do not sufficiently articulate what is different about early childhood. The NDIS currently recognises early childhood as a distinct approach for children younger than nine years and their families. The access process should similarly recognise the unique developmental characteristics of this life stage. The National Best Practice Framework for Early Childhood Intervention provides an important foundation for understanding this context.
Any future access process should consider the child, family and environment, rather than treating functional capacity as an isolated characteristic of the individual child.
Conclusion
A well-designed access process has the potential to reduce unnecessary assessment burden, improve consistency and provide families with greater certainty about how access decisions are made.
However, consistency must not come at the expense of developmental responsiveness.
ECIA VIC/TAS recommends the addition of an explicit developmentally responsive and family-centred principle to the final guiding principles. The success of access reform should ultimately be measured not only by whether decisions are consistent, but by whether children and families receive the right support, from the right system, at the right time.
This requires an access process that recognises the expertise of families and professionals, responds to developmental trajectories and ensures that children with significant disability are not required to wait for their needs to become more severe before they can receive appropriate support.
1 Framework Links – Preci Australia