NDIA Accountability Project

Impacts on early intervention services for children with autism

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National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No.

1) Bill 2024

Committee Secretary Senate Standing Committees on Community Affairs PO Box 6100 Parliament House Canberra ACT 2600

Re: National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No. 1) Bill 2024

AEIOU welcomes the opportunity to provide a second submission to the Senate Standing Committee on the National Disability Insurance Scheme Amendment (Getting the NDIS Back on Track No. 1) Bill 2024 (the Bill). We appreciate the Committee’s consideration of both our previous submission (and other service providers) when the Bill was first introduced, and this updated submission.

AEIOU reiterates our previous concerns regarding the lack of consultation and clarity in the Bill’s details. These concerns have been exacerbated by current trends of reduced plan values, funding delays, and restrictions on choice and control for families seeking AEIOU’s specialist early intervention services. AEIOU fears these trends imply that reform changes have already been implemented before this Bill and other NDIS Review related legislative reforms have been enacted.

Background

AEIOU’s mission is to enhance the lives of children with autism and their families through evidence- based, successful early intervention programs and practical support. AEIOU operates eleven centres across regional and southeast Queensland, South Australia, and the ACT, enrolling up to 300 children each year.

Each child is supported by an expert transdisciplinary team of therapists and educators, who share the responsibility of assessing, planning, delivering, and evaluating each child’s individual plan. AEIOU’s commitment to providing the highest quality evidence-based early intervention services is grounded in our extensive research efforts, which give valuable insights into the efficacy of the AEIOU program, its impact on NDIS participants’ lives, the community and the overarching importance of early intervention.

Lack of Consultation

While AEIOU appreciates the Commonwealth Government’s announcement last year that an initial tranche of NDIS Review-related legislation would be introduced in the first half of 2024, AIEOU was disappointed by the lack of sector consultation prior to the Bill’s introduction to parliament on 27 March 2024.

Promises to “keep the voices and needs of people with disability’ at the heart of all NDIS reforms” were not kept during the creation of this legislation, with widespread media reporting that only select handpicked disability advocates were briefed on the Bill but bound by non-disclosure agreements before its introduction.

To ensure the Commonwealth Government adheres to its commitment of inclusive co-design, key stakeholders must be engaged earlier and more meaningfully throughout the NDIS reform process.

Engaging these stakeholders – disabled people and their families, the disability sector and peak bodies, state/territory governments – throughout the reform process is critical to mitigating disruptions to NDIS participants and ensure market and sector health.

Transparency and clarity regarding timeline

The five-year transition period for implementing the NDIS Review’s recommendations lacks detailed timelines, leaving participants and providers uncertain about the impact of these changes. Some recommendations appear to have been implemented without public awareness, causing potential negative side effects such as market disruption, job losses, and loss of confidence in the reforms.

To avoid these issues, the government must commit to transparency throughout the NDIS reform consultation process – including when introducing legislation like. This includes providing a clear roadmap of the five-year transition period and ensuring stakeholders are informed and have many opportunities to provide feedback.

Ongoing NDIS Concerns

As mentioned earlier, AEIOU’s concerns regarding the Bill have been exacerbated by current trends negatively impacting families seeking AEIOU’s specialist early intervention services. AEIOU is concerned changes have already been made before this Bill and other NDIS Review related legislative reforms have been enacted.

Our key trends of concern are:

  • Decreased Plan Values: In 2024, the average AEIOU plan value dropped by 20%. Additionally, in 2024 alone, 90 children have already accessed AEIOU funded financial support on average for up to 3 months.
  • Funding Delays: Families are experiencing significant delays in plan reassessments, reviews, and changes of circumstance approvals, which causing financial hardship for families.
  • Restrictions on Choice and Control: Feedback suggests NDIS delegates are vetoing plans based on “dosage” of therapy, specialist environments, and perceived provider bias. This denies autistic children access to critical early intervention programs.
  • Lack of Transparency: The NDIS Review appears to be implementing changes without proper notice to participants or providers.

It is imperative that whatever change or directive that has been made to instigate these negative trends is reversed by the Commonwealth Government while NDIS reform legislation is enacted, as the children accessing early intervention services like AEIOU have complex, high needs and require specialist care.

Children who attend AEIOU have early learning skills (IQ/DQ) that are not only well below the typically developing child, but also well below most autistic individuals. They are autistic children

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with complex, high needs that required a specialised service that most mainstream settings cannot provide.

Our research shows that on average, children who enter AEIOU’s service are approximately 3.89 years old, but developmentally, are at the level of a child aged 1.9 years old. This puts them at a significant developmental disadvantage to their peers. The greatest early learning delays were in expressive language and receptive language, where children at AEIOU performed in the 3.4th percentile. This means the language skills of AEIOU ’s children are lower than 96.6% of children the same age.

Recommendations

We urge the Committee to consider recommendations that incorporate:

  • Improved consultation and co-design: Ensure genuine co-design with the disability sector, peak bodies, and state/territory governments for future NDIS reforms. Include the voices of parents/carers and experts when young children cannot advocate for themselves.
  • Transparency: Increase transparency throughout the NDIS reform process, including clear communication of timelines and impacts of rule changes. Ensure stakeholders are informed and have opportunities to provide feedback.

Meanwhile, AEIOU calls on the Commonwealth Government to take the following actions throughout the NDIS reform process:

  • Ensure timely access to plans and funding for current NDIS participants: Prioritise timely access to NDIS plans and ensure funding levels are adequate to meet individual needs.

p 07 3320 7500 e info@aeiou.org.au w www.aeiou.org.au Central Office – 60 Leichhardt Street, Spring Hill | PO Box 107, Spring Hill QLD 4004 ABN 19 135 897 255 Registered Charity CH1818

Conclusion

AEIOU is committed to working collaboratively with the government to ensure the NDIS remains sustainable into the future while also giving profoundly autistic children the ability to access quality early intervention services that will help them live their best lives and reduce reliance on ongoing supports.

I welcome the opportunity to share more information regarding AEIOU’s data, which is unique in Australia, and globally.

Thank you for your consideration.

Sincerely,

Alan Smith Chief Executive Officer

p 07 3320 7500 e info@aeiou.org.au w www.aeiou.org.au Central Office - 60 Leichhardt Street, Spring Hill | PO Box 107, Spring Hill QLD 4004 ABN 19 135 897 255 Registered Charity CH1818