Submission

Executive Summary: THE $39 BILLION FISCAL TRAP REGARDING:

National Disability Insurance Scheme Amendment (Thriving Kids Initiative) Bill OBJECTIVE:

Fiscal and Systemic Risk Assessment of Proposed Foundational Support Transitions

THE FISCAL AND CLINICAL RISK EXPOSURE The Thriving Kids Bill aims to reduce NDIS growth by $32 billion over five years by transitioning children aged eight and under with “low-to-moderate” needs into foundational supports delivered through community hubs. However, children with genuinely low needs do not receive NDIS funding and therefore cannot contribute to NDIS savings.The only cohort relevant to the Bill’s savings target ischildrenwithmoderatefunctionalimpairmentscurrentlyreceiveindividualizedearlyinterventionundertheNDIS.No actuarial modelling has been released todemonstratethatdivertingthiscohortinto lower-intensitysupports can achieve the projected savings.This assessment evaluates theBillagainstAustralia’sNHMRC-approvedclinicalstandards:TheAutismCRCNationalGuidelineandthenationalADHDClinicalPractice Guideline.Acrossallevidence-aligned scenarios,the findings are consistent. 1.Clinical Misalignment Creates Predictable Escalation Risks The national guidelines state that children with developmental,behaviouralandneurodevelopmentalanalysisrequire individualised,multidisciplinary,capacity-building supports. Standardised,lown-touchprogramsarenotidentifiedassufficientforchildrenwith moderate functional impairments.

Submission 1571

The Thriving Kids model provides supports that fall below these minimum evidence-based requirements. National datasets show that children with moderate functional impairments who receive sub-clinical support experience a 15–25% annual deterioration risk. This is a risk profile grounded in government data, not a deterministic claim.

Five-Year Fiscal Comparison: Path A vs Path B The relevant cohort is 240,000–300,000 children over five years who:•currently receive NDIS early intervention•meet functional impairment thresholds, and/or require guideline-aligned supportsThese are the only children whose diversion can produce (or fail to produce) NDIS savings.Cost Comparison:

Path A: Guideline-Aligned Early Intervention Average Cost Per Child / Year$15,000Scenario 1: 150,000children $18B(ThrivingKidsTarget) NetFiscalPositionBaseline Scenario 2: 240,000children $69B(Evidence-BasedNeed–Low-End) Scenario 3: 300,000children $7.5B(Evidence-BasedNeed–Upper-End) Note: These results remain directionally stable across sensitivity tests using deteriorati on rates from 10% o% and crisis-level costs from $50K o$100K per child per year.

Submission 1571

Long-Term System Liabilities

Adult NDIS Re-Entry

Children whose functional needs are unmet in early childhood have a higher likelihood of requiring lifelong NDIS support. Conservative lifetime costs: • $3– 5 million per individual • €10 million+ for those requiring supported independent living

Justice System Costs

government data shows that 30 — **40%of incarcerated adults have neurodevelopmental or cognitive developmental disability.Adult incarceration cost $120,₉000-₊$200, per person per year excluding policing courts forensic mental health homelessness services If only (\text{20}) - ((\mathbf{3})of justice involvement among this cohort were preventable through early supports, avoidable life time cost is: • $``1. .8– ``6 billion`

Legislative Conclusion Across all evidence aligned scenarios Thriving Kids Bill unlikely to achieve net fiscal savings Instead it shifts costs:* • From Early Intervention Crisis Response • from the Commonwealth State Systems • Childhood Adulthood The bill introduces material risk to health education child protection mental and justice systems

Recommended Amendments Functional Access Guarantee Ensure children with clinically verified functional impairments retain access Individualised Supports Mandatory Guideline Compliance Require foundational support programs demonstrate alignment Autism CRC National ADHD Guidelines before replacing NDIS packages.

Submission 1571

I welcome any further inquiries or requests for clarification from the Committee, and look forward to providing any additional data or context in writing. Thank you for considering this critical legislative risk assessment as you finalise the Committee’s report. Kind regards, Nicola Ross GradDip(Mental Health & Neuroscience) BNursing/BEarly Childhood Teaching(0–5) Nursing representative/Justice Health Clinical Ethics Advisory Panel