Submission to the NDIS Evidence Advisory Committee: Early Intensive Behavioural Intervention (EIBI) (Provider advocacy)

Submission 366 - Attachment 1

Submission to the NDIS Evidence

Advisory Committee: Early Intensive

Behavioural Intervention (EIBI)

Prepared by: Niesha Illingworth (President) on behalf of the Association for Behaviour Analysis Australia

Approved by:

Executive Board of Directors

Date: 27th March 2026

Association for Behaviour Analysis Australia

PO Box 61

Sandy Bay, TAS 7005

Email: admin@auaba.com.au Website: auaba.com.au

ABN 24165099392

Submission 366 - Attachment 1

Table of contents

1. Executive Summary …………………………………………………………………………………………………… 4 1.1 Overview ………………………………………………………………………………………………………….. 4

1.2 Key position of ABA Australia ……………………………………………………………………………… 5

1.3 Summary of recommendations ……………………………………………………………………………. 6

2. About ABA Australia ………………………………………………………………………………………………….. 6
3. The policy and funding question before the EAC……………………………………………………………. 7 3.1 Why this review matters ………………………………………………………………………………………… 7

3.2 The relationship between evidence reviews and funding architecture ………………………. 8

3.3 Why workforce recognition and support effectiveness are linked ……………………………… 8

4. How EIBI should be defined and assessed …………………………………………………………………… 9 4.1 What EIBI is ……………………………………………………………………………………………………… 9

4.2 What EIBI is not ………………………………………………………………………………………………… 9

4.3 Why review framing matters ……………………………………………………………………………… 10

4.4 Recommended approach to assessment ……………………………………………………………. 10

4.5 Overall position ……………………………………………………………………………………………….. 11

5. Contemporary EIBI: models, delivery, individualisation and care context ………………………… 11 5.1 Contemporary models of behaviour analytic early intervention ………………………………. 11

5.2 Goals, intensity, and individualisation …………………………………………………………………. 11

5.3 Delivery across settings and everyday contexts …………………………………………………… 12

5.4 Multidisciplinary care and behaviour analytic expertise …………………………………………. 12

5.5 Overall position ……………………………………………………………………………………………….. 13

6. Why access to evidence-based EIBI matters under the NDIS ………………………………………… 13 6.1 Participant and family benefit …………………………………………………………………………….. 13

6.2 Timely access and longer-term implications ………………………………………………………… 14

6.3 Economic and Scheme relevance ……………………………………………………………………… 14

7. A recommended evidence framework for the EAC ……………………………………………………….. 15 7.1 What should count as evidence …………………………………………………………………………. 15

7.2 Evidence should be considered in context ………………………………………………………….. 15

7.3 Functional and clinically meaningful outcomes …………………………………………………….. 16

7.4 Implementation and delivery capability ……………………………………………………………….. 16

7.5 How evidence gaps should be handled ………………………………………………………………. 16

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7.6 Overall position ……………………………………………………………………………………………….. 17

8. Summary of the evidence for behaviour analytic EIBI and its functional relevance under the NDIS …………………………………………………………………………………………………………………………. 17

8.1 Communication and language outcomes ……………………………………………………………. 17

8.2 Social communication, interaction, and participation …………………………………………….. 18

8.3 Adaptive functioning and daily living skills …………………………………………………………… 18

8.4 Learning readiness and engagement in everyday environments ……………………………. 19

8.5 Reduction of barriers to learning, participation, and safety…………………………………….. 19

8.6 Family and caregiver outcomes …………………………………………………………………………. 20

8.7 Generalisation and maintenance of gains …………………………………………………………… 20

8.8 Overall position ……………………………………………………………………………………………….. 20

9. Ethical, person-centred, and professionally accountable EIBI ………………………………………… 21 9.1 Ethical practice principles …………………………………………………………………………………. 21

9.2 Person-centred and family-centred planning ……………………………………………………….. 22

9.3 Quality of life and meaningful outcomes ……………………………………………………………… 22

9.4 Safeguards, workforce accountability, and implementation quality …………………………. 23

9.5 Overall position ……………………………………………………………………………………………….. 24

10. Current system gaps and the risks of non-recognition …………………………………………………. 24 10.1 Existing service reality under the NDIS …………………………………………………………….. 24

10.2 Claiming and pricing ambiguity ………………………………………………………………………… 25

10.3 Recognition and workforce pathway gaps …………………………………………………………. 25

10.4 Risks for participants and the Scheme ……………………………………………………………… 25

10.5 Overall position ……………………………………………………………………………………………… 26

11. Recommendations to the EAC and NDIA ………………………………………………………………….. 27
12. Conclusion ……………………………………………………………………………………………………………. 29
13. Appendices …………………………………………………………………………………………………………… 31 Appendix A. Definitions and terminology ………………………………………………………………….. 31

Appendix B. Evidence summary table: reviews and key supporting studies ………………….. 33

References …………………………………………………………………………………………………………………. 34

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1. Executive Summary 1.1 Overview

ABA Australia welcomes rigorous evidence review and supports the Evidence Advisory Committee’s role in strengthening access to evidence-based supports under the NDIS. This submission concerns behaviour analytic Early Intensive Behavioural Intervention (EIBI): an evidence-based therapeutic support for a defined cohort of young children, delivered by a specialist workforce, but not consistently recognised or operationalised within the Scheme.

ABA Australia submits that behaviour analytic EIBI should be assessed by the EAC as a distinct therapeutic support area within the broader field of applied behaviour analysis, rather than grouped with conceptually and clinically different early intervention models. This submission focuses on EIBI as a defined and evidence-based application of behaviour analytic practice, while recognising that applied behaviour analysis has broader relevance across therapeutic supports under the Scheme. In our view, the relevant question for this review is for which young children, with which goals, in which contexts, and with what outcomes behaviour analytic EIBI demonstrates meaningful benefit. This approach is consistent with the logic of the Duckett Review and better reflects the heterogeneity of both developmental presentations and evidence, the complexity of implementation, and the practical realities of policy decision-making under the Scheme.

EIBI is a critical support for some young children because it helps build the foundational skills that shape communication, learning, independence, safety, and long-term participation. Yet the current system remains marked by confusion, inconsistency, and poor alignment between evidence, funding, and workforce recognition. Families are too often left to navigate a mixed landscape of early intervention options that vary substantially in their evidence base, quality, and professional oversight, while being forced to fight for access to the support they and their treating professionals know is appropriate for their child.

The consequences of this uncertainty are being felt directly by children, families, and the specialist workforce. It creates inequity in access, pushes families into avoidable review and Administrative Review Tribunal processes, delays intervention during a developmentally critical period, and contributes to workforce leakage as highly trained clinicians are not able to reliably provide this work through the Scheme.

ABA Australia submits that the evidence for EIBI should be interpreted in relation to meaningful functional outcomes, including communication, adaptive functioning, daily living skills, participation, safety, flexibility, coping, and family capability, rather than symptom reduction alone or narrow developmental metrics. The evidence is not without limitations, and outcomes vary across children, but the overall body of evidence is sufficiently strong and relevant to support recognition of behaviour analytic EIBI as an evidence-based therapeutic support for an appropriate cohort.

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This submission also addresses implementation and professional accountability. The NDIA has advised ABA Australia that the Scheme generally funds professions and service models rather than therapy labels in isolation. Where evidence supports behaviour analytic early intervention, the NDIS must therefore provide a coherent pathway through which appropriately qualified professionals with relevant expertise, including Certified Behaviour Analysts (CBAs), Certified Behaviour Analyst - Undergraduates (CBA-Us), and other allied health professionals able to demonstrate equivalent competence, can deliver that support within a standards-based framework. The current lack of formal recognition is increasingly difficult to justify given the NDIA has recently advised ABA Australia that behaviour analytic professionals account for approximately 5.6% of services delivered under the Other Professionals line item, while remaining without clear recognition in the Provider and Price List (PAPL) and related Scheme or NDIS Quality and Safeguards Commission documents.

1.2 Key position of ABA Australia

ABA Australia’s key position is that behaviour analytic EIBI should be assessed and understood as a defined therapeutic support area within the broader early intervention landscape. It should not be treated as synonymous with all ABA, nor grouped uncritically with other early intervention modalities that differ in theoretical framework, intervention components, delivery arrangements, and intended outcomes.

At the same time, the submission does not focus only on methodological separation. The broader issue is whether the Scheme will clearly recognise an evidence-based therapeutic option, delivered by a specialist and accountable workforce, for children for whom it is clinically indicated and appropriate. In our view, current uncertainty regarding recognition, funding pathways, line items, and workforce status is creating avoidable hardship for families, delaying access during a critical developmental window, and undermining the Scheme’s capacity to support timely, effective intervention.

The EAC should therefore assess EIBI by asking whether it demonstrates benefit for a defined cohort of young children in relation to meaningful developmental and functional goals, under identifiable implementation conditions. The evidence should be interpreted through a NDIS lens, with particular attention to communication, adaptive functioning, daily living, participation, safety, flexibility, coping, and family capability, and in a way that distinguishes clinically and functionally meaningful change from narrow or compliance-based interpretations of improvement.

If EIBI is found to be a relevant therapeutic support area, that finding should be matched by a clearer pathway for access through a professional and supervisory framework that reflects qualifications, supervision, ethics, accountability, and structured role differentiation. This includes clearer recognition of the behaviour analytic workforce, particularly CBAs and CBA-Us, within the Scheme and future PAPL arrangements. In our view, this is the most coherent way to align evidence, access, accountability, and participant benefit under the NDIS.

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1.3 Summary of recommendations

ABA Australia recommends that the EAC and NDIA take the following steps across three core areas: access and recognition, workforce and implementation, and outcomes and system improvement.

1. Recognise behaviour analytic EIBI as an evidence-based therapeutic support area for an appropriate cohort of young children, as determined through individualised assessment and clinical expertise.

2. Interpret the evidence for EIBI in relation to meaningful functional outcomes under the NDIS, including communication, adaptive functioning, daily living skills, participation, safety, and family capability.

3. Adopt an evidence framework that is rigorous, proportionate, and suitable for complex interventions already in use within the Scheme, including implementation and real-world outcomes considerations.

4. Translate any positive evidence finding for EIBI into a clear and workable access pathway under the NDIS, so that families are not forced to rely on indirect funding pathways, inconsistent planner interpretation, or lengthy review and appeal processes.

5. Formally recognise the ABA Australia behaviour analytic workforce, including CBAs and CBA-Us, within Scheme documentation and guidance relevant to the delivery of EIBI, including the competencies, supervision structures, ethical obligations, and accountability mechanisms required for safe and effective implementation.

6. Ensure that EIBI is delivered within a standards-based professional framework, supported by coherent funding, claiming, pricing, and documentation arrangements.

7. Recognise EIBI as one important evidence-based application within a broader field of behaviour analytic expertise under the NDIS, rather than as a narrowing of behaviour analytic practice to early childhood alone.

8. Strengthen routine collection and collation of intervention and outcomes data to support future evidence review, transparency, and accountability.

Overall, ABA Australia recommends an approach that links evidence recognition, functional outcomes, participant access, workforce recognition, and implementation quality. If EIBI is recognised as an evidence-based therapeutic support area for an appropriate cohort, that recognition should be matched by a clear access pathway, formal recognition of the ABA Australia workforce, and inclusion of that workforce within Scheme documentation and guidance.

2. About ABA Australia ABA Australia is the national self-regulatory body for behaviour analysts in Australia and a qualifying member of the National Alliance of Self-Regulating Health Professions (NASRHP). Our role is to support safe, ethical, and effective practice by promoting appropriate standards of education, supervision, competency, and professional conduct.

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ABA Australia represents practitioners, educators, researchers, students, and organisations committed to the evidence-based application of behaviour analysis to improve meaningful outcomes and quality of life. Our members work across early intervention, disability, education, mental health, aged care, and behaviour support, including within the NDIS.

A significant proportion of our membership provides services to NDIS participants, including autistic people, people with developmental or intellectual disability, and others requiring individualised, evidence-informed supports to build skills, increase independence, reduce risk, and enhance participation. Many are directly involved in early intervention for young children and their families, while others work across related service systems. This provides ABA Australia with direct insight into both the evidence base and the practical realities of implementation within the NDIS.

ABA Australia also plays a key role in strengthening workforce capability and professional standards across the sector, including expectations regarding competence, supervision, ethical conduct, accountability, and the delivery of services by qualified professionals and supervised staff. Our contribution to this review is therefore informed by both the research literature on EIBI and our understanding of workforce, credentialing, and implementation issues that affect service quality in practice.

We are committed to promoting safe, person-centred, and rights-based practice aligned with dignity, consent, and least restrictive principles. We recognise that service quality is as critical as the evidence base itself. Accordingly, our interest in this review extends beyond whether EIBI demonstrates benefit to the conditions required to ensure it is delivered appropriately, including individualisation, developmental appropriateness, and a focus on meaningful outcomes for children and families.

ABA Australia is therefore well placed to contribute to this consultation, bringing expertise across the evidence base for behaviour analytic intervention, workforce and credentialling frameworks, ethical safeguards, and the practical delivery of services within the NDIS.

3. The policy and funding question before the

EAC

3.1 Why this review matters

ABA Australia welcomes the opportunity to contribute to this review and supports the EAC’s role in strengthening the evidentiary basis for NDIS-funded supports. This review matters because its findings may shape whether behaviour analytic EIBI is clearly recognised within the Scheme as an evidence-based and fundable option for the children who may benefit.

For ABA Australia, the issue is not only how EIBI is classified within the review. It is also whether vulnerable children and families can access timely evidence-based support without

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unnecessary uncertainty, delay, or hardship. At present, behaviour analytic EIBI is not consistently recognised within planning and funding processes, despite a substantial evidence base and the existence of a specialist workforce with the expertise to design, oversee, and deliver it. This creates inequity in access, delays intervention during a critical developmental period, and contributes to avoidable reliance on review and ART processes.

This review therefore has significance beyond evidence interpretation alone. It is an opportunity to improve how evidence-based supports are recognised and operationalised within the NDIS in ways that affect access, guidance, and system capability.

3.2 The relationship between evidence reviews and funding architecture

ABA Australia’s contribution to this consultation is guided by the view that evidence review and funding design are closely linked. The key question is not simply whether an intervention label is recognised in isolation, but whether a support with evidence of benefit can be accessed in practice through a clear, appropriate, and accountable funding pathway.

This is particularly important in the NDIS context, where supports are generally accessed through professions, line items, operational guidance, and scheme architecture rather than through endorsement of therapy names alone. Recognition of EIBI as an evidence-based therapeutic support area is entirely compatible with this profession-based funding architecture. The relevant questions are whether EIBI demonstrates benefit for an appropriate cohort and whether the Scheme provides a competent and accountable pathway through which it can be delivered. Where evidence supports behaviour analytic early intervention for an appropriate cohort, the Scheme should provide a coherent pathway through which families can access that support without needing to navigate prolonged dispute, confusion, or inconsistent planner interpretation.

That pathway must include clear recognition of the specialist workforce required to provide behaviour analytic EIBI safely and effectively (Bayley et al., 2022; National Academies of Sciences, Engineering, and Medicine [NASEM], 2025). Without recognition of the workforce, evidence recognition alone will not resolve the current access problem. If the Scheme accepts that a support is evidence-based but does not clearly recognise the professionals qualified to design, supervise, and deliver it, families will continue to face inconsistency and delay in practice.

Framed in this way, the EAC’s work has direct policy relevance. A clear evidence finding should support clearer guidance, more consistent funding decisions, and formal recognition of the specialist workforce needed to translate evidence into accessible, high-quality care.

3.3 Why workforce recognition and support effectiveness are linked

ABA Australia considers it essential that this review address both the evidence for EIBI and the workforce required to deliver it. These issues are distinct, but inseparable in practice. Evidence of benefit is essential, but participant outcomes also depend on whether there is a defined,

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competent, and accountable workforce available to provide the support safely and effectively (Bayley et al., 2022; McKinnon et al., 2024; NASEM, 2025).

This is especially relevant for EIBI, which is often intensive, individualised, team-based, and implemented over time with caregiver involvement and structured supervision (Bayley et al., 2022; McKinnon et al., 2024). In practice, access to quality intervention depends not only on whether the model is supported by evidence, but on whether the Scheme clearly recognises the specialist workforce and delivery conditions required to provide it.

In ABA Australia’s view, clear recognition of the behaviour analytic workforce is therefore necessary, not optional. Recognition of behaviour analytic EIBI must be matched by recognition of the specialist workforce, including CBAs and CBA-Us, with the competencies to design, oversee, and deliver these supports within a framework of evidence, supervision, ethics, and accountability.

Accordingly, ABA Australia’s submission addresses both the evidence for behaviour analytic EIBI and the need for clearer workforce recognition within the Scheme.

4. How EIBI should be defined and assessed 4.1 What EIBI is

ABA Australia submits that EIBI should be assessed as a distinct therapeutic support area within the broader field of applied behaviour analysis and the wider early intervention landscape. Clear definition matters because the way EIBI is framed will shape how its evidence is interpreted and, in turn, how it is recognised within policy and funding settings.

EIBI is best understood as a comprehensive early behavioural intervention for young autistic children and other young children with developmental needs for whom this model is clinically indicated, based on the principles of applied behaviour analysis, delivered over time, and targeting multiple developmental and functional domains. It is individualised to the child’s developmental profile, needs, and family context, and may address communication, adaptive functioning, learning, social engagement, participation, and behaviours that interfere with safety or learning (NASEM, 2025; McKinnon et al., 2024). High-quality EIBI also includes caregiver involvement and capacity building (McKinnon et al., 2024; Trembath et al., 2022).

4.2 What EIBI is not

EIBI is not synonymous with applied behaviour analysis as a whole. Applied behaviour analysis is a broader field of practice grounded in behavioural science that spans ages, settings, goals, and service models. EIBI is one defined application within that broader field (NASEM, 2025).

EIBI is also not equivalent to generic intensive therapy, Positive Behaviour Support, or early intervention more broadly. While some of these approaches may share features or principles,

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they differ in purpose, structure, delivery, and intended outcomes. Treating them as interchangeable risks obscuring the evidence for the intervention actually under review (Trembath et al., 2021; Bent et al., 2024).

4.3 Why review framing matters

ABA Australia supports a review framework that assesses EIBI in relation to the cohort, goals, outcomes, and delivery conditions for which it is intended. The key policy question is not whether EIBI is universally effective in the abstract, but for which children, with which goals, and under which conditions it demonstrates meaningful benefit.

This matters because the evidence base changes depending on how EIBI is defined. Different reviews have used different inclusion criteria, and broader definitions can collapse importantly different interventions into a single category. In our view, this reduces the usefulness of the review for policy and funding decision-making.

For the NDIS, meaningful benefit should be understood in functional terms. Relevant outcomes include communication, adaptive functioning, participation, daily living skills, safety, and family capability, rather than narrow reliance on abstract score changes alone (Trembath et al., 2022; McKinnon et al., 2024).

4.4 Recommended approach to assessment

ABA Australia submits that EIBI should be assessed using a structured framework that considers:

1. participant cohort
2. age and developmental profile
3. goals targeted
4. outcome domains
5. intervention components
6. intensity and duration
7. setting
8. provider qualifications and supervision arrangements This would support a more rigorous and policy-relevant review by distinguishing EIBI from broader ABA practice, generic intensive therapy, behaviour support, and other early intervention models in scope. It would also better support conclusions that are clinically meaningful and practically useful within the Scheme. Consideration of provider qualifications and supervision arrangements is particularly important because contemporary EIBI is typically delivered through tiered staffing, structured oversight, and ongoing supervision rather than as an undifferentiated therapy model (Bayley et al., 2022; McKinnon et al., 2024; NASEM, 2025).

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4.5 Overall position

Overall, ABA Australia submits that EIBI should be assessed as a defined therapeutic support area within the broader field of applied behaviour analysis. In our view, this is the clearest and most policy-useful way to assess the evidence and its relevance to participant access, implementation, and funding decisions under the NDIS.

5. Contemporary EIBI: models, delivery, individualisation and care context

In considering contemporary EIBI, this submission is informed by the recent National Academies of Sciences, Engineering and Medicine review, together with additional literature (including from the Australian context) emphasising that intervention amount and delivery should be individualised, functionally oriented, and responsive to the child’s needs, family context, and everyday environments (Bent et al., 2024; NASEM, 2025; Trembath et al., 2021).

5.1 Contemporary models of behaviour analytic early intervention

Contemporary behaviour analytic EIBI includes a range of models and delivery arrangements tailored to the child’s developmental profile, goals, and family context. A useful distinction is between comprehensive and focused intervention. Comprehensive intervention (such as EIBI) addresses multiple developmental and functional domains and is typically used where a child requires coordinated support across areas such as communication, adaptive behaviour, social engagement, learning, and behaviours that interfere with participation or safety. Focused intervention targets a smaller number of specific goals, such as communication, self-care, safety, or other barriers to participation. This distinction is clinically important because it reflects the reality that early intervention must be matched to individual need rather than assumed to follow a single uniform model (NASEM, 2025).

5.2 Goals, intensity, and individualisation

Contemporary behaviour analytic early intervention is broader in its aims than is sometimes assumed. Goals are selected on the basis of the child’s developmental profile, practical barriers in daily life, and the priorities of the child and family. These may include communication, adaptive behaviour, self-care, participation in routines, social engagement, emotional and behavioural regulation, flexibility, safety, learning readiness, and reduction of barriers that interfere with functioning across home, preschool, school, or community settings. Caregiver capability may also be an important target, particularly where involving and upskilling parents is likely to strengthen consistency, generalisation, and progress across everyday settings, provided this is appropriate to the family’s context (McKinnon et al., 2024; NASEM, 2025).

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ABA Australia submits that intensity should not be treated as a proxy for quality or appropriateness. In the context of EIBI, the more relevant question is what form, amount, and configuration of support is required to achieve meaningful functional outcomes for a particular child. The literature supports the view that EIBI is generally comprehensive, delivered over time, and often substantial in intensity. At the same time, it does not support reducing intervention to a single fixed hourly threshold or assuming that more hours are always preferable irrespective of the child’s developmental profile, goals, family context, or implementation conditions. Recent literature also highlights that recommendations about intervention amount should be individualised and grounded in what is scientifically plausible, practical to deliver, desired by the child and family, and defensible in light of likely benefits and burdens (Trembath et al., 2021; NASEM, 2025).

In ABA Australia’s view, decisions about intensity, dosage, and configuration should be guided by appropriate clinical and developmental assessment, made by a qualified treating professional with relevant expertise in behaviour analytic early intervention, and determined in collaboration with the child’s family. For some children, a comprehensive and higher-frequency model may be clinically appropriate. For others, a more focused, consultative, preschool-embedded, or caregiver-supported model may be more suitable. This flexibility does not detract from the evidence base for EIBI. Rather, it reflects the reality that evidence-based early intervention must be individualised in both design and implementation (Bent et al., 2024; Trembath et al., 2021).

5.3 Delivery across settings and everyday contexts

Contemporary behaviour analytic early intervention should not be understood as clinic-bound or limited to a single delivery format. In practice, intervention may be delivered across home, clinic, preschool, school, community, and hybrid settings, depending on the child’s goals, the contexts in which those goals are most relevant, and the arrangements most likely to support generalisation and sustained functional benefit. Intervention may include direct work with the child, caregiver coaching, environmental adaptation, team consultation, or shared implementation across settings (McKinnon et al., 2024; Wood et al., 2018).

Recognising this diversity is important both clinically and for policy. It helps avoid the misconception that evidence-based early intervention is defined by a traditional one-to-one clinic model and supports a more accurate understanding of how meaningful gains are achieved in everyday life. In the NDIS context, outcomes such as communication, routines, self-care, safety, flexibility, and participation are meaningful only if they improve functioning across the settings in which children actually live, learn, and engage.

5.4 Multidisciplinary care and behaviour analytic expertise

Recognition of behaviour analytic expertise within the NDIS should not be understood as implying siloed, exclusive, or duplicative service delivery. Rather, it should support clearer role delineation within coordinated care arrangements for children whose needs, goals, and response to intervention indicate that behaviour analytic early intervention is clinically relevant. A profession-based funding architecture does not require profession-based isolation. On the

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contrary, clearer recognition of behaviour analytic expertise would support more coherent care planning by clarifying when this form of intervention is indicated, what goals it is appropriately directed towards, and who is qualified to design, oversee, and deliver it.

This is especially important in early intervention, where meaningful outcomes often depend on coordinated planning across home, educational, and community environments, with different professionals contributing within their respective areas of expertise. Clear recognition of behaviour analytic expertise is therefore compatible with multidisciplinary and family-centred care, and may strengthen it by improving accountability, role clarity, and implementation quality (Bayley et al., 2022; McKinnon et al., 2024; NASEM, 2025; Trembath et al., 2022).

5.5 Overall position

Overall, ABA Australia submits that contemporary EIBI should be understood as flexible, individualised, and responsive to developmental need and context. Its goals should be functionally meaningful, its intensity matched to participant need, and its delivery compatible with coordinated care across home, educational, clinical, and community settings, by qualified professionals. In our view, this is the most accurate and policy-relevant way to understand EIBI in the context of contemporary early intervention under the NDIS.

6. Why access to evidence-based EIBI matters under the NDIS

Access to evidence-based EIBI matters under the NDIS because, for an appropriate cohort of young children, it has the potential to improve foundational areas of functioning that shape everyday life, participation, safety, and longer-term support needs (Eldevik, 2026; Peters Scheffer et al., 2011). The key question is not whether a therapy label or modality should be endorsed in the abstract, but whether a defined early intervention support, delivered by a qualified workforce, can help children and families achieve meaningful outcomes in daily life.

6.1 Participant and family benefit

ABA Australia submits that access to EIBI matters because it is directed towards capabilities that affect how children function across home, early learning, and community settings. Across the literature, the clearest overall picture is one of meaningful benefit in areas such as communication, adaptive functioning, learning, participation, safety, and reduction of barriers that interfere with everyday life (Eldevik, 2026; Frazier et al., 2021; Wood et al., 2018). For children and families, these outcomes mean a greater ability to communicate needs, participate in routines, engage in learning, and navigate daily life with less distress and risk.

These gains matter not only because they influence longer-term trajectories, but because they support inclusion, dignity, safety, and everyday quality of life in the present. Where support is

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well designed, it may also strengthen caregiver capability, reduce daily stressors, and improve the family’s capacity to support the child across settings. This is particularly relevant under the NDIS, where meaningful outcomes are best understood in functional terms and in relation to real-world participation and family life.

6.2 Timely access and longer-term implications

Timely access matters because the preschool period is one in which foundational communication, adaptive, learning, and self-regulation capacities are still emerging. Where barriers in these areas are addressed early and effectively, children may be better supported to build skills that promote participation, independence, safety, and engagement across settings. Where access is delayed, children and families may miss an important developmental window, and the burden of that delay is borne in everyday life (Frazier et al., 2021).

This point also has practical significance in the current policy context. Where families face uncertainty, delay, or the need to pursue review and appeal processes before accessing EIBI, the cost is not merely administrative. It is experienced by children and families during a developmentally important period in which time matters, family burden may increase, and opportunities for earlier skill development may be lost.

6.3 Economic and Scheme relevance

This issue is also directly relevant to the Scheme as a matter of sound policy, stewardship, and the efficient use of public resources. In addition to its clinical and functional importance, there is a growing body of economic literature suggesting that, for an appropriate cohort of children, timely access to intensive early intervention may generate meaningful longer-term cost offsets and broader social and economic benefit (Chasson et al., 2007; Jacobson et al., 1998; Peters Scheffer et al., 2012; Tsiplova & Ungar, 2023). Australian modelling has also suggested a positive return on investment, including projected reductions in future NDIS expenditure and broader gains in quality of life and functional outcomes (Synergies Economic Consulting, 2023).

In ABA Australia’s view, timely access to evidence-based EIBI is therefore of critical importance under the NDIS for the children for whom it is clinically appropriate. EIBI targets foundational areas of development that influence communication, learning, participation, safety, independence, and family functioning during a period in which support may be especially consequential. Where access is delayed, made uncertain, or denied, the cost is borne first and most significantly by children and families in everyday life. It may also increase longer-term demand on the Scheme and other service systems by allowing avoidable support needs to become more entrenched. The Scheme should therefore ensure that children who may benefit are able to access high-quality EIBI without avoidable delay, confusion, or inconsistency, both because this is important for participant outcomes and because early, effective support is likely to represent better long-term stewardship of public resources.

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7. A recommended evidence framework for the

EAC

ABA Australia supports an evidence framework that is rigorous, structured, and relevant to the decisions the EAC is being asked to inform. The central question is not whether a therapy label should be endorsed or rejected in the abstract, but whether a defined therapeutic support area demonstrates meaningful benefit for an appropriate cohort, in relation to relevant goals and outcomes, and can be delivered within a clear, competent, and accountable professional framework.

This is particularly important in the present review, where the consultation scope includes multiple early intervention models that differ in theoretical basis, components, intensity, delivery arrangements, and intended outcomes. A broad or undifferentiated review approach risks producing conclusions that reflect heterogeneity rather than the strength or limitations of the evidence for the support actually under consideration. ABA Australia therefore submits that the EAC should adopt a framework that considers participant benefit, implementation quality, and delivery capability together.

7.1 What should count as evidence

ABA Australia supports an evidence framework that draws on multiple forms of relevant evidence. Systematic reviews and meta-analyses should provide the foundation, supported by empirically rigorous group and single-case experimental designs where appropriate. However, the EAC should avoid an unnecessarily narrow conception of evidence that excludes forms of inquiry commonly relied upon in the evaluation of complex, individualised interventions. In the context of EIBI, this may include high-quality single-case experimental evidence, implementation and effectiveness studies, and real-world outcomes data where intervention definitions and outcome measures are sufficiently clear.

Professional standards, consensus guidance, and evidence relating to implementation requirements are also relevant to the EAC’s task. These sources are not substitutes for outcome evidence, but they are important in determining whether an intervention can be delivered safely, ethically, and with sufficient fidelity to justify participant access under the NDIS (Trembath et al., 2022; Bayley et al., 2022).

7.2 Evidence should be considered in context

In ABA Australia’s view, an evidence framework that considers interventions in relation to the cohort, goals, and delivery conditions for which they are intended is more useful than asking whether an intervention is universally effective or ineffective across all populations and contexts. Conclusions should therefore be tied to the cohort, goals, and delivery conditions for which the intervention is intended (Trembath et al., 2023). For EIBI, this means considering the evidence in relation to young children with developmental needs for whom the model is clinically indicated, the developmental and functional domains the intervention is intended to address,

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and the conditions under which it is actually delivered (NASEM, 2025; Trembath et al., 2022, 2023).

ABA Australia acknowledges that much of the EIBI evidence base has been developed internationally, with Australian-specific research continuing to emerge. However, this does not diminish its relevance. Where intervention models, participant characteristics, and outcome measures are sufficiently aligned, international evidence can still be highly relevant to the current review. Continued development of Australian research and outcomes data is important, but should not be a barrier to recognising an established and relevant evidence base.

7.3 Functional and clinically meaningful outcomes

ABA Australia considers it essential that the EAC distinguish between statistical significance and outcomes that are clinically and functionally meaningful under the NDIS. The key question is not simply whether an intervention produces measurable change on a standardised instrument, but whether it assists participants to achieve outcomes that matter in daily life (Eldevik, 2026; Trembath et al., 2022).

For EIBI, these outcomes may include communication, adaptive functioning, participation, self care, safety, learning readiness, and reduction of barriers that interfere with inclusion and wellbeing. Functional significance should be understood in terms of increased capability, reduced barriers to participation, greater independence, improved safety, and better quality of life for children and families (Eldevik, 2026; McKinnon et al., 2024; Trembath et al., 2022).

7.4 Implementation and delivery capability

ABA Australia submits that the EAC should assess not only whether a support area has evidence of benefit, but also whether it can be delivered safely, competently, and accountably. This is particularly important for EIBI, where outcomes depend not only on the existence of an evidence base, but on the presence of an appropriately qualified workforce, clear role delineation, adequate supervision, ethical safeguards, and attention to quality (Bayley et al., 2022; McKinnon et al., 2024; NASEM, 2025). Importantly, this workforce already exists within ABA Australia’s membership base in the form of CBAs and CBA-Us and is continuing to grow as Australian universities now offer formal qualifications in behaviour analytic coursework.

The evidence for EIBI is not evidence for generic support delivery in the abstract. It is evidence for intervention delivered under particular conditions, including competent assessment, individualised goal selection, data-based decision making, and appropriate clinical oversight. If those conditions are absent, there is a risk that the support being delivered no longer reflects the intervention for which evidence of benefit is claimed.

7.5 How evidence gaps should be handled

ABA Australia recognises that the evidence base for EIBI, like many areas of disability and early intervention, is not without limitations. These should be acknowledged directly. However,

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evidence gaps should not be handled in a way that collapses a relevant support area into blanket uncertainty or exclusion.

In our view, the appropriate response is a transparent and proportionate framework that weighs the available evidence, identifies where confidence is stronger or weaker, and makes explicit how uncertainty will be managed. This may include specifying the cohort and goals for which evidence is strongest, identifying where implementation safeguards are especially important, recommending improved routine outcomes collection, and supporting ongoing review as better evidence becomes available.

7.6 Overall position

Overall, ABA Australia recommends an evidence framework that is rigorous, transparent, and practically relevant to participant access and Scheme decision-making. For EIBI, this means considering not only whether evidence of benefit exists, but for whom, for which goals, and under what implementation conditions. In our view, that is the most useful way for the EAC to assess a support area that is clinically important and highly consequential for children, families, and the specialist workforce available to deliver it.

8. Summary of the evidence for behaviour analytic EIBI and its functional relevance under the NDIS

ABA Australia submits that the evidence for EIBI is best understood by the EAC with reference to the domains of functioning it is intended to affect and the practical significance of those outcomes under the NDIS. Across the literature, the overall pattern is one of positive effects in several important domains for an appropriate cohort of young children, particularly in adaptive functioning and intellectual functioning, with additional positive findings in communication and language and broader relevance to participation, safety, and family capability (Eldevik et al., 2026; NASEM, 2025; Peters-Scheffer et al., 2011; Reichow et al., 2012). For the EAC, the key question is not whether EIBI changes abstract scores alone, but whether it supports gains that matter in everyday life, including communication, adaptive functioning, participation, safety, and quality of life for children and families.

8.1 Communication and language outcomes

Communication and language are among the most important outcome domains in the EIBI literature and among the most relevant under the NDIS because they are closely tied to participation, learning, safety, and everyday functioning. Across the evidence base, findings in this domain are generally positive, although less consistent and less robust than those reported for adaptive behaviour and cognitive outcomes (NASEM, 2025). Meta-analytic and review

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literature has reported positive effects for receptive and expressive language, as well as broader communication-related outcomes, although effect estimates vary across reviews depending on how EIBI is defined and which studies are included (Peters-Scheffer et al., 2011; Reichow et al., 2012; Wood et al., 2018).

Under the NDIS, this is a domain of clear functional importance. Improvements in communication affect a child’s capacity to express needs and preferences, request help, reduce distress associated with being misunderstood, engage in routines, access learning opportunities, and participate more effectively in family and community life. ABA Australia therefore considers communication and language outcomes to be central to the relevance of EIBI under the Scheme.

8.2 Social communication, interaction, and participation

The evidence also supports social communication and interaction as relevant outcome domains for EIBI, although the strength of evidence is somewhat more variable than for adaptive and cognitive outcomes. The National Academies report identifies positive findings in communication and related domains within the broader literature on comprehensive ABA-based intervention, while also noting that the evidence is not equally strong across all outcomes (NASEM, 2025). More broadly, the goals of comprehensive early behavioural intervention commonly include social engagement, joint activity, responsiveness to others, and participation in reciprocal interaction, even where these outcomes are measured in different ways across studies (Peters-Scheffer et al., 2011).

For the NDIS, the importance of this domain lies in whether intervention helps a child engage more meaningfully and successfully in everyday social contexts. Social communication difficulties often affect access to preschool, family routines, peer interaction, and broader participation. The practical relevance of EIBI is therefore not in narrow or compliance-based notions of social change, but in whether it supports greater access to relationships, play, learning, and community life (Trembath et al., 2022).

8.3 Adaptive functioning and daily living skills

Adaptive functioning is one of the strongest and most consistent outcome domains in the EIBI literature. The National Academies report concluded that the evidence for comprehensive ABA programs shows replicated positive outcomes in adaptive behaviour for autistic children aged approximately two to nine years and characterised this as one of the clearest areas of benefit in the literature (NASEM, 2025). The recent individual participant data meta-analysis by Eldevik et al. (2026) also reported positive effects in adaptive behaviour, alongside evidence of clinically significant change for a greater proportion of children receiving EIBI. Earlier meta-analytic work similarly found positive effects for adaptive behaviour and related domains, including communication and daily living skills within adaptive functioning measures (Peters-Scheffer et al., 2011; Reichow et al., 2012; Wood et al., 2018).

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This is one of the clearest areas of NDIS relevance because adaptive functioning is closely aligned with the outcomes the Scheme is intended to support. These include self-care, participation in routines, independence in everyday tasks, safety-related skills, and reduced reliance on others for basic daily activities. ABA Australia considers adaptive functioning to be one of the strongest parts of the evidence case for EIBI and one of the clearest reasons it warrants recognition as an evidence-based therapeutic support area.

8.4 Learning readiness and engagement in everyday environments

Although learning readiness and participation are not always isolated as stand-alone outcome categories in the review literature, they are strongly implicated in the domains EIBI is designed to address. Comprehensive early behavioural intervention typically targets foundational capabilities that affect whether a child can engage with teaching, tolerate structured activity, benefit from preschool or school environments, and participate more successfully in family and community routines (McKinnon et al., 2024; Peters-Scheffer et al., 2011). The National Academies report also recognises that ABA-based intervention may validly target communication, adaptive skills, daily functioning, and behaviours that interfere with learning and participation (NASEM, 2025).

For NDIS purposes, this is highly significant. In many cases, the practical value of EIBI lies not in isolated changes on formal assessments, but in helping a child become more available for learning, more able to participate in routines and early education, and less restricted by barriers that interfere with inclusion. ABA Australia considers these outcomes central to the functional relevance of EIBI under the Scheme.

8.5 Reduction of barriers to learning, participation, and safety

The literature also supports the relevance of EIBI where behaviours interfere with learning, participation, safety, or access to everyday environments. The National Academies report identifies the reduction and replacement of harmful or interfering behaviours as a legitimate treatment target within ABA-based intervention and notes that behavioural techniques are particularly relevant where maladaptive behaviour disrupts the implementation of a broader comprehensive program (NASEM, 2025). More broadly, comprehensive early behavioural intervention is commonly described as addressing not only skill acquisition, but also behaviours that create barriers to functioning and inclusion (Peters-Scheffer et al., 2011).

This domain is highly relevant to the NDIS, particularly where early intervention may reduce barriers before patterns become more entrenched or more likely to require reactive or restrictive responses. ABA Australia’s position is not that all young autistic children require intervention for behaviours of concern, nor that behaviour reduction should be privileged over quality of life or skill development. It is that where behaviours interfere with communication, safety, learning, or participation, EIBI may be highly relevant as part of a broader developmental and functional intervention approach.

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8.6 Family and caregiver outcomes

The literature also supports the importance of family and caregiver outcomes, although this area is generally less well developed than child-level clinical outcomes. The National Academies report recognises that treatment plans may appropriately include parent and caregiver goals and that intervention should be individualised to the needs and preferences of the child and family (NASEM, 2025). More broadly, EIBI has long been described as involving caregiver participation in ways intended to support generalisation and maintenance across everyday contexts (Peters-Scheffer et al., 2011). Australian guidance also emphasises family wellbeing, preferences, and feasibility as relevant considerations in early intervention planning (Trembath et al., 2022).

At the same time, the broader literature cautions that family involvement should not be treated as burden-free or uniformly feasible. Economic and methodological analyses in autism intervention have highlighted the importance of caregiver spillover effects, family capacity, and the need to consider outcomes that matter to families alongside child-level measures (Tsiplova & Ungar, 2023). In ABA Australia’s view, this supports an approach to EIBI that is family centred, but also realistic and sustainable. Family and caregiver outcomes are relevant not only because they matter in their own right, but because they often influence whether gains for the child can be supported and maintained over time.

8.7 Generalisation and maintenance of gains

Generalisation and maintenance are especially important in evaluating EIBI because the practical value of early intervention depends not only on whether gains occur during treatment, but on whether they extend into everyday settings and endure beyond the intervention period. The conceptual literature on EIBI has long emphasised the importance of generalisation across people, settings, and routines, with parental participation often described as important to this process (Peters-Scheffer et al., 2011; Wood et al., 2018). Long-term outcome evidence remains more limited than short-term evidence, but it is not absent. Smith et al. (2021) reported that gains in cognitive and adaptive standard scores achieved during two years of EIBI were maintained at follow-up approximately 10 years later, with a significant reduction in autism symptoms also reported.

For the NDIS, this matters because the value of early intervention lies in whether gains translate into improved day-to-day functioning over time and across contexts, not merely in whether change is observed during a treatment period. ABA Australia therefore considers the evidence on maintenance to be promising and relevant, particularly as support for the proposition that meaningful gains achieved through EIBI can extend beyond immediate intervention contexts.

8.8 Overall position

Taken as a whole, the literature supports the conclusion that EIBI is a relevant and important therapeutic support area for young autistic children when assessed in relation to the developmental and functional domains it is intended to address. The strongest and most

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consistent evidence relates to adaptive functioning and cognitive outcomes, with additional positive evidence in communication and related domains, and a broader rationale for its relevance to participation, safety, and reduction of barriers that interfere with learning and inclusion (Eldevik et al., 2026; NASEM, 2025; Peters-Scheffer et al., 2011; Reichow et al., 2012).

ABA Australia therefore submits that EIBI should be recognised by the EAC as an evidence based therapeutic support area of clear functional relevance under the NDIS. Its significance lies not in score change alone, but in its capacity to strengthen communication, adaptive functioning, participation, safety, and family capability in ways that matter in everyday life for young children and their families.

9. Ethical, person-centred, and professionally accountable EIBI

Ethical, person-centred, and professionally accountable practice is central to both EIBI and the evidence that supports it. The issue before the EAC is not only whether EIBI is effective, but whether it can be delivered under conditions that protect children and families and reflect contemporary standards of safe, respectful, high-quality care.

Concerns raised by some autistic people, families, and advocates about harmful, coercive, or poor-quality applications of ABA should be taken seriously. In the context of EIBI, those concerns reinforce the importance of clear safeguards, qualified provision, meaningful family involvement, and strong accountability. They do not weigh against recognising EIBI. Rather, they highlight why EIBI should be understood and implemented within a framework that emphasises participant dignity, developmental appropriateness, quality of life, and professional oversight.

Contemporary EIBI should be individualised, responsive to assent and preferences, focused on meaningful skills and quality of life, and delivered within clear ethical, professional, and supervisory safeguards (Bayley et al., 2022; McKinnon et al., 2024; Rajaraman et al., 2022). Contemporary literature also supports the view that behaviour analytic practice should continue to evolve in response to evidence, ethical reflection, and the lived experiences of autistic people and families, rather than being understood as fixed or defined by earlier applications alone. This is consistent with the National Academies report, the trauma-informed ABA literature, and recent commentary on reform and progression in the field, which emphasise individualised goals, family-centred planning, qualified provision, safety, trust, choice, shared governance, and skill building over intrusive, rigid, or potentially harmful practices (ABA Australia, 2022; Johnson, 2025; Leaf et al., 2016; NASEM, 2025; Rajaraman et al., 2022).

9.1 Ethical practice principles

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ABA Australia’s Code of Ethical Practice provides an explicit framework for behaviour analytic practice in Australia, grounded in beneficence, non-maleficence, autonomy, justice, competence, accountability, collaboration, transparency, and equality (ABA Australia, 2022). It also sets clear expectations regarding informed consent, privacy, competence, billing, supervision, complaints handling, and responsible assessment and intervention (ABA Australia, 2022).

For EIBI, these standards are directly relevant. Ethically sound early intervention requires appropriate assessment, meaningful goal selection, ongoing data-based review, clear communication with families, responsiveness to the child’s wellbeing and dignity, and recognition of the limits of practitioner competence (NASEM, 2025). Rajaraman et al. (2022) reinforce this by highlighting the importance of safety, trust, choice, shared governance, and skill building in trauma-informed practice. These principles are central to contemporary applications of EIBI.

9.2 Person-centred and family-centred planning

EIBI should be person-centred and family-centred in both design and delivery. Intervention should be based on the child’s developmental profile, strengths, support needs, communication style, and everyday context, and should be planned in meaningful collaboration with the family. The National Academies report is clear that treatment goals should be individualised to the strengths, needs, and preferences of the child and family, and may appropriately include parent and caregiver goals (NASEM, 2025; Trembath et al., 2022).

This also requires close attention to the child’s experience of intervention. Ethical practice requires monitoring of assent, withdrawal, avoidance, distress, and other indicators that a child may not be experiencing intervention as safe or tolerable, and adjusting intervention accordingly (Rajaraman et al., 2022; Trembath et al., 2022). Recent reform-oriented literature also highlights the importance of ensuring that intervention goals and outcomes are not defined solely by neurotypical expectations, but are directed towards outcomes that respect the autonomy, individuality, and lived experience of autistic children (Johnson, 2025). Caregiver involvement is important, but it must be realistic, sustainable, and matched to family capacity rather than assumed to be neutral or burden-free (NASEM, 2025; Trembath et al., 2022).

9.3 Quality of life and meaningful outcomes

EIBI should be directed towards quality of life and meaningful outcomes, not behaviour change in the abstract. ABA Australia’s Code of Ethical Practice states that successful ABA is not mainly about reduction of behaviour of concern, but about enhancement of quality of life and acquisition of important skills (ABA Australia, 2022).

In practice, this means EIBI goals should target outcomes that matter in everyday life, including communication, adaptive functioning, participation, safety, emotional and behavioural coping, and reduction of barriers that interfere with inclusion and wellbeing. Meaningful outcomes are those that increase capability, reduce distress, strengthen safety, support self-expression, and

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improve daily functioning for the child and family (Eldevik, 2026; Trembath et al., 2022). This is also consistent with more recent calls for neurodivergent-affirming and assent-based practice, in which socially valid outcomes are defined not by conformity for its own sake, but by whether intervention improves the person’s ability to engage in everyday life with dignity, authenticity, and support (Johnson, 2025).

9.4 Safeguards, workforce accountability, and implementation quality

The evidence for EIBI is not evidence for generic service delivery by an undefined workforce. It is evidence for intervention delivered under conditions that include competent assessment, individualised planning, skilled supervision, family collaboration, and ongoing clinical oversight (Bayley et al., 2022; McKinnon et al., 2024; NASEM, 2025). If those conditions are absent, the support being delivered no longer reflects the intervention for which evidence of benefit is claimed.

For this reason, safeguards matter at more than one level. The NDIS Rules and oversight by the NDIS Quality and Safeguards Commission provide an important baseline layer of protection for children and families receiving supports under the Scheme. In the context of EIBI, however, this baseline is strengthened considerably when accompanied by clear professional standards, defined competencies, structured supervision, and ongoing accountability within a recognised professional framework.

That additional layer exists within the behaviour analytic workforce represented by ABA Australia, including Certified Behaviour Analysts (CBAs) and Certified Behaviour Analyst Undergraduates (CBA-Us). These practitioners sit within defined training and supervision pathways, are subject to continuing professional development requirements, practise in accordance with ABA Australia’s Code of Ethical Practice and are subject to formal ethical and disciplinary review where complaints are raised. While some aspects of EIBI may be implemented by supervised team members (allied health assistants or behaviour technicians), responsibility for assessment, case formulation, treatment planning, clinical review, supervision, and significant treatment decisions should remain with appropriately qualified professionals with relevant expertise (Bayley et al., 2022; McKinnon et al., 2024; Trembath et al., 2022). In the Australian context, the professionals best suited to provide evidence-based EIBI are CBAs and CBA-Us. This tiered workforce is also continuing to grow as Australian universities begin to offer and expand formal qualifications in behaviour analytic coursework.

In the context of EIBI, this matters because participant protection depends not only on external regulation, but on whether the professionals designing, overseeing, and delivering the intervention are accountable to clear standards of competence, ethics, and supervision. Stronger alignment between Scheme safeguards and professional oversight would better protect children and families while supporting consistent, high-quality implementation.

ABA Australia’s professional framework, including its Code of Ethical Practice and information regarding education, certification, and supervision standards, is publicly available on the

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Association’s website, supporting transparency regarding the expectations and safeguards that apply to this workforce.

9.5 Overall position

Contemporary EIBI depends on strong ethical standards, person-centred planning, and clear professional accountability. The protections available through the NDIS Rules and Commission oversight are an important foundation, but they are strengthened considerably when complemented by an additional layer of professional oversight, competency standards, supervision, and ethical accountability.

In ABA Australia’s view, this layered approach is especially important for a vulnerable population receiving intervention during a developmentally significant period. EIBI should therefore be understood not only as an evidence-based therapeutic support, but as one that must be delivered within a framework that protects dignity, supports family-centred care, and promotes high standards of implementation. The professional oversight and accountability provided through ABA Australia’s workforce framework, including CBAs and CBA-Us, is an important part of that safeguard structure.

10. Current system gaps and the risks of non- recognition

The current position under the NDIS is marked by significant practical ambiguity in relation to behaviour analytic services. Behaviour analytic early intervention is already being delivered within the Scheme, and practitioners are already operating within existing funding arrangements. However, there remains no clear or consistent framework for how this area of practice is formally recognised, how it should be accessed, or how the relevant workforce should be understood within the Scheme’s profession-based architecture.

This is not simply an administrative issue. It creates a material gap between evidence, implementation, and participant access. Where the system does not clearly recognise when EIBI is indicated, what expertise it requires, and how it should be accessed, evidence-based intervention is left without a reliable pathway. As a result, access becomes inconsistent, delayed, and dependent on local interpretation rather than evidence and participant need.

10.1 Existing service reality under the NDIS

Behaviour analytic services are already being delivered across therapeutic supports, early intervention, behaviour support, and multidisciplinary disability services. This reflects both participant need and the presence of a skilled workforce contributing to the Scheme, even in the absence of clear and consistent recognition.

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The issue, therefore, is not whether behaviour analytic intervention exists in practice. It is whether the Scheme provides sufficient clarity about when it is appropriate, how it should be accessed, what expertise is required, and what standards and accountability structures apply. Without that clarity, access to EIBI where clinically indicated remains inconsistent and, in many cases, contingent on families navigating complex and indirect pathways.

10.2 Claiming and pricing ambiguity

Current arrangements require behaviour analytic services to be delivered through multiple, often indirect, line items. This reduces transparency about what services are being delivered and by whom, and creates inconsistency in how supports are classified, priced, and accessed.

In practice, this contributes to avoidable complexity for both providers and families. Where EIBI is clinically indicated, access should not depend on whether practitioners can align services to ill-fitting categories or whether families are able to pursue review or appeal processes to secure appropriate funding. Clearer recognition of the value of EIBI, together with formal recognition of the ABA Australia behaviour analytic workforce, including CBAs and CBA-Us, would support more consistent, transparent, and equitable access.

10.3 Recognition and workforce pathway gaps

The absence of clear recognition also limits the further development of a visible, accountable, and standards-based workforce pathway. Where funding and registration structures are tied to recognised professions, but behaviour analytic expertise is not clearly defined within those structures, there is ongoing uncertainty about practitioner roles, qualifications, and accountability.

This matters directly for EIBI, where outcomes depend on who is designing, overseeing, and delivering intervention. The Scheme should be able to clearly identify the competencies required, the professionals responsible, and the standards under which this work is delivered. At present, that clarity does not exist. Formal recognition of ABA Australia’s certified workforce, including CBAs and CBA-Us, would provide a practical and standards-based solution to that problem.

Importantly, this issue is not confined to early intervention. Behaviour analytic practitioners contribute across the lifespan to capacity-building supports under the NDIS, including communication, adaptive functioning, skill acquisition, participation, and reduction of barriers to everyday life. Recognition of EIBI should therefore be framed as recognition of one important evidence-based application within a broader field of behaviour analytic expertise, not as a narrowing of that expertise to early childhood.

10.4 Risks for participants and the Scheme

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Leaving the current system unchanged or further restricting funding pathways and funding levels for children with autism and developmental delay or disability who would benefit from EIBI, carries serious and immediate risks for participants.

Information received by ABA Australia from members, families accessing services, organisations, and disability advocates indicates that, while overall Scheme expenditure has increased considerably and beyond budget expectations, early intervention funding has continued to tighten. At the same time, planners and the NDIA are increasingly resisting adequate funding for EIBI where it is clinically indicated. As a result, many families are being forced into lengthy, exhausting, and avoidable review processes in order to access a strongly evidence-based support. Although these reviews are frequently resolved in favour of EIBI funding, the current system still creates substantial barriers to timely and equitable access.

This creates a significant risk in the current landscape. Access to EIBI is becoming increasingly inconsistent and increasingly dependent on variable planner interpretation, provider structure, or a family’s capacity to endure review and appeal processes, rather than on participant need and evidence-based decision-making. This delays intervention during a developmentally critical period, increases family burden, and places timely access to effective support further out of reach. Any further narrowing of funding pathways or reductions in available funding for children who would benefit from EIBI would intensify that risk.

The risks extend beyond access alone. A lack of clear recognition reduces transparency, weakens professional role clarity, and creates ongoing confusion in claiming, pricing, and accountability. It also distorts workforce development, as a skilled and growing workforce continues to operate without clear and consistent recognition. This creates a real risk of workforce attrition and undermines the Scheme’s capacity to sustainably provide evidence based supports where they are needed.

Most importantly, the current system leaves a direct disconnect between evidence and implementation. If EIBI is recognised as an evidence-based therapeutic support area, but families still cannot reliably access it through a clear pathway delivered by appropriately qualified professionals, then the practical value of that recognition is substantially undermined. That disconnect will persist unless recognition of EIBI is matched by formal recognition of the ABA Australia workforce, including CBAs and CBA-Us, and clearer inclusion of that workforce in Scheme documentation and implementation pathways.

10.5 Overall position

The current lack of clarity surrounding behaviour analytic services under the NDIS is a material policy issue. It affects access, consistency, transparency, workforce development, and alignment between evidence and implementation.

If EIBI is recognised as an evidence-based therapeutic support area for an appropriate cohort, this must be accompanied by a clear and workable implementation pathway. That pathway should include formal recognition of the ABA Australia behaviour analytic workforce, including

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CBAs and CBA-Us, and clear inclusion of that workforce in Scheme documentation and guidance so that competencies, supervision structures, and accountability requirements are transparent and enforceable.

At the same time, this should sit within a broader understanding of behaviour analysis as a discipline that contributes across the lifespan and across capacity-building domains under the NDIS. Recognition of EIBI should therefore operate as recognition of one important evidence based application within a broader field of behaviour analytic expertise, not as a narrowing of that expertise to early childhood alone.

In ABA Australia’s view, clearer recognition of EIBI, together with formal recognition of the ABA Australia workforce and its role within the Scheme, is necessary to align evidence, participant access, and implementation quality.

11. Recommendations to the EAC and NDIA ABA Australia submits that the current review should result not only in a clear assessment of the evidence for EIBI, but in a practical response to the access, implementation, and workforce problems currently affecting children, families, and providers under the NDIS. We recommend that the EAC and NDIA:

12. Recognise behaviour analytic EIBI as an evidence-based therapeutic support area for an appropriate cohort of young autistic children, as determined through individualised assessment and clinical expertise.

This should include clear differentiation of EIBI from other conceptually distinct early intervention models included in the review, and assessment of EIBI in relation to the cohort, goals, outcomes, and implementation conditions for which it is intended.

2. Interpret the evidence for EIBI in relation to meaningful functional outcomes under the NDIS.

Assessment should focus on outcomes that matter in everyday life, including communication, adaptive functioning, daily living skills, participation, safety, flexibility, coping, and family capability, rather than abstract score change alone.

3. Adopt an evidence framework that is rigorous, proportionate, and suitable for complex interventions already in use within the Scheme.

This should draw on systematic reviews and meta-analyses, supported by empirically rigorous group and single-case experimental designs where appropriate, together with implementation, effectiveness, and real-world outcomes data where relevant. Where the evidence base is less developed, uncertainty should be managed transparently and proportionately, rather than through blanket exclusion.

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4. Ensure that any positive evidence finding for EIBI is translated into a clear and workable access pathway under the NDIS.

Families should not have to rely on indirect line items, inconsistent planner interpretation, or lengthy review and appeal processes in order to access a strongly evidence-based support where it is clinically indicated.

5. Formally recognise the ABA Australia behaviour analytic workforce, including

Certified Behaviour Analysts (CBAs) and Certified Behaviour Analyst -

Undergraduates (CBA-Us), within Scheme documentation and guidance relevant to the delivery of EIBI.

This should include recognition of the competencies, supervision structures, ethical obligations, and accountability mechanisms required for safe and effective delivery.

6. Recognise that EIBI should be delivered within a standards-based professional framework, not as a generic therapy label or undefined service model.

Where EIBI is clinically indicated, the funding and implementation framework should support access to appropriately qualified professionals with relevant expertise, including behaviour analysts and, where appropriate, other allied health professionals able to demonstrate equivalent competence in behaviour analytic early intervention.

7. Review claiming, pricing, and documentation arrangements so that behaviour analytic services are no longer forced through ill-fitting or opaque pathways.

Clearer classification and documentation would improve transparency, consistency, participant access, workforce visibility, and accountability across the Scheme.

8. Recognise EIBI as one important evidence-based application within a broader field of behaviour analytic expertise under the NDIS.

Recognition of EIBI should not narrow the role of behaviour analytic practitioners to early childhood alone. Behaviour analysts contribute across the lifespan to capacity-building supports including communication, adaptive functioning, skill acquisition, participation, and reduction of barriers to everyday life.

9. Strengthen routine collection and collation of intervention and outcomes data for behaviour analytic and other therapeutic supports.

This would improve future evidence review, transparency, and understanding of which supports are producing meaningful benefit, for whom, and under what conditions.

Overall, ABA Australia recommends that the EAC and NDIA adopt an approach that links evidence recognition, functional outcomes, participant access, and implementation quality. If EIBI is recognised as an evidence-based therapeutic support area for an appropriate cohort,

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that recognition should be matched by a clear access pathway, formal recognition of the ABA Australia workforce, and inclusion of that workforce within Scheme documentation and guidance. In our view, this is the most coherent way to align evidence, participant need, and safe implementation under the NDIS.

12. Conclusion Behaviour analytic EIBI is a strongly evidence-based support for an appropriate cohort of young children with developmental needs, yet under the NDIS access remains inconsistent, delayed, and too often dependent on indirect funding pathways, variable planner interpretation, and exhausting review processes.

Throughout this submission, ABA Australia has argued that the relevant question is whether behaviour analytic EIBI demonstrates meaningful benefit for an appropriate cohort in relation to defined goals, functional outcomes, and delivery conditions. In our view, the answer is yes. The literature supports the relevance of EIBI to outcomes that matter directly under the NDIS, including communication, adaptive functioning, daily living skills, participation, safety, and reduction of barriers that interfere with learning and inclusion. It also supports an understanding of contemporary EIBI as individualised in its goals, intensity, format, and setting, and as requiring person-centred, family-centred, ethically grounded, and professionally accountable implementation.

The problem, then, is not the absence of evidence, but the failure to translate that evidence into a clear and workable access pathway under the Scheme. If EIBI is formally recognised as an evidence-based therapeutic support area under the NDIS, that recognition must be matched by recognition of the qualified behaviour analytic workforce available to design, oversee, and deliver it, including ABA Australia’s CBAs and CBA-Us, together with clearer inclusion of that workforce in Scheme documentation and guidance so that competencies, supervision structures, and accountability requirements are transparent and enforceable.

This should also sit within a broader understanding of behaviour analysis as a discipline that contributes across the lifespan and across capacity-building domains under the NDIS. Recognition of EIBI should therefore operate as recognition of one important evidence-based application within a broader field of behaviour analytic expertise, not as a narrowing of that expertise to early childhood alone.

ABA Australia submits that clearer recognition of EIBI, together with formal recognition of the qualified behaviour analytic workforce required to implement it, is necessary to resolve the current disconnect between evidence and access and to reduce the burden currently being borne by children and families seeking timely, evidence-based support.

ABA Australia thanks the EAC for its time and consideration of this submission and would welcome ongoing engagement with the Committee and the NDIA on these matters, including

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the evidence for EIBI, the implementation conditions required for safe and effective delivery, workforce recognition, and other issues relevant to behaviour analytic service provision under the Scheme.

Sincerely,

Niesha Illingworth – President, ABA Australia

Psychologist and Behaviour Analyst (CBA/BCBA)

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13. Appendices Appendix A. Definitions and terminology

Adaptive functioning Adaptive functioning refers to the practical skills needed for everyday life, including communication, daily living, social functioning, independence, and coping with routine environmental demands. It is a key functional outcome domain relevant to the NDIS.

Applied Behaviour Analysis (ABA)

Applied Behaviour Analysis is grounded in the science of behaviour and concerned with understanding and improving socially meaningful behaviour through the application of behavioural principles. It supports meaningful improvements in learning, communication, independence, participation, and other outcomes of social significance across a wide range of ages, settings, and goals. ABA is not synonymous with EIBI.

Behaviour analytic early intervention Behaviour analytic early intervention refers more broadly to early intervention approaches grounded in applied behaviour analysis. It may include comprehensive intervention such as EIBI, as well as more focused intervention targeting a smaller number of goals.

Certified Behaviour Analyst (CBA)

A Certified Behaviour Analyst is a practitioner recognised by ABA Australia as having met defined standards for master’s-level behaviour analytic education, supervised practice, demonstrated competence, and professional conduct. They have specific expertise and training in designing, delivering, and supervising EIBI programs.

Certified Behaviour Analyst - Undergraduate (CBA-U)

A Certified Behaviour Analyst - Undergraduate is a practitioner recognised by ABA Australia as having met defined standards for undergraduate-level behaviour analytic education, supervised practice, demonstrated competence, and professional conduct. They have specific expertise and training in designing, delivering, and supervising EIBI programs.

Early Intensive Behavioural Intervention (EIBI)

Early Intensive Behavioural Intervention refers to a comprehensive early behavioural intervention for young autistic children and other young children with developmental needs, where clinically indicated. It is based on the principles of applied behaviour analysis, delivered over time, individualised to the child and family, and targets multiple developmental and functional domains.

Evidence-based practice Evidence-based practice refers to practice informed by the best available evidence, applied with professional expertise and in light of the needs, goals, and context of the child and family. In this

31

Submission 366 - Attachment 1

submission, it does not refer simply to endorsement of a therapy label in the abstract, but to the appropriate use of defined supports under appropriate conditions.

Functional outcomes Functional outcomes are outcomes that reflect meaningful changes in a child’s ability to communicate, participate, learn, manage everyday routines, cope with daily demands, and function more effectively and safely in real-life settings. In this submission, functional outcomes are central to judging the relevance of EIBI under the NDIS.

Supervision

Supervision refers to structured professional oversight by a qualified practitioner with responsibility for service quality, safety, and clinical integrity. In the context of EIBI, this includes treatment planning, review of progress, fidelity monitoring, guidance to implementers, and oversight of significant clinical decisions.

32

Submission 366 - Attachment 1

Appendix B. Evidence summary table: reviews and key supporting studies

social        of                                                school-                             longer-     of            of

living,       safety,                                   school                                            living,                                                     activities                                         living,                             living,                                     activities                                                          activities                                    supported

daily                                                                                                                                                                                                                   daily                                                                                                                                                                                                                                 school- social              daily                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         participation.             adaptive school                                      adaptive school- social                                                                                                                                                                                                 educational                          daily               of skills,   and                                                of functioning,                                          adaptive                                                                          of functioning,                                                                                    of functioning,                            domains                                                                                                                                                                                       living,                                                                                                                                                             developmental                   living,                                        living,                NDIS                           Activities adaptive communication, behaviour independence.                                                    Communication, readiness, participation.                                          Activities adaptive functioning.                                             Communication, daily functioning, readiness, participation.                 Activities adaptive readiness.                      Activities adaptive term trajectories,         Communication, daily functioning, readiness/educational placement.                       Communication, daily functioning, readiness, participation.

of

on                                     EIBI                                                                                                                                                      than                                                                                                                                                                                                                vary                                                                                                                                policy                                                                                                                                                                                                                                                               defined                                                                                                                                                                                                                                                                                                                                                                                                                                                                          treating                                                                                                                                                                                                                                             review                                                                                                            in                                                                       of                                                                                                                                                                                                                                                 moderate                                 non-                                                                                                                                                                                                                                                                                                                                                                                                                                         supports                                                                                                                                                                                                                                                                                                                                                          different                                                                                                                                              for                                                                                                                                                                                                                                                              reinforces                                             ASD.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        intensity,                                                                                                                                                                                  positive                to                                                                                                                                                                           especially                                                                                                                                                                                                                                rather                                                                                                                                                                                                                                     than                                                                                             treatment                                                                                                                                inform                                                                                          had                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           context-free                                                                                                                                                                                                                                 designs                                                                                                                                                                                                                                                               clearly                                                                                                                                                               and                                                                                                                                                                                                                                                                evidence.                                                                                                                                                                                                                                                                                                                                                                                                                                 findings                                                                                                                                                                                                                                             single                                                                            and                                             with                                                                                   concluded                                    a                                           to                                                                                                                                                                                                                                                                                                     intervention                         due                                                                                                                     or                                       a                                                                                                                               school-                                                                                                                                                                                                                                                                                            useful                                                                                     the                                                                                                                                                                                                                          however                                                                                                                        EIBI                                                                                                                                                                                                                                                                                                                                                         evidence gains.of                                                                                                                                                                                                                                                                                                                                                                                                                                                 evidence                                                                                                                                                                                                                                                                                                                                                       rather                                                                         as                                                                                                                                                                                                                EIBI                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  cross-setting                            but                                                                                                                                                                 study interpretative                                                                                                                                                                                                                                                                                                                                                                                                                                                                  delivery                                                         of                                                                                                                                                                                                                                                                                                                                                                  importance                                                                                                                                                              into                                 bias                                                      and                                                                                                                                                                                  Supports                                                                                                                                                                                                                                                                                                                                                                                                                                       domain-specific,                                                                                                                                                                                                                                                                                                                                                 category,                                                                                                                                                                                                                                                                                                                               domain                                                                                                                                                          evidence,                                                                                                                                                                                                                                             audit                                                                                                                                                                  the                                                                                                                        that                                                                                                                                                                                               relevance.                of                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     implementation                                                                                                                                                  EIBI                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    substantively                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      intervention                                                                                                                                                                                                                that                                                                                                                                                    and                                                                                                       considered                                                                                           children                                                                                                                                                                                                                supplementary                                                                                                                                                                                                                                                                                                                                                                                                                        uniform                                                                                                                                                                                                                                                                                                               comprehensive                                                                                                          the                                                                                                                                                                         and                                                                               for meaningful                                                                                                                                                                                                           outcomes                                                                                                                                                                                                                                                         effects,                                                                                                              to                                                          a                                                                                                                                                                                                                                        careful                                                                                                                                                                                               developed                                               of                     be                                  for                                as                                 risk

as                    notes                                                                                                                                                 language                         funding.             need                   large                                                                                                                                     maintenance                                                       outcome            Key                Noted randomisation should choice                      Useful longitudinal for placement       Report and effects ABA/EIBI-aligned targeted the clinically interpretation      Concluded to heterogenous require consideration. Supports assessing intervention collapsing interventions grouping.                     Supplementary for                   Community Australian relevance translation.      Highlights by interpreting relation duration, characteristics, EIBI category.

for             in  at                      for but       all   the                sizes   was

that                                                     age lower                                                            on    with effects                                                                                  reliable                                                                                                                                                                                                                                                                                                                                             adaptive    EIBI                     children language,

in                                 1.36                                                                                                                                                                                                                          effect    EIBI                                                                                                                                                                                                                                                                                                                                  across                                                                 and    that and                                                         post-                                                                                                                                                                                                                                                                                                           adaptive                                                        and                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         functioning                                                                                                                                                                                                                          after                                                                                                   Better                                                                                                                             and                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             associated                                                        higher                                                                                                                                                                                                                       positive                                                                                                                                            increases                                                                                                                           earlier                                                                                                                                                                      evidence                                                                                                                                                                                                               outcomes                                                                                                                                                                                                                                                                                                                         reduced                         and                                                                                                                for                                                                                                                                                                                                                                 points,                                                                                                                                                                                                                                                                                                                                                       differences                                                                                                                                                                                                                                                                                                                                                                                                           adaptive                                                                                                                                                     target                                                                                                                                                                                                                                                                                                                                            months,                                                                                                                                                                                                                                                                          positive                                                                                                                                                  mean                                                                                                                                                                                                    effects                                                         range                                                          adaptive                                                                                                                                                                                       adaptive                                                                                                                                                                                                                     gains                                                  to                                                                                  achieved                                                                                                                                                                                                                                                                                                                                                                                                                                                   receptive                                                                                                                                                                                                                          years                                                                                                        that                                                                                                            were                                                                                                                                                                                                                                                                                                                                        social                                                                      with                                                                                               24                                                                                                                                                              ASD.                                                                                                                                                                                                                                                                                                                                                          concluded                                                                                                                                                                                                                                                                                                                                                                                                                                             reported                                                              ABA                                                                                                                                                    and                                                                                                                                                                                                                                                                                                                                           comparisons                                                                                                                                                                              outcomes                      for                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                functioning                                                                                                    and                                                                                                 in                                                                    for                                                                                                                                                                       function,                                                                                       10                                                                                                                                                                                                                                                                                                                                                                                                                                                             duration                                                                                                                                              for                                                                                                                                                                                                                                                                                                                                                                                       cognitive                                                                                                                                                                    and                                                                                                    used                                                                                                                                                              with                                                                                                                                                                                                                     these                                                   group                                                                                                                                                                                                                                                                                                           .30–1.09                                                                                                                                                                                                                       were                                                                                                                                  notes                                                                                                                                                                                                                                                                                                                      demonstrating                             0.66                                                                                                                                                                           substantial                                                                                                                        significantly                                                                                                                                                                                                                                                                                                                                                          skills,                                                                                                                                                                                                                                                                                                   weighted                                                                                                                                                                                                                       expectations.                                                                                                   functioning,                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     significantly                                                                                                                                                                                                                                                  gains                                                                                                                                                                                                                                                                                                                    significant         A                                                                                                                                                                                                                          about                                                                                                                                and                                                                                                                                        non-clinical                                                                                                                and                                                                                                                                                                              targeted                                         EIBI                                                                                                                                                                                                                                                                                                                                                                                                                                                                      adaptive                                                                                                                                                                                                                                                                                                                                                                                               living,                                                                                                        also                EIBI                                                                                                                                                                                associated                                                                                                                                                                                                                                                                          language                                                                                                                                                                                                                                                                                                                                                                                                                                                                  standard-score                             were                                                                                                                                                                       cognitive                                                                                                                                                                                                                                                                                                                                                                                                                     between-group                                                                                                                                                                       skills,                                                                                                                                                                                   also                                                                                                                                                                                       outcomes                                                    It                                                                           IQ                                                                                                                                                                                                                                                                                                                                                                                       effects                                                                                                                                                                                                                                                                                                                            children                                            on                                  the                                                                                                                                                                                                                                                                                                                                                                                       increased        to                               the                                                                                             showed                                                                                                                                                                                                                                                                                                                                                                         outperformed                                                                                                                                                                                                                                                                                                                                                                                                                    characteristics                                                                                                                                                                                                                     EIBI,                                                                                                                                                                          and                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            intervention                                                                                                                                                                                                                                                         frequently                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    meta-analyses                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          hours/week                                                                                                    and                                                                                                                                                                                                                                                                                 daily                       in                                                                                                                for                                                                                                                                                                                                                                                                              comprehensive                                                                                                                                                                                                                                                                                                                                                                                                                                                             cognitive                     in                                                                                                               measures.                                                                      were                                                  is                                                                                                                                                                                                                                                                                        clinically                                                                                   severity.                                                                                                                                                     normative                                                                                                                                                                 15.21                                                                                                                                                                                                                                                                                                                                                                                                                                                                         follow-up.                                                                                                                                               living                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    significant                                                                                               20                                                                                                                                                                                                                                                                            large                                                                                                                                                                                                                                                                                                                                                                                                         follow-up                                                                  IQ                                                                                                   intellectual                                                  effects                                                                                                                                                          five                                                              EIBI                                                                                                                        EIBI                                                                                                                                                                                                     young                                 to                                                                                                                                                         effects                                                                to                                                                                   that                                                                                                                                                                                       positive                                                                                                                                                     baseline                                                                                               of                                                                                                                                                                                                                                                                                                                                                       behaviour.                                                                                                           to                                                                                       at                                                                  in                                                                                                                                                                                                                                                                during                                                                                                                                                                                                                                                         Reported                                                                                                                                                                                                                                                                                                                                              longer                                                                             of                                                                                                                                                                  autism                         for                                                                           ABA                                                                                                                                         and                                                              these                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             meta-analyses,                                relevant                                                                                                                                                                                                                                                                                                                                                                      symptoms                                                                    scored                                                                                                                       daily                                                                                                                                                                                                                                         outcomes.                                                                                                                                                                                 severity.                                                                                                                                                                                                                                                                                                                                                                                                                                                                      language                                                        autism                                                                                  children                                                                                                                                 4.96                                                                                                                                                                                                                                                                                                           .38–1.19                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             significantly                         on                                                                                                                                                              many                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            language,                                                                                 and                                                                                                                                                                                                                               with                                                                                                                  notes                                                                                                                                                                                                                                                                                                                                                                                                                                                             language,                                                                                                                                                  five                                 0.87                                                                                                                                                          Four                   in                                                                                                                             states                     of                                                                        and                                                                                                                higher                                                        -                                                                                                                                    relative                                                                                                                                                                                                                   trajectories                                                                                                                                                                                                                                        effects                                                                                                                                                                              positive                                                  summary                                                                                                                                                                                                                                                                scores                                                                                                                                                                                                                                                                                        considered                                                                                                                                                                                                                                                                                  intake                                                           ASD                                                                                                                      for                                                                                                                                            receiving                                                                                                                                                                                                                                                                               receiving                                                                                                                                  those                                                                                                                                                                                                                                                                                                                                            average                                                                                                                                                                                                                                                                                                                                  medium                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     statistically                                                                                                                                                                                                                                                                                  adaptive                                                                    and/or                                                                                                                                 from                                                                                                                                                      from                                                                                                                                                                                                                                                                            Autism                                                                                                             the                                                                                                                                                                  skills                                findings                                                                                    not                                                                                                                                                                                                                                                                                                                                                                                                                                                     maintained                                                                                                                                                                                                                                                                                        outcomes.                                                                                               an                                                                                                                start,                                                                                                       for                                                                                                                                                                                                                                                                                                                                                                                                                                                                      stronger                                                                                                                             report                Main                 Adjusted behaviour, reductions proportion change intervention                 Children language language EIBI baseline The indicates specifically behaviour comprehensive improve social were summary. Children main ranged strongest also       Across ranged behaviour. effective              Participants standard were ended. between   After showed expressive behaviour.                 Positive intellectual, outcomes with outcomes.

living                                         non-                                                                                                                                                                                                                                                                                                 motor

/                                                                                                                                                           review                and daily skills         such   and                autism /                                                                   receptive                                     of                     from                                assessed                                                                                                                                                                                                                                                                                           adaptive                                                                                                                                                                                                                                                                                                                                                                                                              placement                                                                                                                                                                                                                                                                                                                                                                   training,                                                                                                                                                                                                              social                                                                                             clinically                                                                                                                                                                                                                                                                                                   reviewed                                                                                                                                                                                                                                                                                                                                                                                                       adaptive                                                                                           reliable                                                                                                                                                              IQ, language

/                                                                                                                                                                                                                                                                                                                                                                                                intensity,                                                                                                          and                                                                                                       and                                                                              ABA          IQ, language,                                                                                                   functioning,                                                                                                                                                  also moderators                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     educational                                                                                                                                                                                                                                                                                                                                                                                                                                                     adaptive functional daily                                                              change                                                                                                                                                                                                                             later context      language, language,                                                                                                                                                                                                                       trajectories; placement predictors                                      secondary                                                                                                                                                                                                                                                                                                                                                      skills,                                                                        behaviour,                                                                                                                                                                                                                                             parent                                                                       IQ                                                                                                                                                                                                                                                                                                  language, behaviour,                                                                                                                                                                                                                                                                                                                                                                             training.       functioning, behaviour,                                                                           on                                                                        and domains                                                         range                                                                                   severity;                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                         socialisation,                                                                                                                                                                                                                                                skills,                                outcomes                                                                                                                                                                                                                                                                                                             non-verbal                                                                  treatment                                                                                                                                    non-verbal expressive                Main                 Adaptive intellectual autism significant clinical change                                            Receptive/expressive language educational outcomes; response                      Primary outcome comprehensive          IQ, expressive receptive adaptive living Primarily behaviour; findings as duration, supervisor     Cognitive adaptive symptoms, attainment      Receptive expressive cognitive behaviour, placement  IQ, and composite, behaviour, communication, skills, skills

in                                                              in                    of

data                                                                                                                               meta-                             EIBI                                                                                                                                                                                                                   study                                                                                                                                                                                              young                                                                                                                                                                                 EIBI                                                                        months;                                                                                             344                                                                                                                                                                                                                                                                                                  receiving                                                                                                                                                                                                                  including                                                                                                                                                                         for              of                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                              entry/exit                                                                                                                                                                                                                                                                                                                                                                                                                                                   children,                                                                                        of                                                                                                   children                                                                                                                  for                                                                                                                                                                                                       versus                         ASD                                                                                   receiving                                             were                     12                                                                            ABA       11                                                                                                                                                                                                                                     with                                                                                                                                                                                                                                                                         meta- dose–                                                                                                 45                                                                      with                                                            of            of                                                                                                                                                                                         meta-                           in                                                                                                                                                                                                                                 EIBI                                                                                                                     ASD                                                                                                 ASD                                     341                                     5                                                                                                 of                                                                                                     groups. observational children                                                                                                                                                        EIBI                                                                                                                                     EIBI                                                                                                                                            report of                                 with                                                                                                                                                                  and                                                                                                                                                                                                                             years                                             data                                                                                                                of                                                                                                                                                                                                                                                                                                                                                                                           follow-up who                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          community-                                                   least                                                                                                                                                                                                                                                         studies,                                                  studies                                                        participant 15                                              years                                                                          of                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             meta-analysis                                                                      EIBI language                                                                            of                                     for                                        280                                                                                                                                                  review                                            2                                                  131                                                                                                                                                            with                                                                                                                                 with                                                                                                     32                     at                                                                                                                                                                                                                                                  audit                                                                                                                                                                                                                                                                                                                                                                                                                                                                          children                            2–6 for      and    of                                                                                                                                                                                                                                                         childhood                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 standardised for                                                Design/Scope Individual meta-analysis controlled childrenfor aged EIBI participant obtained EIBI comparison Longitudinal study receiving repeated measurement                        Consensus umbrella comprehensive analyses                                   Meta-analysis controlled children ABA-based control/comparison             Overview analyses children                   Long-term adolescentsof received early           Australian based with data                       Meta-analysis, regression response studies22 young autism/PDD-NOS

et                                                           (2026)                                         (2021)                    and                                                                                                        (2021)                         (2018)                                   (2010)

al.                                                     al.                                                                                                                                                   al.                                                                                                                                                                                                                  Academies             (2025)                                                               (2012)              al.                    et                                   et

et                                                                                                  et                                                                                                                                                                                                                           Sciences,                                            (2011)                        Source                                 Eldevik                                                Frazier                                      National of Engineering, Medicine                                                                Peters-Scheffer al.                              Reichow                        Smith                 Wood                                                                           Virués-Ortega

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Submission 366 - Attachment 1

References

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Progressive. Journal of Autism and Developmental Disorders, 46(2), 720–731. https://doi.org/10.1007/s10803-015-2591-6

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Trembath, D., Waddington, H., Sulek, R., Varcin, K., Bent, C., Ashburner, J., Eapen, V., Goodall, E., Hudry, K., Silove, N., & Whitehouse, A. (2021). An evidence-based framework for determining the optimal amount of intervention for autistic children. The Lancet Child & Adolescent Health, 5(12), 896–904. https://doi.org/10.1016/S2352-4642(21)00285-6

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Wood, S., Christian, M. P., & Sampson, A. (2018). Audit of outcomes following a community based early intensive behavior intervention program for children with autism in Australia. Australian Journal of Psychology, 70(3), 217-224. https://doi.org/10.1111/ajpy.12193

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