Submission Regarding Proposed NDIS Reforms and the Thriving Kids Program

Objective

I am writing as a parent of a neurodivergent child who has firsthand experience navigating school access barriers, disability supports and the realities families face trying to access appropriate early intervention.

I am deeply concerned about the proposed NDS reforms, particularly the move towards Foundational Supports, including the first phase known as Thriving Kids, for children aged eight and under with developmental delay and/or autism and low to moderate support needs.^1,2^

This submission focuses particularly on the impact the proposed reforms may have on autistic and neurodivergent children experiencing school refusal and barriers to accessing mainstream settings such as schools.

Concern 1: School access as a barrier

On paper, the idea of improving early supports sounds positive. But from the perspective of families living this reality every day, there are serious gaps in the logic of how this is being proposed.

A major concern for me is the apparent assumption that children will be able to access supports through schools and other mainstream settings. That may work in theory for some children. But for a huge number of autistic and neurodivergent children, school itself is the barrier.

The Australian Parliamentary Library research paper on school refusal and related matters notes that school refusal and persistent non-attendance are significantly higher among autistic children and children with ADHD, and it cites research showing elevated rates of persistent absence in autistic student samples.^3,4^

A child may be highly verbal, academically capable or intellectually gifted, while simultaneously being unable to consistently attend school, cope with the sensory demands of the classroom, manage transitions, regulate emotionally or participate safely and meaningfully in daily life.

Functional impairment is not always obvious on the surface and is not always accurately captured through standardised assessments.

Concern 3: Schools are already stretched

There also seems to be a significant assumption within these reforms that schools can simply absorb the responsibility for increasing levels of disability support and therapeutic intervention.

But schools are already struggling. Parents, teachers and advocates have consistently raised concerns about inadequate support staffing, lack of specialist training, sufficient funding and growing numbers of neurodivergent students requiring support.^5^

It is difficult to see how schools can realistically take on even more responsibility without substantial investment, staffing and training.

Concern 4: Short-term savings, long-term costs

Another major concern is that these reforms appear heavily focused on reducing costs in the short term, without adequately considering the long-term consequences of withdrawing or limiting early intervention.

It may reduce spending today, but there is a real risk that it simply pushes far greater costs down the road.

The evidence consistently shows that early intervention can improve functional outcomes and reduce the level of support many children require later in life. A recent economic analysis of infant autism intervention reported a predicted return of about three dollars for every dollar invested, with savings in future disability support costs by age 13.^6^

If children do not receive appropriate support early, the consequences do not simply disappear. Those needs often become more complex, more entrenched and more expensive to address later. The costs are then shifted elsewhere — into schools, mental health systems, hospitals, family crisis, workforce participation impacts, carer burnout and increased long-term disability support needs.

Early intervention is not simply an expense. It is an investment in reducing future support needs, improving participation and preventing more significant social, educational and economic costs down the track.^7,6^

Concern 5: Uncertainty in rollout

I am also concerned about the uncertainty surrounding the Thriving Kids rollout itself.

The Government has stated that Thriving Kids will form the first phase of Foundational Supports, with services and information for children aged eight and under with developmental delay and/or autism and low to moderate support needs, delivered through broader community systems rather than the NDIS.^1,2^

Yet there is still limited clarity around:

• what services will actually exist;
• how families will access them;
• what eligibility criteria will apply;
• how consistency will be achieved across states and territories;
• what happens to children who cannot attend school consistently; and
• how continuity of support will be maintained for children currently relying on NDIS-funded intervention.

At the same time, many families are already reporting uncertainty during the transition period.

That is incredibly concerning.

Early intervention only works if it is genuinely accessible. It cannot be considered accessible if the child is unable to access or tolerate the environment through which the support is delivered.

Recommendations

The proposed reforms should ensure that:

• supports remain accessible outside school settings for children who cannot consistently attend school;
• school attendance is not used, formally or informally, as a gateway to accessing disability-related supports;
• autistic and neurodivergent children experiencing school refusal are specifically considered in the design of eligibility and support systems;
• individualised supports remain available where functional impairment significantly impacts daily life and participation;
• children do not lose access to evidence-based intervention before equivalent supports are demonstrably operational and accessible;

• schools are not expected to absorb additional therapeutic responsibilities without substantial increases in funding, staffing and specialist training; and

• long-term social and economic costs are considered alongside short-term budget savings when evaluating the impact of these reforms.

The success of these reforms should not be measured by how many children are removed from the NDIS.

It should be measured by whether children can actually access the support they need to participate in life, education and their community.

Right now, for many autistic and neurodivergent children experiencing school refusal, I do not believe these reforms adequately answer that question.

Thank you for considering my submission.