Concerns regarding reduced access to early intervention for children with developmental delay (Provider advocacy)

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Submission 736

Protecting Early Intervention and Community-Based

Paediatric Supports for Children and Families

I am a speech pathologist and co-owner of Munchkin Allied Health, a paediatric allied health clinic based in South Morang in Melbourne’s northern

growth corridor. Our clinic provides speech pathology and occupational therapy services to approximately 120 children and families across South Morang, Wollert, Epping, Wallan, Research, Bundoora and surrounding areas.

Most of the children we support are autistic or have ADHD, developmental delay, intellectual disability or complex communication needs. Many families come to us before diagnosis and we often support them through the process of accessing paediatricians, assessments, schools and the NDIS.

We employ three speech pathologists, two occupational therapists, an allied health assistant studying speech pathology, administration staff, and provide ongoing support and supervision to our team. We work closely with schools,

kindergartens, childcare centres and families to support children in real-world environments, not just within clinic sessions. This submission reflects our concerns about the practical impact the

proposed reforms may have on children, families, therapists and small community providers.

Munchkin Allied Health

102/2 Murdoch Rd South Morang

3752 munchkinah.com.au admin@munchkinah.com

Submission 736

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Concerns regarding reduced access to early intervention

We understand the need for a sustainable NDIS and support efforts to

improve consistency and reduce fraud. However, we are concerned that some of the proposed reforms may unintentionally reduce access to timely early intervention for children with developmental delay and neurodevelopmental conditions. In paediatrics, early intervention is often preventative. Children who receive

support early are more likely to develop communication, emotional regulation, social participation and school readiness skills before difficulties escalate. Many children we see do not present with clear or severe disability at age two or

three. Their challenges become more obvious as social, communication and educational demands increase. Some children appear to cope in structured or supported environments but struggle significantly in kinder, school or community

settings. We are concerned that stricter interpretations of “functional capacity” may not adequately capture how neurodivergent children function in real life, particularly where difficulties fluctuate across environments.

A child’s functioning is often closely connected to:

  • family support
  • school supports
  • sensory environments
  • emotional regulation
  • communication demands

Munchkin Allied Health

102/2 Murdoch Rd South Morang 3752

munchkinah.com.au admin@munchkinah.com

Submission 736

3

  • routine and predictability In practice, these factors cannot always be separated from disability-related

support needs. Concerns regarding reassessment restrictions

We are also concerned about the proposed restrictions around plan reassessments. Children do not develop in a straight line. Support needs can

change quickly due to:

  • school transition
  • behavioural escalation
  • burnout
  • increasing academic demands
  • mental health concerns
  • family breakdown
  • loss of informal supports In our experience, reassessments are often requested because families are

struggling and existing supports are no longer adequate. A longer reassessment process and stricter thresholds may delay support during critical developmental periods. For children, delays of six to twelve months

can have significant long-term impacts on communication, learning, emotional regulation and participation.

Munchkin Allied Health

102/2 Murdoch Rd South Morang 3752

munchkinah.com.au admin@munchkinah.com

Submission 736

4

Families are already experiencing stress navigating diagnosis pathways, long waitlists and school systems. Additional barriers may increase pressure on parents,

schools and already stretched health services.

Impact on families and schools

Much of the work performed by paediatric allied health providers is not limited to direct therapy sessions. Our clinicians regularly:

  • attend Student Support Group meetings
  • liaise with schools and kindergartens
  • support families through diagnosis pathways
  • help parents understand reports and recommendations
  • provide emotional support
  • assist with transitions into school
  • train educators and childcare staff
  • coordinate with paediatricians and care teams This work is essential to positive outcomes for children but is often difficult to measure within narrow funding frameworks. If children lose access to flexible and

relationship-based supports, the impact will likely shift elsewhere:

  • schools managing more unsupported behaviours
  • parents reducing work participation
  • increased family stress and burnout

Munchkin Allied Health

102/2 Murdoch Rd South Morang 3752

munchkinah.com.au admin@munchkinah.com

Submission 736

5

  • increased mental health concerns
  • greater pressure on public health systems Impact on workforce and small providers

Our clinic has intentionally focused on clinician support, supervision and staff

retention because workforce instability is already a major issue within paediatric allied health. We are concerned the proposed reforms may increase uncertainty for providers and families at a time when the sector is already under strain. Small community providers operate differently from large corporate services.

We rely heavily on long-term relationships, continuity of care and local knowledge. Many families choose smaller providers because their child feels safe, known and understood.

If funding becomes harder to access, less flexible or more administratively burdensome, smaller practices may struggle to remain viable, particularly in growth corridors and outer suburban areas where workforce shortages already exist.

Provider closures or workforce loss would likely increase waitlists and reduce access to experienced paediatric clinicians.

Growth corridor concerns

Melbourne’s northern growth areas are already experiencing rapid population growth and increasing demand for paediatric supports. Families in outer suburban and regional areas often face:

Munchkin Allied Health

102/2 Murdoch Rd South Morang 3752

munchkinah.com.au admin@munchkinah.com

Submission 736

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  • long waitlists for paediatricians
  • transport barriers
  • limited therapy availability
  • difficulty accessing multidisciplinary supports Changes that reduce flexibility or continuity of care may disproportionately

affect these communities.

Conclusion

We support the goal of improving the long-term sustainability of the NDIS and ensuring supports are directed toward those who need them most. However, we are concerned that some aspects of the Bill may create unintended

consequences for children, families and community-based providers. Early intervention and relationship-based care are not optional extras. They are often the reason children can participate successfully in school, community and family life.

We encourage the Committee to carefully consider the practical impact these reforms may have on:

  • continuity of care
  • timely access to supports
  • neurodivergent children with changing developmental needs
  • family wellbeing

Munchkin Allied Health

102/2 Murdoch Rd South Morang 3752

munchkinah.com.au admin@munchkinah.com

Submission 736

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  • workforce sustainability
  • outer suburban and regional service access

Recommendations

  1. Ensure functional capacity assessments adequately reflect the real-world presentation of neurodevelopmental conditions across different environments.

  2. Maintain flexible reassessment pathways for children whose support needs can change rapidly during development.

  3. Protect continuity of care for children already engaged in long-term therapeutic relationships.

  4. Consult closely with frontline paediatric providers, families and educators during the implementation of Thriving Kids and related reforms.

  5. Consider the impact of reforms on workforce retention, small provider sustainability and service access in growth corridors and regional

communities.

  1. Recognise the importance of early intervention, parent support and multidisciplinary collaboration in reducing long-term system costs and

improving participation outcomes.

I appreciate your time and consideration in this matter. I am happy to answer any questions or speak to any of the above points.

Munchkin Allied Health

102/2 Murdoch Rd South Morang 3752

munchkinah.com.au admin@munchkinah.com

Submission 736

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Kind regards,

Ceri Webb

Director / Senior Speech Pathologist, CPSP

BHlthSci (Hons), MSpPath

Munchkin Allied Health

P: E:

Munchkin Allied Health

102/2 Murdoch Rd South Morang 3752

munchkinah.com.au admin@munchkinah.com