Submission 75
Submission to the Senate Inquiry into the National Disability Insurance Scheme Amendment (Securing the NDIS for Future Generations) Bill 2026 and Thriving Kids
Program
Submitted by: Advance Occupational Therapy
To whom it may Concern,
Advance Occupational Therapy submits this response with significant concern regarding both the proposed Thriving Kids program and the broader direction of current NDIS policy and early intervention reform in Australia.
As paediatric occupational therapists working directly with children and families every day, we are witnessing the real-world consequences of government decisions that continue to restrict, delay, and reduce access to early intervention supports for children with autism, developmental delays, sensory processing difficulties, ADHD, emotional regulation challenges, and learning difficulties.
We are deeply concerned that the Thriving Kids program, if implemented without the inclusion of private allied health providers, particularly occupational therapists, will become another bureaucratic framework that fails the very children it claims to support.
The Australian Government cannot continue to publicly promote “early intervention” while simultaneously introducing systems and legislative changes that reduce access to the clinicians delivering that intervention.
Early intervention is not optional. It is essential. The evidence supporting early intervention is overwhelming.
Children who receive occupational therapy and allied health supports early:
- Participate more successfully in mainstream schools
- Require fewer intensive supports later in life
- Develop stronger emotional regulation
- Experience improved social participation
- Build independence
- Reduce behavioural escalation
- Experience better long-term mental health outcomes
- Reduce long-term reliance on public systems
- Are able to form stronger bonds with family members
- Form positive and strong bonds with their parents and siblings Yet despite decades of evidence, government policy continues to move in the opposite direction.
Submission 75
Families are now facing:
- Longer waitlists
- Reduced funding certainty
- Increasing administrative barriers
- Therapist shortages
- Rising out-of-pocket costs
- Delays in accessing developmental supports during critical developmental windows
- Increased stress on a daily basis Every delayed intervention represents a missed developmental opportunity for a child. Government policy cannot continue treating early intervention as a cost burden when it is one of the most effective long-term investments Australia can make.
Current NDIS changes are hurting children and families. The current direction of NDIS reform is creating fear, instability and confusion for families raising children with disabilities and developmental challenges.
We are increasingly seeing:
- Families terrified of losing support and under enormous stress
- Children waiting months or years for therapy
- Clinicians drowning in administrative requirements
- Therapists leaving the sector due to unsustainable systems
- Reduced continuity of care
- Children deteriorating while “waiting for eligibility” The narrative that early intervention services are “overused” or financially unsustainable ignores the reality faced by families every day.
Children do not stop needing support because legislation changes. Autism, developmental delay, sensory processing challenges and learning difficulties do not disappear because governments tighten access criteria.
The consequences are simply transferred elsewhere, all of which are already stretched for resources and funding:
- Schools
- Hospitals
- Emergency mental health services
- Youth justice systems
- Overwhelmed families
- Under-resourced teachers Australia will pay for these failures eventually either through early intervention now or crisis intervention later.
Submission 75
Excluding private occupational therapists would be devastating for these children and their families. Private occupational therapists currently carry a substantial proportion of paediatric developmental support services across Australia. Years of building relationships and rapport with these families have been developed and without private providers, many families would receive no support at all and suffer.
Public systems alone do not have the workforce capacity to meet demand.
Excluding private providers from the Thriving Kids program would:
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Dramatically reduce service accessibility
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Worsen waitlists
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Disadvantage regional communities
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Remove family choice
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Disrupt trusted therapeutic relationships
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Increase developmental delays through preventable service gaps This would be particularly harmful for:
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Children with autism
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Children with learning difficulties
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Neurodivergent children
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Children requiring school participation support
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Children with emotional regulation difficulties Governments must stop designing systems around bureaucracy rather than practical service delivery realities.
Families do not care whether support comes from “public” or “private” providers. They care whether their child can access help when they need it.
The cost of inaction is already visible. We are now seeing an entire generation of neurodivergent children and adolescents experiencing escalating mental health difficulties because they were unsupported early enough.
Children who do not receive early therapy frequently experience:
- School refusal
- Anxiety disorders
- Depression
- Emotional dysregulation
- Social isolation
- Behavioural crises
- Low self-esteem
- Family breakdown
Submission 75
These outcomes are not inevitable. Many are preventable through timely early intervention.
As clinicians, we have directly witnessed children who received early occupational therapy:
- successfully transition into mainstream schooling
- complete high school
- develop independence skills
- maintain social participation
- avoid severe mental health deterioration in adolescence
- have positive relationships with their parents and siblings This is the outcome governments should be investing in.
Instead, current policy settings are creating barriers to precisely the services that prevent long-term disability and mental health escalation.
Restricting access to paediatric occupational therapy is not fiscally responsible policy. It is short-term cost shifting.
The long-term economic consequences of inadequate early intervention include:
- Increased mental health expenditure
- Greater educational support costs
- Increased welfare dependency
- Family workforce withdrawal
- Crisis healthcare utilisation
- Increased long-term disability support costs Investing early is cheaper than managing lifelong crisis. This is not simply a healthcare issue it is an education, workforce participation, mental health and economic productivity issue. Advance Occupational Therapy strongly urges the Australian Government to reconsider the current legislative and policy direction surrounding early intervention and the NDIS.
We call for:
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Legislation that protects access to early intervention services
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Recognition of occupational therapists as essential providers in the NDIS and thriving kids
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Inclusion of private allied health providers within thriving kids
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Reduced administrative barriers for families
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Sustainable workforce planning
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Funding models that prioritise developmental outcomes over cost containment
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Policies informed by clinicians and families rather than solely by budget pressures Children with disabilities and developmental challenges should not become casualties of political cost-cutting.
Submission 75
Recommendations
Advance Occupational Therapy recommends that the Senate Inquny:
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Oppose any Thriving Kids model that excludes private occupational therapists and allied health providers.
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Recommend legislative protections for early intervention access under NDIS-related refonns.
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Recognise occupational therapy as a critical developmental and preventative mental health service.
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Prioritise child developmental outcomes over sho1t-tenn fiscal reduction strategies.
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Consult dn·ectly with frontline paediatric allied health clinicians and families before implementing refo1ms.
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Recognise the established evidence linking early intervention to improved educational pait icipation, mental health outcomes and reduced long-te1m system dependency.
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Ensure continuity of care for children ah-eady engaged in therapy services. Australia is at risk of dismantling the ve1y eai·ly intervention systems that have allowed thousands of children with autism, developmental delays and learning difficulties to successfully paiticipate in mainstream schools, community life and society.
The government cannot continue claiming to suppo1t children’s wellbeing while snnultaneously restricting access to the professionals delivering that support.
Occupational therapists ai·e not an optional addition to childhood development systems, they are an essential pa1t of them.
If changes to the NDIS and the proposed Thriving Kids program is to genuinely nnprove outcomes for children, it must include private occupational therapists and allied health providers as core pait icipants.
Anything less will result in greater inequity, worsening mental health outcomes, increased pressure on schools and families, and preventable long-te1m haim to Australian children.
Regards,
Submission 75