NDIA Accountability Project

Submission 101 — Women's Alcohol and Drug Service- First Thousand Days Clinic — Inquiry into the Thriving Kids initiative

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1st October 2025

Submission to the House Standing Committee on Health, Aged Care and Disability by the Women’s Alcohol and Drug Service – First Thousand Days Clinic (WADS-FTDC).

Background

WADS-FTDC provides multidisciplinary health and developmental care to infants from 0-2 years of age who have experienced complex alcohol or illicit drug exposure prior to birth. Over 170 infants were born into the service 2023-2024, with the majority of infants having been exposed to multiple types of illicit substance, most commonly methamphetamines and cannabis1. Our service cares for children residing in metro Melbourne and in regional Victoria. We frequently refer children with developmental delay to the current NDIS-ECI service, with the aim of facilitating access to appropriate and timely developmental supports in the community. We would like to make the following observations based on our experiences and our knowledge of the particular vulnerabilities of infants with prenatal substance exposure (PSE).

Current Situation

  1. Infants with PSE are at increased risk of: a. developmental delays, behavioural and learning difficulties2-5. b. disruption to caregiving relationships and exposure to the child protective system. c. Adverse Childhood Experiences, including high rates of exposure to family violence. d. Socioeconomic disadvantage.
  2. The current NDIS-ECI framework does not recognise infants with PSE as a distinct group of children with increased neurodevelopmental risk. Fetal Alcohol Spectrum Disorder (FASD) is recognised; however, in Australia the average age at which a FASD diagnosis is received is in middle childhood, despite infants frequently showing developmental difficulties in the early years. Infants who are not in parental care have particular difficulty with meeting the criteria for FASD diagnosis due to loss of information regarding their pre-birth alcohol exposure histories6,7. Thus, children in Child Protective care and younger children with prenatal alcohol exposure and developmental delays may be disadvantaged by the NDIS-ECI system’s current recognition of FASD but not prenatal alcohol or poly substance exposure.
  3. Parents of infants with PSE are more likely to be Aboriginal or Torres Strait Islander1, neurodiverse, living with significant mental illness, and living with cognitive and executive function difficulties. Parents often face their own histories of childhood trauma, unfinished schooling, insecure and transient housing, and poor experiences with healthcare systems, leading to multiple difficulties and barriers8 when trying to interact with the current NDIS-ECI system.

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ABN 62 787 822 077

  1. Infants with PSE face high rates of interaction with the Child Protection system‘. Infants removed from parental care may undergo multiple changes of placement, impairing their ability to access geographically restricted services. Infant’s developmental histories and any increased developmental needs may not be adequately communicated between placements. Infants whose histories are not held by their caregivers face barriers to accessing NDIS-ECI support when assessors primarily determine need based on caregiver interview and not the information supplied by professionals.

  2. Infants who are not in parental care face delays in accessing NDIS-ECI due to inflexibility in the consent process, particularly where NDIS-ECI requires written consent from an uncontactable parent who does not have the child in their care. This scenario particularly impacts young infants (< 2 years) on Interim Accommodation Orders where permanency of legal status is not appropriate.

  3. Infants with PSE have developmental needs that evolve over time and can be impacted by their experiences of their home environments and of warm, attenuated caregiver relationships?°.

Recommendations for Thriving Kids

Given our understanding of neuroplasticity, epigenetics, and the effectiveness of early intervention, we know that infants with PSE have the potential to be Thriving Kids. These children should not be limited by their early experiences; however, realising this potential requires specific and coordinated support that should:

  1. Recognise PSE as a specific developmental risk which qualifies infants for early intervention services.
  2. Facilitate access to appropriate services and not disadvantage children in out of home care or with unstable caregiving situations.
  3. Maintain continuity of care throughout children’s early lives, including across out of home care placements.
  4. Provide trauma sensitive, culturally safe interactions with parents and caregivers, recognising that parental literacy levels, cognitive difficulties, social isolation, neurodivergence and trauma histories should not disadvantage their children from receiving developmentally appropriate care.

Dr Anna C Tottman FRACP PhD, Rochelle Lester BPhysio MPhysio(Paed), Naomi Lourensz BA MSpeechPath, on behalf of the Women’s Alcohol and Drug Service-First Thousand Days Clinic.

References

  1. Report: Women’s Alcohol and Drug Service: Paediatric Activity 2024. Women’s Alcohol and Drug Service, Royal Women’s Hospital, Melbourne 2025.
  2. Lowe JR, DiDomenico J, Stephen JM, Roberts MH, Rodriguez DE. Early developmental trajectory of children with prenatal alcohol and opioid exposure. Pediatric Research. 2022.

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ABN 62 787 822 077 thewomens.org.au

  1. Lee SJ, Woodward LJ, Henderson JMT. Educational achievement at age 9.5 years of children born to mothers maintained on methadone during pregnancy. PLOS One. 2019
  2. Benninger KL, Borghese T, Kovalcik JB, et al. Prenatal exposures are associated with worse neurodevelopmental outcomes in infants with neonatal opioid withdrawal syndrome. Frontiers in Pediatrics. 2020.
  3. Corsi DJ, Donelle J, Sucha E, et al. Maternal cannabis use in pregnancy and child neurodevelopmental outcomes. Nature Medicine. 2020.
  4. Garrison et al. Forty years of assessing neurodevelopmental and behavioural effects of preclinical alcohol exposure in infants: What have we learned? Alcohol Clinical Exposure Research. 2019.
  5. Bakhireva et al. Challenges of diagnosing fetal alcohol spectrum disorder in foster and adopted children. Alcohol. 2018.
  6. Lord L, Rogers J, Gamble GD, Harding JE. Are toddlers with neurosensory impairment more difficult to follow up? A secondary analysis of the hPOD follow-up study. Archives of Disease in Childhood: Fetal and Neonatal Edition. 2024.
  7. Luby JL, Herzberg MP, Hoyniak C, et al. Basic environment supports for positive brain development in the first year of life. JAMA Pediatrics. 2024
  8. Eze N, Smith LM, LaGasse LL, et al. School-aged outcomes following prenatal methamphetamine exposure: 7.5-year follow-up from the Infant Development Environment and Lifestyle (IDEAL) Study. Journal of Pediatrics. 2016

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ABN 62 787 822 077