Submission 136 — Mx Teneille Williams — Inquiry into the Thriving Kids initiative | External submission

Registered Psychologist & Advocate for Neurodivergent Children

Executive summary This submission presents a cohesive, evidence-informed framework to guide the Thriving Kids Initiative. It argues for clear differentiation between emerging developmental difficulties and diagnosed, complex, persistent, permanent disability; attention to intersectionality; realistic appraisal of existing system capacity; rejection of rigid tiered models in favour of individualised supports; and the embedding of psychological expertise throughout policy design and service delivery. The submission integrates lived experience and case illustrations, summarises

contemporary evidence regarding Autism and co-occurring neurodevelopmental conditions, reviews Australian assessment pathways, and outlines legal and human rights obligations. Key recommendations are provided to ensure equitable, timely and sustainable supports so that all children can thrive.

Purpose

The purpose of this submission is to raise urgent concerns about the current framing of the Thriving Kids Initiative and to advocate for evidence-informed and equitable approaches that reflect the complexity of children’s needs. The submission contends that the Initiative risks

causing harm if it does not address five critical issues.

First, there must be clear differentiation between developmental difficulties that are emerging and those associated with a diagnosed, complex, persistent or permanent disability. Early intervention is important for all children, yet conflating emerging vulnerabilities with established lifelong conditions erases nuances of need. Vague terms such as mild or moderate fail to capture functional capacity and can perpetuate harm. Individualised assessment should consider diagnostic profile, functional presentation, and the impact on family, educational and community systems.

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Second, the Initiative must attend to intersectionality. Autistic children and their families often live at the nexus of multiple vulnerabilities where disability intersects with socioeconomic disadvantage, single parenthood, trauma exposure, language and cultural background, and co occurring diagnoses such as Attention-Deficit/Hyperactivity Disorder (ADHD) and Pathological Demand Avoidance (PDA). These intersecting factors compound a child’s functionality and can create additional barriers to accessing supports.

Third, the state systems expected to absorb responsibility for these children, including health, education and community services, are already under significant strain. Shifting disability specific needs into overstretched services will cause children to fall through gaps in care,

leading to delayed assessment, intervention and escalation of need that could have been prevented through timely and targeted support.

Fourth, the proposed tiered approach to support undermines individualised care. In child and youth mental health, tiered models have well-recognised limitations, with young people frequently falling between thresholds and being bounced between services without consistent support. Thriving Kids needs to learn from these mistakes and seek to do better.

Finally, psychological input is required at every level. Psychologists bring expertise in

assessment, intervention, systems understanding and evidence-informed practice that is indispensable for policy and service delivery. Without these perspectives, the Initiative risks overlooking nuanced and relational aspects of development and wellbeing.

Interpretation of the announcement The Australian Government’s Thriving Kids initiative is designed to identify developmental concerns early in children aged eight and under who exhibit mild to moderate developmental delay or Autism, and to provide support for them and their families (Department of Health, Disability and Ageing, 2025). Children with permanent and significant disabilities will continue to be supported through the National Disability Insurance Scheme, while Thriving Kids will

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operate as a complementary system for those whose needs can be met through mainstream and community-oriented services (Department of Health, Disability and Ageing, 2025). The program intends to build on and scale existing services, including child and maternal health, general practice, playgroups, early childhood education and schools, together with digital and telephone-based supports, rather than creating entirely new systems (Department of Health, Disability and Ageing, 2025). A phased rollout is expected from 1 July 2026 with further scaling over the following twelve months (Department of Health, Disability and Ageing, 2025).

System capacity and lived experience Public health, education and community sectors across Australia are operating at or beyond

capacity. Demand already exceeds supply for developmental assessment and intervention, and redirection of disability related needs to mainstream systems risks widening gaps in care. The lived experience described below illustrates the human cost of long waits and fragmented pathways.

Lived experience snapshot The author’s family experienced a four-year wait from initial referral to completion of a comprehensive neurodevelopmental assessment for an Autistic child. There was a two-year wait for an ongoing developmental paediatric review. These delays occurred despite persistent

advocacy and have had enduring effects on participation and well-being.

Case study one: *Ava and the impact of delay and inequity in Western Australia

Background

Ava is a bright and resilient child whose developmental journey has been marked by medical, developmental and systemic challenges. Their story shows how waits, bottlenecks and financial inequities in Western Australia place children at risk of long-term harm.

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Early medical challenges

By eighteen months, speech was largely unintelligible, creating distress and frustration.
Referrals included general practice, private paediatrics, public ear, nose and throat services with waits of approximately eighteen months for consultation and a further eighteen to thirty six months for possible surgery, and private ear, nose and throat review.
Obstructive sleep apnoea worsened with illness and led to repeated emergency presentations and hospital admissions.
Paediatric teams raised concerns about failure to thrive. Referrals were made to dietetics, Child Development Services and speech therapy. Child Development Services declined two referrals, deferring involvement until after surgery.
Surgery proceeded, but complications created further medical trauma and reinforced systemic delay.

Developmental pathway

After surgery, Child Development Services accepted the referral following two earlier rejections.
Despite the need for surgery, Ava would have benefited from early developmental assessment and clinical oversight of social-emotional difficulties. Waiting compounded challenges with speech, frustration tolerance and regulation.
From referral to final assessment, the process took four years and culminated in a Level Two Autism diagnosis.

Impacts on the child and the family

Speech and communication remained compromised during toddlerhood and preschool.
Emotional regulation difficulties emerged early and were linked to communication barriers and lack of timely intervention.
Rigid food preferences developed, likely related to prolonged breathing and airway difficulties, with dietetics noting probable links.
Social participation was restricted, with conflict in play and heightened overwhelm. 4

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Transitions across settings were distressing without tailored strategies.
School refusal developed by Year two.
As a single parent on Centrelink and child support with part-time work, self-funding a private assessment was not feasible. Reliance on public pathways was unavoidable.
Advocacy burdens and emotional strain compounded family stress. Current supports Following National Disability Insurance Scheme access, Ava was able to develop a stable team including Psychology, Occupational Therapy, Speech Pathology and a social skills group. Gains have been achieved, although the late start limited the extent of progress relative to earlier

intervention.

Systemic barriers

Gatekeeping led to two rejected referrals despite clear social-emotional concerns.
Waits included approximately eighteen months for ear, nose and throat consultation, eighteen to thirty-six months to surgery, and four years from Child Development Services referral to completed neurodevelopmental assessment.
Public services were capped at limited sessions per discipline with no long-term support.
Fragmented pathways created duplication and stress.
Financial inequity meant private access could buffer delays, while low-income families faced prolonged waits.

Broader implications Children’s outcomes are shaped by postcode, parental finances and system bottlenecks. Extended waits for ear, nose and throat intervention and neurodevelopmental assessment leave children unsupported during critical windows for language, regulation and social development.

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Case study two: Ava at school

Background

By mid-year two, Ava experienced significant school-related distress that progressed to clear school refusal. Sensory overwhelm, rigid expectations and high demands exceeded capacity for self-regulation.

Escalating concerns

Attendance dropped to sixty-four percent.
Requests for urgent support were delayed for ten months while internal processes were followed.
The school prioritised internal psychology and observations before considering referral to the School of Special Educational Needs Disability, even after implementing recommendations from Ava’s occupational therapist.
During this time, distress and lost learning continued. Intervention and response
After firm advocacy, the School of Special Educational Needs Disability was engaged. However, this came at a significant burden to Ava’s parent. The school acknowledged their lack of awareness of Pathological Demand Avoidance and initially resisted when the parent

provided a professional PDA webinar resource.

This illustrated a top down approach that lacked genuine child centred care.
Once engaged, participation improved with strategies aligned to a Pathological Demand Avoidance profile.
Prior to this, the absence of Pathological Demand Avoidance informed approaches escalated Ava’s distress.

Illustrative incident

A physical education teacher responded with punitive and authoritarian practices that escalated distress and undermined engagement.

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This demonstrated a gap in trauma-informed, neuro-affirming and mental health aware practice. This event had a significant impact on Ava’s ability to attend school, which resulted in their education assistant needing to attend sports with them.

Systemic barriers in education

Delays in specialist input.
Inadequate training in neurodivergence and associated needs.
Rigid internal gatekeeping before external support, mirroring health system bottlenecks.
Reduced attendance and inconsistent accommodations significantly affected progress during critical learning windows.

Broader implications Western Australian schools are not adequately equipped to meet the needs of neurodivergent students, particularly those with multiple diagnoses like Ava (Autism Level 2, ADHD – Inattentive Subtype & Pathological Demand Avoidance). Reliance on parental advocacy before meaningful support is accessed creates inequity.

Evidence-based understanding of Autism Autism spectrum disorder is a neurodevelopmental condition characterised by persistent

difficulties in social communication and interaction, alongside restricted and repetitive patterns of behaviour, interests or activities (American Psychiatric Association, 2022). These features are lifelong. Symptom expression and functional impact fluctuate across the lifespan but do not fully remit (Hong et al., 2023; Lord et al., 2020). Severity specifiers indicate the degree of support required at diagnosis and reflect enduring disability for many individuals at Levels two and three (American Psychiatric Association, 2022).

Neurobiological studies demonstrate atypical patterns of connectivity and processing that remain stable over time (Lord et al., 2020). Interventions can improve adaptive functioning and reduce barriers; however, core differences remain, and functional impairments often persist

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into adulthood (Hong et al., 2023). Impacts are broad across social communication, flexibility, sensory processing, adaptive living and participation in education and employment, with increased risks of loneliness and exclusion (Allison et al., 2023; The Lancet Psychiatry, 2016). Internalising symptoms are common. Contemporary research suggests that anxiety and depression in many Autistic people are best understood as arising from Autism specific mechanisms and environmental mismatch rather than as distinct psychiatric disorders in all cases. Mechanisms include intolerance of uncertainty, sensory over-responsivity, camouflaging/masking and exposure to social adversity such as bullying (Khudiakova et al., 2024; Leekam and Igelström, 2024; Rodgers et al., 2021; Zheng et al., 2024). Longitudinal evidence indicates a bidirectional relationship between camouflaging and mental health

problems (van der Putten et al., 2025). Clinical assessment, therefore, requires Autism informed formulation to avoid misdiagnosis and diagnostic overshadowing (Hudson et al., 2024; Rodgers et al., 2021).

Early childhood neurodevelopmental issues Neurodevelopmental disorders emerge early and impact learning, communication, behaviour and adaptive functioning. Diagnostic categories include intellectual disability, communication

disorders, Autism, Attention-Deficit/Hyperactivity Disorder, Specific Learning Disorder and

motor disorders (American Psychiatric Association, 2022). Each category requires tailored

supports, with co-occurrence common and associated with greater functional complexity (Autism CRC, 2024; Visser et al., 2016).

Early years are critical due to higher levels of brain plasticity, and early intervention is associated with long-term benefits in language, adaptive skills and social functioning (Dawson et al., 2010; Trembath et al., 2022). Supports range from parent-mediated interventions and school-based supports for communication disorders, to combined behavioural and pharmacological approaches for Attention-Deficit/Hyperactivity Disorder, and multidisciplinary interventions for Autism, including augmentative and alternative communication where

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indicated (Ebbels et al., 2019; Faraone et al., 2021; Schreibman et al., 2015; Zwaigenbaum et al., 2015).

Differentiating Autism levels and aligning support Severity specifiers provide a framework for linking support intensity with functional need. Autism Level one indicates noticeable difficulties without supports, often benefiting from adapted cognitive behavioural therapy, peer-mediated social skills and classroom strategies (American Psychiatric Association, 2022; Spain et al., 2015). Level two reflects marked impairments and requires multidisciplinary interventions, with integrated approaches targeting adaptive functioning, communication and co-occurring difficulties (American Psychiatric

Association, 2022; Gotham et al., 2020). Level three requires intensive, high-frequency and individualised supports, including augmentative and alternative communication, intensive developmental programs and one-to-one support in education (Lord et al., 2020). Early intensive supports predict better adaptive outcomes and reduced caregiver burden compared with delayed intervention (Bal et al., 2020). Functional capacity can change over time with appropriate supports, reinforcing the need for regular review (Trembath et al., 2022). Adaptive functioning assessments such as the Vineland-3 and ABAS-3 are more reliable indicators of support requirements than diagnostic labels alone (Harrison and Oakland, 2015; Sparrow et al., 2016; Tillmann et al., 2019).

The harms of vague labels Descriptors such as mild or moderate lack precision and obscure functional needs, increasing the risk of delayed or inadequate support (Lai et al., 2020). Generic labels do not capture context, co-occurrence or ecological validity, and can contribute to stigma and inequity in resource allocation (Botha and Gillespie Lynch, 2022; Emerson and Hatton, 2014; Hodges et al., 2020; Yerys et al., 2019). International best practice emphasises function-based assessment focused on participation, strengths and specific support needs, consistent with the International Classification of Functioning, Disability and Health and the Autism CRC national framework (Autism CRC, 2024; World Health Organization, 2001; Fitzpatrick et al., 2024).

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Autism CRC assessment protocols

The National Framework for Assessing Children’s Functional Strengths and Support Needs

provides a comprehensive approach to evaluating participation, strengths and support needs, grounded in child and family centred principles, cultural responsiveness and ecological validity (Autism CRC, 2024; Fitzpatrick et al., 2024). The framework integrates the F-words-in-childhood disability model, which recommends mixed methods, including interviews, observation and standardised inventories such as ABAS-3 and Vineland-3, interpreted alongside qualitative information to avoid reductionism (Harrison and Oakland, 2015; Rosenbaum and Gorter, 2012; Sparrow et al., 2016; Tillmann et al., 2019). Timeliness is emphasised to protect early

intervention windows (Autism CRC, 2024).

Comorbidities and implications for the National Disability Insurance Scheme Comorbidities are common in Autism and intensify functional complexity. Attention Deficit/Hyperactivity Disorder occurs in an estimated thirty to fifty percent of Autistic children and predicts poorer adaptive functioning, increased behavioural dysregulation and academic difficulty compared with Autism alone (Lai et al., 2019; Yerys et al., 2019). Executive dysfunction across conditions further impairs participation and daily living (Sadozai et al., 2024). Families of children with dual diagnoses report greater stress and higher support needs, including respite

and sustained multidisciplinary intervention (Visser et al., 2016).

Pathological Demand Avoidance, while not a formal diagnostic category in DSM-5-TR, is increasingly recognised as a clinical profile within the Autism spectrum that is characterised by extreme demand avoidance, high situational anxiety and limited response to conventional behavioural approaches. Evidence supports low-demand environments, collaborative problem solving and anxiety-focused strategies for improved outcomes (Christie et al., 2019; Gillberg et al., 2021; O’Nions et al., 2020). When Autism at Level two or three co-occurs with Attention Deficit/Hyperactivity Disorder or Pathological Demand Avoidance traits, intensive and sustained supports across home, school and community are required. In these circumstances,

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classification as ‘permanent and substantially limiting’ under the National Disability Insurance Scheme is consistent with clinical evidence and functional reality.

Child Development Services and Autism Assessment Pathways in Australia

Access to assessment is variable across jurisdictions, with extended waitlists and capacity constraints common despite national guidance promoting multidisciplinary and culturally responsive practice (Autism CRC, 2024). Western Australia has acknowledged unprecedented demand and prolonged delays, with a parliamentary inquiry underway into Child Development Services and a separate state Neurodevelopmental and Autism Service pathway that requires specialist endorsement for referral (Government of Western Australia, 2024a; Government of

Western Australia, 2024b; Select Committee into Child Development Services, 2024). Tasmania

publishes transparent waiting time data that indicate waits of many months for developmental and behavioural paediatrics, with statewide outreach through the Tasmanian Autism Diagnostic Service (Department of Health Tasmania, 2024; Tasmanian Health Service, 2025). Other states report significant pressure, variable transparency and triage practices that prioritise some vulnerable groups while leaving others with long waits, including Queensland, Victoria and South Australia (Clinical Excellence Queensland, 2023; SA Health, 2024; Western Health, 2025;

Victorian Government, 2024; ABC News, 2024). New South Wales and the Australian Capital

Territory provide specialist assessment services for complex presentations but have limited

public reporting of waiting times (ACT Government, 2024; Sydney Children’s Hospitals Network, 2024). Overall, demand exceeds capacity nationwide.

Legal and human rights considerations Using non-diagnostic and non-functional categories to gate access to supports raises significant legal and human rights concerns. The Disability Discrimination Act 1992 prohibits direct and indirect discrimination on the basis of disability, including policies that disproportionately disadvantage people with disability without reasonable justification. Reliance on vague categories such as mild or moderate Autism risks excludes people whose impairments substantially impact daily living and may amount to unlawful discrimination if equal access to

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services is denied (Australian Human Rights Commission, 2020; Disability Discrimination Act, 1992). Australia’s obligations under the Convention on the Rights of Persons with Disabilities include the right to inclusive education with appropriate supports and early, tailored habilitation and rehabilitation. Gatekeeping through non-functional categories undermines these commitments (Degener, 2016; United Nations, 2006).

Recommendations

Differentiation of Needs: Move away from vague “mild/moderate” labels toward functional, individualised assessments (Autism CRC, 2024). Intersectionality: Acknowledge compounded disadvantage for Autistic children with co

occurring conditions, trauma, and socio-economic disadvantage. System Capacity: Do not push disability-specific needs into already overburdened mainstream systems; resource both adequately. Tiered Models: Avoid replicating failed mental health tiered models that leave children between thresholds. Psychological Input: Embed psychologists in policy design, assessment, and service delivery at all levels. Assessment Protocols: Use mixed-methods (ABAS-3, Vineland-3, interviews, observations) within a strengths-based, family-centred model.

Timeliness: Reduce wait times for developmental assessments and publish transparent wait time data across jurisdictions. Legal & Rights Alignment: Ensure compliance with the Disability Discrimination Act 1992 and CRPD by grounding access in functional need, not arbitrary categories. School Systems: Increase PDA-informed training, trauma-informed and neuro-affirming practice, and reduce reliance on parental advocacy. Support for Families: Recognise unique pressures on single-parent households of disabled children and provide equitable, sustainable access to disability supports (particularly through NDIS).

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Summary

The Thriving Kids Initiative presents an important opportunity to reshape developmental and disability supports for Australian children. However, without careful attention to evidence and lived experience, the Initiative risks creating greater inequity. This submission highlights five critical concerns: the need to differentiate between emerging difficulties and permanent disability; recognition of intersectionality, particularly for Autistic children with co-occurring conditions; the urgent strain on health, education and community systems; the risks of replicating failed tiered service models; and the necessity of embedding psychological expertise at every level.

Through lived experience and case study, the submission demonstrates the human cost of systemic delays, fragmented pathways and inadequate school responses. It also shows the impact of inequities on single-parent families navigating disability services. Contemporary research and national guidelines provide clear direction: supports must be timely, individualised, function-based, and responsive to the complexity of children’s lives.

The recommendations offered call for practical reform, clearer differentiation of need, increased capacity in mainstream and disability services, transparent wait time reporting, neuro-affirming school practices, recognition of single-parent pressures, and alignment with

Australia’s legal and human rights obligations. Together, these measures will help ensure the Thriving Kids Initiative is equitable, sustainable and truly evidence-informed, giving all children the opportunity to thrive.

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