Submission to the Standing Committee on Health, Aged Care and Disability

October 2025

About NACCHO

NACCHO is the national peak body representing 148 Aboriginal Community Controlled Health Organisations (ACCHOs). We also assist several other community-controlled organisations.

The first Aboriginal medical service was established at Redfern in 1971 as a response to the urgent need to provide decent, accessible health services for the largely medically uninsured Aboriginal population of Redfern. The mainstream was not working. So it was, that over fifty years ago, Aboriginal people took control and designed and delivered their own model of health care. Similar Aboriginal medical services quickly sprung up around the country. In 1974, a national representative body was formed to represent these Aboriginal medical services at the national level. This has grown into what NACCHO is today. All this predated Medibank in 1975.

NACCHO liaises with its membership, and the eight state/territory affiliates, governments, and other organisations on Aboriginal and Torres Strait Islander health and wellbeing policy and planning issues and advocacy relating to health service delivery, health information, research, public health, health financing and health programs.

ACCHOs range from large multi-functional services employing several medical practitioners and providing a wide range of services, to small services which rely on Aboriginal health practitioners and/or nurses to provide the bulk of primary health care services. Our 148 members provide services from about 550 clinics. Our sector provides over 3.1 million episodes of care per year for over 410,000 people across Australia, which includes about one million episodes of care in very remote regions.

Our services build ongoing relationships to give continuity of care so that chronic conditions are managed, and preventative health care is targeted. Through local engagement and a proven service delivery model, our clients ‘stick’. Clearly, the cultural safety in which we provide our services is a key factor of our success.

ACCHOs are also closing the employment gap. Collectively, we employ about 7,000 staff – 54 per cent of whom are Aboriginal or Torres Strait Islanders – which makes us the third largest employer of Aboriginal or Torres Strait people in the country.

Enquiries about this submission should be directed to:

NACCHO
Level 5, 2 Constitution Avenue
Canberra City ACT 2601
Telephone: 02 6246 9300
redacted
Website: naccho.org.au

Recommendations

NACCHO recommends:

the Thriving Kids Initiative is explicitly aligned with the National Agreement and its four Priority Reform Areas.
funding for Aboriginal and Torres Strait Islander-specific programs under Thriving Kids is delivered through the ACCHO sector, and led by NACCHO to ensure national oversight of targeted early childhood detection and intervention supports.
the ACCHO sector is represented on the Thriving Kids Advisory Group.
Thriving Kids funding agreements for mainstream providers include a requirement for staff cultural awareness training, and accountability for the delivery of culturally responsive care to Aboriginal and Torres Strait Islander children and their families.
cultural supports are included within the Thriving Kids initiative.
findings from NACCHO’s sector-led training needs analysis are built upon to identify workforce required to deliver the Thriving Kids Initiative
a sector mapping and capability review be undertaken to determine the level of thin and culturally-thin market support and intervention required.
workforce development training and pathways for ACCHO/ACCO staff is delivered through the existing network of ACCRTOs.
funding for a national sector-led health promotion campaign around neuro-developmental delay that enables ACCHOs to deliver place-based promotion and educational activities for families.
extension of funding to enable the continued roll-out of ASQ-TRAK training to meet the demand from the ACCHO sector.

Acknowledgements

NACCHO welcomes the opportunity to provide a submission to the Inquiry into the Thriving Kids initiative, and is happy to be involved in further discussions and involved in the ongoing implementation of the Thriving Kids Initiative.

NACCHO would like to acknowledge the valuable input received to this submission, from:

Aboriginal Health Council of South Australia
Aboriginal Health Council of Western Australia
Aboriginal Medical Services Alliance Northern Territory
Victorian Aboriginal Community Controlled Health Organisation
Kimberley Aboriginal Medical Services
Victorian Aboriginal Health Service.

NACCHO would like to extend that acknowledgement to all the ACCHOs and staff working on the programs mentioned throughout – as well as all those working without funding to support Aboriginal and Torres Strait Islander children living with disability.

NACCHO also supports the submissions to this consultation made by NACCHO Members and Affiliates.

National Agreement on Closing the Gap

Advocating for and securing the National Agreement on Closing the Gap was an historically significant act of Aboriginal and Torres Strait Islander self-determination. The National Agreement is evidence of a new era of engagement by and with Aboriginal and Torres Strait Islander people. It commits Australia to a new direction and is a pledge from all governments to fundamentally change the way they work with Aboriginal and Torres Strait Islander communities and organisations – to support self-determination and build the capacity of the community-control sector.

The reforms and targets outlined in the National Agreement seek to overcome the inequality experienced by Aboriginal and Torres Strait Islander people and achieve life outcomes equal to all Australians. Governments at all levels have committed to the implementation of the National Agreement’s four Priority Reform Areas, which offer a roadmap to meaningfully impact structural drivers of poor health and social outcomes for Aboriginal and Torres Strait Islander people:

Priority Reform Area 1 – Formal partnerships and shared decision-making

This Priority Reform commits to building and strengthening structures that empower Aboriginal and Torres Strait Islander people to share decision-making authority with governments, and to accelerate policy making that centres Aboriginal and Torres Strait Islander voices.

Priority Reform Area 2 – Building the community-controlled sector

Recognising that community-controlled services achieve better outcomes, employ more Aboriginal and Torres Strait Islander people and are often preferred over mainstream services, this Priority Reform commits to building Aboriginal and Torres Strait Islander community-controlled sectors to deliver services to support Closing the Gap.

Priority Reform Area 3 – Transformation of mainstream institutions

This Priority Reform commits to systemic and structural transformation of government organisations to identify and eliminate racism, embed and practice cultural safety, deliver services in partnership

with Aboriginal and Torres Strait Islander people, support truth telling about agencies’ history with Aboriginal and Torres Strait Islander people, and engage fully and transparently with Aboriginal and Torres Strait Islander people when programs are being changed.

This Priority Reform commits to shared access to regional data and information to inform local-decision making and support achievement of the first three Priority Reforms. This Priority Reform supports principles of Indigenous Data Sovereignty.

Despite some progress, the need for fundamental systemic reform remains evident. In its first review of the National Agreement on Closing the Gap, the Productivity Commission found that governments are not adequately delivering on their commitments. Despite support for the Priority Reforms and some good practice, progress has been slow, uncoordinated, and piecemeal.

The Commission noted that to enable better outcomes, governments needs to relinquish some control, share decision making and acknowledge that Aboriginal and Torres Strait Islander people know what is best for their communities. Aboriginal Community Controlled Organisations must be treated as critical partners rather than passive funding recipients, and trusted to design, deliver and measure government services in ways that are culturally safe and meaningful for their communities.

‘Too many government agencies are implementing versions of shared decision-making that involve consulting with Aboriginal and Torres Strait Islander people on a pre-determined solution, rather than collaborating on the problem and co-designing a solution’.^1

NACCHO recommends the Thriving Kids Initiative is explicitly aligned with the National Agreement and its four Priority Reform Areas.

Background

The Thriving Kids Initiative will focus on identifying developmental concerns earlier and establishing a national system of supports for children aged 8 and under with mild to moderate developmental delay and autism, and their families. The program will be delivered by scaling and building on existing mainstream and community services that can better support families and children in settings they already are connected to. This includes child and maternal health, GPs, playgroups, early childhood education and care and schools, as well as digital and phone-based supports.^2

NACCHO is concerned at the lack of clarity on how Thriving Kids will be implemented, and the lack of consultation prior to its announcement. It is also unclear exactly what supports will be provided under Thriving Kids. The program’s architecture should ensure no child is worse off or left in the limbo between Thriving Kids supports and the NDIS.

Thriving Kids cannot be used as a vehicle to reduce the number of children receiving supports. It is critical that children being transitioned off the NDIS have a pathway to get back onto the NDIS later in life if needed, via streamlined eligibility processes. In remote areas, often children are only screened for developmental vulnerability as they begin school at 7 or 8 years of age. Currently the NDIS only accepts new applicants with developmental delay up to age 6. There must be additional pathways for

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^1 Productivity Commission, Review of the National Agreement on Closing the Gap, Study Report, Canberra, 7 Feb 2024 https://www.pc.gov.au/inquiries/completed/closing-the-gap-review/report.

^2 Department of Health, Disability and Ageing (DHDA), Thriving Kids – Fact Sheet, August 2025, https://www.health.gov.au/resources/publications/thriving-kids-fact-sheet?language=en.

children identified as having support needs though Thriving Kids screening and diagnosis, who are technically ineligible for the NDIS due to age. Continuing supports should also be available for children who participate in Thriving Kids when they age out of the program.

Early intervention for Aboriginal and Torres Strait Islander children

Early intervention programs are particularly important for Aboriginal and Torres Strait Islander children, who in the 2021 Australian Early Development Census were 20% more developmentally vulnerable on one or more domains, compared to non-Indigenous children (42% compared with 22%).^3

Dedicated services that can facilitate screening, streamline referral pathways and improved service integration for children with developmental concerns, is critically needed in the ACCHO sector. Many ACCHOs have established early childhood services and programs in response to need, however many are not well resourced, rely on a patchwork of grant and funding agreements, and are at capacity with waitlists.

Within ACCHOs, primary health care is planned and delivered with the active participation of the community it serves, and is highly aware of the social, economic, historical and political determinants of health. Responsiveness to community need and inclusiveness in action are immutable characteristics of ACCHO service delivery. In this way, ACCHOs provide more than just primary care. They deliver whole-of-person care that provides primordial prevention through addressing environmental, economic, social and behavioural conditions known to increase the risk of disease. This includes food security, housing, economic prosperity, general education and literacy.

Aboriginal and Torres Strait Islander people are twice as likely to experience disability than other Australians. Aboriginal children are twice as likely to be developmentally vulnerable at school entry.

Currently, Aboriginal and Torres Strait Islander people do not access disability services or early intervention supports at a rate commensurate with their level of need. NACCHO’s 2019 NDIS Capacity Building Report^4 notes there are multiple factors contributing to lower access and utilisation rates for Aboriginal and Torres Strait Islander people, including:

Limited or no availability of disability services in Aboriginal communities (thin markets)
The need to provide evidence of disability and the burden on health systems to supply this
Difficulty navigating the system
A lack of culturally appropriate and/or trauma informed mainstream disability service provision (culturally thin markets)
Experiences of systemic and interpersonal racism
Distrust of institutional care as a result of both personal and historical experiences.

While up-take of the NDIS by Aboriginal and Torres Strait Islander people is increasing – NDIS Quarterly reports for 2022-23 show that Aboriginal and Torres Strait Islander people consistently make up more than 9% of new participants to the Scheme^5 - plan utilisation is poor with many Aboriginal and Torres Strait Islander people unable to access vital services and/or culturally safe services.

Thriving Kids is a vehicle for system-wide reform. It provides an opportunity for ACCHOs to build capacity and provide further services within their communities. If implemented effectively and integrated within existing systems, the Thriving Kids initiative presents a valuable opportunity to

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^3 Australian Institute of Health and Welfare (AIHW), Education of First Nations people, September 2023, https://www.aihw.gov.au/reports/australias-welfare/indigenous-education-and-skills#Early%20child%20development

^4 Available from NACCHO on request.

^5 National Disability Insurance Scheme, Archived quarterly reports 2022-23, https://www.ndis.gov.au/about-us/publications/quarterly-reports/archived-quarterly-reports-2022-23.

overcome current barriers to accessing support and build capacity within the community-controlled sector, in line with Priority Reform 2 of the National Agreement.

Importance of an ACCHO-led approach

ACCHOs are central to the success of Thriving Kids—not just due to their established track record in delivering holistic, culturally safe services, but because of their leading role in health system advocacy and reform for Aboriginal and Torres Strait Islander communities. As already trusted members of the community, they also provide continuity of care for children. They are optimally positioned to support children and their parents/carers to respond to what child may need in everyday environments to learn and thrive.

ACCHOs deliver better results for Aboriginal and Torres Strait Islander people than mainstream services.^6,7 Supporting ACCHOs to deliver disability supports and NDIS services, responds to the commitment all governments have made to Closing the Gap, and the four priority reforms. It also responds to recommendation 9.5 of the Royal Commission. As the NDIS Review states, community-led and place-based funding approaches would improve outcomes for Aboriginal and Torres Strait Islander communities and for all participants nationally.

ACCHOs contribute to improving Aboriginal and Torres Strait Islander health and wellbeing through the provision of comprehensive primary health care, and by integrating and coordinating care and services. Many provide home and site visits; medical, public health and health promotion services; allied health; nursing services; assistance with making appointments and transport; help accessing childcare or dealing with the justice system; drug and alcohol services; and help with income support. ACCHOs are best-placed to provide the care that Aboriginal and Torres Strait Islander people need and should be funded universally to provide care or all types to our people in all settings. As the NDIS Review highlighted, a lack of culturally safe disability supports often means Aboriginal and Torres Strait Islander people with disability, need to choose between supports that are not culturally safe or not getting supports at all. ACCHOs are well positioned to respond as they are highly visible and trusted in Aboriginal and Torres Strait Islander communities. Aboriginal and Torres Strait Islander people have a clear preference to access community-controlled services, many bypassing mainstream services to access an ACCHO, where they are confident their cultural safety is guaranteed.^8

In early 2024, 39 ACCHOs were delivering NDIS supports nationally. Of these, 23 were active^9 registered NDIS providers, and 13 located in remote or very remote areas. Currently, NACCHO is undertaking a national survey to identify whether this has changed in the last 18 months. Many ACCHOs are maintaining and strengthening quality disability and allied health service delivery for their communities through existing programs, as well as many delivering fee-for-service NDIS services as both registered and unregistered providers. Critically, the majority of ACCHOs offer maternal and early childhood services and participate in the Connected Beginnings Program.

ACCHOs must be explicitly identified in the strategy as key stakeholders to strengthening the developmental delay and disability ecosystem for Aboriginal and Torres Strait Islander people. Enhancing the role of ACCHOs and ACCOs to deliver neurodevelopmental delay and early

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^6 Pearson, O., Schwartzkopff, K., Dawson, A. et al. Aboriginal community controlled health organisations address health equity through action on the social determinants of health of Aboriginal and Torres Strait Islander peoples in Australia. BMC Public Health 20, 1859 (2020). https://doi.org/10.1186/s12889-020-09943-4.

^7 Mackean Tamara, Freeman Toby, Musolino Connie, Fry Denise, MacDougall Colin, Lewis Virginia, Baum Fran (2025) Leading the way: the contribution of Aboriginal community controlled health organisations to community health in Australia. Australian Journal of Primary Health 31, PY24223. https://doi.org/10.1071/PY24223

^8 Kathryn S Panaretto, Mark Wenitong, Selwyn Button and Ian T Ring, Aboriginal community controlled health services: leading the way in primary care, Med J Aust 2014; 200 (11): 649-652. | doi: 10.5694/mja13.00005

^9 Have drawn down NDIS payments in the 3-months prior to 31 August 2023.

intervention supports as well as NDIS services, ultimately improves access to culturally safe and effective services. This responds to the commitment all governments have made to Closing the Gap, and the four priority reforms.

Funding

A key component of Thriving Kids is the funding redesign, shifting away from individual NDIS plans for children under 9 who do not require specialist support, towards a population-funded, locally administered system of neurodevelopmental delay early intervention and wellbeing services.

A number of ACCHOs already provide disability and related services, most without adequate funding. When funding is provided, it is often short-term contracts. One member service reported that their contract for the Remote Community Connector program (a program through which community members are employed by local ACCHOs to assist in connecting to services, support workers and the NDIA) was only renewed on the day of its expiry. This makes it very difficult for ACCHOs to retain staff and provide continuous service. ACCHOs also report issues with staff leaving to join mainstream services as they can offer more stability. Understandably, this has a negative impact on outcomes for ACCHOs and for the Aboriginal and Torres Strait Islander communities they support.

A research report from Deloitte, coming out of the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability found that:

‘Community Controlled and Aboriginal Community Controlled Health Organisations frequently deliver disability services with inadequate funding and resourcing. Partnerships and shared service delivery arrangements between First Nations and non-Indigenous organisations are often transactional and usually favour the non-Indigenous organisation. Allied health providers often aren’t disability specialists and provide inadequate and culturally inappropriate services.’^10

ACCHOs needs to be appropriately funded for services provided under the Thriving Kids Initiative. NACCHO suggests funding is distinctly directed to ACCHOs for child-centred, family-focused and culturally safe approaches to: screening and referrals; assessment and diagnosis; and intervention and supports.

NACCHO suggests:

Funding ACCHOs to provide targeted early childhood detection and intervention supports. This enables ACCHOs to deliver place-based flexible, early childhood services and programs, to optimally screen, identify and respond to developmental difficulties and delays in children in their community.
Activity-based payments linked to specified, evidence-based service episodes.
Infrastructure funding to ensure ACCHOs can offer an appropriate service environment and equipment to deliver supports under Thriving Kids.

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^10 Deloitte, Research report – Options to improve service availability and accessibility for First Nations people with disability. 2020, https://disability.royalcommission.gov.au/system/files/2023-09/Research%20Report%20-%20Options%20to%20improve%20service%20availability%20and%20accessibility%20for%20First%20Nations%20people%20with%20disability.pdf.

Implementation

The implementation of the NDIS has placed an emphasis on individualised supports, which is at odds with First Nations culture and values of placing family and community first. This is consistent with the evidence and advice from our ACCHO sector which has demonstrated the market-driven, individualist model in its current format does not align with the comprehensive, integrated way in which ACCHOs approach the work within their communities.

The federal government, as part of its 2025–2027 social policy and health budget, allocated $1.5 billion over two years (potentially up to $2.2 billion with state and territory top-ups) to fund the rollout and scale-up of Thriving Kids. The funding is administered (and, where relevant, matched by states/territories) through the Department of Health, Disability and Ageing.

NACCHO is committed to working with commonwealth government and experts to help finalise the design and implementation arrangements for Thriving Kids, through our ongoing advocacy, continued community and sector consultation across multiple jurisdictions.

With demand redirected away from individualised NDIS plans, service providers must adapt to:

Population-based funding models
Improved service integration requirements
New accountability and outcome measurement frameworks.

In remote and regional areas, rigid NDIS pricing structures can prevent ACCHOs from delivering culturally safe supports. Between 2017 and 2022, 6 separate reviews and inquiries recommended alternative funding approaches, particularly in remote and very remote areas.^11 Flexible pricing would allow for tailored service models that reflect local needs and cost realities.

NACCHO previously compiled Making the NDIS Work ‘Our Way’ proposal with input and advice from member services, based on their deep expertise and local knowledge. This proposal outlined the opportunity for a significant, long-term national investment from the Commonwealth Government to support and grow the Aboriginal community-controlled disability service sector. It provides the foundation for a holistic response to improve the quality of life and health outcomes for Aboriginal and Torres Strait Islander people living with disability. NACCHO would be pleased to provide a copy of this document in confidence to the Committee.

The 2020 research report from Deloitte also found that “First Nations people’s NDIS plans are underutilised due to thin markets or unavailability of culturally appropriate services”.^12 Investing in ACCHOs and Aboriginal and Torres Strait Islander-led programs would support the development of the Aboriginal and Torres Strait Islander disability workforce. This is particularly important in remote areas where investment in ACCHOs would build local economies, reduce reliance on fly-in-fly-out services and enhance public spending efficiency by delivering services ‘with community, not to community’.

Implementation will not be without tension between the Commonwealth and states and territories, regarding the volume of funding, role clarity, and risk transfer. The roll-out of the National Skills Agreement – a joint agreement between the Commonwealth and states and territories to strengthen the Vocational Education and Training sector – has highlighted this. Aboriginal Community Controlled Registered Training Organisations (ACCRTOs) have had to make agreements with each jurisdiction, to ensure they receive funding under the National Skills Agreement. Small groups of ACCRTOs have

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^11 NDIS Review, Alternative commissioning for remote and First Nations communities, June 2023, https://www.ndisreview.gov.au/sites/default/files/resource/download/alternative-commissioning%200.pdf.

^12 Deloitte, Research report – Options to improve service availability and accessibility for First Nations people with disability. 2020, https://disability.royalcommission.gov.au/system/files/2023-09/Research%20Report%20-%20Options%20to%20improve%20service%20availability%20and%20accessibility%20for%20First%20Nations%20people%20with%20disability.pdf.

been required to negotiate with governments that have significantly more resourcing and legal knowledge. This has resulted in years-long delays in funding, and a significant administrative burden.

To avoid overburdening small services with high level negotiations, Thriving Kids should consider an alternative funding model. Centrally allocated funding could be administered through NACCHO. Funding ACCHOs through NACCHO will allow for them to have flexibility, ensuring that implementation is tailored to needs of their community. NACCHO can work with its Affiliates (state and territory peak bodies), and states and territory governments to ensure smooth rollout. This is the model for various national programs delivered through NACCHO, including Culture Care Connect, Elder Care Support and the First Nations Health Worker Traineeship Program.

NACCHO has previously recommended such a model to the NDIA to support sector capacity building and delivery of disability services to Aboriginal and Torres Strait Islander communities.

NACCHO recommends funding for Aboriginal and Torres Strait Islander-specific programs under Thriving Kids is delivered through the ACCHO sector, and led by NACCHO to ensure national oversight of targeted early childhood detection and intervention supports.

In the longer term, we recommend ACCHOs are funded to deliver disability services through the Indigenous Australians’ Health Programme or via needs-based funding.

Equity and intersectionality

Equity cannot not just be an afterthought – it needs to be a guiding principle for the entire Thriving Kids Initiative. As such, the National Agreement on Closing the Gap and its Priority Reforms need to be embedded throughout.

NACCHO stresses that one size does not, and cannot, fit all. Thriving Kids needs to allow for flexibility to suit the diversity in peoples’ situation and their specific needs.

NACCHO aligns with the First Nations Disability Network’s statement that the initiative “must be co-designed, community led and it must protect choice and control for First Nations families“.^13 Aboriginal and Torres Strait Islander people need to be partners in the design and implementation of Thriving Kids. The Thriving Kids Advisory Group, which is yet to meet, must include Aboriginal and Torres Strait Islander members and members from the community-controlled health/disability sector.

NACCHO recommends the ACCHO sector is represented on the Thriving Kids Advisory Group.

We know that the cost of autism assessments is a barrier for some Aboriginal and Torres Strait Islander children to seek diagnoses. The Thriving Kids Initiative needs to consider this barrier and how to enable assessments – for autism, ADHD, FASD and developmental delay for all who require them.

NACCHO notes the compounding impact of intersectionality and the need for approaches to be grounded in cultural safety and cultural appropriateness. Culture is a key protective factor and can help in service delivery, and build strength in communities.^14 The Pathways to Good Health Program, which delivers health screening, assessment, planning and referral to Victorian children and young

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^13 First Peoples Disability Network, FPDN to Minister Butler: Don’t Leave First Nations Kids Behind, Blueprint for Thriving Kids Success, August 2025, https://fpdn.org.au/fpdn-to-minister-butler-thriving-kids/

^14 Hunter, S.-A., Skouteris, H., & Morris, H. (2021). A Conceptual Model of Protective Factors Within Aboriginal and Torres Strait Islander Culture That Build Strength. Journal of Cross-Cultural Psychology, 52(8-9), 726-751. https://doi.org/10.1177/00220221211046310.

people aged 0-17 years entering or re-entering statutory care.^15 As part of this program, the Victorian Aboriginal Community Controlled Health Organisation (VACCHO) have been leading work to deliver for Aboriginal children and their carers in ACCHOs.^16

Cultural safety

ACCHOs provide services to over 500,000 people annually.^17 Not every Aboriginal and Torres Strait Islander person chooses to or is able to access an ACCHO. Indeed, nationally 20% of Aboriginal and Torres Strait Islander people said they wanted to access an ACCHO but were unable to do so where they were living.^18

The disability workforce in mainstream services therefore needs to be culturally safe and be capable of trauma-informed care. Ensuring there are culturally safe diagnosis, supports and services is paramount for Aboriginal and Torres Strait Islander communities to ensure there is equity in social, economic and cultural participation.

Currently, Aboriginal and Torres Strait Islander people do not access diagnosis, early intervention supports or disability services at a rate commensurate with their level of need. Critically, the Disability Royal Commission has found that Aboriginal and Torres Strait Islander NDIS participants are 28% less likely to receive care via the NDIS than their non-Indigenous counterparts. The Commission found some of these disability services could be described as ‘unsafe, traumatising and inequitable’.^19

‘Non-Indigenous service providers are more likely to deliver culturally inappropriate services and are less culturally informed about individual and community needs. The ongoing legacy of historical and systemic trauma is compounding for First Nations people with Disability and manifests differently in the sector. First Nations people with disability often feel invisible in the system.’^20

Government is obligated to change the way it works, in line with commitments under Priority Reform 3 of the National Agreement. One suggested transformation is to embed delivery of culturally safe care within mainstream Thriving Kids funding contracts.

NACCHO recommends Thriving Kids funding agreements for mainstream providers include a requirement for staff cultural awareness training, and accountability for the delivery of culturally responsive care to Aboriginal and Torres Strait Islander children and their families.

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^15 Victoria State Government Department of Health, Pathways to good health for children in care, July 2025, https://www.health.vic.gov.au/populations/vulnerable-children/pathway-to-good-health-for-children-in-care.

^16 Victorian Aboriginal Community Controlled Health Organisation, Opinion: National Aboriginal and Torres Strait Islander Children’s Day: Little footsteps, big future, August 2025, https://www.vaccho.org.au/2025/08/04/opinion-national-aboriginal-and-torres-strait-islander-childrens-day-little-footsteps-big-future/.

^17 NACCHO, NACCHO Key Facts, November 2024, https://www.naccho.org.au/app/uploads/2024/12/NAC_NACCHOKeyFacts_241125_Online.pdf.

^18 NACCHO, NACCHO Key Facts, November 2024, https://www.naccho.org.au/app/uploads/2024/12/NAC_NACCHOKeyFacts_241125_Online.pdf.

^19 Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability, The lack of NDIS services for First Nations people with a disability ‘a national crisis’, June 2023, https://disability.royalcommission.gov.au/news-and-media/media-releases/lack-ndis-services-first-nations-people-disability-national-crisis.

^20 Deloitte, Research report – Options to improve service availability and accessibility for First Nations people with disability. 2020, https://disability.royalcommission.gov.au/system/files/2023-09/Research%20Report%20-%20Options%20to%20improve%20service%20availability%20and%20accessibility%20for%20First%20Nations%20people%20with%20disability.pdf.

Cultural supports

Aboriginal and Torres Strait Islander people have long affirmed that health is not solely a biomedical concept, but one that encompasses cultural, ecological, and spiritual dimensions.^21 Maintaining relationships with land, waters, and cultural practices is essential to holistic wellbeing.^22 Embedding these principles into disability policy and practice—through culturally responsive supports and cross-agency collaboration—will contribute to more inclusive, effective, and sustainable outcomes for Aboriginal and Torres Strait Islander participants. Culturally safe, equitable, and community-informed disability supports should be available for Aboriginal and Torres Strait Islander people.

Healing on Country programs where participants engage in cultural activities guided by Elders—such as bush medicine preparation, storytelling, and ceremony not only provide therapeutic benefits but also strengthen identity, community connection, and emotional resilience. Similarly, therapies that reconnect participants with traditional languages are vital for cultural continuity and mental wellbeing yet are rarely recognised under standard support categories.^23

Thriving Kids must ensure transparency and protection for culturally grounded and community-led supports. There is long-standing place-based^24 use of traditional medicine by Aboriginal and Torres Strait Islander people within the culturally safe context of providing disability services, recognising and celebrating the cultural diversity of Aboriginal and Torres Strait Islander communities.

In order to provide culturally appropriate care to Aboriginal and Torres Strait Islander people, Thriving Kids must include cultural supports.

NACCHO recommends cultural supports are included within the Thriving Kids initiative.

Workforce

ACCHOs should be considered a critical part of the disability service eco-system and therefore be considered as an essential service, with support to scale up and work in partnership with other organisations regarding referrals.

Aboriginal and Torres Strait Islander people are underrepresented in the care workforce across the country, particularly in remote communities.^25 There needs to be workforce development opportunities to upskill existing workers to recognise developmental delay and support children and families navigate through referrals and obtaining supports.

NACCHO has supported ACCHO staff to undertake ASQ-TRAK2 Practitioner Training to learn how to administer the ASQ-TRAK2 screening tool. However, the demand for training outpaces NACCHO’s current ability to facilitate training – with more than 700 applications for just 200 training places. There

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^21 AIHW, Indigenous Mental Health and Suicide Prevention Clearinghouse, July 2025, https://www.indigenousmhspc.gov.au/topics/culture-country-spirituality#keystatistics

^22 Johnston. F.H., Jacklyn, Susan, Vickery, Amy and Bowman, D.M.J.S, ‘Ecohealth and Aboriginal testimony of the nexus between human health and place’, EcoHealth, vol.4, 2007, 489-499.

^23 Roxanne Bainbridge, Janya McCalman, Anton Clifford and Komla Tsey (for the Closing the Gap Clearinghouse), Cultural competency in the delivery of health services for Indigenous people. AIHW, 2015, https://www.aihw.gov.au/reports/indigenous-australians/cultural-competency-in-the-delivery-of-health-serv/summary

^24 Erin J. Rooney, Rhonda L. Wilson & Amanda Johnson (2023) Integration of traditional therapies for first nations people within western healthcare: an integrative review, Contemporary Nurse, 59:4-5, 294-310, DOI: 10.1080/10376178.2023.2276718.

^25 Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability, The lack of NDIS services for First Nations people with a disability ‘a national crisis’, June 2023, https://disability.royalcommission.gov.au/news-and-media/media-releases/lack-ndis-services-first-nations-people-disability-national-crisis.

remains an urgent need to scale training in child development screening and assessment in the ACCHO sector in a culturally appropriate manner.

The first step in addressing this should be to carry out a sector-led training needs analysis across the country, to determine:

Current skills of the workforce.
Opportunities for upskilling to help deliver additional support.
How to better support and grow the existing workforce.
Other workforce gaps.

NACCHO is currently undertaking a training needs analysis across ACCHOs on integrated care across the disability support and aged care workforces – with a report due to be finished by end of October. This report will provide some relevant insights, however, consultation began before Thriving Kids was announced and does not focus on training needs relating to children and developmental delay. Further consultation will need to be undertaken, focussing on Thriving Kids, and including ACCRTOs.

NACCHO recommends findings from NACCHO’s sector-led training needs analysis are built upon to identify workforce required to deliver the Thriving Kids Initiative.

NACCHO recommends a sector mapping and capability review be undertaken to determine the level of thin and culturally-thin market support and intervention required.

ACCHOs – particularly those in in remote and very remote areas – have existing issues with staff recruitment and retention. This has meant they have become increasingly reliant on a fly-in-fly-out workforce, which requires additional housing that is often not available. Burnout is common.

A recent inquiry into Child Development Services within Western Australia found that:

“While increased funding would greatly assist ACCHOs to employ or contract allied health staff, the challenges of providing services in remote and regional areas are multifaceted and immensely complex. For example, if ACCHOs are to be successful in filling these roles, measures must still be taken to attract allied health practitioners to regional areas of the State, including the provision of suitable and sufficient accommodation.”^26

In order to carry out the additional services provided through Thriving Kids, local people must be upskilled. Micro-credential programs targeted at young people, such as the Ramaciotti Regional and Remote Health Sciences Training Centre help regional and remote youth overcome barriers to joining the health workforce.^27 Pathways to additional training would help to further build on this.

The First Nations Health Worker Traineeship Program (FNHWTP), coordinated though NACCHO, provides a template for how capacity and capability building could occur. The program supports

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^26 Legislative Council Western Australia Select Committee Into Child Development Services, Compilation Report: Child development services in Western Australia: Valuing our children and their needs, April 2024, https://www.parliament.wa.gov.au/Parliament/commit.nsf/(Report+Lookup+by+Com+ID)/97243864767EFE6E48258B02002A6A67/$file/cd.cds.240418.rpf.003.Web%20Version.pdf.

^27 Menzies School of Health Research, The Ramaciotti Regional and Remote Health Sciences Training Centre, https://www.menzies.edu.au/page/Research/Centres_initiatives_and_projects/The_Ramaciotti_Regional_and_Remote_Health_Sciences_Training_Centre/.

Aboriginal and Torres Strait Islander trainees to become Aboriginal Health Workers or Health Practitioners. Training local people capitalises on their existing local knowledge and connections, while also providing meaningful local career opportunities.^28

Through the FNHWTP, trainees undertake Certificate III or Certificate IV qualifications in the Aboriginal and Torres Strait Islander Primary Health Care training package. ACCRTOs deliver wrap-around cultural and educational supports to trainees, and structured support and training to ACCHO-based supervisors. This training is flexible and could easily be tailored to deliver training on recognising and responding to developmental delay.

NACCHO recommends workforce development training and pathways for ACCHO/ACCO staff is delivered through the existing network of ACCRTOs.

Evidence based information and resources

ACCHOs are already proven leaders in holistic, culturally safe care. As part of their routine comprehensive primary health care for Aboriginal and Torres Strait Islander children, ACCHOs have the capability to screen for developmental concerns. The Medicare-funded 715 Health Assessment for Aboriginal and Torres Strait Islander People includes a development assessment for children to determine whether age-appropriate milestones are being achieved. However, 715 funding does not adequately support the time required to comprehensively screen, assess, respond and monitor a child’s specific developmental needs. Dedicated services that can facilitate screening, streamline referral pathways and improved service integration for children with developmental concerns, are critically needed in the ACCHO sector.

In response, many ACCHOs have established early childhood services and program, who optimally screen, identify and respond to developmental difficulties and delays in children. Early intervention is key to providing necessary support to the children who require it.

Case study: Remote Early Childhood Service (RECS): Kimberley Support The NDIA-funded Remote Early Childhood Service (RECS) at Kimberley Support, is an example of an early childhood approach working in the remote Kimberley region of Western Australia. It is the best practice example of early intervention provided within the ACCHO sector.

The program is run by a consortium of ACCHOs, demonstrating high quality, best practice early childhood intervention, supporting families with children under 9 years with developmental delay or disabilities. Children receive a multidisciplinary, early intervention preventative service through a bi-cultural model of Family Support Workers and Allied Health professionals.

However, many of these services are not well resourced, rely on a patchwork of grant and funding agreements, and are at capacity with waitlists.

The NDIS Review recommended more children are supported through existing services, such as maternal and child health, integrated child and family centres, early childhood education and schools.

The Connected Beginnings Program, is already delivering community controlled, place-based, culturally appropriate wrap around services to Aboriginal and Torres Strait Islander children.

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^28 VACCHO, Alumni Trailblazers: Kayla Harrison on Breaking the Cycle and Leading With Heart, March 2025, https://www.vaccho.org.au/2025/03/04/alumni-trailblazers-kayla-harrison-on-breaking-the-cycle-and-leading-with-heart/.

Case study: Connected Beginnings Program Established in 2016, the Connected Beginnings program is delivered through partnerships between Backbone Organisations (funded by the Commonwealth Department of Education and supported by SNAICC) and the Health Partner (funded by the Department of Health and Aged Care and supported by NACCHO).

The Connected Beginnings program provides a framework and funding to support the integration of early childhood, maternal and child health, and family support services with schools so that Aboriginal and Torres Strait Islander children are ready to thrive at school. It is a community-owned and led program that enables Aboriginal and Torres Strait Islander people to have a say in how activities funded are delivered to their people, in their own places and on their Country. It is place-based, and prioritises investments that meet the needs and aspirations of community whilst building Aboriginal and Torres Strait Islander community-controlled sectors.

The program currently supports just under 25,000 Aboriginal and Torres Strait Islander children aged 0-5 years through its 50 sites across Australia.^29

The inquiry into Child Development Services within Western Australia reported that multiple ACCHOs “discussed how valuable it would be to have multidisciplinary allied health services embedded in the clinic to facilitate an integrated model of care that acts as a ‘one stop shop’ for families accessing services for their children.”^30 Derbarl Yerrigan and the Victorian Aboriginal Health Service (VAHS) provide strong examples of integrated approaches to service provision for children.

Case study: Derbarl Yerrigan Health Service Model Derbarl Yerrigan Health Service, has several clinics across Whadjuk Noongar Boodjar in Perth. They provide care to over 2,000 children aged 0-9. They have developed a culturally responsive paediatric assessment and diagnostic model. Their model enables referrals from their clinics into the paediatric team for assessment, diagnosis and provides seamless access to Derbarl services, programs, and specialist referrals to early intervention allied health and other support services.

This is a one stop shop for families, that reduces wait times, and allows for deeper connection with families and simplified referrals. Case coordinators help families navigate referrals to maximise time for families and clinicians – and taking away the referral burden.

Through focussing on meeting the needs of children and families, their appointment attendance rate is over 90%, which much higher than other childhood services. Clients note the impact of Derbarl Yerrigan’s services on school attendance rates, enabling parents to thrive and ensuring fewer children get ‘lost in the system’.

Case study: Victorian Aboriginal Health Service (VAHS) The Victorian Aboriginal Health Service (VAHS) delivers culturally safe and responsive, community-led health and wellbeing services to hundreds of children aged under 9 years across their four clinics dotted around Wurundjeri Country in metropolitan Melbourne. To better support

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^29 Department of Education, Connected Beginnings, Jan 2025, https://www.education.gov.au/early-childhood/providers/extra-support/community-child-care-fund/connected-beginnings.

^30 Legislative Council Western Australia Select Committee Into Child Development Services, Compilation Report: Child development services in Western Australia: Valuing our children and their needs, April 2024, https://www.parliament.wa.gov.au/Parliament/commit.nsf/(Report+Lookup+by+Com+ID)/97243864767EFE6E48258B02002A6A67/$file/cd.cds.240418.rpf.003.Web%20Version.pdf.

children’s development, VAHS has created a culturally responsive paediatric model in which developmental checks are built into regular visits – like MBS715 Health Checks, Maternal and Child Health appointments, and Key Ages and Stages checks – which aids in identifying issues such as developmental and communication delays early. Integral to his model are Case Coordinators and Navigators from ACCOs who help families access services and reduce stress.

VAHS also connects families and Carers to programs like Pathway to Good Health, which supports Aboriginal and Torres Strait Islander children and young people who are living in out of home care. This cohort of children present with complex needs, requiring intensive wrap around supports. VAHS plays a pivotal role in helping children and their families receive the assessments and reports they need in a culturally enriching environment, enabling improved access to the NDIS. This ensures that children with disability and/or developmental delay receive the early intervention and support that they need.

Workforce development is crucial to this model and in the childhood health space. VAHS recognises the importance of training Aboriginal Health Workers and Practitioners in child development assessment, early identification of developmental delays, and service navigation to build local capacity and provide culturally safe support. VAHS strongly advocates for the development of culturally tailored, evidence-informed health promotion programs and initiatives – similar to the Koori Way – which can support parenting and children’s development by increasing awareness of milestones, while reducing barriers to early intervention.

Evidence also shows that the ACCHO sector is best placed to carry out culturally appropriate health promotion and health messaging activities. Some ACCHOs deliver programs like parent/baby playgroups and use these as an opportunity to educate families to better understand neurodevelopmental delay in their child and how to best to support them. Others provide education for pregnant women and families pre- pregnancy through maternal and child health programs.

NACCHO recommends funding for a national sector-led health promotion campaign around neuro-developmental delay that enables ACCHOs to deliver place-based promotion and educational activities for families.

A key example of such a program is NACCHO’s Strong Born campaign. Fetal Alcohol Spectrum Disorder (FASD) has long been an Aboriginal and Torres Strait Islander community controlled health priority. As it is a sensitive topic, it is particularly important that discussions regarding FASD are culturally safe, culturally appropriate and trauma informed manner.

The Strong Born campaign, the first of its kind, employs a strengths-based approach to FASD awareness and assistance that enables place-based campaigns. It has reached 40 per cent of ACCHOs to date. The campaign includes culturally appropriate health information for women and families, educational materials for our Aboriginal health care workers, and guidance for health care providers that work with communities. ACCHOs are able to tailor the campaign to their local needs and cultural requirements.

Case study: Strong Born campaign at Central Australian Aboriginal Congress Central Australian Aboriginal Congress (Congress) are one ACCHO delivering the Strong Born campaign. As part of this they have a tailored web page with information on FASD, personalised animations and details on how to seek help.^31

Congress’ Child & Youth Assessment & Therapeutic Service reported that 15 per cent of children received a primary diagnosis of FASD between November 2018 and June 2024, with 24 per cent being diagnosed with multiple forms of neurodiversity and/or neurodevelopmental delay. Early

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^31 Central Australian Aboriginal Congress, No Safe Drinking for Bub, https://www.caac.org.au/nosafedrinkingforbub/.

interventions are expected to significantly reduce the rates of children in out-of-home care and interactions with the justice system.

Identifying developmental delay

The Thriving Kids Inquiry is seeking to examine the effectiveness of current (and previous) programs and initiatives that identify children with development delay, autism or both, with mild to moderate support needs and support them and their families. ACCHOs are once again well placed to provide this screening – through scheduled visits but also opportunistically when families visit a service for any reason.^32

Aboriginal and Torres Strait Islander clients have a range of complex needs, including experiences of intergenerational trauma which must be taken into account from the start of any process of assessment and diagnosis. Acknowledgment of the complex experiences and environments in which these assessments are undertaken must embed cultural safety at every stage – the tool itself, the methods of use, and the cultural competence of staff and/or health professionals to undertake the assessments.

Standardised assessments have significant limitations for Aboriginal and Torres Strait Islander people, and considerable caution needs to be taken when applying mainstream assessment tools to Aboriginal and Torres Strait Islander populations. Tools that benchmark norms against mainstream populations are culturally biased and do not take into consideration the needs of Aboriginal and Torres Strait Islander people. Using tools of this nature creates bias when assessing Aboriginal and Torres Strait Islander people. The development and use of any tool must be undertaken in partnership with the sector in line with Priority Reform 1.

Case study: ASQ-TRAK The ASQ-TRAK is a developmental screening tool for observing and monitoring the developmental progress of Aboriginal and Torres Strait Islander children aged 0 to 5. It is designed to be administered by interview, and made to be easy-to-use, family centred. It is focussed on highlighting a child’s strengths as well as screening for delays. Caregivers are co-observers in the process, and as part of the process they can be supported and taught them about child development and their own child’s skills.^33

While many Aboriginal Community Controlled Organisations find ASQ-TRAK to be a helpful screening tool, very few are able to access the required training and resources due to high costs, limited availability of training sessions and university ownership of the intellectual property. Importantly, ASQ-TRAK is able to be used to facilitate access to support and services, including through the NDIS.

NACCHO recommends extension of funding to enable the continued roll-out of ASQ-TRAK training to meet the demand from the ACCHO sector.

Case study: Tracking Cube

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^32 Legislative Council Western Australia Select Committee Into Child Development Services, Compilation Report: Child development services in Western Australia: Valuing our children and their needs, April 2024, https://www.parliament.wa.gov.au/Parliament/commit.nsf/(Report+Lookup+by+Com+ID)/97243864767EFE6E48258B02002A6A67/$file/cd.cds.240418.rpf.003.Web%20Version.pdf.

^33 STRONG kids, STRONG future, ASQ-TRAK, https://www.strongkidsstrongfuture.com.au/asqtrak/.

The Tracking Cube is a culturally responsive approach to screening, diagnosing and monitoring neurodevelopment that helps identify disorders such as FASD, ADHD, Autism in primary healthcare and non-health settings.^34 The Tracking Cube can be used to assess children up to 17 years old. The ASQ-TRAK screening tool can be used as part of the assessment process (limited to 0 to 5 years of age).

Through the Yapatjarrathati Project, a bespoke version of the Tracking Cube was co-created for use by the Kalkadoon nation in the Mount Isa region. This ensures it is culturally safe and appropriate.

The Tracking Cube links evidence-based neurodevelopmental screening with risk and protective factors as well as parent/teacher concerns to provide a holistic understanding of at-risk children. Its digital infrastructure summarises patient data from multiple sources and provides auto-generated referral and report templates to assist triage and support decisions.

It is split into 6 tiers – 5 of which can be carried out by primary health workers such as Aboriginal Health Workers (or workers in schools, childcare and other settings), and the 6th by a specialist. This in effect is able to lower patient wait times and get children the necessary referrals more rapidly.

Support pathways

A critical function of Thriving Kids is to manage the interface with NDIS, ensuring children with lower support needs, or those facing barriers to NDIS access (including many Aboriginal and Torres Strait Islander children and children in remote areas), receive timely, locally governed supports. This approach is projected to reduce pressure on NDIS budgets while lifting rates of both early identification and successful transitions into adult services for high-need cohorts.

The NDIS Review recommended all people with disability have access to a Navigator, who can act on behalf of the person with disability, at their direction, and be incentivised to build capability, help the person meet their goals, facilitate choice and enable inclusion.^35 Specialist Navigators should also be available for people with more complex support needs, certain population groups and people at key life transitions, such as preparing for education, employment and independent living.^36 These Navigator roles will be increasingly necessary as Thriving Kids rolls out and the system becomes more complex and potentially fragmented.

Out of necessity, ACCHOs have been offering navigation/liaison/connector-type supports to ensure Aboriginal and Torres Strait Islander people with disability in their communities receive adequate and culturally safe supports. Many ACCHOs do this as an extension of their comprehensive primary health care approach, while others are funded through targeted NDIS programs such as the Aboriginal Disability Liaison Officers (ADLO); Remote Community Connector (RCC) workers; Evidence, Access and Coordination of Planning (EACP); and Remote Early Childhood Services (RECS).

Through the ADLO program, dedicated support is provided to Aboriginal and Torres Strait Islander people with disability in urban and rural areas to access the NDIS and use their plans. ADLOs are generally members of the communities they work in, understand the culture and often speak the local languages. The insights of ADLOs can contribute to co-design initiatives to improve the way NDIS works with Aboriginal and Torres Strait Islander communities.

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^34 Your Track, The Tracking Cube, https://yourtrack.org/the-tracking-cube/.

^35 NDIS Review, Working together to deliver the NDIS Review: Final Report, pg. 101, 2023, https://www.ndisreview.gov.au/sites/default/files/resource/download/working-together-ndis-review-final-report.pdf.

^36 NDIS Review, Working together to deliver the NDIS Review: Final Report pp. 101, 2023, https://www.ndisreview.gov.au/sites/default/files/resource/download/working-together-ndis-review-final-report.pdf.

Case study: ADLO Program With over 50 Aboriginal Disability Liaison Officers (ADLOs) across 40 ACCHOs, we are dedicated to expanding culturally safe and tailored support throughout the NDIS process. We facilitate a monthly Community of Practice for ADLOs to have a safe platform to share, problem solve and provide support to ADLOs nationally.

Our commitment extends to enhancing mainstream disability services to better meet the needs of Aboriginal and Torres Strait Islander people. By empowering ACCHOs to deliver NDIS services, we strive to ensure equitable access to support for individuals and families, while acknowledging the unique challenges they face.

ACCHOs report that the program has enabled parents to be able to understand the types of services, navigate complex processes, and build confidence to self-advocate. However, they continue to be underfunded. One ACCHO, servicing a large region just outside a major city, has 1 ADLO, available 2 days a week. This is not enough support to meet demand.

The Remote Community Connector program, whereby there are community-based National Disability Insurance Agency representatives that support culturally appropriate service delivery of the NDIS provides similar service.

Case study: Remote Community Connectors The Remote Community Connectors program helps to bridge the gap between the NDIS and remote Aboriginal communities. This is achieved by funding ACCHOs to employ trusted local individuals who understand community needs and help them to navigate the NDIS.^37

Through the Remote Community Connectors program, ACCHOs are able to be a focal point to raise awareness and understanding of the NDIS, identify potential NDIS participants, assist in navigating the NDIS eligibility and access processes and finally support community members in completing their NDIS plans and accessing necessary services. As a March 2021, the National Disability Insurance Agency employed 173 Remote Community Connectors, covering 274 rural and remote communities throughout the Northern Territory, South Australia, Western Australia and Queensland.^38

The NDIS Review recognised, splitting navigator functions across the Partners in the Community, Support Coordinators and Community Connectors (i.e. RCC and ADLO) added to system complexity.

NACCHO has previously suggested that these two programs require consolidation, expansion, and national coordination to ensure consistent service delivery and coverage across regions. This would provide service continuity, workforce stability and program security. Embedding leadership and coordination of these programs within NACCHO would strengthen sector-wide capacity and ensure alignment with community-controlled governance structures.

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^37 South Australian West Coast ACCHO Network, Remote Community Connectors, https://www.sawcan.org.au/remote-community-connectors/.

^38 MyCareSpace, NDIS Remote Community Connectors, September 2025, https://mycarespace.com.au/resources/ndis-remote-community-connectors-rcc .