NDIA Accountability Project

Submission 156 — Pop Family Pty Ltd — Inquiry into the Thriving Kids initiative

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

Submitted by

Kate Laherty Chief Executive Officer Pop Family Senior Speech Pathologist

Monique Martino Clinical Lead Pop Family Senior Speech Pathologist

on behalf of Pop Family

Date: 3 October 2025

Table of Contents

1. Executive Summary

Pop Family is a national online speech pathology service. As one of Australia’s largest single-discipline providers, our team of just under 100 has serviced 8,000+ families in the past nine years, including families in metropolitan, regional, rural, and remote communities who access services solely through videocalling/telehealth. Our submission to the Thriving Kids Inquiry is informed by our daily experience supporting children and families who navigate the complexities of developmental support systems. We see the profound challenges faced by families whose children have mild to moderate developmental differences despite the “severity label” of mild to moderate.

This submission advances three core positions. Firstly, allied health, particularly speech pathology, plays a central role in the early identification and intervention for developmental delay and the successful transition of children between services. Secondly, telehealth models offer tested and scalable solutions that can address critical workforce shortages, access and inequities across Australia. Thirdly, there are significant risks in transitioning children from the NDIS before equivalent, funded, and robust mainstream supports and regulatory frameworks are in place. Without these safeguards, the Thriving Kids initiative risks creating a service vacuum that will fail the very children and families it intends to support.

2. Identifying Mild to Moderate Developmental Delay In Children

2.1. Discussion

Parents are often the first to recognise that their child’s development may be different, but their journey to receiving support is frequently hindered by systemic barriers. Families consistently report receiving mixed messages or “wait and see” advice from primary health and early childhood professionals, which delays access to vital early intervention. Many families present to our service after years of missed red flags and navigating a system that lacks clear, accessible screening and referral pathways.

Parents require clear, practical, and accessible resources to identify developmental concerns early. Evidence supports the effectiveness of:

  • Universal parent checklists and developmental milestone guides, distributed through child and maternal health services, early learning settings, and schools (UNICEF, 2023).
  • Telehealth-enabled screening tools, which provide equitable access regardless of geography (Law & McBean, 2024).
  • Multilingual and culturally adapted resources to support parents from CALD backgrounds (Raban & Milnes, 2021).
  • Peer-support and parent coaching programs, which improve parental confidence in supporting their child’s development.

For example, children with Developmental Language Disorder (DLD) often present with difficulties in understanding or expressing language, which can affect literacy, social participation, and school readiness. Up to 7% of children have DLD, yet only 30% access services before school age (Law et al., 2024). DLD frequently goes unrecognised in mainstream settings because children may have average cognitive abilities and subtle social differences. Universal developmental checks, standardised language assessments, and parent-focused screening tools can improve early identification and access to timely speech pathology support (Law & McBean, 2024; NDIS Research & Evaluation, 2022).

2.2. Recommendations

A. Implement, fund and provide training in universal and repeated developmental checks within existing maternal and child health and GP frameworks, utilising standardised tools.

B. Establish clear, embedded referral pathways from mainstream services (GPs, childcare, schools) directly to allied health for developmental surveillance and screening.

C. Fund and regulate telehealth-based developmental screening services to provide timely and equitable access for families in rural, remote, and other isolated and underserved communities, eliminating prohibitive wait times.

3. Programs For Children With Developmental Delay for Autism And Their Families: A Review

3.1. Discussion

The Thriving Kids initiative’s goal of leveraging community and mainstream programs is logical, but success depends on addressing existing and significant gaps within these settings. Currently, mainstream services like playgroups, early childhood education and care (ECEC), and schools are often disconnected from the allied health expertise required to support children with mild to moderate developmental delays.

Our experience highlights several critical flaws in the current landscape:

  • Allied Health Siloing: Services are often delivered without the direct involvement of allied health professionals like speech pathologists. ECEC

staff, while often the first to notice developmental differences, are not equipped with the training or resources to provide targeted support.

  • Workforce Shortages: Even where programs intend to include allied health, chronic workforce shortages, especially in rural and remote areas, make this impossible. This results in long waitlists and an inability for the system to meet demand (Mja & Smith, 2023; Department of Health, 2022)
  • Unsustainable Funding Models: Many effective community-based programs, such as supported playgroups that successfully engage First Nations and CALD families, are funded through short-term pilots or grants. When this funding ends, the support disappears, leaving families without continuity of care.
  • Lack of Specialised Training: There is a gap in neuro-affirming practices and specialised knowledge within community health settings. Shifting services from private practitioners, who may have deep expertise, to a community model requires a significant investment in training and professional development to ensure quality is not compromised (Watson & Green, 2024).
  • Potential Workforce Skill Gap: Many children supported by the NDIS currently receive care from private practitioners with specialised skills. Moving these children quickly to other providers, like community health services, could lead to lower-quality support if these providers do not have the right training or experience.

Evidence-based interventions for children with DLD include individualised language therapy, parent coaching programs, and structured literacy support. These approaches have been shown to improve vocabulary, narrative skills, and functional communication outcomes (Furlong et al., 2021; Watson & Green, 2024). Embedding these interventions within early childhood education, playgroups, and school programs can ensure children receive consistent support across settings.

Multidisciplinary approaches, including speech pathology, occupational therapy, and psychology, have been shown to improve developmental, social, and emotional outcomes for children with mild to moderate delays (NDIS Research & Evaluation, 2022).

3.2. Recommendations

A. Mandate and fund the direct embedding of allied health professionals, particularly speech pathologists, into community programs, schools, and ECEC centres through in person and telehealth service delivery models

B. Establish robust regulatory oversight for community-based programs to ensure service quality, consistency of care, and adherence to evidence-based, neuro-affirming practices.

C. Move away from short-term pilot funding towards sustained, long-term investment in community programs that have proven effective, ensuring continuity of care for families.

4. Equity and Intersectional Issues

4.1. Discussion

Inequities in access to developmental services are stark and persistent. The Thriving Kids framework must be intentionally designed to address the specific needs of diverse populations.

4.1.1. First Nations Population

First Nations families often prefer and trust services delivered through Aboriginal Community Controlled Health Organisations (ACCHOs). For Thriving Kids to be effective, it must support partnerships between allied health providers and ACCHOs, rather than relying on a mainstream-only approach that is often mistrusted. Consultation with First Nations leaders on the design of culturally appropriate care models is essential. Furthermore, there is a critical shortage of First Nations allied health professionals, which must be addressed through targeted workforce strategies.

4.1.2. Culturally and Linguistically Diverse Populations

Families from CALD backgrounds face distinct barriers, including shortages of interpreters, which prevent them from fully participating in assessments and therapy. Cultural stigma surrounding diagnoses like autism can lead to later identification. Moreover, access can be restricted by citizenship status; under the current system, some children who are not citizens have been unable to access NDIS supports despite being born in Australia, missing the entire early childhood intervention window. Standardised screening tools must also be culturally and linguistically adapted to be valid and equitable.

4.1.3. Neurodiverse Community

The language used in the Thriving Kids initiative, such as “mild to moderate,” risks creating a false and inequitable distinction between physical and non-physical disabilities. This language appears to contradict a modern, spectrum-based understanding of conditions like autism. There is concern that children with significant support needs may be deemed less severe simply because their disability

is not physically obvious, leading to an imbalance in support. The program must clarify how “support needs” will be defined and assessed to ensure equity.

4.2. Recommendations

A. Fund dedicated telehealth access packages, including subsidies for data and devices, to ensure digital inclusion for all families, particularly those in rural/remote and low-socioeconomic communities.

B. Implement regulatory requirements for cultural safety in all Thriving Kids services and fund direct partnerships between allied health providers and ACCHOs and CALD organisations.

C. Ensure eligibility criteria for Thriving Kids are not restricted by citizenship status for children residing in Australia.

D. Fund the provision of professional interpreter services so providers are not forced to absorb this cost, ensuring families can fully participate in their child’s care.

5. Gaps In Workforce Support and Training Required To Deliver Thriving Kids

5.1. Discussion

The success of the Thriving Kids initiative is entirely dependent on the availability of a skilled and sufficient workforce, which currently does not exist. Australia faces a critical shortage of allied health professionals, including speech pathologists, OTs, and psychologists, particularly in regional, rural, and remote communities where vacancies can remain unfilled for years. Furthermore, the existing mainstream workforce - including GPs, nurses, and educators - is not adequately trained in developmental surveillance or neuro-affirming practices.

Addressing workforce gaps requires both expansion and upskilling. Key areas include:

  • Increasing the supply of allied health professionals with paediatric training, particularly in rural and remote areas.
  • Providing continuing professional development (CPD) to generalist staff (e.g., GPs, nurses, teachers) to strengthen developmental identification.
  • Embedding training in trauma-informed and neurodiversity-affirming practice to ensure inclusive care

Simply shifting demand from the NDIS to a new mainstream program without first addressing this workforce crisis will result in a “paper promise,” creating untenable waitlists and leaving families with theoretical access but no actual services. A comprehensive and funded national allied health workforce plan is a prerequisite for the rollout of Thriving Kids.

5.2. Recommendations

A. The government must invest in a national allied health workforce plan with concrete actions and timelines aligned with the Thriving Kids rollout. This should include scholarships, bonded rural placements, and relocation incentives.

B. Invest in telehealth-enabled supervision models to support and retain clinicians in underserved areas.

C. Fund the development and delivery of national standards for training and micro-credentials in developmental surveillance for GPs, nurses, and educators, delivered through regulatory bodies and partnerships.

6. Transition to Mainstream Services

6.1. Discussion

The transition of children and families from the NDIS to the Thriving Kids program presents the greatest risk of service disruption and harm. Providers and families are deeply concerned about the potential for a “service vacuum,” where their NDIS support is withdrawn before a functional and equivalent mainstream alternative is available. Many families currently receiving intensive, individualised therapy under NDIS plans are worried about how a new model will meet their child’s needs, with fears of significantly reduced therapy hours.

Past experiences with large-scale reforms, such as the initial rollout of the NDIS, have shown that a lack of clear guidelines leads to inconsistency and confusion. The Thriving Kids transition must be underpinned by robust regulatory safeguards to prevent a repeat of this. A move toward a more prescriptive or transdisciplinary model, as has been seen in the past, risks reducing flexibility and the individualised support that was the core promise of the NDIS. Such models are only effective with extensive training, multidisciplinary collaboration, and clear guidelines for professionals.

A successful transition requires:

  • Continuity of Care: Families must not be left waiting between the cessation of one service and the commencement of another. This requires coordinated planning and monitoring at both system and provider levels.
  • Warm Handovers: Transitions should involve structured collaboration between NDIS providers, mainstream services, and families, with clear communication and shared planning.
  • Regulatory Safeguards: There must be clear, nationally consistent guidelines for eligibility, service delivery, and oversight.

6.2. Recommendations

A. Mandate that a clear, functional, and nationally consistent definition of “mild to moderate support needs” be co-designed with allied health peak bodies and community stakeholders prior to the program’s rollout to ensure equitable and consistent access.

B. No child should be exited from the NDIS until equivalent mainstream supports under the Thriving Kids program are fully funded, established, tested, and locally available. A funded transition plan should be provided to families to wean services down gradually rather than cutting them off abruptly.

C. The Thriving Kids framework to formally recognise telehealth as a core and essential mode of service delivery, not an optional extra or a temporary substitute for face-to-face services.

D. Allied health professionals must be given a mandated and funded role in developing and implementing transition frameworks to ensure clinical continuity and family-centred care.

7. Other Considerations

For providers to deliver consistent, high-quality services at a national scale under the Thriving Kids initiative, the funding model must be designed for sustainability and reach. A system reliant on short-term, competitive grants or patchy pilot programs will perpetuate the very inconsistencies it seeks to solve. The government could consider funding models such as block funding or national contracts for telehealth-enabled services, which would secure a baseline of access nationally and particularly benefit families in regional and remote communities. This would enable providers to invest in the workforce development required to meet demand.

8. Final Remarks and Conclusion

The Thriving Kids initiative represents a critical opportunity to reform early childhood intervention in Australia. However, its success hinges on learning from the shortcomings of past systems. The transition cannot be a cost-cutting exercise that leaves families stranded without support. It must be a carefully planned, evidence-based reform that places allied health expertise at its core, addresses workforce shortages before increasing demand, and guarantees continuity of care for every child.

Telehealth models offer a powerful and proven means of delivering equitable access, providing vital services to families regardless of their postcode. By recognising and funding these models as an essential component of the mainstream service system, the government can ensure the Thriving Kids initiative becomes a genuine step forward for Australia’s children.

9. References

Law, J., & McBean, K. (2024). Telehealth versus face-to-face delivery of speech language pathology: Systematic review. Journal of Telemedicine and Telecare, 30(4), 217-230. https://journals.sagepub.com/doi/pdf/10.1177/1357633X241272976

Mija, D., & Smith, L. (2023). Building a rural and remote health workforce: An overview of effective interventions. Medical Journal of Australia, 219(3), 150-157. https://www.mja.com.au/journal/2023/219/3/building-rural-and-remote-health-workforce-overview-effective-interventions

National Disability Insurance Scheme (NDIS) Research & Evaluation. (2022). Evidence review: Early interventions for children with autism. https://dataresearch.ndis.gov.au/research-and-evaluation/early-interventions-and-high-volume-cohorts/evidence-review-early-interventions-children-autism

United Nations Children’s Fund (UNICEF). (2023). Best practices in early childhood development: Parent and community engagement. https://www.unicef.org/reports/best-practices-early-childhood

Department of Health, Australia. (2022). Improvement of access, quality and distribution of allied health services in regional, rural and remote Australia: Final report. https://www.health.gov.au/resources/publications/final-report-improvement-of-access-quality-and-distribution-of-allied-health-services-in-regional-rural-and-remote-austral

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Furlong, J., McGorry, P., & Cocks, S. (2021). Parent-mediated interventions for children and adolescents with autism: A systematic review. Frontiers in Psychiatry, 12, 773604. https://www.frontiersin.org/articles/10.3389/fpsyt.2021.773604/full

Raban, B., & Milnes, R. (2021). ASQ-TRAK: Validating a culturally adapted developmental screening tool for Australian Aboriginal children. Early Child Development and Care, 191(12), 1985-2000. https://www.sciencedirect.com/science/article/pii/S0378378221001808

Watson, L., & Green, J. (2024). Effectiveness of parent-focused interventions for improving mental health in parents of children with ASD. Clinical Child Psychology and Psychiatry, 29(2), 345-361. https://www.sciencedirect.com/science/article/pii/S1750946724000643

Law, J., et al. (2024). Developmental Language Disorder prevalence and access to services [in-text reference for DLD statistic]. Journal of Speech, Language and Hearing Research, 67(5), 1234-1245. https://pmc.ncbi.nlm.nih.gov/articles/PMC9804624/

Pop Family Pty Ltd
ABN: 74 608 202 357
Website: https://popfamily.au\ Address: 105 Virginia Avenue, Hawthorne, QLD 4171
Phone: 1300 26 11 60
Fax: 07 3180 2820
Email: home@popfamily.au