Vision Australia Submission: Inquiry into the Thriving Kids Initiative
Submitted to: Standing Committee on Health, Aged Care and Disability
Date: 3 October 2025
Submission approved by: Chris Edwards, General Manager Corporate Affairs and Advocacy
Introduction
Vision Australia welcomes the opportunity to provide a submission to the Standing Committee on Health, Aged Care and Disability to inform its Inquiry into the Thriving Kids initiative (Thriving Kids).
Vision Australia acknowledges the ongoing need in the disability community for supports additional to those provided by the National Disability Insurance Scheme (the NDIS), like Thriving Kids. This submission makes comment on the suitability of Thriving Kids and foundational support programs more broadly, for children whose disability is, or includes, vision impairment. It also sets out some negative consequences that have been experienced by NDIS participants with vision impairment since the concept of foundational supports was introduced.
Topics
This submission covers the following matters:
- Supports and referral pathways outside the NDIS for children with vision impairment
- Stated supports in NDIS plans
Supports and referral pathways outside the NDIS for children with vision impairment
Vision impairment in children may occur as a primary disability, or in conjunction with another condition or spectrum of conditions. No matter the circumstance, the incidence of vision impairment in children can and does result in developmental delay, particularly if vision strategies are not available or applied at an early stage.
There are many children with vision impairment who cannot access the NDIS on the basis of permanent disability because their visual acuity cannot be clearly established. In the case of very young children, it can be particularly difficult to determine visual acuity until the child is able to communicate or begins to access environmental information beyond arm’s length.
Currently, under the early childhood approach, children with developmental delay who are not otherwise full NDIS participants may access early intervention supports for a period until it can be established whether they meet the NDIS criteria for permanent disability. As we understand, this is the stream of supports likely to be replaced by Thriving Kids, and which may capture some children with vision impairment who are not accessing the NDIS on the basis of permanent disability because, for example, accurate measures of visual acuity are unavailable.
Whether or not these children are later diagnosed with a permanent disability for NDIS purposes, early vision specific services are crucial in ensuring that they meet developmental milestones, and have access to any strategies which may allow correction of visual function. These services are often more tailored than those provided by general allied health professionals such as occupational therapists and speech pathologists. Due to the impacts of vision impairment on all areas of development, it is essential that children
are able to access vision specific services without delay. Access to supports for this cohort must also be supported by a clear pathway for families. Parents often have limited knowledge of how to identify developmental delay in vision impaired children or the services available at their child’s point of diagnosis. They need to be supported with a referral process that operates effectively across both the health and disability sectors.
It seems that much of the thinking around foundational supports has and continues to centre on the delivery of supports within existing education and care frameworks to children with disabilities that have a significant prevalence within the community. In this respect, the Department of Health, Disability and Ageing has released information on the scope of Thriving Kids, which states, in part:
“Thriving Kids 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. Children with permanent and significant disability will continue to be supported through the NDIS. 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, playgrounds, early childhood education and care and schools, as well as digital and phone-based supports. There are already many examples of evidence-based services that guide parents and help their kids thrive. The Government will work to leverage those existing systems, such as the infant and maternal health systems that states run, the primary care systems that the Commonwealth funds through Medicare and supports in community health centres. These supports will help children to thrive, right through the life course, from the time they’re born, into the time they get into formal schooling. This would include supporting the parent or carers with routines and advice on things they can do at home and what their child may need in other everyday environments where they learn and play.”
Children with vision impairment, however, represent a low incidence cohort, meaning that those within mainstream frameworks do not have the necessary experience and skills to provide supports that are appropriate for them. To address developmental delay and encourage good functional vision skills, these children require a more individualised and specialised approach within the home and across other natural community settings. This is the case whether a child presents with vision impairment as a single disability or as part of a broader condition or spectrum of conditions. For children with vision impairment, the home setting is the environment where strategies are best learned, due to the level of comfort and familiarity for children within that setting. There is then a greater likelihood of transferring those skills successfully into other settings.
The scope of Thriving Kids does not seem to anticipate the support of children with developmental delay where that delay arises in a child with a vision impairment or with another low incidence disability. It is therefore imperative that either:
(a) the initiative contains a separate funding stream to enable specialist vision providers to work within the mainstream service system to build capacity in vision impaired children with developmental delay; or (b) a similar initiative to Thriving Kids be developed to support children with vision impairment who sit outside the NDIS.
Without a dedicated approach, children with a vision impairment and developmental delay, will not have access to supports outside of the NDIS in the same way that will be available to children with more prevalent conditions.
Stated Supports
Since the introduction of measures to address cost concerns within the NDIS (including foundational supports and the section 10 Rules) Vision Australia has become aware of corresponding changes to participant plans seemingly aimed at fixing costs for NDIS services. The main change is the marked increase in the inclusion of stated allied health supports within participant capacity building budgets, including those of children. This is a deeply concerning practice within the NDIS planning process that severely undermines access to appropriate services, and denies participants the flexibility to access supports that align with their goals. Vision Australia is already seeing significant impacts of this practice, with many participant plans now including stated allied health supports that do not match participant goals or which are not relevant to their registered impairment. For example, we are aware of several vision impaired participants who have been prevented from accessing orientation and mobility services because their NDIS plans state that capacity building funding must only be spent on occupational therapy. This is an unreasonable restriction upon choice and flexibility, with many of these participants forced to seek a plan variation to have the issue rectified, while missing out on valuable supports in the meantime.
In introducing measures like Thriving Kids, it is important to ensure that other practices do not evolve within the NDIS that deny access to evidence based therapies that are genuinely necessary for capacity building within lower incidence cohorts.
Conclusion
Vision Australia thanks the Standing Committee for the opportunity to provide this submission. We would be happy to provide additional information about any of the issues raised in this paper. We recognise that the implementation of supports outside of the NDIS is both complex and extensive, and we look forward to additional opportunities for meaningful participation in future consultations on this topic.
About Vision Australia
Vision Australia is the largest national provider of services to people who are blind, deafblind, or have low vision. We are formed through the merger of several of Australia’s most respected and experienced blindness and low vision agencies, celebrating our 150th year of operation in 2017.
Our vision is that people who are blind, deafblind, or have low vision will increasingly be able to choose to participate fully in every facet of community life. To help realise this goal, we provide high-quality services to the community of people who are blind, have low vision, are deafblind or have a print disability, and their families.
Vision Australia service delivery areas include:
- Allied Health and Therapy services, and registered provider of specialist supports for the NDIS and My Aged Care
- Aids and Equipment, and Assistive/Adaptive Technology training and support
- Seeing Eye Dogs
- National Library Services
- Early childhood and education services, and Felix Library for 0-7 year olds
- Employment services, including National Disability Employment Services
- Accessible information, and Alternate Format Production
- Vision Australia Radio network, and national partnership with Radio for the Print Handicapped
- Spectacles Program for the NSW Government
- Advocacy and Engagement, working collaboratively with Government, business and the community to eliminate the barriers our clients face in making life choices and fully exercising rights as Australian citizens.
Vision Australia has gained unrivalled knowledge and experience through constant interaction with clients and their families. We provide services to more than 26,000 people each year, and also through the direct involvement of people who are blind or have low vision at all levels of the Organisation. Vision Australia is therefore well placed to provide advice to governments, business and the community on the challenges faced by people who are blind or have low vision fully participating in community life.
We have a vibrant Client Reference Group, with people who are blind or have low vision representing the voice and needs of clients of the Organisation to the Board and Management. Vision Australia is also a significant employer of people who are blind or have low vision, with 15% of total staff having vision impairment.
We also operate Memorandums of Understanding with Australian Hearing, and the Aboriginal & Torres Strait Islander Community Health Service.