Submission
to the
Inquiry into the Thriving Kids Initiative
October 2025
Correna Haythorpe
Federal President
Nicole Calnan
Federal Secretary
Australian Education Union
Ground Floor, 120 Clarendon Street
Southbank Vic 3006
PO Box 1158
South Melbourne Vic 3205
Telephone: +61 (0)3 9693 1800
Facsimile: +61 (0)3 9693 1805
Web: www.aeufederal.org.au
E-mail: aeu@aeufederal.org.au
Introduction
The Australian Education Union (AEU) represents over 185,000 educator members employed in the public primary, secondary, early childhood, and TAFE sectors throughout Australia. The AEU believes that a high quality and properly resourced public education system including early intervention for children with mild to moderate autism or developmental delays is a key component of more equitable education system and a fundamental entitlement of all Australian children, regardless of their background, family income, circumstances or where they live. As such, the AEU welcomes this opportunity to present our views to the Standing Committee on Health, Aged Care and Disability on the Thriving Kids initiative. This submission will primarily focus on the existing inadequacy of support for students with disability in schools and the need to ensure the foundational supports for children aged 0-8 that are proposed to be offered as part of Thriving Kids are appropriately and fully resourced through the programs’ own budget.
Students with disability are currently missing out on the support they need
Almost 70% of students with disability attend public schools, which work extremely hard to ensure that issues such as access, specialist support, and health and wellbeing are appropriate so that all students can learn in a high-quality, safe environment. However, the stark reality is that this requires resources, and while the number of students eligible for support through disability loadings continues to grow, the total available funding per student is in decline.
The first full nationally consistent collection of data on school students with disability (NCCD) took place in 2015 following a gradual phasing in of the collection from 2012. The NCCD entails informed professional judgement by teachers to determine the extent of adjustments made to enable participation of students with disability on the same basis as students without disability.
The NCCD has provided a national definition of the four levels of disability support available to students across four levels of increasing frequency and intensity of adjustment as shown in Box 1, below. ^1
^1 National School Resourcing Board, Review of the loading for students with disability: Final report, December 2019, p. 20.
Box 1: Nationally Consistent Collection of Data on School Students with Disability (NCCD)
NCCD gives us a national definition of a student with disability.
The NCCD reports school students with disability by the level of support they receive to access and participate in learning, rather than on category or medical diagnosis of a specific disability.
The NCCD has four levels of adjustment: support provided within QDTP, supplementary, substantial and extensive. The frequency and intensity of the adjustments increases through the levels of adjustment.
- Quality differentiated teaching practice
- Some students may not need adjustments beyond those expected as part of quality teaching/school practice, which responds to different learning needs of all students.
- Adjustments are made infrequently as occasional action, frequently as low level action such as monitoring.
- Supplementary
- Students receive adjustments that are supplementary to the strategies and resources available for all students in the school.
- The adjustments occur for particular activities at specific times throughout the week.
- Substantial
- Students have more substantial support needs, and receive essential adjustments and considerable adult assistance.
- Adjustments to the usual educational program occur at most times on most days.
- Extensive
- Students have very high support needs and are provided with extensive targeted measures and sustained levels of intensive support.
- Adjustments to the usual educational program occur at all times.
Further information is available at www.nccd.edu.au.
The NCCD was linked to loadings for students with disability in 2018, including the application of the four adjustment levels, with only the Supplementary, Substantial and Extensive levels as shown in table 1 in receipt of funding loadings. Three of the NCCD categories attract loadings set as additional funding applied as a percentage of the base Schooling Resource Standard (SRS – the minimal funding level required for most students to meet minimum achievement benchmarks) as shown in table 1.
Table 1: 2025 primary student with disability SRS loadings by NCCD level of adjustment
| School level | Estimated SRS funding amount in 2025 | Supplementary | Substantial | Extensive |
|---|---|---|---|---|
| Primary student | $13,991 | 42% ($5,876) | 146% ($20,427) | 312% ($43,652) |
Students with disability assessed in the fourth level - Quality Differentiated Teaching Practice (QDTP) do not receive any additional SRS loadings. The adjustments offered under QDTP are described as including “a differentiated approach to curriculum delivery and assessment that anticipates and responds to students’ learning differences” and “personalised learning that is implemented without drawing on additional resource”^2. This description is vague enough that a significant range of adjustments can be categorised within it. Additionally, the NCCD requirement that adjustments must be made for at least ten weeks in the prior year make it very difficult for underfunded public schools to demonstrate that they have met the
NCCD requirements to access funded loadings. The impact of this is that there is a substantial and increasing number of public school students who have been deemed to have a disability, but who are categorised as QDTP and are not in receipt of any additional funding to support their learning.
In 2024 there were 505,566 public school students who a supplementary, substantial or extensive educational adjustment due to disability reported in the NCCD representing 19.3% of all public school student enrolments.3 This is an increase from 13.6% of all students in 2015. Over the decade to 2024 there has also been a significant increase, from 5.8% of all enrolments to 7.9% of all enrolments, in the proportion of students who are characterised as having a disability under the NCCD but are assessed at the unfunded QDTP level. This means that in 2024 there were 206,941 students classified as having disability but unfunded for educational adjustments, this is an increase of 64,124 from 2015.4This means that the level of unfunded students assessed as requiring an adjustment but receiving no funding has increased by 45% over the decade.
The impact of this resource gap on teachers and principals is very evident in survey data collected by the AEU. The AEU’s 2024 State of our Schools survey of public-school teachers, principals and education support staff found:
- 81% of principals and 80% of teachers said that they have students in their school assessed within the non-funded Quality Differentiated Teaching Practice NCCD category who require additional support above that level.
- 89% of all principals say they do not have sufficient resources to appropriately meet the needs of students with disability at their school.
- 84% of teachers said the most lacking resource to support Students with Disability was specialist educational support staff.
- 89% of principals reallocate funding from other areas to support students with disability at an average of $158,820 per school, which totals $955 million of funding reallocated to support students with disability when extrapolated nationally5
A further and significant issue with the resourcing of disability loadings for students in public schools is that many public school teachers and leaders do not have the required staffing or time available to them to engage in the repeated assessment and application processes necessary to ensure that their students receive their proper loading and that a lack of resources often prevents schools from providing the adjustments necessary for at least ten weeks to receive the loadings prior to the funding being guaranteed.
3 https://www.acara.edu.au/reporting/national-report-on-schooling-in-australia/school-students-with-disability 4 https://www.acara.edu.au/reporting/national-report-on-schooling-in-australia/school-students-with-disability 5 AEU, 2024 State of Our Schools, unpublished survey data
New foundational supports in schools require new resourcing commitments
The AEU wishes to draw the Committee’s attention to the Better and Fairer Schools Agreement (BFSA) and its associated bilateral agreements that provide substantial increases in funding to public schools over the next decade. The BFSA and its bilateral agreements are clear that this funding is to support the reform aims of the agreement and is not to be used to supplement changes to the NDIS or new foundational support programs. This excerpt from the New South Wales bilateral agreement makes very clear the distinction between additional funding to support students with disability in the classroom and changes to the provision of foundational supports as proposed by Thriving Kids. Page 4 of the NSW bilateral agreement states:
*23. In December 2023, National Cabinet agreed that funding for foundational supports for students with disability is to be agreed through new Federal Funding Agreements, with additional costs split between the Commonwealth, states and territories and final details to be settled through the Council of Federal Financial Relations.
- Disability reforms, including those related to changes to the National Disability Insurance Scheme (NDIS) including foundational supports, may impact NSW’s education services.
Commonwealth funding under the 2025 Agreement and this Bilateral Agreement is not for those purposes.*6
The AEU is very concerned that the introduction of Thriving Kids at the same time as new and additional recurrent funding is provided to public schools may lead to a conflation of the two funding sources, with recurrent SRS funding potentially being diverted, by either schools or systems, towards Thriving Kids. This concern is not alleviated by the description, found on the Thriving Kids Fact Sheet, states that:
*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.*7
The AEU is concerned that to date there is little detail about how the Program will work in schools and Early Childhood Education and Care (ECEC) settings. We are seeking an assurance that the “scaling and building on existing mainstream and community services” including schools will be accompanied by sufficient additional funding to ensure that all children engaged in the program are able to receive appropriate interventions without cross over with funds designated for equity and achievement reforms through increases to the SRS.
6 NSW bilateral agreement p.4 7 https://www.health.gov.au/sites/default/files/2025-08/thriving-kids-fact-sheet.pdf
Greater Clarity is needed on the intersection between Thriving Kids, the NDIS, Schools and ECEC
The Independent Review into the National Disability Insurance Scheme recommended that the “National Disability Insurance Agency and the Department of Education, with state and territory education and disability agencies, should develop a plan to better connect the NDIS and school education systems and improve educational outcomes for children with disability”8 The AEU agrees with that recommendation of the NDIS Review and also agrees that there should be “a dedicated Memorandum of Understanding for the school education and NDIS interface” 9 as recommended by the NDIS Review.
However, there were and still are significant questions that remain about the role of schools in the “foundational supports” proposed by the NDIS review and by the announcement of the Thriving Kids initiative. School systems have ultimate authority for ensuring that students with disability have access to the support that they need to participate in education on the same basis as students without disability, but it is the responsibility of governments who administer and fund these systems to ensure that schools have the resources necessary to support students with disability.
It is also the responsibility of governments to ensure that schools have enough resources and the capacity to complete the administrative and bureaucratic requirements that the system demands. An increased interface between schools foundational supports (whether through Thriving Kids or the NDIS) must not be used to reduce or replace the provision of already insufficient SRS disability loadings for students.
Not only will Thriving Kids need to provide substantial new funding for additional specialist staff to support children 0-8 years of age in ECEC and primary schools, the co-location of early intervention services with schools will require substantial additional school buildings and redevelopment of existing buildings to house new staff and to improve accessibility.
This initiative could result in fundamental changes to the way that early intervention is delivered through schools and ECEC providers requires a strong understanding of the resource implications of foundational supports such as Thriving Kids for school staff, and how those supports would be integrated with the public school system.
The Thriving Kids timeline is overly ambitious and does not consider its impact on schools and ECEC services
Additional clarity is needed on the proposed time frame for the rollout of Thriving Kids. We note that the Fact Sheet states “the first services are expected to be available from 1 July 2026
8 Working together to deliver the NDIS: Independent Review into the National Disability Insurance Scheme Final Report, 2023, p.5 9 Working together to deliver the NDIS: Independent Review into the National Disability Insurance Scheme Final Report, 2023, p.77
and would continue to ramp up over 12 months. This will ensure national services are in place ahead of broader changes to NDIS access arrangements from mid-2027.”10
The AEU is very concerned that a hasty proposed rollout of the initiative less than nine months from now will not provide the necessary time required to properly assess the impact of the scheme on the existing services it is intended to build upon, nor will it provide sufficient time to consider whether the proposed $2 billion in Commonwealth funding (and as yet unknown state and territory contributions) is enough to provide the foundational supports needed to replace current NDIS provision for children with mild to moderate autism or developmental vulnerabilities.
The Commonwealth must take the time to ensure that services are properly integrated and appropriately resourced before the rollout starts.
Disadvantage doesn’t start with school: the case for funded ECE loadings
The value of early childhood education is not just in setting the foundations for cognitive, physical, emotional, social and language development. It is often essential in terms of the detection of impediments to learning which, if not attended to, could affect a child’s learning potential for the rest of their life. ECEC can be the key to identifying and addressing vulnerability and helping to level the playing field. Children and families deserve to be supported from the earliest years, in ways that affirm culture, are inclusive of all family types, and recognise that some families need extra support.
ECEC services need to be resourced and supported to improve quality and outcomes for children where needs have been identified. Teachers need timely access to allied health professionals to help assess children and implement effective early intervention. Teachers and educational leaders also need to be afforded professional trust and autonomy to design and implement appropriate curricula in accordance with the learning frameworks and based on contemporary evidence and best practice.
The AEU has previously recommended that the Commonwealth should support states and territories with targeted funded programs to support children and families with additional needs in ECEC. Together with a base allocation of funding, loadings should be allocated within the framework of a National Equity Program based on the number of children identified as disadvantaged or having additional needs, targeted both at increasing participation and redressing disadvantage/meeting additional needs and providing Foundational Supports.
An example of targeted equity funding occurs in Victoria with School Readiness Funding for three- and four-year-old preschool programs. Each year additional funding is allocated to every preschool on the basis of the needs of children enrolled at the service informed by
10 https://www.health.gov.au/sites/default/files/2025-08/thriving-kids-fact-sheet.pdf
parental occupation and education data. Teachers and the service providers analyse the local needs of the community, analyse local-level data, and plan for a program of support to enhance learning and build the capacity of staff. Preschools identified at the highest level of need can receive over $200,000 per year of extra funding.
The AEU recommends that the Committee consider how existing inclusion support packages in ECEC are working to ensure children and staff are getting support when they need it, and how additional funds to be delivered through Thriving Kids can be incorporated. Appropriate on-site integration and outreach is important to identify families who need extra support in a way that is not perceived as punitive, to enable them to access universal programs and then be connected to the specialist programs they need.
Developmental vulnerabilities are best targeted early in a child’s life, and to ensure early intervention ECEC services should have free access to nurses and allied health professionals such as speech pathologists and physiotherapists. They could also provide pathways for referrals to child psychologists and pediatricians, and work with NDIS liaison partners. Where these services are not integrated on-site, a weekly or regular drop-in model could provide an effective means of support and connection.
ECEC services need to be resourced and supported to improve quality and outcomes for children where additional needs have been identified. In order to help assess children and implement effective early intervention, it is essential that teachers have timely access to allied health professionals.
The move towards “full-service” preschools and schools is welcome but will require significant investment
Three separate reviews published in late 2023 - the Expert Panel of the Review to Inform a Better and Fairer Education System, the NDIS Review and the ACCC Childcare Inquiry have all recommended greater integration between ECEC services, schools, and allied health and health services.
Parents and caregivers also need to be set up for success. Appropriate outreach is important to identify families who need extra support in a way that is not perceived as punitive, to enable them to access universal programs and then be connected to the specialist programs they need.
Coordination between early childhood, schools, health and family services and co-location of services could be significantly expanded to provide a seamless continuum of education and care from birth to eight years and beyond. Ideally, families should have access to a wide range of services in a single location such as long daycare, preschool, outside school hours care, and schooling, particularly for families experiencing disadvantage.
Questions for the Committee’s consideration
All the factors raised in this submission need to be considered before implementation. There are several core questions that must be answered before the scheme can proceed:
- How will Thriving Kids interact with existing loading categories for Students with Disability in schools?
- How will students who are assessed at the unfunded QDTP level of disability be included in the scheme?
- How will the stated aim of integrating Thriving Kids into schools work with the current prohibition on using NDIS funds for “services that are reasonable and necessary for children to participate in education”?11
- How will the additional staff required to conduct assessment and early intervention as part of the rollout of Thriving Kids in schools and ECEC services be hired and managed - by the schools, the Department of Health or by the NDIA?
- How will the substantial building and infrastructure works that will be needed to integrate Thriving Kids into Schools and ECEC services be funded?
- Will the co-location of services be managed by schools and ECEC services or by another agency?
AEU recommendations
- That the application of ECE loadings to preschool funding within the framework of a larger National Equity Program including Thriving Kids are considered.
- That the Committee seeks a guarantee from the Commonwealth that no funding allocated as part of the BFSA and its associated bilateral agreements will be diverted to Thriving Kids.
- That investing in the co-location of Thriving Kids with ECEC services on public school sites is prioritised, and that there is significant new capital investment to allow all services to successfully integrate.
- That additional funding to allow greater integration with allied health professionals to help children and implement effective early intervention is provided to schools and ECEC services in addition to funds provided as part of Thriving Kids.
- That a detailed funding model of the Thriving Kids initiative is produced prior to rollout, so that the recurrent and capital investment required for integration with public schools and ECEC services can be properly budgeted.