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

3/10/2025

Contact:
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About Speech Pathology Australia

Speech Pathology Australia is the national peak body for speech pathologists in Australia, representing more than 16,000 members. Speech pathologists are university trained allied health professionals with expertise in the diagnosis, assessment, and treatment of communication and swallowing difficulties. The Association supports and regulates the ethical, clinical and professional standards of its members, as well as lobbying and advocating for access to services that benefit people with communication and swallowing difficulties.

Table of Contents

• Executive Summary

• Key recommendations

• Response to Terms of Reference

  • Examine evidence-based information and resources that could assist parents identify if their child has mild to moderate development delay and support parents to provide support to these children.

  • 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. This should focus on community and mainstream engagement, and include child and maternal health, primary care, allied health playgroups, early childhood education and care and schools.

    • Identify equity and intersectional issues, in particular, children who identify as First Nations and culturally and linguistically diverse

    • Identify gaps in workforce support and training required to deliver Thriving Kids.

  • Draw on domestic and international policy experience and best practice.

    • Identify mechanisms that would allow a seamless transition through mainstream systems for all children with mild to moderate support needs.

    • References

Executive Summary

Autistic children and children with developmental delay and their families experience inconsistent access to services due to differences in systems, eligibility requirements and a lack of standards for specific minimum levels of service provision in Australia. A nationally consistent support framework is required to ensure that the diverse needs of these children are met.

Thriving Kids must be a robust, inclusive, and adaptive system that integrates with mainstream systems and supports children aged 0-8 years, their families, and the workforce that serves them. All aspects of the system, including integration with mainstream services must be reviewed holistically in order for any new framework to be successful. Current and former services must be reviewed to identify and address barriers to service access/provision.

It is critical that the entire workforce, including the private sector, is involved in the implementation of Thriving Kids to ensure that there is the skilled workforce available to provide these services. Allied health professionals, such as speech pathologists, play a vital role through flexible, evidence-based interventions that address children’s developmental needs. At the same time, upskilling the broader community workforce—including those in early childhood education and care—is essential to providing supports where children live, play, and learn.

Thriving kids must consider both the needs of the child with disability or developmental concerns and the family. Supports for Aboriginal and Torres Strait Islander peoples must be culturally safe and appropriate to the needs of that person and Community. Accessible information is critical to ensuring everyone can navigate the support system effectively.

Given the short timeframes for implementation, Speech Pathology Australia and the greater allied health sector must be involved in service design and implementation to ensure success. We have developed a conceptual model for these supports for the Inquiry to consider, attached in Appendix A.

Key recommendations

Recommendations

• Allied health providers must be included within the model as providers of assessment and direct, child-focused interventions.
• Issues of inequity between available mainstream services in different states and territories must be urgently addressed.
• Available services in mainstream systems must be expanded to provide necessary supports beyond assessment and scaled up to cope with demand. There must be access pathways for children not attending mainstream settings.
• There must be flexibility to provide individualised supports and access to appropriate assessments and equipment and technology when needed.
• There is a need for specific strategies to address the needs of culturally and linguistically diverse children and families and those living in rural, regional and remote areas.
• Specific supports and pathways are required to address the needs of Aboriginal and Torres Strait Islander children and families to ensure they are culturally responsive. These should be community designed and led.
• When developing this system of supports the vulnerability of parents and intersectional issues facing parents with disability must be taken into account.
• Employ a cross-sector approach to the provision of services, involving private, non-government, and mainstream providers to meet workforce demands and ensure quality service delivery that is integrated across the sector.
• Funding models should be adapted to engage a range of providers of supports
• Retention of the current workforce, and upskilling of the future workforce must be prioritised.
• Systems must provide pathways for family support alongside direct child-focused interventions and services must be accessible.
• There must be soft entry points for referrals to lessen barriers to accessing support.
• Develop a national system that includes a service database, tracks engagement and gathers data about available services.
• Establish a national system of governance for providers that is simple, free and incorporates existing governance systems for allied health professionals.
• Upskill the workforce in community and mainstream settings to help identify delays and support needs early in a child’s life and provide supportive environments.

Key principles that must be incorporated are highlighted on the next page.

Key Principles

The Key Principles that should underpin the national standards for Thriving Kids are:

1. No postcode lottery.

   National minimum standards must be set and monitored to ensure all children with disability or developmental delay have equal access to diverse, flexible, timely and culturally responsive supports that meet their needs—no matter where they live.

2. Allied health is essential.

   Allied health professionals must be part of foundational supports to identify delay or disability early, support capacity building, and provide vital interventions.

3. Utilise the whole workforce across sectors to ensure access to care.

   Employ a cross-sector approach to the provision of services, involving private, non-government, and mainstream allied health professionals in health, disability and education systems to meet workforce demands and ensure quality service delivery that is integrated across sectors.

4. Participants must have choice of providers/services.

   There must be more than one option or provider available for children with disability or developmental delay for families to choose from for their supports. Services cannot be limited to one size fits all programs, panel arrangements, or provider monopolies.

5. Ensure continuity of care.

   Foundational supports must be timely and integrate smoothly with the NDIS and mainstream systems, such as health and education, with clear referral pathways and seamless transitions within a connected system. Current services that are working well should be accessible as part of foundational supports, particularly in thin markets.

6. Care must focus on the person with disability or developmental delay, incorporating direct and indirect supports.

   Direct therapy interventions provided by qualified allied health professionals are needed to address the child’s delay or disability needs and allow them to reach their full potential. These supports must be evidence-based and delivered by professionals with the appropriate scope, training, and skills.

7. Accessible and culturally safe care.

   Supports must be inclusive, including communication-accessible services and complaints processes. Supports for Aboriginal and Torres Strait Islander peoples must be culturally safe and appropriate to the needs of that child and Community.

8. Streamlined compliance/governance framework.

   The governance of providers of foundational supports must be consistent nationally. Requirements should reflect existing systems, posing minimal administrative and compliance burden, applying equally to both nationally registered and tertiary qualified self-regulated allied health professionals.

Response to Terms of Reference

Speech Pathology Australia conducted a survey in September 2025 which garnered 719 responses from speech pathologist members working across Australia with children aged 0-8 years. Within this data set were 216 respondents who identified that they worked in a rural, regional or remote area. Aggregate data and direct quotes have been provided throughout this submission.

Examine evidence-based information and resources that could assist parents identify if their child has mild to moderate development delay and support parents to provide support to these children.

Delayed communication skills are a key issue for the proposed cohort who will be accessing the Thriving Kids program. Current data from the Australian Early Development Census National Report (2024)i indicates that 1 in 4 children are not developmentally on track with their communication skills when they start school. Difficulties with social communication form part of the current diagnostic criteria for Autism. Children with developmental delay may experience difficulties with their communication and 1 in 14 children has developmental language disorderii. More than 73% of our members report that they work with children aged up to 12 years.

There are some evidence-based resources to assist parents and early childhood educators in identifying if their child is not on track with their communication skills, such as the Communication Milestones projectiii. This resource provides bright, colourful posters that list the typical communication skills of children at specific time points up to the age of five years. This resource aims to assist in identifying delayed communication skills and encourage referral to a speech pathologist for assessment.

The Hanen Centre has a range of fact sheetsiv about communication development in plain language that are publicly available. They have also developed group training programs for parents to learn to support their child’s communication skills such as It Takes Two to Talk and the More Than Words program specifically for Autistic children. There are some research studies considering the efficacy of these programs, particularly It Takes Two To Talk with different populations of childrenv. It must be noted that these programs are not freely available through public, mainstream systems in Australia and are most often provided through a fee for service model. Nationally, there is a lack of free services and resources for parents and caregivers to assist them in supporting their child.

The 2024 National Framework for assessing children’s strengths and support needs outlines the barriers and proposes a framework for addressing this aspect of care, with a shift away from a focus on diagnosis. Importantly, this framework focuses more on access to a supportive, culturally safe process for families that is centered around function and impactvi to encourage early identification and family empowerment. It discusses the core competencies that are needed to appropriately differentiate support needs and is a recommended resource for this Inquiry to consider.

The appropriateness of capacity building supports

1. Allied health providers must be included within the model as providers of assessment and direct, child-focused interventions.

Parents and caregivers are unlikely to receive the education and training that is provided to allied health professionals regarding child development. They may be aware that something is ‘wrong’ but unable to identify what the exact concern is, or whether intervention is neededvii. Victorian research suggests that parents are less likely to seek help for children with potentially delayed communication skills until after the age of threeviii. It is particularly unlikely that parents will be able to determine the degree of delay or differentiate the level of support needs, as this is the role of a health professional with specific training and expertise.

The importance of intervention from allied health professionals that is directly provided to the child and addresses child outcomes cannot be overstated. Allied health professionals, such as speech pathologists, play a vital role in supporting children’s developmental needs through targeted, evidence-based interventions delivered flexibly.

Supports that focus entirely on upskilling parents, without providing direct supports to the child may not be suitable for all families, particularly where there are additional factors that may impact on parent capacity to provide interventions (including trauma, financial hardship, mental health needs, illness or disability). Family centred supports such as the Key Worker model may be of benefit to families to support case coordination and facilitate system navigation, however these models do not provide direct input to the child, as they are specifically family centred rather than child centredix. There is limited evidence as to the efficacy of these programs due to a lack of formal research and a 2025 scoping review showed that they do not impact upon child outcomesx.

Recent research regarding the parent experience demonstrated that parents and caregivers may not wish to be a therapist for their child, and valued health professionals working with their child directly rather than relying entirely upon coaching. Additionally, the concept of ‘capacity building’ may be used negatively to pressure parents to be therapists and ‘fix’ their child, blurring the role that they have as a caregiver and, in some reports, affecting their relationship with the childxi.

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. This should focus on community and mainstream engagement, and include child and maternal health, primary care, allied health playgroups, early childhood education and care and schools.

Early identification of support needs is critical, but is not always occurring. This was an issue identified in the 2024 ‘A path to universal early childhood education and care’ report by the Productivity Commissionxii and the previous consultation on Foundational Supportsxiii. Funding structures and programs often require a formal diagnosis or entry via a specific referral pathway. This creates barriers to access and a cascade of significant delays to receiving services and opportunity cost as early intervention is not provided in a timely manner. There is a need for soft

entry points to services (e.g. referrals from maternal child health nurses, community workers, or early childhood settings) that are not restricted by particular diagnoses.

The Productivity Commission emphasised the importance of early childhood education and care settings as being the first places that may be able to identify delays or potential disabilities in young children. Therefore, workers in early childhood education and care and other community services (such as playgroups, community hubs and maternal child health nurses) must be part of the system for identification of need for Thriving Kids. The Productivity Commission recommended that allied health services such as speech pathology must be integrated within these community settingsxii to ensure early intervention does occur early in a child’s life.

There have been some projects focused on embedding speech pathology supports in these settings which report positive outcomes such as the Guyati, Garraka Wa Witing project in Kempsey NSW. There are also some Language Development Centres in Western Australia and the Preschool Speech and Language Program is run in eight preschools in South Australia. These aim to provide speech pathology services to children with identified developmental language disorder and severe speech and language impairment respectively.

The Every Toddler Talking initiative, sought to address the finding of the Early Language Victoria Study that up to 70% of parents of children aged 1-3 with early signs of communication problems did not seek help. This state government program involved speech pathology input delivering a Hanen training program to educators and developing educator skills in providing language rich environments in seven selected local government areas in Victoria. Evaluation of this program suggested that it demonstrated improvement in the behaviour of educators following trainingxiv.

Key issues for the Inquiry to consider:

Limited evidence

In terms of effectiveness, factors such as available funding rather than best practice may determine what supports and services are availablexv and whether they are evaluated. Research on the efficacy of programs is lacking, and often children with particular diagnoses, or who come from certain backgrounds (e.g. culturally and linguistically diverse) may be excluded from research studies. This limits the evidence base, and influences the generalisability of certain programs and services to populations where they have not been studied.

Concerns regarding mainstream settings

2. Issues of inequity between available mainstream services in different states and territories must be urgently addressed.

When focusing on the provision of supports in mainstream settings, there is a significant issue of inequity between different states and territories, particularly with regard to education settings. New South Wales, the Australian Capital Territory and Western Australia do not currently employ speech pathologists and other allied health professionals in schools.

Speech pathologists who responded to our survey identified that kindergartens, preschools, primary schools and early education and care settings were the places most lacking supports for children aged 0-8 years. They specified that community health and other health settings

such as hospitals are more likely to have available services for children with mild to moderate support needs. Primary schools were listed third, but with the caveat that all currently available services were not sufficient to meet children’s needs and had long waiting lists.

Speech pathologists working with children report:

“Huge wait lists, small caseloads of public health therapists. 6 sessions per block then back on waitlist. Discharged at age 5 regardless of needs.”

“Hospital services take 0-3 year old children with moderate to complex needs, with priority on those recently discharged from hospital, many children face long wait times as state funded services were de-funded when NDIS came into place!”

“Community health only provides services up to school age, there is a 12-18 month wait for community health services in our area. Once school age there is no SP in schools in NSW.”

“Our local community health supports are the only publicly funded options available to families who are not accessing NDIS. The service is stretched. Children 0-3 years can access a maximum of 12 Speech sessions per year under this support. Kindy and PP aged can access 6 sessions. And School aged is 1-2 services only.”

One member reported that services were:

“Available [in health/hospital] but limited especially for mild - moderate. Waitlist is average of 264 days and only 6 weeks of therapy provided.”

3. Available services in mainstream systems must be expanded to provide necessary supports beyond assessment and scaled up to cope with demand

The lengthy wait to access services and restrictive nature of service offerings (e.g. a block of 5 sessions, or sessions across six weeks) were highlighted as significant issues with mainstream supports.

Survey respondents reported concerns that current mainstream services, particularly those available in schools focused on assessments and diagnostic processes and did not have capacity to provide any interventions to improve child outcomes. Further, intervention services when available were only offered to children with high support needs, with no services available for children with mild to moderate support needs.

“Speech Pathology services are offered to kids with [m]oderate to severe needs at schools. Mild children are typically not seen due to limited resources. Child Development Service does not have enough practitioners to support the needs (only have about 3 - 1 year waiting list)…Don’t believe Speech pathology services are offered to people with mild difficulties in state based disability services. Students must have IQ disability to access special school speech pathologists”

“There are no government services that provide for mild-moderate support needs for the 0-8 yr old cohort. All government services are for severe support or provide information. Charities and the private sector provide services for mild-moderate supports.”

4. There must be support pathways for children who do not attend mainstream settings

Concerns were also raised that if services were limited to mainstream settings, such as schools, then children who do not attend school would miss out. The Disability Royal Commission identified that children with disability (including Autistic children) may face barriers to enrolment in mainstream education settings and research suggests they are more often subject to exclusion and expulsion practicesxvi. School refusal is also more prevalent in Autistic childrenxvii, therefore consideration needs to be given to ensuring accessible pathways to access care for this part of the target cohort for Thriving Kids.

Currently allied health services are not always part of primary care supports, and the engagement of allied health by primary health networks varies significantlyxviii. There would need to be a significant shift in culture to better recognise and engage allied health professionals if these settings were to be utilised to provide supports under Thriving Kids.

Limitations of screening

5. Referral options for assessment and diagnostic services are needed.

Some screening programs are currently being rolled out to better identify young children with support needs, such as the Brighter Beginnings program in NSWxix. However, speech pathologists report concerns that children may be identified through screening processes, only to be unable to access a service, as there are not sufficient supports available to address their identified needs. Additionally, delayed development may indicate another diagnosis or a child’s needs may fluctuate or progress over time, however screening is not assessment and does not permit diagnosis. These issues emphasise the need for referral options for full assessment and diagnostic services in addition to screening.

Speech pathologists report:

“There are massive gaps in access though, for children 0-8, with families often needing to pay for services they cannot afford or not accessing services. There is no statewide program for surveillance and therapy for premature babies / young children and almost no access for kinder and school aged children. There are limited public autism assessment clinics, with waits often 2+ years.”

“I work for a multidisciplinary allied health team (psych, speech, social work) in the public education sector in Victoria…We provide assessment and short term treatment to those referred to our service for support with speech sound production and oral language and literacy difficulties. The service is highly triaged and dependent upon referral structures/inclusion leaders within individual schools. We are the only no cost SP service for school aged children in our area.”

Access to equipment

6. Eligibility requirements and pathways to access assistive technology and equipment must be considered as part of the Thriving Kids program.

Speech Pathology Australia has concerns regarding pathways for children to access necessary equipment under Thriving Kids. Children with communication needs may need to access alternative and augmentative communication (AAC) supports. At present some states and

territories have statewide equipment services for people aged under 65 years, who are not NDIS participants, such as the Victorian Aids and Equipment program (VAEP). These services have different eligibility requirements and supports available depending on the state or territory policy.

We recommend investigating the revival of previous services that worked well but were shut down following the roll out of the NDIS. For example, community assistive technology hubs where both service providers and people with disability were able to investigate and receive advice regarding different technologyxx.

One member proposed:

“I think Disability SA (a former government agency) should be recreated for kids. This was the service which provided support for families needing multiple D[iscipline] support children and was the key way to get a child and their family set up on a properly prescribed and trialled AAC device. Once NDIS was created this service was disbanded and consistent access to this type of service (including their outreach program) was lost creating gaps in connection between agencies and gaps in service.”

Issues facing children in rural, regional and remote areas

7. There is a need for a specific strategy to ensure that children in rural, regional and remote areas do not fall through the cracks.

There is a significant negative impact of the current lack of services, including reported childcare deserts in particular parts of Australia, specifically rural and remote areas. This inequity has been identified within the NDIS Review as a significant issue for families and caregivers. Children in remote areas of the country are experiencing delays in diagnosis and access to supportsxxi. Families may also mistrust outsiders and require time and concerted effort to build trust and rapport with services.

Members in rural, regional and remote areas across Australia reported:

“We work with many families who have significant barriers to accessing services. These are generally the families who need the services the most…Families in this region require relationships and rapport before they will trust providers and work with them successfully.”

“All services in our regional town have extremely long waiting lists (our waiting list currently sits at 259 children who have not been seen - most will never be seen). It takes about 2 years to get into a Paediatrician.”

“The key word here is “available”. I would say that even though some of these services exist, wait lists are years long in my region rendering them a non-existent option.”

Identify equity and intersectional issues, in particular, children who identify as First Nations and culturally and linguistically diverse.

8. Supports and services must be tailored in consultation with culturally and linguistically different (CALD) communities or Aboriginal and Torres Strait Islander Communities.

Note that these two groups are often considered together with regard to policy and alternate service pathways, but they are not the same, thus the needs of these different communities must be considered separately.

Any new system of supports must recognise the ongoing impacts of colonialism, systemic racism, and social determinants of health for Aboriginal and Torres Strait Islander peoples. These factors underpin mistrust of mainstream systems, including fear of surveillance and child removal. Cultural safety must be embedded at every stage of the Thriving Kids program, guided by Aboriginal and Torres Strait Islander knowledges and leadership. This may require soft entry points with trusted community services, different ways of sharing information, and approaches that reflect community concepts of disability and difference. In some cases, whole-of-community upskilling and supports may be preferred. All approaches must be tailored to, and led by, Aboriginal and Torres Strait Islander communities to reflect ways of being and doing.

People from CALD backgrounds may also experience racism and barriers to accessing supports but in different ways that are frequently systemic. Migrant families may not have access to care as they are ineligible for specific funding systems such as Medicare and NDIS due to their residency status. Recently there has been welcome amendment to the legislation regarding applications for permanent residency for children with disability born in Australia to migrant parents, however there may need to be a specific campaign to ensure understanding of these new rules and engage these families.

CALD families face a range of cultural and linguistic barriers, including widespread reports that information about available services and information provided by services is rarely translated due to limited resourcing. There is a concurrent lack of access to funding for qualified interpreters, with workforce shortages for certain interpreter typesxxii. Research often deliberately excludes CALD families in attempts to control variables within data gathering. Screening and assessment tools are very rarely developed or validated for use with families who do not speak English as a first language and they may not be culturally appropriate for particular communities.

One speech pathologist reports:

“Most of the families accessing our services have mental health needs and are from a refugee background. There are a lot of barriers that these individual families face. Unfortunately these barriers especially their mental health and their financial situations are barriers that will prevent them from accessing services with Thriving Kids as a one size fits all approach does not work. They come to us, as we are offering them individual programmes and we are supporting the whole family.”

9. When developing this system of supports the vulnerability of parents and intersectional issues facing parents with disability must be taken into account.

Autism has a genetic component and runs in families, therefore parents may be caring for more than one Autistic child or family member and may be Autistic themselves. A research report published by the Disability Royal Commission discussed that Autistic parents and parents with disability may be affected by systemic bias and prejudice by workers in the child protection system. Parents with disability may deemed to be unfit and face removal of their children, discouraging them from seeking supportsxxiii.

This bias must also be considered with regard to parenting programs, and services to support parents of Autistic children, or children with developmental delay. If a parent is also Autistic, or has a disability, this may affect their engagement with services and prejudice within services themselves. Parents with disability are more likely to experience surveillance and judgements about their parentingxxiii. The appropriateness of programs that involve video feedback and critique must be considered carefully through this trauma informed lens.

General burdens and challenges faced by families must be acknowledged. It has been identified that parents and caregivers of children with disability experience barriers to full-time employment.xxiv Parents of children with disability also report higher rates of mental health challenges and relationship breakdownxxv. A family may have limited supports and experience financial hardship, family violence and trauma. These factors may affect their ability to access or engage with supports for their child. Therefore, in alignment with support/s for the child themselves, there must also be pathways for their families, caregivers and kin to be supported.

One speech pathologist highlighted:

“There also needs to be support available for parents who struggle with executive functioning and communication, especially since neurodivergence has a strong genetic component. In my experience, these parental challenges have been a significant barrier to NDIS engagement and support for their children. Many parents are overwhelmed and at significant risk of carer burnout so streamlined processes with embedded supports for parents are critical to ensure many ‘at risk’ children can engage with supports.”

Identify gaps in workforce support and training required to deliver Thriving Kids.

Retention of skills and knowledge

10. Thriving Kids must involve the entire sector, including private providers to retain the full breadth of this knowledge and experience.

Allied health providers who are highly experienced in working with young children and their families are not confined to the not for profit, non-government organisation (NGO) or mainstream workforces in health and education. Following the advent of the NDIS, many providers who were formerly working in community services or NGOs were required to move to the private sector, as state funded, or block funded Early Childhood organisations were privatised or shut downxxvi.

As highlighted in this submission and the attached Conceptual Model of Foundational Supports, the provision of direct supports, delivered in groups and individually will be required to meet children’s needs. These may be best provided by speech pathologists experienced in providing therapy services in the private sector. Given the workforce shortages, the current workforce within the mainstream, NGO, and community segments alone is insufficient, making it essential to also leverage providers from the private workforce.

New funding pathways

11. Funding models should be adapted to engage therapy providers across the sector.

The current Medicare item for Chronic Condition management that only permits five subsidised sessions across all allied health per calendar year is likely to be insufficient to deliver Thriving Kids. Data from the Early Language in Victoria Study (ELVS) – a large prospective Australian cohort study that tracked language development from infancy through to adolescence– reinforces this point. Children who accessed speech pathology services received a median of 10.8 hours of therapy in 12 months (IQR 4.3–17.3), across a median of 15.2 visits per year (IQR 6.5–26).xxvii

Speech Pathology Australia recommends development of a new Medicare item that can be utilised to facilitate access to critical speech pathology care under the Thriving Kids program. Eligibility must not be confined to limited diagnoses - M10, even with expanded eligibly for speech sound disorders, will be insufficient to provide the care that the Thriving Kids cohort will need. A new item number is therefore recommended to cater for this cohort - for all communication and swallowing needs, as diagnosed by a qualified speech pathologist. Eligibility criteria and item coverage should align with real-world needs and models of care, with MBS rebates increased to reflect the true cost of service delivery (including Award wage rises) and structured through tiered rebate levels based on session duration to prevent widening gaps between service costs and government support. The 2024–25 NDIS Annual Pricing Review found that session lengths for speech pathology at the 75th percentile were 58 minutes for MBS-funded services and 51 minutes for Private Health Insurance (PHI)-funded services. The available rebate must also reflect the cost of providing care, noting the potential savings in the long term.

An analysis by Cronin et. al suggests that $355 per person per year could be saved through effective treatment or early identification of “speech, language and communication needs”, resulting in lifetime savings of $5.22 billion across the population.xxviii Internationally, a 2010 study commissioned by the Royal College of Speech and Language Therapists (RCSLT) (UK) estimated that for every £1 invested in enhanced speech and language therapy, £6.43 was returned through increased lifetime earnings. xxix This demonstrates economic value of communication-focused intervention.

Workforce retention

12. Retention of the current workforce, and upskilling of the future workforce must be prioritised.

Providers of services for young children and their families must have access to clinical supervision, both to ensure best practice, and prevent burnout. Burnout is a significant risk to an already overstretched health sector, particularly following the Covid-19 pandemicxxx.

One research study identified the need for additional training and wellbeing supports for those working within the early childhood space due to the emotional toll of supporting the mental health of families without specific trainingxxxi. Clinical supervision and professional support were also identified as being as important as renumeration by early career speech pathologists in Speech Pathology Australia’s Workforce Reportxxxii.

Organisations, businesses and mainstream departments providing Thriving Kids must be incentivised to provide supervision and support for therapists early in their career, and workers looking to upskill or develop their practice. This may take the form of grants, vouchers, or a connected mentoring program, particularly targeted to rural, regional and remote areas to support isolated practitioners.

System governance

13. There must be a nationally consistent system of governance, regulation and compliance monitoring for providers of Thriving Kids

Governance and or/compliance must be overseen by a national mechanism, so that a worker cannot be banned in one state and then simply move to another jurisdiction and continue to provide services.

It is critical that any provider recognition process is simple and free (or low cost), taking advantage of pre-existing structures to avoid bottlenecks and lengthy delays before being able to begin work. For instance, taking advantage of the state-based working with children check process but having this be held against a national database or utilising the national Medicare provider number system that is already in place for allied health providers.

There should be recognition of qualifications and certification with peak bodies that already provide regulatory oversight. Allied health professionals are subject to robust quality and safety checks through the National Registration and Accreditation Scheme, and peak bodies for self-regulated professions such as speech pathology. Therefore, these two groups must be recognised through the same registration requirements or process for Thriving Kids to avoid a two-tiered system for providers.

Draw on domestic and international policy experience and best practice.

Allied health supports are vital to early childhood development, to enable Autistic children and children with developmental delay to be able to reach their full potential. Evidence suggests that these interventions, particularly when started early, contribute to better long-term outcomes for children with disabilitiesxxxiii.

We have developed a conceptual model for how the system might work in Appendix A. Note that this model reflects an eco-system rather than a simple list of services. The foundation is accessible environments, and informal supports provided by communities and families. As highlighted in the Early Years Strategy, these supports are essential and must be acknowledgedxxxiv. There must also be soft referral options that are not restricted to medical practitioners to enable families and community workers to self refer in to the system, perhaps to access screening or investigation of the need for more direct supports.

The Thriving Kids program should connect with the development of community based supports such as Kids Hubs to support mental health and wellbeing, currently being trialed in South Australiaxxxv.

The Sure Start program in the UK is another example of this type of community support. The program implemented one stop shops for families and young children under the age of five in target areas of low socioeconomic status. Families and caregivers could access a range of supports, including parenting supports, health supports, communication playgroups and be linked in with social workers, maternal child health nurses and allied health providers. Evaluations of this program suggest positive long term impacts up to the age of 16 upon educational attainment, reductions in hospitalisations of older children and adolescents, reduced school absences and lesser need for special education supports at later ages. Research suggests a significant cost to benefit ratio, both in terms of reduction in later government spending and an increase in taxable income and earningsxxxvi.

Survey respondents discussed:

“We need central hubs that provide a home like environment where families feel welcomed and embraced and where a full multidisciplinary team can work together collaboratively to provide holistic general education, group and individualised programs and work in partnership with families.”

“Broad spectrum program, formula based interventions are not best for all parts of our community and creates social bias and exclusion from services. To be immersive in working towards integrated community supports there needs to be therapists on the ground providing care, but in a collaborative and capacity building manner enhancing the collective community supports for at risk individuals.”

A speech pathologist in remote Qld discusses something that is working well:

“Working in predominantly First Nations communities, care is relational and whole of family. A one stop shop, led by health workers, with comprehensive allied health to meet the holistic needs of families, helps stabilise and support families to then engage in screening, diagnosis, and treatment of the child”

Mainstream services are a critical part of the eco-system, both for assessment and referral pathways, but also as potential providers of interventions for children. Services must be tailored to the needs of the child with a flexible framework of service and referral options as they may need access to a range of different allied health supports. These are highlighted in the blue circles and include family centred supports and more direct child centred supports in the conceptual model in Appendix A.

14. Services must include both direct child centred services and non-direct services to support families and caregivers.

The Thriving Kids system for children and their families must consider both the needs of the child with developmental delay and their family, caregivers and kin. However, as stated earlier, supports cannot only be based around case management and parent coaching. Tangible, targeted supports provided by trained allied health professionals such as speech pathologists

are needed. These supports can be delivered in a range of ways and settings, including face to face, individually, in groups, and via telepracticexxxvii. Individual supports may be enabled by the provision of a voucher or grant based program similar to the current Hearing Services Programxxxviii or an appropriate Medicare item number. There must also be provisions for access to necessary equipment, including AAC supports and support with referrals to the NDIS if a child receives a relevant diagnosis, or their needs become more complex.

There were strong recommendations within the NDIS Review about the need for a connected system, with information about supports available to families and caregivers. An important part of these connections is an information database of available services. To ensure the information is reliable, this database must be established and maintained, with regular updates as supports are added and systems evolve.

We believe this should be part of a larger Information Communication Technology system provided at a national level. This should function similar to My Health Record, and be accessible via MyGov with a system that is available to different mainstream providers to share information and document referrals, service delivery and exits. A branch of this system could be accessible to parents to empower them through their journey with their child, similar to the vaccination and infant health records that currently exist (e.g. the blue book in NSW, or red book in South Australia). It would allow for data gathering regarding service gaps and thin markets, ensuring that children do not fall through the cracks.

A governance and compliance framework for providers must be established at a national level and could also be included within this ICT framework. This would also include a complaints pathway that is accessible for families and caregivers.

A proposed pathway through the system presented by the model might be:

1. Identification either by community support or mainstream service of a communication delay in a 4 year old child

2. Attendance at a screening appointment provided by mainstream service

3. Identification of need for support & creation of a record within ICT system/link to existing health record

4. Family linked in with key worker or case navigator

5. Attendance at a playgroup with both speech pathology and OT, notes uploaded to ICT record

6. Key Worker discusses notes with caregiver, need for greater supports

7. Refers to service provided by a speech pathologist experienced in early childhood development via voucher system

8. Child receives specific 1:1 intervention with the speech pathologist and suggestions for school transition are provided to family and Key Worker or navigator

9. Child transitions to school, with access given to record of involvement with Thriving Kids, receives supports via allied health provider at school.

10. Services and supports must be accessible

Accessibility is not just about physical needs, such as being able to enter a building, or participate in an activity with mobility aids but communication accessibilityxxxix, so that

information is able to be understood and families and children are able to interact with the service or support in their chosen communication method.

The NDIS Review also specified that services and supports must also be accessible with regard to cost. Out-of-pocket healthcare spending in Australia accounts for 17% of total health expenditure – one of the highest proportions across Organisation for Economic Co-operation and Development (OECD) countries. xl Research by the Grattan Institute has shown that such costs particularly disadvantage people from lower socioeconomic backgrounds, who are more likely to delay or forgo necessary care due to financial pressure.xl

Identify mechanisms that would allow a seamless transition through mainstream systems for all children with mild to moderate support needs.

16. There is a need for a national ICT system, that is accessible by different mainstream systems and other providers of supports under Thriving Kids.

At present services for children within different mainstream systems are disjointed and involve separate types of support being offered in silos, with little to no connection between systems. For example, school and education-based services and the public health system work independently, with communication about the needs of a child predominantly occurring via written reports.

As specified in the Conceptual Model a national ICT system would enable tracking of touchpoints and engagement with the system, to avoid duplication. This would streamline services, enhancing transitions between different aspects of the ecosystem and lessen the burden on families to repeat information.

17. Policies restricting access to mainstream settings must be reconsidered in the context of Thriving Kids to meet the needs of children and families.

Best practice principles indicate that supports should be provided in natural settings where children live, play and learn. It is acknowledged that while allied health supports are sometimes provided in clinic-based settings, this may be related to systemic issues, such as a policy within a childcare, or educational setting that prohibits external visitors.

Current barriers must be addressed and removed, particularly ‘gatekeeping’ within education systems whereby access to permitted or funded supports is dependent on individual principal choice and control. This has been identified by the Disability Royal Commission as limiting and at times denying children with disability the supports they needxli.

One speech pathologist stated:

“Currently, in real life situations, each school principal decides how easy or difficult they can make it for children to access therapy within schools. Some schools value the collaboration, and we are seeing great outcomes for children. However, some schools are reluctant to collaborate, and we are seeing poor school attendance, suspensions and stressed out children, parents and teachers.”

18. Greater training and capacity building for early childhood educators must be prioritised

The capacity of early childhood education and care-based settings must also be improved, including upskilling this sector to help scaffold other targeted supportsxlii and incorporating allied health supports such as speech pathology within these servicesxliii. The availability of different environments where families may be able to receive advice and supports is critical.

One speech pathologist proposed:

“Beyond workforce limitations, a significant effort must be placed on educating local community groups, early childhood centres, and schools about early childhood development. Many educators still hold outdated views about disabilities and early childhood development, and these perspectives are harmful not only to the mental health of children but also to families who feel unsupported and misunderstood. It is a concerning trend to see children being denied community-based supports because they are labeled as “just naughty”… despite showing signs of needing assistance.

References

^i AEDC National Report 2024
^ii Developmental language disorder (DLD)
^iii Speech Pathology Australia (2018). Communication Milestones. https://www.speechpathologyaustralia.org.au/Public/Public/Comm-swallow/Speech-development/Communication-milestones.aspx
^iv The Hanen Centre - Late Talkers… What We Know, and What We Don’t
^v The Hanen Centre - Research
^vi CRC, A., 2024. National Framework for Assessing Children’s Functional Strengths and Support Needs in Australia: Supporting Information, Autism CRC. Australia.
^vii Sudec, L., Brooks, J. J., & Roberts, M. (2020). Parents’ sensemaking processes in the identification of developmental delays and engagement with early intervention services. Social science & medicine (1982), 255, 112941. https://doi.org/10.1016/j.socscimed.2020.112941; Assessing and responding to parenting support needs in disadvantaged families: Lessons from parent education programs | Australian Institute of Family Studies
^viii Skeat, J., Eadie, P., Ukoumunne, O., & Reilly, S. (2010). Predictors of parents seeking help or advice about children’s communication development in the early years. Child: care, health and development, 36(6), 878-887. https://doi.org/10.1111/j.1365-2214.2010.01093.x\ ^ix The ‘Key Worker’ Model of Service Delivery - CanChild
^x Park, K. K., & Carta, J. J. (2025). Defining the Characteristics and Outcomes Associated With the Primary Service Provider Teaming Approach: A Systematic Review. Journal of Early Intervention, 0(0). https://doi.org/10.1177/10538151251316890
^xi Pozniak, K., King, G., Chambers, E., Martens, R., Earl, S., Kraus de Camargo, O., … Rosenbaum, P. (2023). What do parents want from healthcare services? Reports of parents’ experiences with pediatric service delivery for their children with disabilities. Disability and Rehabilitation, 46(12), 2670–2683. https://doi.org/10.1080/09638288.2023.2229733\ ^xii Productivity Commission (2024) Inquiry Report - A path to universal early childhood education and care - Productivity Commission
^xiii General Support Consultation Paper
^xiv Eadie, P., Taylor, C., & Stark, H. (2017) Every Toddler Talking Final Report.pdf
^xv Nickless, T., Gold, L., Dowell, R., & Davidson, B. (2023). Public purse, private service: The perceptions of public funding models of Australian independent speech-language pathologists. International journal of speech-language pathology, 25(3), 462-478. https://doi.org/10.1080/17549507.2023.2213864\ ^xvi Cleary, M., West, S., McLean, L., Johnston-Devin, C., Kornhaber, R., & Hungerford, C. (2024). When the Education System and Autism Collide: An Australian Qualitative Study Exploring School Exclusion and the Impact on Parent Mental Health. Issues in Mental Health Nursing, 45(5), 468-476. https://doi.org/10.1080/01612840.2024.2328251\ ^xvii Clark, S (2023). School refusal — Parliament of Australia
^xviii The National PHN Allied Health in Primary Care Engagement Framework (2022) The-National-PHN-Allied-Health-in-Primary-Care-Engagement-Framework.pdf
^xix Brighter Beginnings | Northern NSW Local Health District
^xx ComTEC Services; Changes to the provision of ComTEC Services at Yooralla | Yooralla
^xxi NDIS Review (2023) What we have heard report
^xxii Disability Royal Commission (2023) First Progress Report
^xxiii Terri Libesman, Paul Gray, Eloise Chandler, Linda Briskman, Aminath Didi and Scott Avery, Parents with Disability and their Experiences of Child Protection Systems, Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability (2023).
^xxiv Tokić, A., Slišković, A., & Nikolić Ivanišević, M. (2023). Well-Being of Parents of Children with Disabilities—Does Employment Status Matter? Social Sciences, 12(8), 463. https://doi.org/10.3390/socsci12080463

v Australian Institute of Family Studies (2008) The nature and impact of caring for family members with a disability in Australia | Australian Institute of Family Studies

vi Anaf, J., Freeman, T. & Baum, F. (2024) Privatisation of government services in Australia: what is known about health and equity impacts. Global Health, 20, 32. https://doi.org/10.1186/s12992-024-01036-w

vii Skeat J, Gold L, Wake M, Ukoumunne OC, Reilly S. The costs of preschool communication problems. Med J Aust. 2011 Sep 19;195(6):322. doi:10.5694/mja11.10254

viii Cronin P, Reeve R, McCabe P, Viney R, Goodall S. Academic achievement and productivity losses associated with speech, language and communication needs. Int J Lang Commun Disord [Internet]. 2020 Jul 20 [cited 2024 Jun 11];55(5):816-28. Available from: https://doi.org/10.1111/1460-6984.12558

xix Marsh K, Bertranou E, Suominen H, Venkatachalem M. An economic evaluation of speech and language therapy [Internet]. London: Matrix Evidence; 2010 [cited 2025 Apr 16]. Available from: https://speechandhearingbc.ca/wp-content/uploads/2018/04/The-Economic-Case-for-Speech-and-Language-Therapy.pdf

** Australian Institute of Health and Welfare (2024) Health workforce - Australian Institute of Health and Welfare; Mental Health Australia (2022) Mental Health Day 2022 Info 2

xi Young, D., Gibbs, L., Gilson, K. M., Williams, K., Reddihough, D., Tracy, J., Tonmukayakul, U., & Carter, R. (2021). Understanding key worker experiences at an Australian Early Childhood Intervention Service. Health & social care in the community, 29(6), e269-e278. https://doi.org/10.1111/hsc.13350

xii Speech Pathology Australia (2023) Speech Pathology Australia Workforce Analysis Report 2023

xiii Dimakopoulos, R., Vakalaki, T., Spinou, A., Michopoulos, I., & Papadopoulou, M. (2024). Effectiveness of therapeutic interventions on participation in children with cerebral palsy: A systematic review and meta-analysis. Child: care, health and development, 50(4), e13301. https://doi.org/10.1111/cch.13301; Smythe, T., Zuurmond, M., Tann, C. J., Gladstone, M., & Kuper, H. (2021). Early intervention for children with developmental disabilities in low and middle-income countries - the case for action. International health, 13(3), 222-231. https://doi.org/10.1093/inthealth/inaa044 ; heiw.nhs.wales/files/early-years-health-inequalities-toolkit/

xiv The Early Years Strategy 2024-2034

xv Kids Hubs | SA Health

xvi The short- and medium-term effects of Sure Start on children’s outcomes | Institute for Fiscal Studies; Hayre, J., Pearce, H., Khera, R., Lunn, A. D., & Ford, J. A. (2025). Health impacts of the Sure Start programme on disadvantaged children in the UK: a systematic review. BMJ open, 15(2), e089983. https://doi.org/10.1136/bmjopen-2024-089983

xvii Pinkerton, L. M., Murphy, A., Bruckner, E., & Risser, H. (2023). Therapy service delivery for children with disabilities during COVID-19: Parent perceptions and implementation recommendations. Journal of community psychology, 51(6), 2430-2441. https://doi.org/10.1002/jcop.22899

xviii Eligibility for the Hearing Services Program | Australian Government Department of Health, Disability and Ageing

xix Communication access

xx Duckett S, Stobart A, Lin L. Not so universal: How to reduce out-of-pocket healthcare payments. Melbourne: Grattan Institute; 2022. Available from: https://grattan.edu.au/wp-content/uploads/2022/03/Not-so-universal-how-to-reduce-out-of-pocket-healthcare-payments-Grattan-Report.pdf

xli Disability Royal Commission (2023) Final Report - Volume 7, Inclusive education, employment and housing - Part A

xlii Community Early Learning Australia (2021) Investing-in-our-Future-25-Nov-2021.pdf

xliii Productivity Commission (2024) Inquiry Report - A path to universal early childhood education and care - Productivity Commission

Conceptual model Foundational Supports

Data gathering	Service directory	Governance and complaints

• Case management/ navigator

• Key Worker

• Parenting Supports

• Sibling groups

• Carer supports

• Group supports

• Training programs (Parents; educators)

• Transition supports/ programs

• NDIS referral

NDIS

• 1:1 therapy
• Assistive technology

Foundational Supports (or Thriving Kids) may be provided by:

• Non-government organisations
• Private providers
• Early childhood providers
• Education
• Health (including community health)
• Dependent on commissioning arrangements in states and territories

Mainstream services

• Health

• Community health

• Preschool field officers

• Education

• Specialised kindergartens/ preschools

• Maternal child health nurses

• Child protective services and Early Childhood Education and Care

• Council services

• Department of families and communities/ Child protective services

• Informal supports

• Families and communities

• Accessible environments