Submission to the House of Representatives Standing Committee on Health, Aged Care and Disability
Inquiry into the Thriving Kids Initiative
Organisation: Inner West Paediatrics Pty Ltd
ABN: 31 602 963 548
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Date: 03/10/2025
Executive Summary
Inner West Paediatrics welcomes the opportunity to contribute to the Inquiry into the Thriving Kids Initiative.
We are a family-run, NDIS registered, multidisciplinary allied health service in Sydney’s Inner West, providing occupational therapy, speech pathology, feeding therapy, group intervention and allied health assistant services to children, young people and families. Our clinical experience spans NDIS and non-NDIS clients, including a significant cohort of children aged 0–8 with developmental delay or disability who fall outside NDIS eligibility.
Thriving Kids presents a once-in-a-generation opportunity to create a sustainable system of foundational supports. However, the program must avoid repeating the mistakes of pre-NDIS models, where families lacked choice, children received generic interventions, and small innovative providers were squeezed out.
This submission is explicitly aligned with the National Best Practice Framework for Early Childhood Intervention (2025) (henceforth “The Framework”) which defines high-quality, evidence-informed support as family-centred, strengths-based, inclusive and culturally safe, delivered in natural settings through capacity-building approaches (including coaching), multidisciplinary collaboration, and clear accountability for outcomes. Thriving Kids should operationalise these principles across commissioning, practice guidance, evaluation, and workforce policy.
Our submission emphasises the following principles:
- Thriving kids must be grounded in the social model of disability.
- Families must retain choice, continuity, and access to diverse providers.
- Funding must reflect the real cost of delivering evidence-based, goal-oriented supports.
- All models must uphold EBP3: balancing research evidence, professional expertise, and lived experience.
- Programs must be delivered in neuroaffirming ways.
- Align with The Framework’s principles of belonging, participation, and strengths; avoid deficit framing; and co-design supports with families to respect identity, culture, communication style and sensory preferences.
- Implementation should embed equity, cultural safety, and workforce sustainability.
- Thriving Kids should complement, not replace, the NDIS.
TOR 1 – Evidence-based information and resources
Providing pamphlets or static websites alone rarely shifts everyday routines and is insufficient. The 2025 Framework defines quality practice as building family capacity through collaborative goal-setting, modelling, and coaching caregivers in natural environments so strategies are embedded in daily life. Contemporary evidence shows parent-mediated/coached approaches improve child functioning and parental self-efficacy compared with consultation-only models.
Our clinical experience, research, best practice guidelines as well as feedback from participants identifies that embedding coaching into therapy, including modelling, parent training, and follow-up reduces stress, increases
parental confidence, and delivers real outcomes.
Recommendation: Fund resources that are embedded within coaching and ongoing professional support, not as standalone materials, with guidance and fidelity tools that reflect the Framework’s capacity-building, everyday-participation focus.
TOR 2 – Effectiveness of current and previous programs
Evidence-based programs consistently demonstrate measurable impact on children’s social communication, motor skills, emotional regulation, and peer relationships. Families also report reduced conflict, stronger participation in school and community, and greater confidence in supporting their child.
Program outcomes depend on delivery with fidelity - including preparation, coaching dosage, cross-setting collaboration, and structured follow-up. The Framework calls for evidence-informed but context-adapted practice, moving beyond prescriptive packages to co-designed supports that honour family expertise and the child’s identity; this aligns with EBP³ and contemporary neuro-affirming practice expectations.
Randomised and implementation studies indicate that when clinicians coach caregivers (rather than only advise), families report lower stress, higher confidence, and children show gains in participation and targeted skills; yet community services under-utilise formal coaching without structural support, underscoring the need to fund time for coaching and follow-up.
However, the effectiveness of these programs is only realised when they are delivered with fidelity. They are not “off-the-shelf” packages. True impact depends on skilled facilitation, preparation, parent coaching, cross-setting collaboration, and structured follow-up. Proposed funding models fail to account for this reality, which risks diluting quality and undermining outcomes.
Inner West Paediatrics also emphasises that program evaluation must align with EBP³ – balancing research evidence, professional expertise, and the lived experience of children and families. Without recognising the knowledge families bring and the importance of co-design, programs risk becoming prescriptive rather than empowering.
Previous block-funding models were known to be inefficient, were not agile and responsive to children and families’ needs and did not allow for family choice and control. These models were also chronically expensive, with the bloat of bureaucracy and middle management.
Finally, effectiveness cannot be separated from neuroaffirming practice. Programs must be adapted to honour children’s identities and strengths, avoid deficit framing, and build genuine belonging. Evidence without affirmation is incomplete, and risks causing harm.
Recommendation: Fund programs at true delivery cost, including coaching time, teacher/educator liaison, and fidelity monitoring, as specified by the Framework’s emphasis on capacity-building, inclusion, and accountability.
TOR 3 – Equity and intersectional issues
Children from First Nations and culturally and linguistically diverse (CALD) backgrounds face systemic barriers to access. For rural and remote families, lack of trust and absence of service providers and effective referral pathways compound these barriers.
The Framework requires cultural safety, accessible pathways, and community-embedded delivery to address barriers for First Nations and CALD families and for rural/remote communities. Commissioning should prioritise trusted local connectors and continuity across health, education and community services, consistent with the NDIS early childhood approach to family-centred, strengths-based supports.
Inner West Paediatrics’ work with diverse families highlights the importance of cultural safety, long-term relationship-building, and clear navigation supports.
Recommendation: Invest in trusted, culturally safe, community-based navigation and funded outreach that operationalises the Framework’s inclusion and belonging principles (including warm referrals, interpreters, family peer workers, continuity of care).
TOR 4 – Workforce support and training
Educators and early childhood staff are not adequately trained to support children with developmental differences. They require access to on-the-job capacity building from allied health professionals, including education and coaching in context. When used, Allied Health Assistants (AHAs) must work within defined scope under tiered supervision (direct, indirect, or remote) based on competencies and risk, codified across Australian state frameworks and recent governance guidance. Commissioning must therefore fund supervision time, competency development, and role clarity to maintain safety and outcomes. AHA training also needs to be addressed, as it is inconsistent and often of poor quality. Therapists should be embedded in schools and playgroups to build capacity, design curricula, and collaborate with and mentor educators in real time.
Recommendations:
Fund educator PD and in-situ coaching by allied health professionals aligned to the Framework’s capacity-building and inclusion principles. This includes evidence-based autism and developmental supports.
Require AHA models to evidence supervision arrangements, competency assessment, and escalation pathways, in line with state frameworks/guidelines.
Recognise supervision and collaboration time as billable/commissioned activities necessary for fidelity and outcomes.
Embed allied health professionals in classrooms and community programs to build systemic capacity. This does not have to sit as employed positions within these services, but can be contracted work out to external organisations, making use of existing workforce.
TOR 5 – Domestic and international policy experience
International initiatives (including Sure Start in the UK and Strengthening Families in the US) demonstrate that ambitious reforms fail when not locally embedded, when workforce and supervision are under-resourced, or when accountability doesn’t track meaningful outcomes. The Framework’s call for community-embedded, inclusive, and accountable delivery directly mitigates these risks and should anchor Thriving Kids commissioning rules and evaluation.
Australia must avoid repeating these mistakes by ensuring Thriving Kids is community-embedded, not top-down.
Recommendation: Build reforms around consistent, community-embedded delivery models with strong accountability and continuity of funding.
TOR 6 – Seamless transition through mainstream systems
The Framework emphasises coordinated, cross-sector pathways to reduce duplication and administrative burden on families, with clear roles across health, early childhood education, and disability supports. Commissioning should fund proactive transition support at early childhood milestones, with shared outcomes measures and information-sharing protocols. Families consistently describe navigating multiple systems (medical, child health, preschool, school, adolescent services) as exhausting. Each transition brings duplication, new assessments, and long waits.
Thriving Kids must coordinate transitions and reduce the administrative load on families.
Recommendation: Fund proactive transition supports at key points (early childhood, school entry, adolescence) and create shared outcomes frameworks across sectors to prevent duplication.
System Sustainability and Scope
Mainstream systems such as Medicare, schools, and childcare cannot absorb additional responsibilities and clear practice expectations. The NDIS Commission’s child-focused quality guidance helps families identify providers who enact best practice (e.g., family-centred, capacity-building, safe, lawful), providing a practical accountability layer for diversified markets that include small, evidence-driven providers like ours. Expecting teachers or GPs to deliver developmental supports risks burnout and poorer outcomes.
Thriving Kids must not be a vehicle for cost-shifting out of the NDIS. The NDIS must remain viable, inclusive, and complementary to foundational supports.
Thriving Kids needs to consider inclusion of a diverse range of providers, as the experience and expertise of working with children and families now sits in a broad range of organisations, including private practice.
Recommendations:
- Design Thriving Kids to complement, not replace, the NDIS, with aligned quality expectations rooted in the National Framework.
- Maintain provider diversity while enforcing transparent quality criteria families can recognize and use - including small family-run, evidence-based and outcomes-focused practices such as ours.
- Embed transparency and fairness in reform to rebuild trust, avoiding RoboDebt-style mistakes, at the very real cost of human lives.
Conclusion
Thriving Kids, as currently proposed, risks repeating past failures: underfunded supports, loss of family choice, and overloaded mainstream systems.
Children and families deserve better. A successful Thriving Kids program must:
- Be grounded in the social model of disability.
- Fund evidence-based interventions at their true cost.
- Protect family choice and provider diversity.
- Deliver equity through cultural safety and accessible pathways.
- Support a sustainable, skilled workforce.
- Uphold EBP3 and neuroaffirming practice as non-negotiable principles.
Inner West Paediatrics stands ready to partner with government, families, and communities to ensure every child can truly thrive.
References
Moore, T., Imms, C., Luscombe, D., SNAICC authors, Bonyhady, B., Dimmock, K., Deane, K., D’Aprano, A., & Kakoschke-Moore, S. (2025). The National Best Practice Framework for Early Childhood Intervention (commissioned by the Department of Social Services). Department of Health and Aged Care. Department of Health+2Department of Health+2
National Disability Insurance Scheme Quality and Safeguards Commission. (2024, October). Quality support for children in the NDIS: A resource for parents and carers [Booklet]. https://www.ndiscommission.gov.au/sites/default/files/2025-02/booklet-quality-support-for-children-oct-2024.pdf NDIS Quality and Safeguards Commission
Australian Government Department of Social Services. (2016). National guidelines for best practice in early childhood intervention (Early Childhood Intervention Australia). https://www.dss.gov.au/system/files/documents/2024-11/ecia-national-guidelines-best-practice-early-childhood-intervention-2016.pdf Department of Social Services
NDIS Quality and Safeguards Commission. (n.d.). Supplementary module: Early childhood supports (NDIS Practice Standards). https://www.ndiscommission.gov.au/rules-and-standards/ndis-practice-standards/supplementary-module-early-childhood-supports