Submission to the Thriving Kids Program Consultation

Prepared by: Developing Ur Life (Regional South Australia) Contact: admin @developingurlife.com.au | (08) 8632 9700 Date: 1 October 2025

Cover Letter

To whom it may concern,

Developing Ur Life (DUL) welcomes the opportunity to provide feedback on the Commonwealth’s Thriving Kids reform. We are a regional South Australian disability and community services organisation supporting children with Autism and children with developmental differences, along with their families and educators, across Port Pirie and surrounding communities.

This submission is intentionally framed as a risk brief—not a solutions paper. It documents the foreseeable harms, equity impacts, and system safety failures that will occur if children are transitioned out of the National Disability Insurance Scheme (NDIS) into ‘foundational supports’ that are not yet defined, funded, staffed or quality‑assured. Any reform that proceeds without tested capacity and clear safeguards will cause avoidable harm to children and families, and displace costs into health, education, and justice.

We ask that government pause implementation until the risks outlined are independently tested through staged pilots with strong evaluation and rural equity guarantees.

Yours faithfully, Emma Nunan Director, Developing Ur Life

Executive Position and Scope
About Developing Ur Life (DUL)
Why This Is a Risk Brief (Not a Solutions Paper)
Policy Context and Definitions
Lived Experience Evidence (Family Voices)
Practice Evidence (Clinical & Service Delivery)
System Readiness: Education, Health, and NDIS Interface
Rural and Equity Impacts (First Nations, CALD, Low‑Income)
Risk Register and Consequence Analysis
Economic Case: Invest Now vs Pay Later
Safeguards That Must Exist Before Any Transition (Minimal Conditions)
Monitoring, Data and Transparency Requirements
Conclusion
Appendix A: Case Studies (Anonymised)
Appendix B: Indicative Cost–Benefit Sketch
Appendix C: Glossary and Acronyms
Appendix D: Minimal Recommendations
References

1. Executive Position and Scope

Position: The Thriving Kids proposal, as presently framed, risks abandoning thousands of children to systems that are not ready, not resourced, and not safe. Shifting children out of the NDIS prior to proven mainstream capacity will create predictable harm: developmental regression, school exclusion, diagnostic delays, carer crisis, and inequity for rural, First Nations and CALD families.

Scope: This submission documents foreseeable risks, practice impacts, and economic displacement. It deliberately avoids presenting a detailed implementation roadmap to ensure the primary emphasis is on harms and safety. A short list of minimal conditions is provided in Appendix D solely to define what ‘safe enough’ would need to look like to avoid catastrophic outcomes.

2. About Developing Ur Life (DUL)

Developing Ur Life (DUL) is a multidisciplinary organisation operating across the Mid North and Upper Spencer Gulf regions of South Australia. We provide functional capacity assessments, developmental education, social work, behaviour supports, support workers, support coordination and psychosocial services, skill‑building groups, short‑term accommodation (respite), supported independent living and community‑based supports. Our practice is neurodiversity‑affirming, trauma‑informed, family‑centred, and culturally responsive. Regional outreach and school partnerships are core to our model.

3. Why This Is a Risk Brief

Foundational supports are not defined in sufficient detail to guarantee access, quality, or safety.
Workforce, funding and supervision structures are not yet in place—especially outside metropolitan areas.
Families have no clear appeal or escalation pathway if mainstream services refuse or ‘cap’ inclusion due to ratios or behaviour risks.
There is no evidence that large‑scale transition can be achieved without widening inequities for rural and First Nations children.

4. Policy Context and Definitions

Autism is recognised as a lifelong neurodevelopmental disability (DSM‑5‑TR; ICD‑11). The NDIS links eligibility to functional impact. The Thriving Kids concept intends to shift many children with mild‑to‑moderate developmental needs into mainstream ‘foundational supports’. In practice, those supports are not yet a staffed, funded, quality‑assured system. Transitioning children before readiness will cause harm.

5. Lived Experience Evidence (Family Voices)

These narratives illustrate the human impact of policy design when supports are absent or delayed:

Early‑onset dementia (parent): Continued NDIS access based on functional need allowed dignified, safe care through end‑of‑life. This demonstrates the principle that support should follow impairment, not a narrow diagnostic gate.
Siblings with global developmental delay: Both later met criteria for intellectual disability. Under a ‘foundational supports first’ model, early years supports would likely have been denied, risking irreversible developmental loss.
Carer mental health: A mother providing lifelong care experienced severe burden and periods of suicidality in the pre‑NDIS era—a direct result of under‑serviced systems and financial stress.
Regional access: Families travel 60–120 minutes each way for doctor or paediatric reviews. Appointments are cancelled due to workforce gaps; schools/childcare decline enrolment citing ‘capacity and safety’ without funded inclusion supports.

6. Practice Evidence (Clinical & Service Delivery)

Clinical guidelines emphasise early, family‑centred, multidisciplinary support delivered with fidelity and adequate intensity. Inadequate or interrupted support leads to behavioural regression, school refusal, anxiety/depression, and increased crisis presentations.

Early intervention works only when accessible and sustained (not wait‑listed).
ECEC inclusion requires staffing ratios, behaviour support coaching, and specialist back‑up.
Supervision, training and protected time are critical for fidelity and safety.
Families need navigation support to prevent drop‑out and administrative fatigue.

7. System Readiness: Education, Health, and NDIS Interface

Current signals of system unreadiness include:

Education/ECEC: staffing waivers; limited inclusion capability; behaviour escalation without specialist input.
Health: paediatric and allied‑health wait lists exceeding acceptable benchmarks; telehealth cannot fully substitute hands‑on work.
NDIS interface: risk of children being ‘ping‑ponged’ between systems with no practical support during critical developmental windows.

8. Rural and Equity Impacts (First Nations, CALD, Low‑Income)

Rural/remote (MMM 4–7): long travel times, workforce scarcity, higher out‑of‑pocket costs, and limited choice.
First Nations children: need culturally safe, community‑controlled pathways; mainstream systems frequently fail to engage safely.

CALD families: interpreters, translated materials, and culturally responsive practitioners are necessary to ensure access.
Low‑income families: without NDIS, a two‑tiered system re‑emerges where only those with means buy private supports.

9. Risk Register and Consequence Analysis

Risk ID	Risk Description	Consequence	Likelihood	Overall Rating	Foreseeable Harms if Unmitigated
R1	Mainstream exclusion due to capacity limits	Reduced attendance, regression, family distress	High	Extreme	ECEC/schools decline enrolment; increased suspensions; social isolation
R2	Diagnostic and intervention delays	Missed critical periods; escalation to crisis	High	Extreme	Late diagnosis; hospital presentations; ED visits; CAMHS overload
R3	NDIS interface gap (‘ping‑pong’)	Children stranded without services	Medium‑High	High	Missed therapy windows; parent workforce exit; financial stress
R4	Workforce burnout and turnover	Quality and safety degrade	Medium	High	Increased incidents; restrictive practices;
R5	Inequity for First Nations/CALD families	Lower engagement and outcomes	Medium	High	Distrust; disengagement; poorer developmental trajectories

10. Economic Case: Invest Now vs Pay Later

The economic logic for maintaining access during early years is straightforward: every avoided school exclusion, parental workforce exit, crisis presentation, and justice involvement yields savings greater than the marginal cost of timely supports. Below is an indicative sketch using conservative assumptions to illustrate orders of magnitude (not precise forecasts).

Domain	Unit Impact (Conservative)	Annualised Cost Avoided per Child	Notes
Parental workforce participation	0.3 FTE retained	$12,000–$18,000	At average wages; reduces welfare reliance
School exclusion avoidance	1 exclusion/child avoided	$3,000–$7,000	Special arrangements, attendance support
Health crisis (ED/hospital) avoided	0.5 ED + 0.1 admission	$1,500–$4,000	Presentations drop with stable supports
Justice system diversion (teen onward)	1 in 20 risk reduction	$1,000–$3,000	Long‑term social cost reduction
Therapy continuity vs regression	Reduced intensity later	$2,000–$6,000	Avoided ‘catch‑up’ costs after regression

Indicatively, avoided downstream costs of $19k–$38k per child per year can reasonably offset early supports. At scale, disinvestment now simply shifts higher costs to other portfolios and to families.

11. Safeguards That Must Exist Before Any Transition (Minimal Conditions)

These are not recommendations for ‘how to do it’, but minimum safety conditions without which proceeding is unsafe:

Proven capacity: regional wait times for paediatrics/allied health ≤ 8 weeks before any transition.
Inclusion guarantees: funded ECEC inclusion loadings and behaviour coaching available on demand.
Interface rule: children with substantial functional impairment retain NDIS access; no child loses supports due to admin settings.
Rural equity: funded outreach and travel support; telehealth plus periodic in‑person; clear escalation pathways.
Cultural safety: co‑designed pathways with ACCHOs; funded interpreters and community brokers.

12. Monitoring, Data and Transparency Requirements

Domain	Indicator	Source	Frequency	Threshold for Pause
Access & timeliness	Wait times (paeds/therapy/ECEC inclusion)	Admin + provider reports	Monthly	If >8 weeks sustained 2 months
Child outcomes	Communication/adaptive skills; GAO	Standardised tools	Baseline/6/12 months	No clinically meaningful gains
Family wellbeing	Carer distress; satisfaction	Validated scales + survey	Quarterly	<85% satisfaction or rising distress
Equity	Access by MMM, First Nations, CALD	Admin + community reports	Quarterly	Gap >10% vs metro
Safety	Incidents/restrictive practices	Provider reporting	Quarterly	Upward trend without mitigation

13. Conclusion

Transitioning children out of the NDIS without proven mainstream capacity will produce predictable harm: regression, exclusion, diagnostic delay, carer crisis and widened inequity. The safest course is to pause, test, and independently verify capacity—with rural and cultural equity guaranteed—before any child’s supports are altered.

Appendix A: Case Studies (Anonymised)

Case A: Rural travel burden and ECEC refusal

A single parent of two autistic children travels 90 minutes each way for paediatric reviews. Appointments are frequently rescheduled due to workforce gaps. Two childcare services declined enrolment citing ‘capacity and safety’. Participation improved only after NDIS-funded inclusion and communication supports were in place.

Case B: First Nations family with delayed access and anxiety/selective mutism

An Aboriginal family waited 18 months for speech therapy. The child entered school with high anxiety and selective mutism. Culturally safe engagement through an ACCHO plus telehealth and outreach enabled gains—but required flexible funding and inter-agency coordination not standard in mainstream settings.

Case C: Regression after support reduction

A child with autism and ADHD progressed with consistent specialist supports and school collaboration. When supports were reduced amid eligibility uncertainty, behavioural distress and school refusal increased. Multidisciplinary supports restored stability.

Case D: Carer mental health crisis in pre‑NDIS landscape

A mother providing lifelong care experienced severe burnout and periods of suicidality before NDIS availability. The absence of timely supports, financial strain, and constant advocacy demands created an unsafe environment for both carer and child.

Appendix B: Indicative Cost–Benefit Sketch (Assumptions)

Assumes conservative wage rates and service costs for regional SA.
Parental workforce effect estimated at 0.2–0.4 FTE retained with stable supports.
Health crisis avoidance based on observed reductions with consistent community supports.
Does not count intangible benefits (wellbeing, social inclusion) which are material but hard to price.

Appendix C: Glossary and Acronyms

Term	Meaning
NDIS	National Disability Insurance Scheme
Foundational supports	Mainstream, non‑NDIS supports proposed for children with developmental needs
DSM‑5‑TR / ICD‑11	Diagnostic classification systems recognising autism as a neurodevelopmental disability
MMM	Modified Monash Model – rurality classification
ACCHO	Aboriginal Community Controlled Health Organisation
GAO	Goal Attainment Outcomes (goal‑based measurement)

Appendix D: Minimal Recommendations

Affirm autism as a disability and base access on functional impact and need.
Publish NDIS–Thriving Kids interface rules; no loss of supports due to administrative settings.
Set and verify capacity benchmarks (regional paediatrics/allied health wait ≤ 8 weeks; inclusion loadings live) before transition.

Guarantee rural equity: outreach hubs, telehealth plus periodic in‑person, travel assistance.
Independent evaluation of staged pilots with public reporting before scale.

References

ABS (2022). Disability, Ageing and Carers, Australia: Summary of Findings.
Autism CRC & NHMRC (2018–2023). National Guidelines for Assessment/Diagnosis and Supports for Autistic Children.
American Psychiatric Association (2022). DSM‑5‑TR.
World Health Organization (2019). ICD‑11.
Productivity Commission (2022). Early Childhood Education and Care workforce findings relevant to inclusion capacity.
Carers Australia (2022). National Carer Survey (carer distress and burden).
United Nations (2006). Convention on the Rights of Persons with Disabilities.
WHO (2001). International Classification of Functioning, Disability and Health (ICF).

Submission 238 — Developing Ur Life — Inquiry into the Thriving Kids initiative