Submission to the Parliamentary Inquiry into the Thriving Kids Initiative

Submitted by: Nobody Worse Off (NWO) Coalition
Date: October 2025

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Parliament House, Canberra ACT 2600

Introduction

About the Nobody Worse Off Coalition

The Nobody Worse Off Coalition is a national alliance of Disabled people, Disabled People Organisations (DPOs), families, support workers, unions, and allies standing against harmful cuts to funding and ensuring that children and families have access to fully funded supports that are co-designed and disability affirming, this includes children with developmental delays.

Our member organisations include:

• Australian Neurodivergent Parents Association (ANPA)
• Regional Autistic Engagement Network Tasmania (RAEN)
• Disability Action Dharawal
• Disabled People Against Cuts (DPAC)
• Over 1,500 allied health professionals.

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We are united in our commitment to ensuring that Australian children and their families have access to Early Childhood Intervention and supports that are fair, accessible, and fully funded. An Australia that honours our obligations under the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD) and stays true to the original intent of the National Disability Insurance Scheme Act 2013.

We are a national coalition that advocate for evidence-informed, neurodiversity-affirming, trauma-informed, and culturally safe support systems that genuinely and authentically help children and families thrive.

We share the Inquiry’s concern for improving early childhood development outcomes and reducing barriers to inclusion. However, we hold deep concerns about the current proposed design and rollout of the Thriving Kids initiative. If implemented without major revision and ongoing codesign, this policy risks dismantling existing individualised support pathways, shifting vulnerable children into under-resourced systems, and exacerbating long-term harm and inequality.

We call for codesign of supports for children that are designed and led by Disabled People/DPROs. Children are our future and without support in the early years the impacts will be lifelong. We must take time designing supports to ensure that they are fit for purpose.

Harm Tracker Project

The NWO launched the Harm Tracker as a grassroots community project to monitor the changes to the NDIS since the 2024 legislative changes which includes changes to the Early Childhood Intervention pathway, eligibility and supports for children. The harm tracker has recorded the impacts that are already occurring as a result of these changes, and this information should be used to allow government to reflect on the impact of their actions and ensure that nobody is worse off in the development of the Thriving Kids Initiative.

HARM Tracker Data

• With over 370 responses, approximately one third of responses are directly related to children,
• Over half of the responses from NDIS participants/families have reported their funding has been cut, they are more socially isolated, they no longer have access to the practitioner support they require and/or their mental health has been negatively affected by the changes,
• Data highlights that when the government does not fully fund supports within the home and community, individuals are disadvantaged, become isolated and support needs within families and across government and non-government systems increase.

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• Individuals that have had access revoked from the NDIS have advised greater reliance of other supports including emergency departments, community health services, education department, family and community welfare services, as well as needing to privately paying for vital services. Indicating that when support needs are not fully addressed or are dismissed, the costs are merely shifted to other supports and risk costing the government more in the long term.
• Below are direct quotes from Harm Tracker, related to children, when asked how changes have impacted them directly:
  • Living regional we now have to travel 45 minutes to appointments and 45 minutes back. I need to take a day off work to accommodate. My son also has extreme phobia around travel so even getting there is hell on earth emotionally. He is being traumatised. As such it’s just not worth continuing therapy. He will be a burden on the government in future as a result.
  • Family unit breakdown, escalation of family violence
  • Have to fight for supports. Advocacy services at capacity. We are both isolated due to my child’s disabilities. I as the carer have no social life. I have no informal supports. I am confined to my house because of my child’s disabilities. My child won’t leave the house unless on rare occasion wants to do something. Even then I can only do what my child wants then have to head straight home. My child doesn’t cope when outside of the house due to unpredictability. Forced to homeschool due to many reasons, lack of understanding of disabilities, partial school attendance, suspensions, bullying, school lockdowns, child can’t cope in a school setting at all.
  • I am a mother of 3 Neurodivergent children and all 3 have had psychology cut. I have had to take time off work due to cuts for my children and cannot afford the gap fee for Medicare rebated sessions.
  • Due to cuts to funding, mum needs to leave employment every day, causing employment issues
  • Choice and control have been taken away
  • We have lost NDIS funding, but my child needs support, community health is a 2 year waitlist and I can’t afford to pay myself.

NWO Responses to Terms of Reference

TOR 1: 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.

• The terms “mild” and “moderate” are medically ambiguous, outdated, and misleading. They create false hierarchies that risk denying essential support to children who

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experience lifelong disability and support needs. Our government must reject ableist terms to create an Australia committed to the inclusion of all individuals.

• Current developmental screening tools used in maternal and child health checks often miss neurodivergent profiles—especially for children who mask, are multiply disabled, or whose families face barriers to access.
• There is little evidence that online hubs or coaching programs alone can replace direct clinical assessment and support.
• To understand the true impact of disability or developmental delay and supports required, the individual must have access to assessment options of their choosing, in an environment and format that works for them and their family.
• Families already stretched thin will be forced to navigate fragmented systems with fewer direct resources and trusted relationships with support services. Where targeted supports are absent, parents with disability are at greater risk of child protection involvement, and families may reach crisis (Dowse et al., 2016).
• GP’s as the proposed workforce to complete developmental checks would require extensive training to be in a position to do this well, as they are not considered to have expertise in the nuances of child development, especially those who present with subtler or less apparent supports needs, commonly referred to by government as children in the ‘mild’ category – those children who are arguably in the best position to respond to early intervention.
• We have concerns with the proposal of GP’s as an accessible screening option, using a medical model to provide disability supports restricts access and fails to consider a social model of supports. Many families currently have long wait times to access GP services, especially those with an interest or knowledge in Paediatric care. Appointments are time limited, typically 15 minutes. This does not allow time to explore the nuances of developmental delays and disability. It also does not allow time to consider parental support needs and accommodations.
• Multimodal forms of communication and resources must be available to parents from the initial contact, the government must consider parental capacity, mental health and ability to engage in non-direct supports without support. Information packs and websites, whilst informative, can cause additional stress, create a sense of pressure or failure as a parent Especially if they are based on neuronormative expectations and do not provide opportunities for individualised support.
• Disabled children and those with developmental concerns or delays require access to specialised early childhood practitioners in addition to universal child and family health, ECEC and school services and integrated child and family support services, as recommended in the National Best Practice Framework for Early Childhood Intervention.
• Availability and access to services is currently reliant on knowledge and awareness of the professional supporting the child or parents that actively research support options. When Facshia and Better Start initiatives were operational prior to the NDIS, DSS held a provider database that was easily accessible, searchable by location and service type.

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Families need to be able to easily explore available options and supports within their local area.

• Disabled children and those with developmental concerns or delays require access to more than one practitioner and supports need to be provided within a collaborative team with child and family leading. Practitioners do not need to be located within mainstream or government services and can come from a range of services, which is supported by the Best Practice Framework.

Recommendations:

1. Ensure all parent-facing resources are grounded in disability-affirming and culturally safe practice. Are delivered in addition to, not instead of, funded professional supports, including family coaching. Ensuring supports use plain-language and are co-designed.
2. Reject the use of simplistic diagnostic levels (e.g. “mild/moderate”) to determine eligibility for support. These terms are stigmatising and clinically invalid.
3. Open the workforce for these assessments to include established expert professionals such as Allied Health professionals and ensure any GP’s completing the assessments have access to training and resources that cover the subtlety of baby and early childhood development, including neurodiversity. This will allow families to access practitioners of their choice, promoting safety and allowing flexibility of service provision.
4. Consider the capacity of families when developing supports, whilst we want to integrate supports and not overwhelm families, we need to ensure that we not restrict access to support that allows families to make progress.
5. The government must not pass off mainstream supports and parenting resources as foundational supports, leaving and ongoing gap between the thriving kids initiative and support provided by the NDIS.

TOR 2: 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.

• Redirecting children from individualised supports into mainstream-only systems will lead to increased waitlists, educator burnout, and greater referrals to child protection.
• Previous block funded only approaches ensures that the most urgent and complex of referrals make it to the top of the waiting list and those children with lower support

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needs or more subtle challenges tend to miss out when resources don’t stretch far enough.

• Families rely on individualised services and wrap-around NDIS supports—including AAC, consumables such as nutrition support product (HEN), support worker assistance and trusted therapy relationships. Loss of these may cause trauma and regression, a reduction in parental workforce participation, and reduced developmental outcomes.
• Block funded programs tend to fund the back of house functions of organisations far more heavily than the fee for service model of the NDIS, reducing ‘bang for buck’.
• Group and block funded scripted programs such as the Inklings program do not meet the needs of children with multifaceted developmental needs which include sensory, motor, cognitive, eating/feeding or communication needs.
• Families in rural and remote areas tend to miss out when block funded-only services are available. While this has continued to be problematic with the NDIS model, there has been incentives and possibility for innovative models to be created and implemented, such as Fly2Health and access to local solo practitioners (among others).
• Programs like Inklings and PACT are being positioned as scalable alternatives to NDIS-funded therapy, yet lack long-term evidence and raise ethical concerns:
  • Inklings is based on behavioural compliance models and involves video surveillance of parenting. This is distressing for neurodivergent parents and those with trauma histories, with no clear evidence of long-term benefit
  • The autistic and wider disabled community has strongly voiced concerns relating to the Inklings program for several years.
  • NWO coalition is aware that 4 therapists have been involved in rewriting the Inklings manual to promote affirming care and have publicly supported this program, however, the disabled community and the NWO coalition continues to have grave concerns. Whilst these changes have reportedly been completed and significant changes made as the manuals were review ‘sentence by sentence’ they have not been implemented in the programs that are currently being funded under the NDIS as a trial.
  • The Inklings program therefore is continuing to provide a support system that knowingly risks maternal mental health and does not support authentic diversity.
  • If the Inklings program is rolled out nationally and using the proposed changes to the manual, this would effectively mean that the Thriving Kids initiative is supporting a program where the evidence base is flawed and invalid.
  • Therapists working within the Inklings program have advised current concerns that the access criteria as limited and there is only a small population that is deemed appropriate for this program. If this program is limited at a trial phase, how does the government expect it to be appropriate at a national level, and considers those with diverse needs.
  • Therapists working within the Inklings program have also reported that the program is prescriptive and does not allow adequate time for follow up support and connecting families with support beyond the allotted program. Whilst an additional 30-minute session has been recently added to the program to allow for community

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connection, it highlights the lack of awareness in the time required to provide support to effectively connect families with their communities.

• Parents consistently report the NDIS Early Childhood Approach as a lifeline, allowing for responsive, individualised care. Replacing this with under-resourced programs risks regression, distress, and increased child protection involvement.
• This initiative rests on a myth of scarcity. Cutting children from the NDIS will not reduce costs overall; it will shift them to health, education, child protection, and justice systems. Far from being efficient, the reforms risk higher long-term fiscal costs and lost productivity.
• The introduction of the NDIS saw us throw away many long-term programs, such as parent and sibling supports. This removed the opportunity for children with subtler or less apparent support needs to access funded supports. However, the ability for families to access intensive individualised supports has also been life changing and has stimulated the growth of a skilled workforce that did not previously exist. It is essential that we do not repeat our previous errors in returning to the old status quo and lose everything that is good about individualised funding and choice and control.
• The development of the Thriving Kids program does not align with the foundational supports consultations that were completed by the social deck. Whilst the final report of these consultations is yet to be released, their webinar “What We Heard”, highlighted the strong trends towards individualised funding and supports, continuation of choice and control, and access to local services. The proposed Thriving Kids initiative seems to have adapted the supports previously referred to as general supports whilst dismissing the need for tiered tailored supports.

Recommendations:

6. Support the implementation of the DPRO tick of approval for early childhood and parental programs. This has been launched by The ANPA and RAEN to promote transparency, human rights alignment and disabled leadership and oversight of programs supporting Disabled children, children with developmental delays and their families. Quality assurance will support positive outcomes for children and families.
7. Pause expansion of unproven programs like Inklings and invest in rigorous co-designed evaluations before scaling. Fund a wider range of disability and neurodiversity affirming supports already backed by research and community endorsement.
8. Develop integrated systems for knowledge sharing, networking and communication within the Early Childhood intervention to allow for collaboration, connection and to empower families.
9. Continued individualised supports, and maintaining access to vital items and interventions.
10. Make ongoing consideration and funding adjustments for families who do not have ready geographical access to supports.

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11. If standardised programs of support are to be made available, as well as ensuring they meet the requirements of recommendation 6, they should be implemented by experienced professionals working within their scope of practice and support all developmental areas (such as cognitive development, physical development, eating and feeding development, motor development etc.), not just social and communication developmental differences.
12. If eligibility of Autistic people and other cohorts including children with developmental delays is changed, impacting access to the NDIS, then funding for wrap around services must be included as a part of foundational supports services.

TOR 3: Identify equity and intersectional issues, in particular, children who identify as First Nations and culturally and linguistically diverse

Children from First Nations and CALD communities, regional families, and disabled parents already face significant structural barriers. Removing NDIS supports and redirecting families into general systems without redesign or capacity-building will exacerbate exclusion:

• The Best Practice Framework highlights the need for ecologically based, culturally safe, and rights-driven ECI services.
• Thriving Kids was announced without co-design with state governments, First Nations communities, or DPROs.
• First Nations, CALD, and rural families already face access barriers. Thriving Kids may worsen this divide.
• Proposed Medicare additions as an alternative individualised support pathway without fully funded rebates and adequate assess to ongoing supports introduces unaffordable gap payments, particularly in regional areas (noting that currently available equivalent Medicare rebates are grossly inadequate to meet the rising costs of service delivery).
• Current Medicare benefits for children are limited to 5 sessions per year for most children (across a range of ECI practitioners) under a chronic disease management plan. Access is limited by prescribing medical practitioner for children with more subtle support needs that may not be apparent in a quick GP check-up. Alternatively, 20 sessions in a lifetime are available through the complex neurodevelopmental disorder or disability line item. Medicare rebates are funded on support services provided predominantly in 20 and 40 minute sessions creating significant out of pocket gap fees for families that require longer sessions.
• Medicare supports have to be provided directly with the child present, it is a medical model that does not support parental and caregiver support. It also fails to account for the non face-to-face support time that is required beyond direct provision to provide quality support and the time it takes to build trusted relationships with practitioners.
• If services are block funded small First Nations-led or regional providers may not be eligible, risking service loss.

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Recommendations:

13. Fund First Nations-designed services, ensure language access and transport.
14. Protect local and small providers with access to funding grants related to ECI foundational support services.
15. Extend consultation timelines beyond July 2026 and commit to community-led design, especially with First Nations communities.
16. Maintain current NDIS access for all children until equitable, accessible alternatives are proven operational and effective.

TOR 4: Identify gaps in workforce support and training required to deliver Thriving Kids

• Thriving Kids assumes generalist settings can absorb responsibility for complex developmental needs without a funded training pipeline.
• Educators and GPs report lacking confidence and knowledge in neurodevelopmental care.
• Despite having policies that proclaim an inclusive educational philosophy, this is not the experience of those of us with or supporting children that the government refers to as ‘mild’ or ‘moderate’. Significant cultural change and training to the educational workforce in both accommodating students within the mainstream environment as well as how to work with additional supports coming in to support those students is urgently required if this model is going to be successful.
• Allied health professionals are leaving the disability and developmental support sectors due to financial uncertainty, burnout, and exclusion from policy planning. This workforce is both ready with specialist developmental training and expertise and requires the least amount of capacity building to run with the proposed Thriving Kids model yet remains the least included and informed of the new policy shifts. Many therapists within the private sector are disabled and neurodivergent, the private sector allows them to engage in employment that was not possible under previous block funded models or within government agencies. These practitioners will not transition to working within block funded models or government departments that do not support or accommodate their needs.
• Block-funded models risk collapsing small businesses and forcing families into long waitlists or limited public services. Families report that the want to continue to access the right supports for their individual and unique needs. Provider market diversity is essential to facilitate optimal developmental outcomes and allow choice and control.
• Total remuneration packages for government employees and operational costs far exceed those in the private sector, therefore shifting services from the private sector to the government sector such as health or education, risk limitations to service provision

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as the costs associated with administration of programs absorb available funding provisions.

• We need to ensure that quality assurance is maintained for providers, however registration or provision requirements must be equitable across the sector from solo providers to large organisations allowing the current workforce to be utilised and maintaining choice and control.
• University training is not aligned with disability-affirming, neurodiversity-affirming or trauma-informed practice.
• The NDIS encouraged and enabled the development of a sector and market to provide supports to children & families that provides choice, diversity in offerings and access to a full complement of individualised supports. Innovation, workforce and mature system of support to a young workforce are now more evident in the private sector yet this sector has been excluded from consultation or consideration for provision of support. The private sector is most operationally ready to provide supports required under Thriving Kids and foundational supports.
• The limited information provided on the Thriving Kids initiative tends to lead towards block funding models of large-scale program rollout presumably by not-for-profit organisations. This fails to understand the current market structure, restricts access to trusted supports and has the potential to create inaccessible supports for families that do not feel safe accessing these less tailored supports.
• Employing early childhood intervention practitioners directly within schools, can lead to siloing, a focus on educational supports, and restrict access to engagement within professional networks.

Recommendations:

17. Fund a national ECI workforce strategy, validate diverse professions (e.g., music therapists), and mandate ongoing training in affirming care across the sector.
18. Invest in workforce development that includes: a. Training in developmental and trauma-informed care b. Neurodiversity-affirming practices (not behaviour reduction) c. Co-developed learning by and with the disability community
19. Engage the existing private practice sector — particularly those with neuroaffirming, culturally informed, trauma-informed and family-centred expertise as partners, not competitors.
20. Government to support the development of a collaborative and integrated network database of supports that are available based on location, that is accessible to families, providers and the wider sector including GPs and educators. The database must be easy to update and current, providing valuable information regarding how to engage with supports, (Best Practice Guidelines)

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TOR 5: Draw on domestic and international policy experience and best practice.

PRECI undertook considerable community consultation in the development of the National Best Practice Framework for Early Childhood Intervention and this work was completed and sent to government by May 2025, yet the government failed to publicly release this document and supporting documents until the 29th of September 2025 with supporting documents being released up until the 2nd of October 2025. These documents are essential in the development of the Thriving Kids Initiative, yet government has restricted access to the community, in doing so that have failed to provide adequate time to effectively review and interpret the new best practice framework in relation to this inquiry.

Australia’s commitments under the UN Convention on the rights of persons with Disabilities (CRPD), UN Convention on the rights of the child (CRC), and National Autism Strategy require:

• Respect for family life and support to prevent child removal
• Genuine co-design with disabled people and their representative organisations
• Promotion of autonomy, participation, and identity

Thriving Kids, as currently proposed:

• risks breaching CRPD Articles 7, 19, 23, and 24.
• Lacks transparency or accountability mechanisms
• Reinforces ableist assumptions that some children are “less deserving” of support
• International models relying solely on parent coaching show only modest outcomes and risk compliance-focused goals.
• Does not reflect the newly released National Best Practice Framework for Early Childhood Intervention

The NDIS experience has produced thousands of wonderful outcomes:

• Generously funding an individualised approach to Early Childhood Intervention has supported thousands of Australian families through these tricky developmental years, many of whom had previously been sitting on waiting lists for block funded services and missed out on opportunity for tailored supports.
• The NDIS has taught us that families have the capability to choose their providers, prefer to do so and engage well when solid relationships have been able to be formed. Returning to a block funded system risks returning to the situation of no choice of provider or professional supporting the child – regardless of whether that relationship has been able to be established.
• While government views the growing NDIS budget as a problem, it seeks to manage it by limiting resources for children at their most vulnerable time. Managing budgets through waiting lists was how things were done before the NDIS – and many simply

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went without. We should be instead valuing the outcomes and long-term cost saving by providing individualised supports.

Recommendations:

21. Pause rollout until full co-design occurs, adopt CRPD General Comment No. 7 that requires consultation with Disabled people through their representative organisations, not only with carers or providers, and additional supports once codesigned without defunding individualised supports.
22. Establish an independent disability oversight body (as recommended by the Disability Royal Commission) to review all early childhood reforms against rights-based benchmarks.
23. Individualised funding must be maintained in some form and must not rely on families making gap payments.

TOR 6: Identify mechanisms that would allow a seamless transition through mainstream systems for all children with mild to moderate support needs.

• Mainstream systems are currently fragmented, underfunded, and exclusionary.
• The proposed concept in Thriving Kids to provide early childhood intervention supports within schools and ECECs is concerning. Whilst these are environments that are natural environments for children, they do not have the systems to support alignment with the best practice framework. Some states within Australia currently employ therapists within schools (QLD) and others have previously used this system (WA, NSW). Whilst there maybe benefits to this system it fails to put the child and family at the centre of the supports. Many children with subtle or less apparent support needs are often overlooked within the school environment due to masking, fawning and compliance based positive behaviour systems ingrained with ablest views and neuronormative expectations. Supports must consider the child wholistically and be tailored to the individual not provided in a convenient setting.
• The past decade has seen a significant increase in the uptake of home schooling across the country directly related to school can’t. It is essential that children are not restricted in their access to supports because they are unable to access mainstream support such as schools.
• Children need support transitioning into schools, child health, or early learning settings—not forced reliance on under-trained professionals.

Recommendations:

24. Fund collaborative teams with key worker/leading practitioner and navigators, create neurodiversity-affirming environments, and invest in inter-system

collaboration, who oversees the child’s journey across systems, a role that is funded and not time limited. 25. Mainstream education is epically failing neurodivergent kids – they are overrepresented in statistics re: suspensions and exit from the school system – the education system is ill-equipped to meet the needs of the target population Thriving Kids purports to serve and therefore supports must operate alongside and integrate rather than work within the education system. 26. Clear referral protocols between child health, allied health, early childhood centres, and schools that are supported by strong relationships and an open-door philosophy that is not limited by sessions. 27. Access to secure, standardised tools where reports, therapy plans, and assessments can be accessed by all relevant providers with consent from the family. 28. Case conferences involving parents, allied health, educators, and other professionals before a child starts school that is child centred and not framed by the education departments funding categories. 29. Upskilling mainstream staff (teachers, childcare educators, GPs) so they understand how to support children with ‘mild’/’moderate’ needs, as well as how to work and collaborate effectively with external support professionals. 30. Upskilling external support professionals about how to work with schools and ECEC providers. 31. Flexible funding that allows children to continue receiving access to the same early childhood intervention practitioners and supports as they move between NDIS, health, and school systems. It benefits no one when kids have multiple of the same support. 32. Individualised supports that ensure equitable access to supports for children that are unable to access mainstream services, supports and environments including children who experience school can’t.

Overarching Risks

Economic: Cutting early intervention now leads to increased downstream costs in education, justice, and health systems. The proposed allocation of federal funding grossly underestimates the actual community need. Legal: Reforms may contravene existing legislative and international obligations. Social: Families report deep fear, confusion, and trauma around potential loss of supports. Workforce: Existing services risk collapse without inclusion of the entire sector to provide experienced and quality supports to disabled children and those with developmental concerns or delays.

Conclusion & Call to Action

Disabled children, along with children with developmental concerns or delays deserve support that is affirming, timely, family-centred, and continuous. The proposed Thriving Kids program risks becoming a cost-containment exercise that fragments care, increases long-term harm, and undermines Australia’s obligations under the CRPD.

We urge the Committee to recommend:

• A pause on rollout until co-design occurs with DPROs, families, First Nations, and providers.
• Independent modelling of workforce impacts and long-term fiscal risks.
• A rights-based redesign that strengthens—not replaces—individualised supports with truly inclusive, integrated systems.

Please ensure no child is made worse off, and that all children have access to the supports they require as early as possible.

The Nobody Worse Off Coalition urges this Committee to recommend a staged, rights-based redesign of Thriving Kids initiative that puts children, not cost containment, at the centre of policy. Children should not be removed from the NDIS as a cost cutting measure because their disability and support needs are deemed lesser which is prioritised over their wellbeing, independence and participation.

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References available on request