NDIA Accountability Project

Submission 260 — Dr Tristan Nickless — Inquiry into the Thriving Kids initiative

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Submission to the Thriving Kids Initiative

Executive Summary

This submission responds to the Terms of Reference for the Thriving Kids initiative, with a focus on ensuring that all Australian children with communication and swallowing needs can access timely, effective, and equitable speech-language pathology (SLP) services.

The evidence base demonstrates:

  • Current public funding models are often misaligned with scientific evidence on effective therapy dosage and intensity (Nickless et al., 2024).
  • Children face inequities in access, depending on diagnosis, parental education, and postcode (Nickless et al., 2023a).
  • Funding design strongly affects both efficiency (value for taxpayer investment) and acceptability (trust from families and clinicians) (Nickless et al., 2023b).

The Thriving Kids initiative offers a unique opportunity to design a funding model that is congruent with evidence and embedded in the principles of equity, efficiency, and acceptability (Nickless, 2025).

Background and Context

  • Communication is a fundamental human right. Delays or disorders affect learning, social inclusion, and long-term employment (McLeod, 2018).
  • Government-subsidised funding is often the only way families can access SLP services.
  • However, evidence mapping shows that some contemporary public funding (e.g., Medicare’s Chronic Disease Management Plan [CDMP]) does not align with best-practice therapy intensity; five sessions per year is inadequate (Nickless et al., 2024).
  • By contrast, previous versions of NDIS shows stronger alignment but is limited in eligibility (Nickless et al., 2024).
  • Families currently carry heavy out-of-pocket costs, which undermines the principle of universal healthcare (Nickless et al., 2023a).

Policy Considerations (PC)

PC 1: Ensuring Access for All Children

  • Many children fall through the cracks because funding eligibility is tied to diagnosis categories rather than functional need.
  • Families with lower literacy or fewer resources struggle to navigate complex systems (Nickless et al., 2023a).
  • Thriving Kids must simplify access and include all communication and swallowing disorders, not just autism or narrow diagnostic groups.

PC 2: Alignment with Scientific Evidence

  • Speech pathologists deliver care based on dose, frequency and intensity of therapy. Research consistently shows that children often need 12–20 or more sessions delivered in intensive blocks (Nickless et al., 2024).
  • CDMP’s limit of five annual sessions spreads care too thinly over years, leading to poor outcomes and wasted resources.
  • Thriving Kids should fund therapy at the intensity required to achieve real change.

PC 3: Promoting Equity

  • Current funding models privilege families with higher literacy and advocacy skills (Nickless et al., 2023a).
  • Rural and low-SES communities are disproportionately disadvantaged.
  • Equity demands that Thriving Kids ensure consistent access across geography, diagnosis, and socio-economic background.

PC 4: Delivering Efficiency

  • Inefficient funding leads to long-term social, educational, and economic costs.
  • Evidence shows that shorter, more intensive programs produce better outcomes in less time, maximising taxpayer value (Nickless et al., 2024).
  • Thriving Kids should prioritise funding models that achieve goals quickly, reducing the burden on families and the health system.

PC 5: Ensuring Acceptability

  • Acceptability requires trust: families must believe funding meets their child’s needs, and professionals must be able to provide best-practice care without compromise.
  • When funding rules force clinicians to ration care or contradict evidence, trust in the system is eroded (Nickless et al., 2023b).
  • Thriving Kids should be co-designed with families, professionals, and peak bodies to ensure it is fair and fit-for-purpose.

Ethical and Practical Considerations

  • Ethical duty of care: Professionals are bound to provide evidence-based care; misaligned funding undermines this duty (Nickless et al., 2023b).
  • Human rights: Communication and swallowing are essential rights; denying adequate therapy is a breach of these rights (McLeod, 2018).
  • Professional trust: Clinicians need confidence that funding provisions support, not obstruct, their recommendations (Nickless et al., 2023b).

Recommendations

  1. Align funding with evidence: align funding with latest scientific evidence.
  2. Broaden eligibility: include all communication and swallowing disorders in access criteria.
  3. Language: Ensure that the language and terminology used is accessible to all users, particularly families.
  4. Simplify access pathways: reduce reliance on complex gatekeeping processes that disadvantage vulnerable families.
  5. Embed principles of equity, efficiency, and acceptability: ensure funding delivers outcomes fairly, effectively, and with professional and community trust.

Conclusion

The Thriving Kids initiative is an opportunity to transform children’s futures by embedding evidence into funding design. By ensuring models are congruent with scientific evidence and grounded in equity, efficiency, and acceptability, Thriving Kids can deliver life-changing outcomes for children and long-term value for the Australian community.

Yours sincerely,

redacted

Dr Tristan Nickless

Speech-Language Pathologist BA(Hons)/BBus(Mgmt), MSpPath, PhD, MSPAA, CPSP

References

McLeod, S. (2018). Communication rights: Fundamental human rights for all. International Journal of Speech-Language Pathology, 20(1), 3–11. https://doi.org/10.1080/17549507.2018.1428687

Nickless, T. (2025). An investigation of Australian public funding models for paediatric speech-language pathology and their congruence with scientific evidence, [Doctoral Thesis, University of Melbourne]. http://hdl.handle.net/11343/355599

Nickless, T., Davidson, B., Finch, S., Gold, L., & Dowell, R. (2024). Aligned or misaligned: Are public funding models for speech-language pathology reflecting recommended evidence? An exploratory survey of Australian speech-language pathologists. Health Policy OPEN, 6, 100117. https://doi.org/10.1016/j.hpopen.2024.100117

Nickless, T., Gold, L., Dowell, R., & Davidson, B. (2023a). 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

Nickless, T., Gold, L., & Davidson, B. (2023b). The million-dollar question: What are the ethical considerations of public funding provisions for Australian speech-language pathologists engaged in independent practice? Journal of Clinical Practice in Speech-Language Pathology, 25(2), 52–59. https://doi.org/10.1080/22087168.2023.12370392