03 October 2025
IAHA Submission to the House Standing Committee on Health, Disability and Ageing Inquiry into the Thriving Kids Initiative
Introduction
Indigenous Allied Health Australia (IAHA) welcomes the opportunity to contribute to the Committee’s inquiry into the Thriving Kids initiative. Indigenous Allied Health Australia (IAHA) is a national, Aboriginal and Torres Strait Islander community controlled and member-based allied health workforce organisation. As leaders in Aboriginal and Torres Strait Islander education, training, and workforce development, IAHA support and elevate the Aboriginal and Torres Strait Islander allied health workforce to lead transformative change across health and wellbeing systems, grounded in Aboriginal and Torres Strait Islander ways of knowing, being and doing, for better health and social and emotional wellbeing.
We are committed to health equity and a culturally safe and responsive health system, ensuring that Aboriginal and Torres Strait Islander peoples are central in the design, delivery, and evaluation of health, disability, and early childhood services. There is an opportunity for the Commonwealth to transform the way services are delivered to children and how these services support parents, guardians and caregivers. However, to succeed equitably, the program must be underpinned by a culturally safe, empowered workforce, systemic integration, and genuine co-design with Aboriginal and Torres Strait Islander people, families and communities.
Critically, the Commonwealth must effectively co-design and partner with experts of autism and developmental delays, including the Aboriginal and Torres Strait Islander allied health workforce, and those with lived experience to ensure that Thriving Kids meets its intended outcomes.
We offer the following comments against the Terms of Reference.
1. 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 these children.
IAHA supports the development of evidence-based, culturally responsive resources to support parents and caregivers identify developmental concerns and support for their children early. Resources need to be developed in co-design with Aboriginal and Torres Strait Islander communities, and allied health professionals, to ensure there is effective knowledge translation for Aboriginal and Torres Strait Islander people through shared understanding and relevance. Resources must be strengths-based, acknowledging the role of families, kinship, and culture in children’s development. Tailored communication strategies should reflect
cultural, linguistic, and geographic diversity, ensuring Aboriginal and Torres Strait Islander families and worldviews are included. Additionally, it is critical that once a child has been identified with potential developmental delays that there is a focus on intervention. There needs to be resources to support Aboriginal and Torres Strait Islander families from identification to intervention. This is important to ensure Aboriginal and Torres Strait Islander children receive supports within Thriving Kids in a timely manner.
2. Examine the effectiveness of current (and previous) programs and intiatives 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 and maternal health, primary care, allied health playgroups, early childhood education and care and schools.
Firstly, it must be acknowledged the lack of research and evaluation for Aboriginal and Torres Strait Islander programs for identifying, diagnosing and supporting families and children. Additionally, funding for Aboriginal and Torres Strait Islander specific programs should be based on outcomes, and Aboriginal and Torres Strait Islander led wherever possible, rather than continually directed to mainstream services that may not necessarily be culturally safe. In alignment with the National Agreement on Closing, however, everyone has a role to play and in addition to building the community-controlled sector, and the workforce which services it, we need to transform all services (discussed in further detail below).
The Aboriginal and Torres Strait Islander Child Health Assessment (MBS715) provides a mechanism to identify children with developmental concerns. However, the MBS715 is general practitioner focused and often fails to integrate the expertise that allied health clinicians have in early childhood development, including diagnosis. This is compounded due allied health workforce shortages and the limitations of the Medicare system in supporting allied health in primary care. Additionally, there are cultural safety concerns with Aboriginal and Torres Strait Islander people accessing mainstream general practices to access MBS715, with the lack of Aboriginal Health Workers/Practitioners in mainstream services. The 2018-19 Health Survey¹ suggests that 34% of Aboriginal and Torres Strait Islander people (whole population) accessed an Aboriginal Community Controlled Health Organisation (ACCHO), although this number increases in remote and rural communities, and is likely to be higher for children aged 0-12. With systemic changes for the MBS715, including moving away from GP centric assessments and embedding allied health expertise offers an approach for diagnosis of developmental issues for Aboriginal and Torres Strait Islander children. This will facilitate a bridging mechanism from intervention into the Thriving Kids initiative.
The Aboriginal and Torres Strait allied health workforce is a critical workforce to support development for culturally appropriate, culturally validated diagnostic screening tools. Currently assessment tools being used lack cultural responsiveness, they are often prescriptive, deficit-based and developed through a non-Indigenous worldview. The assessment for Aboriginal and Torres Strait Islander children to go on the Thriving Kids Initiative needs to be culturally appropriate, strengths-based and localised. It can’t be a ‘one fits all approach’.
For Thriving Kids to be effective, there is a need to factor in how autism can impact early development, limit daily living as well as educational, health and social and economic outcomes. Currently, the way government operates, the systems are fragmented and siloed
which leaves families confused about where to seek help and how to navigate complex systems. This leaves families and children to ‘fall through the cracks’ which has greater implications for families and children including poorer educational outcomes, contact with the justice system, and limited engagement in employment. Therefore, if the Thriving Kids initiative is sufficiently resourced for across the social determinants of health, it is likely to have a strong return of investment as children haven’t fallen through the cracks and will contribute economically. To facilitate this Thriving Kids must adopt a “no wrong door” approach, where all services (primary health, child and maternal health, early learning, schools, allied health) provide clear navigation and integrated support.
3. Identify equity and intersectional issues, in particular, children who identify as First Nations and culturally and linguistically diverse.
It must be acknowledged that Aboriginal and Torres Strait Islander people with autism spectrum disorder are some of the most marginalised people in Australian society². Ongoing colonisation, racism, and discrimination that is exacerbated from continued policy initiatives that are violent is compounded for Aboriginal and Torres Strait Islander people with disability. Aboriginal and Torres Strait Islander children are disproportionately affected by developmental delays³ yet remain underserved by mainstream systems. This inequity means that Aboriginal and Torres Strait Islander children with autism might experience poorer long-term social and wellbeing outcomes as compared with non-Indigenous Australians with autism². The National Agreement on Closing the Gap⁴ priority reforms provides a framework to address issues with a systems approach and how the Thriving Kids initiative should be developed and implemented. There needs to be a fundamental shift in the implementation of the National Agreement that empowers self-determination for Aboriginal and Torres Strait Islander people, communities and organisations including for Thriving Kids.
The Thriving Kids initiative needs to apply a First Nations cultural model of inclusion and the social model of disability. This ensures that the Thriving Kids initiative is strengths-based and that services and supports and culturally responsive and inclusive and is from a disability rights informed approach. IAHA refers to and supports the leadership of First Peoples Disability Networks (FPDN) Cultural Model of Inclusion Framework as an approach. IAHA recommends that the Thriving Kids initiative needs to have strong input, leadership and governance from FPDN as the national representative body for Aboriginal and Torres Strait Islander disability, supported by the expertise of the Aboriginal and Torres Strait Islander allied health workforce. Aboriginal and Torres Strait Islander people with disability also have a strong connection to the cultural determinants of health that are deeply interconnected to wellbeing. The Thriving Kids initiative should have the flexibility for Aboriginal and Torres Strait Islander children and families to have access to services on Country, that engage with culture as a strength and enabler for healthy development and embed social and emotional wellbeing. It can’t be a rigid approach, that is fundamentally based on Western, biomedical perspectives.
The initiative must address structural racism and systemic barriers by embedding cultural safety and anti-racism as legislative and program requirements. Therefore, cultural safety and regulation must be embedded in Thriving Kids and influenced in action through mechanisms such as commissioning frameworks, funding agreements and KPIs. It should also consider how the program design empowers – or could contrain – the workforce in operating in a culturally informed way. This aligns with Priority Reform 3 of the National Agreement on Closing the Gap, which commits governments to transform their organisations
to be culturally safe and responsive. Cultural safety is already embedded as a legislated expectation within the Ahpra-regulated health professions. The same standard should apply across all of the disability workforce, regardless of profession, ensuring shared accountability for culturally safe practice. With the portfolios of health, disability, and aged care now housed within a single Commonwealth department, there is a unique opportunity to strengthen collaboration, reduce fragmentation, and embed cultural safety consistently across policy, service delivery, and regulation.
As noted in Occupational Therapy Australia’s submission, children in remote and very remote communities have additional considerations when it comes to need and having access to services. Whilst mechanisms can be leveraged such as telehealth, there should be investment and existing models of community-based, culturally safe allied health services should be built upon and scaled. Whilst telehealth can be an option, it cannot be a replacement for face-to-face services, particularly for Aboriginal and Torres Strait Islander children where there are existing barriers. Thriving Kids should have an equity-based approach, including investing in rural and remote workforce pathways, and funding should not be contingent on geography and socioeconomic status. Likewise, guidelines should ensure that services supported by other workforces, such as allied health assistants, are eligible for funding to improve access, continuity and quality of care, particularly in areas with workforce challenges in key professions.
4. Identify gaps in workforce support and training required to deliver Thriving Kids.
The health care and social assistance workforce is the largest workforce in high demand, with a projected growth of (25.9%) over the next ten years, increasing to share of the total workforce to 17.4%⁵. However, there are already an allied health workforce shortages and maldistribution issues, heightened by an aging population and the Royal Commission into Aged Care, reforms to NDIS and foundational supports and ongoing needs in primary, tertiary and acute care. There is a need for significant investment in allied health pathways, support, and career progression. The allied health workforce is the second largest clinical workforce and is critical for the health and wellbeing of all Australians, yet it was notably absent from the Commonwealth’s recent Aboriginal and Torres Strait Islander Primary Care campaign.
There needs to be a clear, coordinated approach to workforce development nationally, tosupport a joined up and cross sectoral approach to workforce development and avoid shortages of critical workforces for Thriving Kids to succeed. This strategy requires government recommitment to the National Aboriginal and Torres Strait Islander Health Workforce Strategic Framework & Implementation Plan 2021–2031⁶ which provides a clear national workforce strategy and implementation plan, that state and territory jurisdictions have previously supported IAHA calls for investment in recruitment, training, and upskilling of Aboriginal and Torres Strait Islander allied health workforce across all 30 disciplines we represent. Pathways need to be localised, culturally safe and Aboriginal and Torres Strait Islander led. The IAHA National Aboriginal and Torres Strait Islander Health Academy (the Academy) is a demonstrated workforce pathway that is building the next generation of the allied health workforce. A supported, culturally centred school-based traineeship program, the Academy has graduated over 170 allied health assistants, having over 85 per cent retention and completion rates, and with 85 per cent of graduates moving to further education, training and employment within six months post completion. Not only is it growing the workforce, but the program is successfully graduating young people who are requiring additional supports, increasing participation of Aboriginal and Torres Strait Islander people with disability in the
social sector workforce. This is a case study of Aboriginal and Torres Strait Islander led; co-designed and culturally safe pathways lead to success. Pathways such as the Academy should be invested in and scaled up, by bringing together resources from governments and across portfolios.
For Aboriginal and Torres Strait Islander children and their families accessing services for Thriving Kids should have the right to access services that are culturally safe, especially in the mainstream sector. Therefore, annual cultural safety and anti-racism training should be mandatory for all members of the Thriving Kids workforce. Additionally, there should be a mandate for services to embed culturally safe governance and workforce capability and measure and publish annual cultural safety compliance reports, aligned to greater focus on cultural safety within service standards. Failure to meet standards for cultural safety will face regulatory action. The Lowitja Institute Cultural Safety in Australia discussion paper⁶ and the Australian Commission on Safety and Quality in Health Care user guide for Aboriginal and Torres Strait Islander health⁷ are two resources that can assist with developing cultural safety standards for Thriving Kids/
5. Draw on domestic and international policy experience and best practice.
The Department of Health, Disability and Ageing should consider the following:
- The First Peoples Disability Network Cultural Model of Inclusion Framework.
- International models (e.g., Canada, New Zealand) highlight the importance of culturally safe early intervention and community-led service design, including the Nuka System of Care.
- Evidence of successful models and holistic care for Aboriginal and Torres Strait Islander children in Australia, such as Bubup Wilam Aboriginal Child and Family Centre.
- Adoption of similar best practice by embedding First Nations co-design, leadership, and governance at every stage of Thriving Kids.
- Investment in community-based allied health pathways aligns with international evidence of best practice for sustainable, equitable child development outcomes.
- Aligning the Thriving Kids initiative to the United Nations Conventions on the Rights of Persons with Disability⁸ and the United Nations Declaration on the Rights of Indigenous People⁹.
6. Identify mechanisms that would allow a seamless transition through mainstream systems for all children with mild and moderate support needs.
Families often face significant barriers navigating between health, education, disability, and community systems. This is due to highly fragmented and siloed approaches within mainstream services. They are complex, prescriptive, and compete for funding. Priority reform 3 of the National Agreement on Closing the Gap provides a mandate and framework for government systems to change their ways of working. Not only will it be beneficial for Aboriginal and Torres Strait Islander people, but it will also be better for all Australians. To do this there needs to be collaboration and coordination between government portfolios, including cutting bureaucratic red tape, having a strategic approach, understanding who is responsible for certain activities, and data interoperability across systems. There needs to be clear pathways between child health, early childhood education, schools, and allied health that are integrated and transparent and between Thriving Kids and the NDIS as appropriate. To
support Aboriginal and Torres Strait Islander children and families, there needs to be culturally safe coordination services.
The Department of Health, Disability and Ageing need to embed guarantees of the continuity of supports for children transitioning from the NDIS to new arrangements, avoiding service gaps. There is already fear in the community with children with autism on the NDIS will have their supports reduced. Secondly, with children and their families that are approved to be on Thriving Kids, whatever it looks like, it must be based on needs, supports and outcomes and cannot be reduced to a cost cutting exercise via the government. This includes supports for daily living, to participate in education, social connection and activities, and modifications to homes, if necessary, all of which provide strong social and economic returns. Families and caregivers, especially those with Aboriginal and Torres Strait Islander children should not be left out of pocket. This is critical for Thriving Kids to succeed and reduce spending later as children have participated in the education system, have necessary social skills to thrive, will contribute to the economy via employment, and experience better physical, mental and social and emotional wellbeing long term.
Accountability, Monitoring, and Evaluation
IAHA calls for strong accountability measures to be embedded across Thriving Kids. A reminder that Thriving Kids should align to the United Nations Conventions on the Rights of Persons with Disability and the United Nations Declaration on the Rights of Indigenous Peoples. Firstly, language and definitions need to be addressed. The terms ‘mild’ and ‘moderate’ autism needs to be defined; however, it must be acknowledged that autism is not static or not something to be ‘fixed’. IAHA suggests listening and working with the relevant organisation and people with expertise in this area to ensure the government does not harm those with autism. Additionally, there is relevant information for including other development disorders in Thriving Kids, for example what will this policy direction mean for children who don’t have autism but have other developmental disorders (such as FASD) that don’t meet the threshold for NDIS, and which require multidisciplinary allied health teams to appropriately identify and diagnosed.
There needs to be independent oversight with Aboriginal and Torres Strait Islander leadership with decision-making powers in alignment to the National Agreement Priority Reform 1 and 3. Aligning to Priority Reform 4, there is a need for disaggregated data (including by Indigeneity, gender, geography) to monitor equity, workforce planning and evaluation. This data should be accessible to community and be co-designed with relevant communities that centre around Indigenous data sovereignty and cultural intellectual property. Finally, there needs to be a framework to measure cultural safety, workforce quality, and outcomes, including through culturally validated measures of wellbeing such as those identified in the Mayi Kuwayu Study¹⁰ led by Professor Ray Lovett and his team the ANU.
Conclusion
Thriving Kids presents a unique opportunity to transform how Australia supports children with mild to moderate developmental delay or autism, however it also presents uncertainty and risks which need to be appropriate understood and managed. To realise the potential, the initiative must be grounded in cultural safety, a strong and diversified workforce with empowered Aboriginal and Torres Strait Islander participation, systemic integration, and
genuine co-design with Aboriginal and Torres Strait Islander, people families and communities. IAHA stands ready to partner with government, First Peoples Disability Network, and other stakeholders to ensure Thriving Kids delivers equitable, strengths-based outcomes for all children and families.
Contact
Paul Gibson
Chief Operating Officer
Indigenous Allied Health Australia
(02) 6285 1010
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References
- Australian Bureau of Statistics. National Aboriginal and Torres Strait Islander Health Survey, 2022–23 financial year [Internet]. Canberra: ABS; 2024 Nov 26 [cited 3 Oct 2025]. Available from: https://www.abs.gov.au/statistics/people/aboriginal-and-torres-strait-islander-peoples/national-aboriginal-and-torres-strait-islander-health-survey/latest-release
- Bailey B, Arciuli J. Indigenous Australians with autism: a scoping review. Autism. 2020;24(5):1031-46. doi:10.1177/1362361319894829.
- Roy M, Balaratnasingam S. Missed diagnosis of autism in an Australian indigenous psychiatric population. Australas Psychiatry. 2010;18(6):534-7. doi:10.3109/10398562.2010.498048.
- Commonwealth of Australia. National Agreement on Closing the Gap [Internet]. Canberra: Australian Government; 2020 Jul [cited 3 Oct 2025]. Available from: https://www.closingthegap.gov.au/sites/default/files/2021-03/national-agreement-ctg-mar-21_0.pdf
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- Mohamed J, Stacey K, Chamberlain C, Priest N. Cultural Safety in Australia: Discussion Paper [Internet]. Melbourne: Lowitja Institute; 2024 Aug [cited 3 Oct 2025]. Available from: https://www.lowitja.org.au/wp-content/uploads/2024/08/CulturalSafetyinAustralia_DiscussionPaper_Aug2024.pdf
- Australian Commission on Safety and Quality in Health Care. User Guide for Aboriginal and Torres Strait Islander Health [Internet]. Canberra: ACSQHC; 2017 [cited 3 Oct 2025]. Available from: https://www.safetyandquality.gov.au/standards/nsqhs-standards/resources-nsqhs-standards/user-guide-aboriginal-and-torres-strait-islander-health
- United Nations. Convention on the Rights of Persons with Disabilities [Internet]. New York: United Nations; 2006 Dec 13 [cited 3 Oct 2025]. Available from: https://www.un.org/development/desa/disabilities/convention-on-the-rights-of-persons-with-disabilities.html
- United Nations. United Nations Declaration on the Rights of Indigenous Peoples [Internet]. New York: United Nations; 2007 Sep 13 [cited 3 Oct 2025]. Available from: https://www.un.org/development/desa/indigenouspeoples/declaration-on-the-rights-of-indigenous-peoples.html
- Mayi Kuwayu National Study of Aboriginal and Torres Strait Islander Wellbeing. Research publications [Internet]. [cited 3 Oct 2025]. Available from: https://mkstudy.com.au/research-publications