Inquiry into the Thriving Kids Initiative

The Royal Children’s Hospital Submission on the Terms of Reference consultation.

October 2025

Submission to the House of Representatives Standing Committee on Health, Aged Care and Disability

Re: Inquiry into the Thriving Kids Initiative
Date: October 2, 2025

Dear House of Representatives Standing Committee on Health, Aged Care and Disability.

The Royal Children’s Hospital welcomes the opportunity to contribute to the national inquiry into the Thriving Kids initiative. We commend the Minister for Health and Ageing, the Hon Mark Butler MP, for prioritising foundational supports for children with developmental concerns and for initiating this significant reform.

This submission draws on the clinical, research, and educational expertise of professionals across the Royal Children’s Hospital, reflecting the collective experience of frontline services supporting children and families navigating developmental challenges.

We strongly support the intent to improve early identification and intervention for children under 8 with emerging developmental needs. However, we caution that removing children from the NDIS without a robust, equitable, and well-resourced alternative risks exacerbating existing service gaps and inequities. The Thriving Kids initiative must be designed to:

• Embed early supports in universal and community-based settings, not rely on diagnosis-driven models.
• Ensure equitable access regardless of postcode, cultural background, or family capacity.
• Strengthen the allied health workforce and integrate services across health, education, and disability sectors.
• Support parents and caregivers through navigation, education, and culturally safe services.

This reform presents a once-in-a-generation opportunity to reshape Australia’s early childhood development system. We urge the Committee to place equity, inclusion, and family-centred care at the heart of its recommendations.

redacted
Associate Professor Michelle Telfer
Chief of Medicine

redacted
Adj. Associate Professor Doug McCaskie
Executive Director Ambulatory Services & Chief Allied Health Office

Context and Urgency

In Australia, 12.5% of children—approximately 36,060—begin school developmentally vulnerable across two or more domains. This indicates a substantial cohort of children requiring developmental support during their early years, with many potentially going unidentified until later stages of schooling. This concern is reflected in longitudinal data showing a steady increase in the proportion of children identified by teachers as having emerging developmental needs—including medical, physical, behavioural, emotional, or cognitive concerns. Since 2009, this figure has risen from 18% to 23.6% in 2024, equating to 68,092 children (see Figure 1). These trends suggest that schools are increasingly acting as the primary point of identification for developmental issues, often in the absence of accessible community-based services.

Figure 1: “Emerging vs Established Needs” [Source: Commonwealth of Australia (2005). AEDC National Report 2025 — Early childhood development in Australia. Department of Education, Canberra.]

There is a persistent and well-documented socioeconomic gradient in developmental vulnerability. Children from disadvantaged backgrounds are nearly three times more likely to be developmentally vulnerable across two domains compared to their more advantaged peers (20.3% vs. 7.6%). These disparities have remained consistent since 2009.

Figure 2 Source: Commonwealth of Australia (2005). AEDC National Report 2025 — Early childhood development in Australia. Department of Education, Canberra.

Given the scale and persistence of these issues, a coordinated public health systems response is required. This must ensure that all children- regardless of background- are supported and engaged within the mainstream systems where they live, learn, and grow. A key component of this response is the development of a connected and inclusive system for children on the NDIS, ensuring that Australia delivers on its commitment to equity and inclusion for all children.

The proposed removal of children under 8 with developmental concerns from the NDIS and the allocation of $2 billion to the Thriving Kids initiative from July 2026 represents a significant shift in national policy. While the RCH supports the intent to improve access to early intervention, we caution that without a robust, equitable, and integrated system, this reform risks deepening existing service gaps and inequities

Key Issues and Recommendations for Terms of Reference

We respectfully submit that the proposed Terms of Reference be strengthened to achieve the desired aims. Our submission recommends:

1. Clarify definitions of “mild to moderate developmental delay” and adopt function-based assessment frameworks

The terminology of “mild to moderate” developmental delay is problematic and risks undermining the initiative’s effectiveness. These terms lack clinical precision, are inconsistently understood, and often fail to reflect the real-world complexity of children’s developmental needs. They may also be experienced by families as dismissive of genuine concerns. For example, a child with “mild” delay may experience minimal impairment in a nurturing environment, while the same delay may be more impactful in a less supportive context.

We recommend:

• Define developmental delay using functional impact rather than diagnostic labels.
• Ensure assessments are inclusive, culturally safe, and accessible in community settings.
• Enable early identification and in partnership with health and disability professionals.
• We advocate for a function-based approach that considers the child’s ecology.

The F-words Framework developed by McMaster University’s CanChild Centre offers a robust, evidence-based model for understanding and responding to functional impairment. This child- and family-centred approach, grounded in the International Classification of Functioning, Disability and Health (/CF), supports seamless transitions across service systems.

2. Evaluate Program Effectiveness and Accessibility

The inquiry should examine the effectiveness of current and previous programs that identify and support children with developmental delay, autism, or both-particularly those with mild to moderate support needs. The current pathways to access support are overly reliant on formal diagnosis, creating inequitable access to early supports. Families often face long wait times for assessments, particularly in public paediatric services, which can delay intervention during critical developmental windows. The current approach disadvantages children who cannot access timely assessments due to workforce shortages or socioeconomic barriers. This is predominantly experienced by families with CALO or First Nations backgrounds and those who live in rural or low-SES areas.

We recommend:

• A review of all early childhood intervention programs across health, education, disability, and mental health sectors-not just those delivered in mainstream systems.
• A shift to a function-based, allied health-led model that enables access to support without requiring formal diagnosis to access early intervention services.
• Enable interim supports while families await NDIS access or assessments.
• Remove administrative bottlenecks that disadvantage families unfamiliar with clinical systems.
• Ensure equity-weighted funding to support children in underserved communities.

3. Invest in place-based, integrated service models.

Children and families benefit most when services are embedded in the environments they already attend-such as early learning centres, schools, and community hubs. Absence of integrated service models that allow families to access multiple supports in one place contribute to fragmentation which leads to delays and missed opportunities for early intervention. Currently families in the community particularly regional and rural, lack access to public paediatricians, child development and allied health services outside the NDIS.

RCH supports evidence based, scalable models, such as ENVISAGE, which are designed to empower caregivers to navigate the experience of parenting a child or children with developmental concerns by embracing contemporary strengths-based ideas about health, wellbeing, and development.

[Reference: About Us - Envisage Families]

We recommend:

• Prioritising community-based access that co-locate publicly funded allied health, paediatrics, education, and family support to reduce the demand on tertiary service.
• Embed developmental expertise in mainstream settings to enable early identification and response.
• Ensure services are flexible and scalable, allowing for varying levels of intervention based on need.

4. Ensure continuity and seamless transitions between systems (Thriving Kids, NDIS, Mainstream services)

Children’s developmental needs change over time, and systems must enable smooth transitions without disruption. Current funding models-such as the MBS and NDIS-are poorly aligned, creating gaps in access and continuity of care. MBS supports a medico-centric model, limiting early access to allied health-led assessment and intervention. Meanwhile, NDIS services are increasingly incompatible with public healthcare, with reduced hospital-based offerings in Victoria. Activity based funding models used in public hospital settings also undervalues developmental care, particularly allied health-led services. Thriving Kids must identify mechanisms to ensure integrated, flexible funding and service pathways that follow the child, not the system.

We recommend:

• Establish a single point of access for all children with developmental concerns.
• Design flexible pathways that allow movement between Thriving Kids, NDIS, Public Health and mainstream services as needs change.
• Empowering frontline services-Maternal and Child Health Nurses, allied health, and Early Childhood Intervention providers-to deliver care without being constrained by inadequate funding models.
• Ensure transition supports are in place for children exiting ECEI programs or entering school.
• Align federal and state funding to avoid service gaps and duplication.

5. Address workforce shortages through targeted incentives and training pipelines, especially in underserved areas

The success of Thriving Kids depends on a skilled, distributed workforce and a system designed for flexibility and responsiveness. Workforce shortages-particularly in allied health-are a major barrier to timely intervention. This is especially acute in rural, regional, and low-SES areas.

We recommend:

• Invest in training pipelines, scholarships, and incentives to attract professionals to underserved areas.
• Support publicly funded allied health pathways accessible outside of the NDIS-especially for children with emerging or mild developmental concerns
• Embedding interdisciplinary teams-including allied health, education, and social services-within community hubs and early learning environments to deliver integrated, family-centred care.
• Aligning national and state workforce planning with projected service demand under the Thriving Kids initiative to ensure sustainable capacity and equitable access.

Conclusion

The Thriving Kids initiative presents a generational opportunity to reshape Australia’s early childhood development system. To succeed, it must be:

• Equitable - ensuring all developmentally vulnerable children can access timely support regardless of background.
• Integrated - embedding supports in the places children live, learn, and grow.
• Family-centred - recognising parents as partners in development.
• Evidence-based - drawing on best practice models and robust data.

We urge the Committee to place children and families experiencing the greatest disadvantage at the centre of its recommendations and to ensure that this reform delivers on its promise of a brighter future for all.

redacted

redacted

Chief of Medicine

Executive Director Ambulatory Services & Chief Allied Health Office