Submission on Review of the Thriving Kids Initiative

3 October 2025

Primary author:
Ross Joyce
Chief Executive Officer

ABOUT AFDO
ACKNOWLEDGEMENT
1. INTRODUCTORY COMMENTS
2. SUMMARY OF RECOMMENDATIONS
3. CONCLUDING COMMENTS

AFDO consents to the publishing of this submission inclusive of email contacts.

AFDO Ltd. 2024

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About AFDO

The Australian Federation of Disability Organisations (AFDO) is a Disabled People’s Organisation (DPO) run by and for people with disability, reaching over 4.5 million Australians. We are a representative organisation for population-based and disability-specific communities and the pre-eminent national voice representing people with disability across Australia and internationally.

Our Members are national and state disability advocacy organisations run by and for people with disability and their families, representing Australians with disability. Our vision is to achieve a community where people with disability can participate in all aspects of social, economic, political, and cultural life.

Our Members:

Advocacy for Inclusion Inc. – ACT | Blind Citizens Australia Autism Aspergers Advocacy Australia | Deaf Australia Brain Injury Australia | Deafness Forum Australia Deafblind Australia | Disability Justice Australia Disability Advocacy Network Australia | Physical Disability Australia Disability Resources Centre – Vic | Polio Australia Enhanced Lifestyles – SA | South West Autism Network – WA People With Disabilities WA | Women With Disabilities ACT Post Polio Victoria | All Means All Women with Disabilities Victoria | AMAZE – Vic National Mental Health Consumer & Carer Forum | Aspergers Victoria Advocacy WA | Bus Stop Films Ltd – Aust AED Legal Centre – Vic | Disability Voices Tasmania Arts Access Victoria | Integrated disAbility Action – NT Disability Advocacy & Complaints Service - SA | Lived Experience Australia Leadership Plus – Vic | Multiple Sclerosis Australia National Organisation for Fetal Alcohol Spectrum Disorder | National Union of Students - Disabilities Dept. Parkinsons Australia | Star Victoria Inc Settlement Services International - Aust | Tourettes Syndrome Assoc. of Australia Youth Disability Advocacy Service - Vic

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Acknowledgement

AFDO acknowledges Aboriginal and Torres Strait Islander people as the traditional custodians of the land on which we stand, recognising their continuing connection to land, waters, and community. We pay our respects to the peoples of the lands on which these operate and to their respective Elders past and present. We also pay our respects to the traditional owners of all lands on which we operate or meet around the country.

AFDO acknowledges people with disability, particularly those individuals that have experienced or are continuing to experience violence, abuse, neglect, and exploitation. We also acknowledge their families, supporters, and representative organisations and express our thanks for the continuing work we all do in their support.

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1. Introductory comments

AFDO welcomes the federal government’s commitment to early identification and support for children aged under 8 with mild to moderate developmental concerns through the proposed Thriving Kids program.

The intent to build foundational supports via mainstream and community services aligns with inclusive practices and aims to preserve the National Disability Insurance Scheme (NDIS) for those with permanent and significant disabilities. However, AFDO raises important issues, concerns, and recommendations to ensure the initiative delivers equitable, high-quality outcomes for children with disability and their families.

This submission is respectfully presented for consideration in the House Standing Committee on Health, Aged Care and Disability inquiry into the Thriving Kids initiative. AFDO and its member organisations remain committed to ongoing engagement and collaboration throughout the program lifecycle.

Advantages of the Thriving Kids Initiative

Early identification and support for developmental concerns in familiar community settings can improve long-term developmental outcomes for children.
The program aims to relieve pressure on the NDIS by redirecting children with lower support needs to appropriate foundational services.
Integration into mainstream services such as maternal and child health centers, early learning, and schools may simplify service navigation for families.
Joint Commonwealth and state funding demonstrates a national commitment to accessible and sustainable early childhood supports.
Engagement through the Thriving Kids Advisory Group and inquiries reflects an inclusive approach to policy design.

Issues and Concerns

Lack of clear definitions for “mild to moderate” developmental delay risks inconsistent eligibility assessments and potential exclusion of children needing support.
Transitioning children out of the NDIS without guaranteeing equivalent, timely alternatives may lead to service gaps, especially harmful during rollout phases.

Mainstream services face workforce shortages and may be inadequately resourced or trained to meet increased demand, particularly in rural and underserved areas.
Financial barriers could emerge if families must pay out-of-pocket for allied health or psychosocial therapies under Thriving Kids.
Priority populations, including children in out-of-home care, First Nations children, and culturally diverse families—may face disproportionate risks without tailored strategies.
Transparency in program outcomes and accountability mechanisms are essential but currently underdeveloped.
Jurisdictional complexities between federal and state governments risk uneven service provision.
There must be strong, meaningful inclusion of people with disability and their representative organisations such as AFDO and our member organisations, in the design, implementation, and ongoing monitoring of the Thriving Kids model.
The Thriving Kids Advisory Group, co-chaired by the Minister for Health and Ageing and experts, includes representatives from disability fields and lived experience. However, AFDO urges that beyond advisory roles, disability communities have formalised co-design and governance roles, ensuring the principle of “Nothing About Us Without Us” guides decision-making. This inclusive approach will enhance program relevance, responsiveness, and accountability to those it is intended to support.
Further, the Thriving Kids Advisory Group and any additional disability co-design and governance groups must remain in place during the entire development, implementation and roll-out of the program, until Thriving Kids is fully operational and accessible across the country. This includes completion of the phased rollout, establishment of sufficient service capacity, workforce readiness, and the resolution of policy and procedural arrangements across Commonwealth and state/territory governments.
Accessibility needs specific to disability communities, inclusive of both children and their parents or carers, must be mandated explicitly in the program model. Thriving Kids should ensure that services and information are delivered in formats and

environments that accommodate diverse physical, sensory, communication (including first language), and cognitive needs.
Considering accessibility for parents with disability is imperative to support family-centered care effectively. Accessibility must be integral to the design, delivery, and evaluation frameworks to guarantee equitable participation and outcomes for all families.
Special consideration and resourcing must be dedicated to workforce development and service delivery in rural, regional, and remote communities to prevent exacerbation of existing geographic inequities. Workforce shortages of allied health professionals and specialists are more acute in these areas and require targeted recruitment incentives, training, and retention strategies.
Service models must incorporate flexible and culturally appropriate delivery methods such as telehealth, mobile outreach, community navigators, and peer support, particularly for First Nations and culturally diverse communities. Infrastructure investments including improved connectivity and funding for community-controlled organisations are critical. Without these focused measures, many children and families risk losing equitable access to foundational supports.
Crucially, no child or family should be transitioned off the NDIS until the Thriving Kids foundational supports are fully operational and accessible across all relevant jurisdictions. This includes completion of the phased rollout, establishment of sufficient service capacity, workforce readiness, and the resolution of policy and procedural arrangements across Commonwealth and state/territory governments. Premature transition risks gaps in essential supports and disrupts care continuity, undermining families’ trust, and well-being.
AFDO calls for clear, formal safeguards to manage transitions with transparent communication, comprehensive planning, and support to ensure no child or family loses access to vital services during reform.

Implementation Timeline and Additional Considerations

The Thriving Kids program is set to commence on 1 July 2026 with a phased rollout over 12 months, enabling national service setup ahead of broader NDIS access changes planned for mid-2027.

This phased approach provides an opportunity for careful transition planning, workforce preparation, and stakeholder engagement to minimise disruption.
AFDO stresses the importance of clear communication to families and service providers throughout this transition to ensure continuity of support and build understanding of the new service framework.
The rollout timeline should include ongoing evaluation and responsiveness to feedback to refine implementation and address emerging challenges.

2. Summary of recommendations

Establish and publish clear, operational definitions and eligibility criteria for “mild to moderate” developmental and disability needs, subject to iterative review with sector input.
Guarantee no child or family loses essential NDIS supports before Thriving Kids is fully operational in their region and sector capacity is proven. Transition arrangements must be coordinated across governments with robust safeguards and communication.
Secure dedicated funding to expand and train the workforce in mainstream and community services, prioritising equity for rural, remote, and disadvantaged regions.
Prevent new financial barriers by ensuring foundational supports are universally accessible without additional costs to families currently supported by NDIS.
Develop targeted strategies and resources to uphold equity for priority cohorts, including culturally appropriate approaches and specialist outreach for children with care experience.
Implement robust data monitoring, public reporting, and transparent governance frameworks tied to measurable outcomes.
Strengthen cross-jurisdictional coordination mechanisms to ensure consistent, high-quality delivery nationwide.
Mandated formal roles and processes for meaningful, ongoing co-design and partnership with people with disability and their representative organisations in all phases of the program’s lifecycle.

Mandate accessibility standards throughout the program framework to accommodate the full spectrum of needs of children with disability and their parents or carers, delivering services and information in inclusive, barrier-free formats and settings.
Fund and implement dedicated workforce development strategies that address shortages in rural, regional, and remote areas, including recruitment incentives, continuous training, and diversified roles beyond allied health. Service delivery models in these communities must be flexible, culturally safe, and supported by infrastructure such as telehealth and mobile outreach to ensure equitable access to foundational supports.

3. Concluding comments

AFDO and its member organisations recognise the potential of Thriving Kids to enhance early childhood developmental support in Australia as the first step in providing wider foundational supports. However, to succeed, the program must be carefully designed and resourced with the voices and needs of children with disability and their families at the center.

AFDO urges the federal government to address the identified risks and embed best practice, equity, transparent governance, authentic co-design, accessibility, rural equity, and robust transition safeguards throughout implementation. With genuine partnership and accountability, Thriving Kids can be a transformative reform advancing inclusive outcomes for all Australian children.

Background information links:

Submission Contact:

Organisation: Australian Federation of Disability Organisations (AFDO) Contact Person: Ross Joyce, CEO Email: office@afdo.org.au redacted

Submission 275 — Australian Federation of Disability Organisations (AFDO) — Inquiry into the Thriving Kids initiative