Submission 298 — Neurodiversity Special Interest Group of Australasian Society of Developmental Paediatrics (ASDP) — Inquiry into the Thriving Kids initiative

3rd October 2025

House Standing Committee on Health, Aged Care and Disability Parliament of Australia

Dear Sir/ Madam, Re: Submission for Terms of Reference for the Thriving Kids Initiative By Neurodiversity Special Interest Group (ND SIG) members of Australasian Society of Developmental Paediatrics (ASDP)

We are a collective of paediatricians and medical doctors who are either neurodivergent ourselves or parents of neurodivergent children. This combination of professional expertise and lived experience gives us a unique and powerful perspective on what truly constitutes safe, evidence-based, and neuroaffirming supports and therapies for children. We urge policymakers to give our input substantial weight as our group brings an unparalleled perspective. We would like to see this reform genuinely meet the needs of the children and families they are meant to serve.

We have outlined both significant concerns and risks, and key elements we strongly endorse, opportunities and positives that can come out of this process. This reform, first and foremost, must not harm children. Please ensure the new programs are implemented in a way that protects vulnerable families, preserves access to essential supports, and upholds the dignity and rights of neurodivergent children.

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Submission for Terms of Reference for the Thriving Kids Initiative By Neurodiversity Special Interest Group (ND SIG) members of Australasian Society of Developmental Paediatrics (ASDP)

We are a collective of paediatricians and medical doctors who are either neurodivergent ourselves or parents of neurodivergent children. This combination of professional expertise and lived experience gives us a unique and powerful perspective on what truly constitutes safe, evidence-based, and neuroaffirming supports and therapies for children.

In response to Minister Mark Butler’s NDIS reform announcement on 20 August 2025, we have outlined both significant concerns, key elements we strongly endorse and positives that can come out of this process. This reform, first and foremost, must not harm children. Please ensure the new programs are implemented in a way that protects vulnerable families, preserves access to essential supports, and upholds the dignity and rights of neurodivergent children.

We urge policymakers to give our input substantial weight. Our group brings unparalleled perspective - grounded in clinical knowledge and the real-world lived experiences of neurodivergent families. We are committed to assisting in any way to ensure that this reform genuinely meets the needs of the children and families they are meant to serve.

This document is authored by and represented the voices of:

• JN: Dr Justine Chen Ti Noble, MED0001605514, NSW
• ZA: Dr Zayna-Selena Adamu, MED0002008471, WA
• KC: Dr Karly Casamento, MED0001795230, NSW
• KE: Dr. Kareena-Anne Easton, MED000199376, WA
• MC: Dr Michele Wen-Chien Campbell, MED0001160025, VIC
• AM: Dr Andrea McGlade, MED0000950896, QLD
• PB: Dr Phyllis Nolly Bogopa, MED0001192490, NSW
• KP: Dr Karen Proudman, MED0001142054, NSW
• KS: Dr Ketaki Sharma, MED0001602891, NSW

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Concerns and Risks:	Shared by these members:
	KP
Risk that children who mask at school will not be recognised as needing support, or if they are offered support, they are unlikely to engage with it authentically in the setting where they are used to masking because they need to.	ZA JN KC MC PB KP KS
Risk of harmful physically or emotionally unsafe childcare environments due to low standards of care in these settings. This comes with risk of support not provided for children who need them.	AM: Careful consideration regarding the childcare environments to ensure they provide safe, high quality and responsive care for all children. Foundational supports delivered in environments where there is low quality of care are counterproductive. Thus foundational support needs to be implemented alongside significant reform of the childcare sector to raise standards across the sector. There needs to be increased investment in staffing, higher staff ratios (including removing the ‘under the roof ratio’), and increased upskilling for childcare workers to have a better understanding of the presentation of developmental and regulation disorders in early childhood. Only then can the children who need help be accurately identified, and appropriate and responsive developmental care provided. JN ZA KP KC
Risk of lack of appropriate and essential sensory protective considerations in childhood environments.	AM: Neuroaffirming care means making childhood environments more supportive of the sensory needs of all children, including the right to freely access quiet spaces as required, not spend long periods of time with limited to no capacity to move away from noisy and visually busy environments, and opportunities for movement.
	JN ZA PB KP KS KC

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Concerns and Risks:	Shared by these members:
There is a risk that, without careful planning and focus on improving local services in regional, remote or otherwise disadvantaged areas, the move to develop and build on existing community services may increase rather than reduce inequity in these areas.	ZA JN KC MC AM PB KP KC
Transition between preschool/childcare to primary school then primary to high school will be additionally difficult for neurodivergent children if all of their therapists are also changed. There will need to be smooth transition planning built into the system.	KC ZA MC JN PB KP KS
Risk that children with working parents will miss out on access if therapies are only offered during normal office hours and the children attend full-time childcare, unless these services are also in-reach to childcare centres.	KE MC PB ZA KP KS
Close monitoring of therapists/programs is essential, as entire cohorts of children will be disadvantaged if service provision is not gold standard at all sites. This concern could be mitigated by the ability for families to anonymously feedback concerns about service provision standards and separate overseeing bodies to review these concerns and action in a timely manner.	KE MC JN ZA PB KP KC
For years, we have emphasised the importance of early intervention, with ECEI equated to early therapy with an allied health	MC JN PB

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Concerns and Risks:	Shared by these members:
focus. There needs to be clear messaging and strategic programming to ensure that families of children who are moved to Thriving Kids do not feel they are missing out or are being provided lesser levels/quality of care.	ZA: There needs to be clearer messaging that the goals of early intervention should be on sensory accommodations, emotional regulation support, and increasing understanding and acceptance, rather than trying to change the child to seem more neurotypical. KC KP
Success of cross-sectoral collaborations needs to be backed up by sustainable funding from multiple sources on federal and state levels, across portfolios, with regular stake-holder inputs and evaluations to improve services. There is a clear intersection of health, disability, education and community-based resources that need to be accessed for this to work equitably, effectively and sustainably over time.	MC JN ZA PB KP KC
Community-based supports need to have the flexibility to provide universal health coverage as well as more tailored and inclusive support for individual needs.	MC: There is currently a general lack of support for kids who are high functioning developmentally (e.g. language and cognitive skills) but very emotionally volatile and socially anxious. They do not always do well in groups and are opting out of the mainstream school environment. JN ZA PB KP KC
Concern about diagnosis-based discrimination.	PB MC: For example, ADHD and learning difficulties, or sensory processing disorder without autism are currently not NDIS funded. Will they be supported under Thriving Kids at their level of need? KC JN: This is already an issue currently. The ideal is to provide support to each child as

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Concerns and Risks:	Shared by these members:
	soon as their needs are observed at the ground level by parents and educators/teachers, rather than having children wait for further assessments for diagnosis to allow them to start getting support. This delay is harmful to the children’s development. ZA: It is specified in the DSM-5-TR that: “The descriptive severity categories should not be used to determine eligibility for and provision of services; these can only be developed at an individual level and through discussion of personal priorities and targets“. So, these levels should not be used to determine NDIS eligibility. KP KC
Isolation of family from therapeutic environments - childcare, preschool, schools. Parents need to be involved so that they can understand their child’s developmental needs in that setting but also to be able to apply therapeutic strategies across environments, including home.	AM JN ZA PB KP KC
Consideration on how support will be provided to children not attending childcare.	PB ZA JN KP KC - I work in an area with many vulnerable families. There are existing barriers to accessing childcare including financial, cultural barriers and availability of positions particularly in rural and remote areas. If access to early intervention therapy were linked to accessing childcare then these vulnerable children would face additional disadvantage.

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Positives and Opportunities:	Shared by these members:
Services are provided in the child’s immediate environment	JN ZA KC KE MC PB
Potential for more therapies provided to groups of like-minded local children which would be more cost effective and go further towards bringing together local communities of neurodivergent families for peer support and to celebrate neurodivergent social skills.	KC ZA MC JN PB
Opportunity to transform environments, such as schools, to be neurodiversity-affirming and better meet the needs of all children, including those with diagnosed or undiagnosed neurodivergence.	ZA KC KE JN PB
Opportunity to reshape the delivery of services to ensure they are neurodiversity-affirming, co-designed and more equitable. These goals need to be centred in the implementation and development of this reform.	ZA PB KC: More neuroaffirming education for educators should be built into the model of care KE: Regular upskilling of educators and assistants should be essential JN
Opportunity for therapy supports becoming more multidisciplinary. Currently, children often see their therapists individually often at different services and it is difficult for the whole team to communicate and work together; multidisciplinary meetings are rare in the private space due to logistical issues and lack of care coordinators. With therapists based at education centres, there is more opportunity for collaboration and joint therapy	KC ZA KE: Additional opportunity/funding for developmental paediatricians to enter this space and optimise care for disadvantaged children would be incredibly valuable for families and communities. MC JN

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Positives and Opportunities:	Shared by these members:
sessions and interdisciplinary communication which will improve outcomes for children.	PB
Opportunity to take the Australian national curriculum out of Preparation/Kindergarten year, as this is a significant stressor for a large proportion of children, especially boys.	AM: The expectations in the year’s curriculum are frequently not developmentally appropriate for this group of children. Mandating that they meet these expectations attracts unnecessary therapeutic services engagement. ZA
Potential to reduce unnecessary costs of privately managed services and administration costs, to be more cost-effective whilst maintaining adequate support.	ZA KE PB KC: Due to the model of multiple small businesses that cover their own running costs, cost of individual therapy sessions has risen which is a significant barrier for seeking help for those who are not NDIS funded. Hopefully with more centralised care, therapy provision will be more equitable. JN
Opportunity to provide access to new high quality, evidence-based parenting programs for children with developmental disabilities.	AM: I would like to put forward a current evidence-based program that sits outside the usual Triple P/COS parenting: Parenting with Acceptance and Commitment Therapy - Online program (PACT online), which is currently being trialled in a large RCT and is readily available for dissemination. KC ZA PB
Opportunity to separate the reasons for seeking diagnosis (self-understanding, sense of identity and self-acceptance) from support needs, which can be delivered independently of the family’s ability or readiness to assess assessment/diagnosis.	ZA KC JN

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Positives and Opportunities:	Shared by these members:
Opportunity to capture, in transdisciplinary, cross-sectional ways, the impact of rising stress in childhood, and closely monitor outcomes with this shift to foundational support with this reform.	AM ZA
Invaluable and unmissable opportunity for adequate data collection on the progress of children’s development, the impact of the transition, ongoing provision of foundational support, and beyond.	AM: There is a key opportunity here to use data linkage of key datasets, such as childcare attendance, preschool/kinder attendance, applications for Inclusion Support Program in the early childhood education sector, AEDC data, NDIS datasets, and particularly, education. Key education data would include information from NCCD and disciplinary data by school year, as children with disabilities are significantly over-represented in disciplinary actions at school. JN: Individuals with disabilities are also significantly over-represented in the justice system. Data linkage from the justice system with the above data would be illuminating and instructive ZA

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