Submission on Thriving Kids

From: Alliance of Registered Therapy Providers Date: 3 October 2025

Background: Alliance of Registered Therapy Providers (ARPT)

The Alliance of Registered Therapy Providers are a group of quality registered providers delivering therapy services across Australia. They currently support more than 150,000 NDIS participants. The recent introduction of the Thriving Kids Initiative has prompted concern from quality registered providers, many of whom provide therapy services to participants in this age group, across metropolitan, regional and remote areas of Australia.

Summary

The Thriving Kids initiative presents an opportunity for the disability ecosystem to support children with developmental delay or ‘mild to moderate autism’ to create an improved balance between the NDIS, ‘Foundational Supports’ and mainstream services

However, the Thriving Kids announcements has led to many key unknowns and questions which need resolving and should be a focus of this inquiry. These include:

Entry Criteria: who qualifies under Thriving Kids as opposed to NDIS.
Service and program consistency: what supports and services will be the responsibility of federal versus state governments. If state led how will national consistency be achieved across juridstictions.
Integrated ecosystem: how will the Thriving Kids initiative ensure effective collaboration across all sectors and providers in the ecosystem.
Equity of Access: how will Thriving Kids ensure equity of access for all Australian children regardless of where they live, their cultual background and their socio-economic status.
Funding: how will funding of programs be developed to ensure affordable for all children and families in need while also ensuring sustainablity for providers delivering supports and services.
Workforce: how do we ensure there is adequate workforce across all disciplines who are effectively trained in the broader intergrated ecosystem and best practive in early childhood services.
Quality: how will funding of programs ensure that allied health expertise is not omitted in favour of programs delivered by a lower skilled workforce. Thriving Kids must be built on evidence based practice which acknowledges the critical role that allied health intervention plays across the continuum of disability and development delay.

Having taken the lead on the Thriving Kids initiative the federal government must work effectively with states and territories to ensure:

Consistency of care, regardless of national or state and territory led supports, to assist children and families navigate the support and services available.
Ensuring access to the same high standards of support and services regardless of where the child lives including regional and remote participants.

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Establish clear roles, responsibilities and accountability mechanisms for all parties involved
Promoting collaboration and-sharing of best practices and resources between all levels of government and service providers.
Measurement of cost benefit to demonstrate effective outcomes of early intervention and subsequent reduced reliance of future support needs.
Ensure quality registered therapy providers have the opportunity to be involved in co-design, to make any required changes to their service models to support organisational sustainability under Thriving Kids, to build allied health workforce and program capability to address program gaps, and to champion participant outcomes and best practice to promote Thriving Kids and NDIS sustainability.

Thriving Kids creates an opportunity to apply an integrated ecosystem of disability supports to the child and family through.

Multi-disciplinary teams: opportunity for true multi-disciplinary teamwork where navigators, medical practitioners), allied health professionals and educators to work together
Delivery in community-based, natural environment settings.
Upskilling of primary caregivers and staff in community settings
Priority of access: to vulnerable children and families including:
- Aboriginal and Torres Strait Islander children;
- children under Guardianship of the Minister/ engaged with the Child Protection System;
- children of parents with disabilities and families with multiple children with delays/disabilities;
- children experiencing significant socio-economic disadvantage.

Key Thiving Kids Components

1. Consistency of Care:

It would be proposed that supports and services would follow a consistent pathway including:

Navigators: the introduction of Thriving Kids represents an ideal opportunity to introduce the role of Navigators. This role would be key to supporting the child and family through the range of supports across the ecosystem.
Service Delivery:
- Early Childhood Screening against areas of developmental concern
- Formal Assessment and Diagnosis
- Ongoing Supports and Services including allied health in health, community and education settings

2. Workforce training and support:

attraction of a quality workforce to service the initiatives. It would be underpinned by induction and training in best practice early childhood services and also provide educational support to the broader Thriving Kids ecosystem

3. Funding considerations:

ensuring participant affordability and therapy provider sustainability

4. Appropriate Registration and Regulatory Controls-

to ensure safeguarding for the child and family in a reasonable manner for providers to achieve compliance

Access Pathways

To ensure children and family gain easy access to appropriate supports and services the following are key considerations:

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NDIS Exits

The Department must ensure that the NDIA is not exiting children requiring ongoing supports from the scheme until a new ecosystem of Thriving Kids supports and services are funded and readily available nationally.
On commencement of Thriving Kids services there must be a clear transition process for children who are exiting the NDIS.

New Entrants

For new entrants to the scheme there should be an easily accessible, centralised first point of contact through the navigator network- more detail follows.

Navigators

The Thriving Kids initiative presents an ideal opportunity to introduce the Navigator function as recommended by the NDIS review. The Navigator functions serves as a centralised, easily accessed first point of contact to guide the family through available supports and services both generally and locally.

Success of the introduction of the Navigator role is dependent on:

Securing sustainable funding models;
Ensuring widespread availability in rural and remote areas;
Refining training and accountability mechanisms for Navigators;
Ongoing consultation with people with disability, their families, and service providers.

General Foundational Supports

The information provided to families by Navigators and the other key stakeholders aligns with ‘General Foundational Supports’ as also proposed by the NDIS Review. In July 2025, the Department of Health, Disability and Ageing, published two grant opportunities to deliver supports that will be ‘progressively replacing supports provided through the current ILC program’ and form the ‘building blocks for General Foundational Supports’.

The reformed ILC program will have the following categories:

Individual capacity building
Family capacity building
Community capacity building
Information and advice

While both grants refer to ages 9 and above, it is expected there would be suitable application for Thriving Kids initiative through:

Identifying if the tools are suitable for the 0-8 age group and if yes include as an available resource for children and families to be directed to
Modify these tools or release new grant opportunities if not deemed suitable

Technology

All stages of the Thriving Kids program would benefit from effective use of technology solutions to underpin supports and services. This would include:

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Capturing relevant information about the child and family: thus allowing the family to ‘tell their story once’.
Creating links to relevant information and resources for families and providers to expand knowledge and improve access to find and choose appropriate services more easily.

Screening: Early childhood health and development screening

It is critical that concerns need to be identified early in life so that they can families can access the appropriate supports. through early childhood health and development screening.

Recommendations: establish a consistent schedule of screening opportunities for children, including those in rural and remote communities, Aboriginal communities, and culturally and linguistically diverse communities requires. This would include

Initial Engagement strengthen the initial engagement processes for childhood screening during the maternity and hospital period.
Community Supports: undertake proactive approaches with home visits, telehealth and/or transport to community health centres for health and development screening.
Tracking: ensure proactive tracking of the child and families so that they don’t fall through the gaps and miss critical health and development checks.
Review of developmental screening protocols: ensure there is consistent and high-quality screening tools utilised. The screens need to be holistic- not just medical and therefore be a combination of GP and allied health components.

Assessment and Diagnosis

Where screening identifies area of concerns referrals are made for more formalised assessment to formally evaluate the child’s development, cognitive, social-emotional, and/or behavioural functioning in order to develop:

A diagnosis (if appropriate)
A functional profile exploring strengths and support needs
Recommendations for intervention, support plans and funding

Ongoing Supports and Services

Having established a formal diagnosis it is critical that the Thriving Kids result in a formal, integrated ecosystem of supports for the child and family.

Allied health therapy providers play a critical role in provision of these ongoing supports and services including:

Supporting assessment and diagnosis (where needed)
General group programs (larger groups, low needs)
Targeted group programs (smaller groups, moderate needs)
Individual programs (fixed sessions, time limited)
Crisis management
ELC/ School services (group therapy, educator/ parent training)

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Thriving Kids Locations

To ensure supports and services are easily accessible for all children there must be a range of available locations for these services to be delivered from. Where a child is already engaged in a supports, such as playgroups or childcare, services should be delivered from these familiar environments. However there will remain a significant cohort who are not already engaged in formal settings who will need to informed of and given access to alternatives such as community centres.

Schools

Provision of therapy services in the school environment is challenging for NDIS providers due to inconsistent approaches across states, resistance of Principals and school staff to engage with providers and the volume of children requiring services in the school environment.

To improve school access it would be proposed under the Thriving Kids initiative:

A national review of school access for allied health therapists is established and ensure state and territory Education Departments develop consistent approaches to access.
To establish a nationally consistent school access framework that allow schools to access pre-populated information such as employer insurances, Working with Children Checks and acknowledgement by the provider they have reviewed necessary school procedural documentation.
Educator Training: allied health professionals delivering training to educators at all schools to improve understanding and benefits of therapy delivered in the school environment and establish mutually beneficial collaborative approaches.

Funding

It is critical that funding opportunities include the opportunities for therapy providers to deliver required services across the continuum of disability.

Viable and sustainable funding models are critical to the success of Thriving Kids. The current NDIS pricing models has created significant instability and uncertainty in the provider market. However the lessons from these challenges for both the NDIS and providers can prove invaluable in creating a model for Thriving Kids funding.

Recommendations

Collaboration: state and federal governments must work together to create a harmonised and simplified policy and funding system for Thriving Kids initiatives.
Benchmark prices: use appropriate benchmarking to ensure that services are adequately funded.
Consultation: undertake close, direct consultation with service providers.
Location: ensure the ability to service regional and remote participants.
Quality: consideration of costs of extensive induction and training for all clinical staff, monitoring service quality and in maintaining a comprehensive governance system.
Governance: consideration to the costs of ensuring quality and safeguarding and adherence to regulatory (and likely registration) requirements.

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Administrative Burden: Thriving Kids Programs should minimise administration requirements for therapy providers and ensure simple booking processes and minimal documentation requirements for clinicians.
Medicare: if as indicated Medicare is to be used more widely in funding Thriving Kids services, then the rates assigned to the new codes must be reflective of the costs of service delivery and not require the addition of a gap fee as commonly occurs with current allied health services. Pricing that facilitates a gap fee would isolate a significant portion of Thriving Kids children and families and subsequently reduce the effectiveness of the initiative and increase the cost burden to the economy in future years.

Regulation

It is proposed that regulation for Thriving Kids initiatives should be nationally consistent and include

Mandatory registration of all providers.
Appropriate registration requirements and obligations- clear guidelines to reduce subjectivity and ensure a focus on outcomes rather than administrative preferences.
National consistency regardless of state led programs. This should include transition to a National Working with Children Check.
Timeliness and efficiency: minimise administrative delays in regulatory processes by reviewing internal workflows and resourcing to ensure timely decision-making.

Avoid Duplication of Registration Requirements

Many quality providers maintain registration across a number of systems or schemes. For example ISO 9001:2015 - Quality management systems certification is commonly held as it ensures providers have consistent and compliant quality areas. Any registration requirements under Thriving Kids must reduce duplication and provide concessions to registration requirements for organisations holding appropriate registration or certification.
Professional Registration: as allied health professionals our clinical staff are required to maintain annual professional registration. It is recommended that no additional checks, with the exception of Working with Children Checks, are required for clinicians under Thriving Kids and current approvals can be applied.

Identify gaps in workforce support and training required to deliver Thriving Kids.

To ensure an adequate suitably qualified and trained workforce we recommend:

Workforce supply: increase in university intake of students studying allied health courses to meet current and future demand.
Training:
- Work with universities and accrediting bodies to ensure the Best Practice Guidelines for Early Childhood Intervention are a requirement of the curriculum.
- Ensure staff are well trained in best practice early childhood service delivery. Such quality comes at a cost to the employer so it is recommended funding models allow for implemetation of workforce initiatives.

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