Submission 318 — Square Peg Round Whole — Inquiry into the Thriving Kids initiative | External submission

SQUARE PEG ROUND WHOLE ADVOCACY GROUP

SUBMISSION TO THE

Table of Contents

Who we are: 3

General comments on the Inquiry 3

TOR 1: Evidence-based information and resources for parents 5

TOR 2: Effectiveness of Current & Previous Programs 7

TOR 3: Equity and Intersectionality 9

TOR 4: Workforce Support and Training 10

TOR 5: Domestic and International Best Practice 12

TOR 6: Mechanisms for Seamless Transitions 14

Conclusion 16

References: 18

WHO WE ARE:

Square Peg Round Whole (SPRW) is a fully volunteer-run, neurodivergent-led grassroots advocacy community dedicated to achieving inclusive education for all children in Australian schools.

Founded by the late Louise Kuchel—a passionate parent advocate and creator of the Square Peg Round Whole podcast—SPRW continues her legacy by bringing allies and advocates together, amplifying unheard voices, and driving systemic change grounded in dignity, human rights, and equity.

Our Community Includes:

Parents and carers of children with disability and neurodivergence
Teachers, doctors, researchers, lawyers, and healthcare professionals
Individuals with lived experience of autism, ADHD, dyslexia, anxiety, giftedness, trauma, dyspraxia, and other conditions

Our members share a common goal: securing the understanding, accommodations, and supports necessary for every child to access their right to education on an equal basis with their peers.

Families often face interconnected challenges across education, health, and disability support systems. Accessing appropriate diagnosis and services is frequently a prerequisite for schools to acknowledge or accommodate a child’s needs, leaving parents advocating across multiple systems—a process described as exhausting and relentless.

“We already spend hours coordinating between school, health, and the NDIS. Without proper advocacy, Thriving Kids risks just adding another system for parents to juggle.” – SPRW member

Our Guiding Principles:

Inclusive education: Every student has the right to learn alongside their peers in their local school (UN CRPD Article 24).

Neuroaffirming behaviour support: Replace behaviourist approaches (e.g., ABA, PBL) with collaborative, respectful models.

“Nothing about us without us”: Disabled and neurodivergent voices, and those of families, must be central in shaping policies and systems.

Equity: Co-design with First Nations communities, CALD communities, and other marginalized groups is essential to reduce barriers and ensure access.

Through these principles, SPRW envisions education systems that welcome diversity, provide timely support, and ensure every child belongs and participates.

GENERAL COMMENTS ON THE INQUIRY

Square Peg Round Whole (SPRW) welcomes the opportunity to provide input into the Thriving Kids Inquiry. As a neuroaffirming, disabled-led and ally-supported grassroots organisation, we approach this process with a strong focus on children’s human rights, the social model of disability, and the obligation of governments to ensure equal participation in education.

We acknowledge the Inquiry’s Terms of Reference and the need for better coordination and support for children with developmental delay and disabilities within the community and mainstream sectors. However, we are concerned that the framing of “mild to moderate” needs risks introducing deficit-based language and functional classifications that are inconsistent with the CRPD and contrary to contemporary understandings of disability and neurodivergence. We urge the Committee to ensure that the Inquiry’s language and recommendations reflect a human rights framework and avoid reproducing outdated, harmful categorisations.

SPRW also notes that the design and delivery of Thriving Kids must be co-designed with disabled people and families at every stage. This is essential to ensure the program responds to lived experience, avoids unintended harm, and builds trust with the communities it seeks to serve. We also urge the inquiry to ensure that First Nations voices are central to any decision making and design to ensure culturally responsive service design and delivery.

“If Thriving Kids ends up being ABA in disguise, it will retraumatise children. We need supports that respect autonomy, not compliance training.” – SPRW member

Our submission focuses specifically on the educational implications of Thriving Kids. Education is the domain where our members consistently experience barriers, and it is where systemic change has the greatest potential to enhance participation and belonging. We recognise that the Inquiry has a broader scope, including maternal and child health and early childhood services, but we believe it is crucial to highlight the risks and opportunities within schooling systems.

Thriving Kids must supplement, not substitute, existing supports. It must not become a mechanism for diverting children away from the NDIS into no alternative pathways to access services and support, or rationing access to essential services. Families must retain access to their chosen individual therapists and providers where targeted interventions are required. Schools must not be expected to absorb new responsibilities without resources; instead, Thriving Kids should strengthen capacity by embedding specialist expertise, providing advocacy and rights information, and improving system-level coordination.

“Carers and families are already stretched to their limits. Thriving Kids must strengthen family wellbeing, not become another system we have to fight through.” – SPRW member

Finally, we emphasise that information and resources created through Thriving Kids must include access to independent, rights-focussed advocacy and clear statements of rights and service obligations. Without this, families are left unable to exercise informed choice or hold providers and systems accountable.

Through this submission, SPRW offers both policy analysis and lived experience evidence to inform the Inquiry. We encourage the Committee to ensure that Thriving Kids is designed as a rights-based, inclusive initiative that empowers families and schools, rather than adding to existing burdens or legitimising outdated practices.

TOR 1: EVIDENCE-BASED INFORMATION AND RESOURCES FOR PARENTS

The Terms of Reference ask the Committee to examine evidence-based information and resources that could assist parents in identifying developmental delay and supporting their children. SPRW recognises the value of accessible information, but stresses that the framing, quality, and purpose of this information will determine whether it supports or harms families.

Rights-based, not deficit-based

We are concerned by the Inquiry’s use of deficit-based language such as “mild to moderate developmental delay.” This framing re-introduces functional categorisations that are inconsistent with the CRPD, obscure the fluctuating nature of disability, and perpetuate stereotypes. Families have already observed how this framing risks excluding children whose needs are considered “not bad enough” for support.

As one SPRW member noted:

“Already hearing of many families not being accepted for early childhood approach as ‘not bad enough’. Where do these kids go? And will Thriving Kids include or exclude?” – SPRW member

Evidence must acknowledge lived experience

Historically, autism and developmental research has been dominated by behaviourist frameworks such as Applied Behaviour Analysis (ABA). These programs have been widely promoted as “evidence-based,” despite extensive testimony from autistic people and families documenting harm (Kupferstein, 2018; Milton, 2019). Families are deeply concerned that Thriving Kids risks repeating this error.

“I feel like these proposed supports and approaches are all based on an understanding of autism/neurodivergence that is mistaking distress behaviours or nervous system responses to feeling unsafe and unwelcome for autistic traits. And therefore without distress there is no apparent ‘problem’ to put resources into. No supports needed. It will leave us parents where many of us are now which is subsiding the whole system with our time, energy, money and ultimately mental and physical health.” – SPRW member

A rights-based definition of “evidence” must therefore require three components:

Empirical validation,
Consistency with human rights obligations (CRPD, DDA), and
Integration of lived experience evidence – including consultation, collaboration and co-design from disabled people, families, and representative organisations.

This aligns with the Disability Royal Commission’s recognition that lived experience is critical to exposing systemic harms and identifying solutions that research alone has overlooked (DRC, 2023).

Information that empowers, not burdens

Families are clear that what they need are resources that provide not only developmental information but also practical rights-based knowledge: what supports children are entitled to, what responsibilities schools and services hold, and where to go for advocacy if those obligations are not met.

“Families need honest information about their rights, not just a brochure with a list of programs. If we don’t know what we’re entitled to, we can’t hold schools or services accountable.” – SPRW member

Crucially, these resources must not add further strain to families already operating beyond capacity. They must inform and empower, not place responsibility for disability specific supports and care onto families and caregivers. Thriving Kids must build capacity around families, not shift responsibility back onto them.

“Carers and families are already stretched and at or beyond their capacity. Thriving Kids must not become yet another obligation or burden shifted to their shoulders, or become something that reduces their access to supports and services aimed at building family wellbeing and care sustainability.” – SPRW member

Individuality and choice

Families also highlight the risk that information and screening tools may function on stereotypes rather than recognising individual differences and the complexity of the neurodivergent community.

“My concern is the individuality of the program – will it function on stereotypes of what they think kids with these diagnoses need or will the time be taken to understand just how different each one is despite what is documented on paper?” – SPRW member

Resources must embed the principle of choice and control. The ability to select trusted therapists and neuroaffirming supports must not be lost to “one size fits all” or bulk-purchased, group-therapy approaches that save money but compromise outcomes.

“Where does the element of choice lie in the system? Will the option to choose your own therapists be available, or will it be whoever you are allocated regardless of whether your child is able to build a relationship with them?” – SPRW member

Summary of Recommendations under TOR 1

Redefine “evidence-based” to include human rights alignment and lived experience testimony.
Remove deficit-based categorisations such as “mild to moderate.”
Ensure resources are co-designed with disabled people and families.
Embed explicit information on rights, advocacy, and accountability.
Provide materials in accessible formats and across multiple channels.
Guarantee choice of providers and recognition of individual differences.

Ensure resources support family wellbeing and do not add further burdens.

TOR 2: EFFECTIVENESS OF CURRENT & PREVIOUS PROGRAMS

The Inquiry asks for examination of the effectiveness of past and present programs designed to identify and support children with developmental delay, autism, or both, with “mild to moderate” needs (to reflect the language of this inquiry, not SPRW language choice). SPRW submits that the effectiveness of such programs must not be judged by short-term outputs (e.g., attendance, compliance, therapy hours delivered), but by whether they have reduced barriers, improved inclusion, and strengthened young people and families’ ability to thrive in their communities and schools.

The limits of school-centred design

Our members express deep concern that Thriving Kids — like Better, Fairer Schools before it — is being designed primarily through an education system lens, with an overemphasis on attendance as the key measure of success.

“My concern is that programs like Better, Fairer Schools and Thriving Children are being designed too much through a school lens. While the aim is better attendance and quality education, it risks forcing families into narrow pathways and limiting access to supports outside of schools. Children thrive in many environments, including home education — so foundational supports need to stay flexible, accessible and inclusive of all pathways.” – SPRW member

Programs that focus narrowly on school attendance without addressing safety, belonging, or the social environment risk replicating failures already documented in Australia’s education systems (DRC, 2023). Children may be “in” school, but excluded from participation, denied adjustments, or subjected to restrictive practices.

Misuse of “evidence” and behaviourist dominance

Past initiatives have leaned heavily on behaviourist approaches marketed as “evidence-based.” Programs such as ABA and PBL have been widely promoted despite strong testimony from autistic people about trauma and harm (Kupferstein, 2018; Milton, 2019).

One member reflected:

“It looks like ABA dressed up. Changes to the program to be more neuro-affirming haven’t been studied.” – SPRW member

This pattern undermines trust in government programs and highlights the urgent need for Thriving Kids to centre neuroaffirming approaches and reject outdated models that equate effectiveness with compliance.

Systemic barriers and delayed access

Many families report that existing programs fail to reach children in time. The early intervention window has been narrowly defined, and many neurodivergent children are not flagged or supported until well beyond the age thresholds. By then, they have often “aged out” of eligibility or lost access to programs by virtue of timing, not need.

“A lot of neurodivergent kids are not flagged by the mainstream education system within the window of early intervention, and even if they are, they have aged out by the time they receive any assessment, diagnosis, or support. How will Thriving Kids address this cohort of children?” – SPRW member

This is compounded by reassessment requirements and shifting eligibility. Families whose children are on the developmental delay pathway often lose access to NDIS supports while waiting for formal assessments. Families fear that this limbo will become permanent if these young people are no longer supported via the NDIS.

“Reassessments for kids on the developmental delay pathway who are losing access to NDIS supports – sometimes because they are on CDS waitlists for autism or FASD assessment, sometimes because their conditions are not recognised by NDIS (e.g. childhood apraxia of speech, developmental coordination disorder).” – SPRW member

These examples highlight that “effectiveness” cannot be measured by program throughput. It must be defined by whether programs sustain access, continuity, and meaningful support across developmental stages.

Burden on education systems

Programs that rely on schools as delivery vehicles have regularly proven ineffective because schools are already stretched beyond breaking point. Teachers and education assistants report being unable to meet even current adjustment obligations. Without resourcing, training, and embedded specialist expertise, adding new layers of responsibility will reduce, not improve, support for students.

“The possibility of the onus falling on the education system to incorporate these demands when many can barely navigate the IEP process means that in effect kids will be seen as receiving help when it is in reality of little to no benefit.” – SPRW member

This risk is even more acute for children in non-government schools (independent and Catholic), or those who are home-educated, who may find themselves excluded from supports delivered only through state school systems.

“To the above point, if Thriving Kids is in fact to be delivered via government education departments, how will children in non-mainstream school settings access supports? Or children who attend private schools?” – SPRW member

Effectiveness must therefore be judged against reach and equity — not simply ease of delivery through state systems. Any evaluation schemes or program reviews must be against criteria developed in co-design with disabled people, to address this risk.

Risk of uniform, standardised approaches

Families are concerned that Thriving Kids could follow a trend of using one size fits all segregated group-based therapy models, which may be cost-efficient but are often a vehicle for segregation or individual goals being ignored.

“Will it have a basis in group therapy sessions which save money from a funding perspective but make progress harder for many kids?” – SPRW member

Effective programs must acknowledge individuality and the necessity of tailored supports. One-size-fits-all approaches are inconsistent with the principles of choice and control and risk reproducing the very inequities the Inquiry seeks to solve.

Summary of Recommendations under TOR 2

Redefine effectiveness to mean increased participation, belonging, and continuity of supports, not just attendance or throughput.
Ensure programs reach children who fall outside narrow early intervention windows.

End reliance on behaviourist models marketed as “evidence-based.”

Guarantee continuity of support for children moving between stage or age pathways
Resource schools properly if they are expected to play a role in delivery, and avoid overloading teachers and EAs.
Ensure children in non-government and home education settings have equitable access to Thriving Kids supports.
Reject group-based “efficiency” models in favour of individualised supports where needed, with school based services focussing instead on empowerment and capacity building through initiatives like UDL and MTSS.

TOR 3: EQUITY AND INTERSECTIONALITY

The Terms of Reference ask the Committee to identify equity and intersectional issues, particularly for children who are First Nations or from culturally and linguistically diverse (CALD) communities. SPRW emphasises that equity cannot be achieved by treating all families facing barriers as a single “disadvantaged” category. Each equity group has unique contexts, histories, and needs, which require distinct strategies.

It is also vital to recognise that the drivers of inequity differ.Thriving Kids must avoid flattening these diverse experiences into a single category and instead respond to each on its own terms. Central to this is ensuring that affected communities have autonomy, self-determination, and a genuine role in co-designing the program.

First Nations children and families

Equity for Aboriginal and Torres Strait Islander children means recognising sovereign rights, community autonomy, and self-determination. Thriving Kids must not replicate top-down, imposed programs. It must be co-designed and led in partnership with Aboriginal organisations, co-designed with Aboriginal people who are best placed as experts in design and delivery of culturally responsive care.

Culturally and linguistically diverse families

Thriving Kids must ensure cultural autonomy and co-design with CALD communities, using bicultural workers and cultural consultants, embedding cultural sensitivity across workforce training, and recognising diverse ways of understanding disability and neurodivergence. Without this, programs risk exclusion by default.

We note that there are also factors that can create disadvantage and additional barriers to service and support access that affect equity. This includes:

Rural and regional families

Geography creates barriers that require locally co-designed solutions. Families outside metropolitan centres face inequity through long waitlists, limited services, and higher costs. Telehealth can assist but cannot replace in-person relationships. Thriving Kids must invest in workforce distribution and infrastructure for rural and regional areas, with solutions shaped in collaboration with those communities to ensure local relevance and sustainability.

Families experiencing socioeconomic disadvantage

For families experiencing socioeconomic disadvantage, equity means ensuring that cost is never a barrier to access. Families in this group highlight that programs too often assume parents can take time off work, afford travel, or pay gap fees. Thriving Kids must embed economic equity as a

principle by covering associated costs, embedding supports in community settings, and designing flexibly with those families so that participation is genuinely possible.

“Carers and families are already stretched and at or beyond their capacity. Thriving Kids must not become yet another obligation or burden shifted to their shoulders, or become something that reduces their access to supports and services aimed at building family wellbeing and care sustainability.” – SPRW member

Intersectionality

Many families experience multiple overlapping inequities — for example, a First Nations family in a rural area, or a CALD family experiencing financial hardship. Thriving Kids must be designed to identify and respond to these compound barriers, not just treat each in isolation. A strong intersectional lens must be built into program design, monitoring, and evaluation.

Summary of Recommendations under TOR 3

Recognise each equity group (First Nations, CALD, rural/regional, socioeconomic disadvantage) as distinct, with separate strategies.
Ensure Thriving Kids is co-designed with lived experience communities, embedding autonomy and self-determination.
Partner with Aboriginal-led organisations to ensure First Nations leadership.
Provide culturally and linguistically accessible services for CALD families, embedding bicultural workers and cultural sensitivity training.
Address geographic inequity with locally co-designed solutions and investment in rural and regional workforce distribution.
Remove financial barriers for families experiencing socioeconomic disadvantage, including gap fees, transport costs, and time burdens.
Monitor and respond to intersectional inequities where families experience multiple overlapping barriers.

TOR 4: WORKFORCE SUPPORT AND TRAINING

The Terms of Reference ask the Committee to identify workforce support and training requirements needed to deliver Thriving Kids. SPRW submits that the program will only succeed if it focuses on building workforce capacity without shifting additional burdens onto already stretched teachers and education assistants (EAs). Thriving Kids must invest in embedding specialist expertise and co-designed professional learning, rather than assuming schools can take on new responsibilities with no additional resourcing. It must also be careful to avoid segregation via service delivery, by utilising programs and models of support that enhance not reduce inclusive education.

Avoiding overload on schools

Our members consistently stress that schools are struggling even to meet their current obligations under the Disability Discrimination Act and the Disability Standards for Education. Adding a new layer of responsibility through Thriving Kids, without new resources, risks creating an illusion of support rather than meaningful change.

“The possibility of the onus falling on the education system to incorporate these demands when many can barely navigate the IEP process means that in effect kids will be seen as receiving help when it is in reality of little to no benefit.” – SPRW member

Thriving Kids must therefore embed external allied health expertise and systemic supports rather than loading more expectations onto classroom teachers and EAs.

Building capacity, not compliance

Workforce training must move beyond compliance checklists. Professional learning should be neuroaffirming, rights-based, and co-designed with disabled people and families. Training should focus on creating safe and welcoming environments, understanding distress as a communication of unmet need, and replacing behaviourist frameworks with collaborative, proactive approaches.

This requires a deliberate phasing out of outdated practices like ABA and PBL, which prioritise compliance over wellbeing, and embedding training that strengthens educators’ ability to support participation and belonging.

Universal Design for Learning (UDL)

A cornerstone of workforce development must be Universal Design for Learning (UDL). UDL provides teachers with the tools to design learning environments that are inclusive from the outset, reducing reliance on retrofitted adjustments and one-to-one supports. Embedding UDL across professional standards and teacher training creates systemic capacity for inclusion, benefitting all students while particularly addressing inequities faced by neurodivergent and disabled children.

The UN Committee on the Rights of Persons with Disabilities (CRPD General Comment No. 4, 2016) identifies UDL as a requirement for inclusive education. Thriving Kids must therefore explicitly integrate UDL capability into its workforce strategy, ensuring all educators are equipped with inclusive pedagogical skills.This, supplemented with Multi-Tiered Systems of Support for those students with individualised support needs, enables all students to receive high quality support and education experiences.

Multi-disciplinary collaboration

Effective supports require collaboration between educators, allied health professionals, and families. Thriving Kids should fund and embed multi-disciplinary teams within schools, providing coaching and modelling for teachers rather than withdrawal-based therapy that isolates children from learning. Families must also retain access to their own chosen external therapists to ensure continuity and trust.

“Integration with education is critical for more efficient delivery of supports and embedded allied health would go a long way in providing support and capacity building.” – SPRW member

Supporting the workforce itself

Equity must extend to the workforce. Teachers, EAs, and allied health professionals report burnout, high attrition, and unsafe workloads. Thriving Kids must include workforce sustainability measures such as:

Time release for training and collaboration.
Safe caseload limits for allied health professionals.
Recognition and access to fair remuneration and ongoing professional development for EAs.
Access to reflective practice and professional supervision.

Summary of Recommendations under TOR 4

Build workforce capacity through investment in resources and embedded allied health, not by overloading teachers and EAs.

Ensure all training is co-designed with disabled people and families, rights-based, and neuroaffirming.

Phase out behaviourist and compliance-driven training models, embedding collaborative and proactive approaches instead.
Embed Universal Design for Learning (UDL) as a central framework across all teacher training and professional standards.
Fund and support multi-disciplinary collaboration between educators, therapists, and families.
Provide sustainability measures to protect the wellbeing and retention of teachers, EAs, and allied health professionals.

TOR 5: DOMESTIC AND INTERNATIONAL BEST PRACTICE

The Terms of Reference call for analysis of both domestic and international best practice. SPRW submits that “best practice” cannot simply mean efficiency or throughput. It must be judged against human rights standards, particularly the UN Convention on the Rights of Persons with Disabilities (CRPD), and on whether programs create safe, inclusive environments where children and families can thrive.

The danger of repeating past mistakes

Domestically, many programs promoted as “best practice” have been later shown to be harmful or exclusionary. Behaviourist approaches such as ABA were exported internationally as “gold standards,” yet autistic-led organisations and research have documented their damaging impacts (Kupferstein, 2018; Bottema-Beutel et al., 2020). These examples demonstrate that “evidence-based” does not automatically equate to “rights-based.”

“It looks like ABA dressed up. Changes to the program to be more neuro-affirming haven’t been studied.” – SPRW member

True best practice requires integrating lived experience into evaluation, ensuring that families and disabled people themselves are central to defining what “effective” means.

International examples recognised by the UN

The CRPD General Comment No. 4 (2016) outlines the principles of inclusive education as an international obligation. It identifies:

Universal Design for Learning (UDL) as the pedagogical framework for system-wide inclusion.
Individualised supports provided within mainstream classrooms, not through segregated settings.
Capacity-building of mainstream systems rather than parallel or special streams.

These principles have been endorsed by the UN and adopted in jurisdictions such as Italy, which abolished segregated schooling and invested in building inclusive capacity within mainstream systems. While contexts differ, the core lesson is clear: inclusive education is a rights obligation, not an optional innovation.

Domestic lessons

In Australia, small-scale models have demonstrated best practice when they:

Are co-designed with families and communities.

Focus on capacity-building of schools and early childhood services, not outsourcing responsibility.
Provide seamless access to allied health expertise without disrupting learning or isolating and excluding young people from the classroom.
Retain individual choice of providers, so families can work with trusted, neuroaffirming professionals.

Guardrails for Thriving Kids

Thriving Kids has the opportunity to align itself with genuine best practice by ensuring:

Human rights alignment: All frameworks must be consistent with the CRPD, the Disability Discrimination Act, and Australia’s obligations to inclusive education.

Community autonomy and co-design: First Nations leadership, CALD community input, and parent and disabled people’s voices must drive design.

System capacity, not parallel systems: Supports must strengthen mainstream services through UDL, multi-disciplinary teams, and training.

Individual choice and control: Families must retain access to their own chosen providers, ensuring autonomy and continuity of care.

Summary of Recommendations under TOR 5

Define “best practice” in terms of rights compliance and lived experience validation, not just clinical “evidence.”
Reject behaviourist models exported as “gold standards” that have been shown to harm.
Align Thriving Kids explicitly with the UN CRPD (General Comment No. 4) framework for inclusive education.
Learn from domestic examples that emphasise co-design, capacity-building, and seamless allied health support.
Ensure families retain choice of providers alongside school-based capacity-building.
Adopt guardrails that prevent exclusion, deficit-based eligibility, and siloing of supports.

TOR 6: MECHANISMS FOR SEAMLESS TRANSITIONS

The Terms of Reference ask for mechanisms that would allow a seamless transition through mainstream systems for all. SPRW stresses that seamlessness must be understood not just as moving through systems efficiently, but as continuity of support, protection of rights, and the removal of barriers to belonging across all stages of a child’s education and development.

Continuity across life stages

Families consistently report that transitions — between early childhood, primary school, high school, and post-school pathways — are among the most stressful times. Too often, supports drop away, assessments must be repeated, and families are forced to start again in each new setting. Thriving

Kids must ensure that supports and information flow with the child, rather than being reset at every stage.

“Reassessments for kids on the developmental delay pathway who are losing access to NDIS supports – sometimes because they are on waitlists for autism or FASD assessment. Sometimes because their conditions are not recognised by NDIS.” – SPRW member

Seamless does not mean standardised

A seamless system must not equate to a one-size-fits-all model. Families fear that in practice, seamlessness could mean being locked into monolithic service providers or group therapy models that deny choice and individualisation.

“Where does the element of choice lie in the system, will the option to choose your own therapists be available or will it be whoever you are allocated regardless of whether your child is able to build a relationship with them?” – SPRW member

To be truly seamless, mechanisms must combine system capacity-building (so supports are embedded in schools and community services) with family choice and control (so children can continue to work with trusted providers who know them well).

Enhancing, not Excluding from learning

One of the most pressing concerns is that supports are often delivered in ways that disrupt or isolate children from their learning environments — such as withdrawal models or scheduling therapies during core curriculum time. Schools are not clinics, and Thriving Kids must ensure that embedded expertise enhances inclusive teaching rather than pulling children out of learning.

“Integration with education is critical for more efficient delivery of supports and embedded allied health would go a long way in providing support and capacity building.” – SPRW member

The focus must be on embedding allied health expertise into classroom environments, modelling inclusive practice for educators, and ensuring children participate fully in the social and academic life of their school.

Risks of restrictive practices

The risk of restrictive practices must also be explicitly addressed. Education systems in Australia already have a documented pattern of using restraint, seclusion, and informal exclusions against students with disability (DRC, 2023). Without safeguards, Thriving Kids could inadvertently increase these risks — for example, if programs prioritise compliance over belonging, or if “challenging behaviour” is pathologised without recognising distress as a communication of unmet need.

Australia’s NDIS Restrictive Practices Framework establishes important safeguards, but these do not currently extend to schools. Thriving Kids must ensure that no interventions delivered in educational settings increase the use of restrictive practices and that oversight and accountability mechanisms are built in.

Multi-disciplinary collaboration and advocacy access

Seamless transitions also require multi-disciplinary collaboration — between educators, allied health, medical providers, and families. Mechanisms such as shared planning tools, joint professional development, and family-centred meetings can reduce duplication and create continuity.

Equally important is access to advocacy and rights information. Families must have independent support to understand their rights and navigate systems at key transition points. Without advocacy,

seamlessness risks becoming a one-way process of being slotted into whatever program is available, rather than exercising informed choice.

Summary of Recommendations under TOR 6

Ensure supports flow with the child across life stages, preventing gaps at key transitions.
Guarantee choice and control so families can continue with trusted providers rather than being restricted to allocated services.
Avoid withdrawal-based or disruptive service models; embed allied health in classrooms to strengthen inclusive teaching.
Introduce safeguards against restrictive practices, with oversight in education settings aligned to NDIS principles.
Fund and require multi-disciplinary collaboration across schools, health, and community services.
Provide families with access to advocacy and rights information at every transition point.
Define seamlessness as continuity, inclusion, and rights protection — not standardisation or system convenience.

CONCLUSION

Square Peg Round Whole welcomes the opportunity to contribute to this Inquiry and recognises the potential for Thriving Kids to deliver meaningful change for families, children, and educators. However, to succeed, However we have significant concerns with the current framing and intention of the program, and urge for meaningful redirection and co-design as a priority. Thriving Kids must be grounded not in deficit language or standardised program design, but in a human rights framework, the principles of the CRPD, and the lived experience of the very communities it seeks to serve.

Throughout this submission, we have emphasised several key themes:

Co-design is non-negotiable: Disabled people, families, First Nations communities, and CALD groups must not just be consulted but must share leadership in the design, delivery, and evaluation of the program. Community autonomy and self-determination are the foundation of equity.

Continuity and choice matter: Seamless transitions must not mean standardisation or loss of autonomy. Families must retain access to chosen providers and trusted professionals, with supports flowing with the child across life stages.

Guardrails are essential: Without strong safeguards, Thriving Kids risks inadvertently increasing restrictive practices or reproducing the harms of past “evidence-based” models that prioritised compliance over wellbeing.

Language matters: Terms such as “mild to moderate” developmental delay are inconsistent with a rights-based approach and risk reintroducing harmful hierarchies and exclusions.

Families are already at capacity: Thriving Kids must build capacity around families, not create new obligations or burdens.

Schools are not clinics: While educators are central to inclusion, they cannot and should not bear responsibility for delivering therapy. Instead, Thriving Kids must embed allied health expertise into classrooms in ways that enhance, not disrupt, learning.

SPRW calls for a Thriving Kids program that is:

Neuroaffirming: recognising distress as communication, rejecting behaviourist models, and valuing individual differences.
Inclusive by design: embedding Universal Design for Learning and systemic capacity-building so that every child belongs in their local school.
Equitable: responding to the unique contexts of First Nations, CALD, rural/regional, and socioeconomically disadvantaged families with tailored strategies, not homogenous labels.
Sustainable: protecting the wellbeing of families, teachers, EAs, and allied health professionals by investing in system capacity and workforce sustainability.
Co-designed at all levels as a priority and urgent action. This includes proactively engaging with marginalised communities and those who may not have been included in the likely submission respondents.

Australia has an opportunity to set a benchmark in inclusive practice and uphold its commitments under the CRPD. Thriving Kids will only achieve its goals if it, rejects deficit-based frameworks, and instead delivers a program that strengthens communities, empowers and supports families holistically and retains their autonomy over individualised support, and ensures that every child is supported to learn, participate, and thrive.

REFERENCES:

Bottema-Beutel, Kristen, et al. “Research Review: Conflicts of Interest (COIs) in Autism Early Intervention Research—A Meta-Analysis of COIs and Their Relationship to Research Outcomes.” Journal of Child Psychology and Psychiatry, vol. 62, no. 1, 2021, pp. 5–15.

Disability Royal Commission. Final Report: Volume 7 – Inclusive Education. Australian Government, 2023.

Kupferstein, Henny. “Evidence of Increased PTSD Symptoms in Autistics Exposed to Applied Behavior Analysis.” Advances in Autism, vol. 4, no. 1, 2018, pp. 19–29.

Milton, Damian. “The Double Empathy Problem.” Disability & Society, vol. 27, no. 6, 2012, pp. 883–887.

United Nations. Convention on the Rights of Persons with Disabilities. General Assembly Resolution A/RES/61/106, 2006.

United Nations Committee on the Rights of Persons with Disabilities. General Comment No. 4 on the Right to Inclusive Education. UN Doc CRPD/C/GC/4, 2016.

Square Peg Round Whole. Submission to the Disability Royal Commission on the Final Report Recommendations. 2024.

Square Peg Round Whole. Submission to the National Autism Strategy Consultation. 2023.

Square Peg Round Whole. Better and Fairer Education Submission. 2023.

Square Peg Round Whole. Submission to the Senate Standing Committee on Education and Employment. 2022.

Australian Coalition for Inclusive Education (ACIE). Position Statement: Therapy Supports and Allied Health Services in Schools. 2023.