NDIA Accountability Project

Submission 319 — The University of Melbourne — Inquiry into the Thriving Kids initiative

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Submission 319
THE UNIVERSITY OF MELBOURNE\

Submission to the House Standing Committee on Health, Aged Care and Disability inquiry into the Thriving Kids initiative

Joint submission by the University of Melbourne

3 October 2025

Contributing Authors:

Dr Anne Bellert Prof Bruce Bonyhady A/Prof Ben Cleveland Dr. Eli Cohn Prof Tricia Eadie A/Prof Matthew Harrison Dr Chelsea Hyde Prof Christine Imms A/Prof Lisa McKay Brown Dr Sharon Klieve Dr Catherine Smith Prof Kate Reynolds Dr. Jessica Riordan Prof Marek Tesar Dr. Sarah Timperley

Positionality of the contributing authors

Many Australians who are neurodivergent have highlighted the importance of lived experience and co-design in research about these populations. Given the focus of this submission, Contributors A/Prof Matthew Harrison, Dr Sarah Timperley, and Dr Jessica Riordan voluntarily disclose being neurodivergent, either having ADHD, being autistic, or being both autistic and having ADHD. Additionally, some authors have neurodivergent children with diverse support needs, both within the ages of 0-8 and above. This disclosure is made to reassure these communities that people with direct lived experiences of neurodivergence were involved in the development of this submission.

Contact details for corresponding author

✉ redacted

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Table of Contents

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Our Vision for Thriving Kids and Education and Care settings

Child-centred approach: The vision prioritises the individual needs, interests, and development of each child. Taking the time to get this right and learning the lessons of past systematic changes is important to minimise the risk of harm to certain communities, and will further reduce negative impacts. The voices of children, and families within Disabled communities need to be at the centre of the design of any new systems of support – “Nothing about us without us” (Charlton, 1998). There is also a need to include the perspectives of Aboriginal and Torres Strait Islander people about autism (NACCHO, 2022).

Equity and inclusion: Education and care environments provide settings where all children, regardless of their background or circumstances, feel welcomed, respected, and supported and can easily access supports to meet needs. This aligns with the Sustainable Development Goal (SDG) 10 which seeks to empower and promote the social, economic and political inclusion of all, irrespective of age, sex, disability, race, ethnicity, origin, religion or economic or other status. Here, SDG 10 is broader than that of SDG 4, which focuses on education, but is relevant as Thriving Kids is about whole person needs. Further, the focus is on equity, equality and non-discrimination – all of which are important factors when considering this initiative.

High-quality Early Childhood Education and Care (ECEC) and Primary School: Our vision stresses the importance of providing children with enriching learning experiences that promote their social, emotional, cognitive, and physical development. Evidence-based/evidence-informed and culturally safe practices in early childhood centres and schools need to be implemented in ways that that aligns with the human rights of the child (neurodiversity-affirming practices). A major workforce capability and capacity uplift is urgently needed in early childhood education and primary school settings so children and families can be supported within systems that they already access. This capacity uplift will provide equity and create greater accessibility; particularly for families with limited support. Here, the sector requires both structural (standards and regulations) and process (workforce) uplift.

Wrap-around services and collaboration: The hardships of supporting children/students whose presentations are externally judged to be less complex should not be shifted to parents/families, as such perceptions may not accurately reflect their challenges. The submission advocates for a network of support services that work together to address children’s holistic needs, including family involvement, community partnerships, and collaboration across sectors. Systems need to be integrated to allow collaboration among the child, families, teachers/educators, teaching assistants, allied health professionals, medical professionals, and social workers.

The need for further consultation and planning: While there has already been significant and deep engagement through the NDIS Review and other processes relating to Foundational Supports since the NDIS Review was published, the fastest way to fail families is to rush a policy and program roll-out without child data-safety guardrails, to slice eligibility by simplistic “functioning” gradients, and to bolt on short-term interagency meetings in place of embedded partnerships. Thriving Kids must fund the relational and coordinating work and protect children’s data rights from day one (Dickinson et al., 2023; Smith et al., 2025a, 2025b; Office of the Australian Information Commissioner [OAIC], 2022; United Nations Committee on the

Rights of the Child, 2021). Further, additional priority should be placed on engaging with members of otherwise marginalised communities such as Aboriginal and Torres Strait Islander Representative, rural and remote settings, migrant communities, and those from English as an additional language background.

The need for design and build inclusive environments: Ensuring an inclusive educational environment requires careful consideration of students’ sensory sensitivities. Many students, particularly those with neurodivergent conditions, can become overwhelmed by sensory stimuli such as noise from crowded corridors, busy classrooms, or loud hand dryers in bathrooms. These environmental barriers, often rooted in social, cultural, spatial, and material factors, can limit access and meaningful participation in education.

Identifying and addressing these barriers is a complex challenge, but designing inherently accessible environments that can be adapted to individual needs and changing student cohorts is essential.

Recent studies (Mostafa, 2018; Alterator, et al, 2022; Cleveland et al., 2025) highlight the need for spaces that are available, accessible, and adaptable to meet the needs of each learner. Engaging with individuals with lived experience of disability through participatory or co-design processes is crucial for promoting inclusion, as it can help identify environmental barriers and enablers to students’ participation (Tufvesson & Tufvesson, 2009).

Efforts towards more inclusive schools are underway, such as the establishment of Supported Inclusion Schools in Victoria, which showcase a commitment to providing better access to mainstream education for students with additional needs. These schools feature design elements like operable spaces that can be easily connected or separated, and acoustically isolated sensory reset/retreat spaces, providing educators with the flexibility to meet diverse educational and personal needs.

Creating truly inclusive school environments requires considering the requirements of students with and without disabilities, as well as those of teachers and support staff. Applying principles of safety, well-being, and belonging can help establish communities where everyone receives support suited to their needs.

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Focus of this submission

This submission draws on expertise and lived-experiences across the University of Melbourne with respect to disability, learning difficulties, autism, early childhood and community and early and primary education settings, and workforce strengths and challenges (e.g., teachers, allied health professionals). It also draws heavily on previous enquiries in related fields, as follows:

  • Select Committee on Autism. (2022). Services, support and life outcomes for autistic Australians (Executive summary). Parliament of Australia https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Autism/autism/Report
  • Classroom strategies for Autistic Students and Students with ADHD. Findings from an umbrella review, draft September, 2025
  • The review of best practice in early childhood intervention and development of the new National Best Practice Framework for Early Childhood Intervention, launched in September 2025 by the Department of Health, Disability and Ageing
  • Melbourne Graduate School of Education Submission to the Australian Government’s Early Years Strategy (prepared by REEaCH Centre)
  • OECD Good practices in delivering integrated care- examples from the Netherlands, Denmark, France and Ontario. 2023, Output 4.
  • Educational and Developmental Psychology experience with the Helping children with Autism fund (ended with NDIS), used for assessment, allied health support (e.g., Autism Queensland).
  • ACECQA Development of Inclusive Practice Framework
  • Working Together to Deliver the NDIS: Final report of the Independent Review of the National Disability Insurance Scheme

Alongside previous enquires in related fields, this report also draws upon the expertise from across various academic groups, research centres and hubs at the University of Melbourne, that each focus on children and families in various ways:

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Given the research and professional expertise of the contributing authors, we have decided to focus on three of the six terms of reference:

  • Term of reference 2: Examine the effectiveness of current (and previous) programs and initiatives that identify children with development delay, autism or both, with low to moderate support needs and support them and their families. This examination should focus on community and mainstream engagement, and include child and maternal health, primary care, allied health, playgroups, early childhood education and care and schools.
  • Term of reference 5: Draw on domestic and international policy experience and best practice.
  • Term of reference 6: Identify mechanisms that would allow a seamless transition through mainstream systems for all children with low to moderate support needs.

Context in which the transition to Thriving Kids is occurring

We believe that there are a number of contextual considerations that need to be taken into account when considering the response to the transition to Thriving Kids. The first of these relates to the focus populations of this initiative. When announcing this transition, the Minister explicitly ‘called out’ autism in the framing of Thriving Kids. It is our perspective, however, that the initiative must adopt a more contemporary and non-categorical approach based on support needs rather than a diagnosis. The current focus on autism has led to a perception by many parents, including parents who are autistic themselves, that they and their children are being unfairly singled out and targeted in response to expenditure concerns with the NDIS.

It is also important to situate these concerns in the broader global context. Recent policy developments in the United States have had a chilling effect on neurodiversity advocacy and the confidence of communities worldwide. The Trump administration has sought to silence neurodiversity advocacy organisations within universities, focusing on cure narratives rather than support, and there has been a removal of National Science Foundation funding for critical neurodiversity-related research. These high-profile events, all of which have received widespread media attention, are contributing to a general sense of distrust of government by neurodivergent communities globally. This distrust is deeply relevant to the Australian context and highlights the importance of ensuring Thriving Kids is developed in genuine partnership with autistic people and the broader neurodivergent community.

Thriving Kids is also being introduced while multiple policy settings are in motion across education, early childhood, disability and data governance. It is necessary for the policy and program approach to be integrated and joined up to provide clarity to families and service providers. There is limited information about the potential overlap, synergies, and co-ordination of these efforts across a range of sectors.

The following are noted as co-occurring or occurring close together in time;

  • The Disability Standards for Education (DSE) Review 2025 proposes stronger consultation and continuity of adjustments across transitions, and clarity on

responsibilities for assessment authorities and course developers across schooling and ECEC interfaces (Department of Education, 2025).

e Disability Discrimination Act (DDA) Review 2025 canvasses a positive duty to prevent discrimination and a stand-alone duty to provide adjustments;

e Better & Fairer Schools Agreement (BFSA) 2025-2034 lifts Commonwealth funding contributions tied to equity and workforce reforms;

e The 3 Day Guarantee (from January 2026) will replace the Activity Test and ensures all CCS eligible families can access at least 72 subsidised hours per fortnight of subsidised early education and care; First Nations families will be entitled to 100 subsidised hours per fortnight per child;

e Building Early Education Fund (BEEF-$1B) to build ECEC centres, including in the regions and outer suburbs. This will give more families access to early childhood education and care in areas where they are needed most;

e Early Years Learning Frameworks have been approved and are in place nationally;

e National Quality Framework Child Safety Review has led to nationally consistent child safety and information sharing reforms—both of which shape day-to-day inclusive practice and data handling in services;

e Inclusion Support Program (ISP) has a new national fund manager and updated Guidelines v2.6 (October 2025);

e Preschool Outcomes Measure (POM) is being trialled to track child development progress in the preschool year;

e ACCC childcare inquiry final report and the Productivity Commission ECEC inquiry final report recommend stronger, locally responsive levers for affordability, access and inclusion;

e NDIA adoption of ICAN v6 for the new support needs assessment under the NDIS planning framework (staged from mid-2026).

These initiatives and changes/add-ons to practices are occurring when workforces remain the binding constraints: teacher shortages persist; GP and allied health supply is uneven; and governments have introduced a Worker Retention Payment for ECEC alongside fee growth caps are useful, but not a capacity panacea (Department of Education, 2022; Department of Education, 2025g).

There are, of course, differences by sex assigned at birth and by gender identity People assigned female at birth (AFAB) are, on average, identified later than people assigned male at birth (AMAB) in many studies. International syntheses indicate that observed autism diagnosis ratios are shaped partly by ascertainment and measurement bias: the often-quoted 4:1 “male:female” ratio compresses toward ~3:1 when better case finding is used, suggesting under-identification among people assigned female at birth (AFAB) (Lloomes et al., 2017). AFAB individuals are more likely to mask/camouflage autistic traits and to be diagnosed later, contributing to missed or delayed identification and additional mental-health burden

(Lockwood Estrin et al., 2020; Hull et al., 2019; Milner et al., 2022). Importantly, trans and gender‑diverse (TGD) people report higher rates of autism diagnoses and autistic traits than cisgender peers, underscoring the need for affirming, tailored pathways and staff who understand both neurodiversity and gender diversity (Warrier et al., 2020; Strang et al., 2018). We therefore describe the research using the terms SAAB and by current gender identity, recognising non‑binary identities, and treating observed gaps as signals to improve case‑finding, tools, and access, not as immutable binaries.

Finally, data rights and governance are a precondition for trust. APP Guidelines (OAIC) and UNCRC General Comment 25 (digital environment) establish rights to view, correct, and limit use of children’s data—guardrails that should frame any Thriving Kids data flows across health, ECEC and schools (OAIC, 2022; UNCRC, 2021). Further information can be found in the appendices of this submission.

Assumptions about Thriving Kids on which this submission is based

This submission is based on the publicly shared information provided by the Australian Government regarding the Thriving Kids initiative, as outlined on the Thriving Kids website (Department of Health and Aged Care, 2024). Thriving Kids has been designed as a targeted early intervention program for children aged less than 9 years experiencing “mild to moderate developmental delays or autism”. It is a joint funding arrangement between the Commonwealth and the states and territories, with the federal government committing $2 billion. The initiative is intended to operate across multiple service points, including child and maternal health, general practitioners, playgroups, early childhood education and care, and schools, as well as through digital and phone-based supports. It is also considering introducing new elements, such as: Medicare bulk-billed items for three-year-old child development checks; allied health supports, including occupational therapy and speech pathology; and a nationally consistent online information service for parents.

A further assumption underpinning this submission is that Thriving Kids will place emphasis on embedding services into everyday settings such as early education and care centres, playgroups, and schools, rather than relying on individualised NDIS plans. New Medicare items are also expected to create additional pathways for therapies such as occupational therapy, speech pathology, psychologists, and psychosocial supports, enabling providers to access funding streams beyond the NDIS. The Commonwealth government has also indicated that it will work in partnership with state and territory governments and experts to finalise the design and implementation arrangements for Thriving Kids. Importantly, children already enrolled in the NDIS, or those who enrol before the changes take effect, will remain supported under existing arrangements. These assumptions, as publicly communicated through official government channels, form the foundation of this submission’s analysis and recommendations.

The importance of philosophy and language in conceptualising Thriving Kids

Throughout the response below we do not use the terminology of mild to moderate developmental delays. We caution against such categorisations and language because there is

a risk of a dichotomy between “mild and moderate” and “severe,” as well as re-energising a diagnostic driven response. The policy temptation to stratify supports by a single linear “mild–moderate–severe” continuum or by “functioning labels” is not aligned with current research evidence and risks misallocation of help. Autism, like all developmental conditions, is heterogeneous, with diverse developmental trajectories and high rates of co-occurring conditions. There are also children who are autistic with co-occurring intellectual disabilities, and this submission pays close attention to ensuring their needs and preferences are carefully considered. Needs are best understood as profile- and context-dependent (i.e., the same child may have strengths in one situation and need for support in another and these may change across development). This variability is not well captured by simplistic global.

Terms such as “mild” and “moderate,” which are often taken to mean “high functioning” as compared with “low functioning,” also create significant problems—particularly for the autistic population. We now know that populations who mask heavily, often described as “high functioning,” can also experience a range of co-occurring conditions that are not captured by such labels, including eating disorders and mental health concerns. Additionally, functioning is highly context-dependent, and describing a child in global terms ignores the fluctuating nature of their support needs.

We believe that terms such as “lower support needs” and “more complex support needs” are preferred, but even then, these terms are often applied externally, and these judgements often fail to reflect the reality of peoples’ lived experience. Additionally, peoples’ support needs are not fixed and can change over time and across environments. Therefore, practice should instead focus on supports required in environments, not on reductive categories (Bottema-Beutel et al., 2021). To support this transition, Intellectual disability is not considered a spectrum construct. Instead, it is defined by significant limitations in intellectual functioning and adaptive behaviour, interpreted within environmental demands and supports (Schalock et al., 2021). Rather than relying on fixed categories of diagnosis or “severity”, funding and eligibility should follow needs-based profiles and adaptive functioning in real-world settings.

Recommendation: Ensure that Thriving Kids adheres to the principles, goals and values of the neurodiversity movement.

What we know is that a continuum of supports driven by needs better recognises the domain-specific capabilities of each child, as well as the variability across settings and stages of development.

Additionally, neurodiversity-affirming teaching practices view neurological differences such as autism and ADHD as natural variations, not deficits (Cherewick & Matergia, 2024; Wagland et al., 2025). This perspective represents a shift away from traditional deficit-based models, focusing instead on adapting educational environments to better support diverse learners (Cherewick & Matergia, 2024). These practices involve changes to physical, social, and cultural settings (Jones et al., 2023b), and prioritising student voice, developing inclusive classroom environments, and the removal of social barriers. For autistic students, this might mean incorporating their interests into learning and embracing varied communication styles (Lerner et al., 2023; Wagland et al., 2025). For students with ADHD, it can include strategies that support executive functioning, reduce sensory information and allow movement during learning activities (AADPA, 2022). These approaches are vital for fostering both academic

success and social inclusion. They aim to reduce sensory overload, provide alternative ways for students to show their learning, and create environments where every student feels they belong (AADPA, 2022).

A central principle to a neurodiversity-affirming approach is recognising each student’s individuality and moving beyond stereotypes (Chapman et al., 2020; Kapp, 2013). While diagnostic labels can offer useful insights, the focus remains on supporting the person rather than the label (Harrison et al., 2024). Ultimately, this approach celebrates the unique strengths and challenges of all students, ensuring they are not just accommodated but truly valued.

Responding to Term of Reference 2: Effectiveness of current (and previous) programs and initiatives

High-quality universal programs can enhance outcomes for all children, including those with developmental vulnerabilities, across socio-economic backgrounds. On this front there are some challenges including that there are significant gaps in Australia to identify high-quality research and translate such insights into policies, programs, initiatives and practices. For example, we do not have a culture in our Education Departments to conduct high quality pilot research to inform next steps.

A 2025 review shows that only a small fraction of studies on teaching practices in primary and secondary school settings are conducted locally (Pettersson-Bloom et al, 2025) and most current evidence focuses on specific outcomes for students with ADHD, with less information for Autism and developmental delays. There is a need for more dedicated research on promising directions in existing national and international research for the Australian context and research that addresses fundamental gaps. For example, the under-diagnosis in Aboriginal and Torres Strait Islander communities, as well as access to services for culturally and linguistically diverse children and children living in rural and remote locations. Unfortunately, much of the existing knowledge draws on small (and very small) sample sizes, varied methodologies, has a lack of focus on learning outcomes (as opposed to social and behavioural areas), and the comparison group is often ‘typical students’-not similar “support needs” child samples that did not experience the added support.

Despite limited research being available, it is also imperative that high-quality, culturally safe teaching and learning practices are implemented by ECEC professionals who continually gather and review evidence to support optimal outcomes for the children in their care. High-quality ECEC programs emphasise educator-child interactions that focus on children and their needs, based on a recognition that, “Educators are uniquely positioned to observe children’s development, interactions and behaviour, to identify any issues of concern, and to take action to support all children’s safety and wellbeing.” (Australian Government Department of Education, 2022, p. 44). Staff in high-quality ECEC services also communicate with families and collaborate with other services. In this way, they develop strong, responsive, reciprocal educator-family partnerships (EYLF 2.0 Principle – Partnerships and NQS Quality Standard 6 – Building Partnerships with Families) that build on families’ knowledges and expertise as their children’s first teachers and contribute to a sense of community and belonging, while supporting the different needs of children. Here, early education and school attendance should also be seen as protective factors. That is, High quality early childhood education leads to long term benefits for children. One outcome of this is improved school attendance. Ansari and Gottfried (2018) found that children who attended centre-based care were more likely to

have higher attendance in the early years of schooling. This is an important finding because low attendance rates are associated with many negative outcomes including poorer academic achievement, early school leaving, and poorer health and mental health (Allison et al, 2019).

Australian children would also benefit from a unified education system from birth through to high school that supports the continuity of their learning, with similar reporting requirements, accountabilities, status, pay, and recognition for early years and school teachers. As highlighted by the Productivity Commission (2011) and our recent wellbeing research with early childhood educators (Eadie & Levickis et al., 2021; Eadie et al., 2022; Murray et al., 2022), maintaining high-quality ECEC is strained due to levels of educator burnout and staff turnover. As a result, ECEC’s are at crisis point, compromising the quality of services that are accessible to children and families.

Recommendation: A dedicated research and implementation entity (with a particular focus on education) needs to be established (e.g., ARC Centres of Excellence) to uplift the innovation and quality of evidence, on supports that make the most difference with a focus on different individual trajectories across time.

Various recent reviews have highlighted existing programs that do have a solid and promising evidence base that are ready for upscaling for wider impact. A stronger, nationally consistent funding and policy approach is needed to scale and embed effective programs and interventions within the early years system.

Our expert team would like to draw attention to the following:

  1. The Early Years Education Program highlights the benefits of collaboration among parents, educators, and family support services—educators interact with children for extended periods, offering valuable insights unlike short-term family visits (Jordan & Kennedy, 2019);
  2. The right@home Nurse Home Visiting program provides regular nurse visits to mothers experiencing adversity from pregnancy through age two. This initiative showed modest long-term benefits for children’s mental health, parenting, family relationships, and maternal wellbeing, illustrating how universal interventions tailored to needs can be effective (Goldfeld et al., 2019, 2022);
  3. Supported playgroups and inclusive early childhood education (ECEC) improve early literacy, social skills, and school readiness when delivered with fidelity and appropriate support for staff. Supported playgroups, such as Smalltalk and Peep-Learning Together Program, demonstrate positive impacts when facilitation is delivered by skilled practitioners with established outreach and referral networks (AIFS, n.d.; EEF, 2020; NSW DCJ, 2024);
  4. Integrated child and family centres (ICFCs) as service and social hubs that provide a single location for the delivery of a range of child and family services such as early learning programs, maternal child health services, allied health and family supports;
  5. Connected Beginnings now operates at 50 sites, explicitly braiding health, ECEC, family support and community‑controlled leadership to improve school readiness (Department of Education, 2025i; Department of Health and Aged Care, 2025);

  1. Parenting programs and information, such as the Strengthening parent support program for parents and carers of child 0-18 with a disability or development delay:

  2. The ENVISAGE - Enabling Visions and Growing Expectations — program for those raising children with developmental concerns or disability (aged <9years) is now delivered across Australia, and demonstrates parent/carer increased confidence and competence in managing their child and situation and that they are empowered to make decisions to support their child and family to thrive (Miller et al., 2023);

Aboriginal and Torres Strait Islander children and autism resources including Positive Partnerships resource suite: Autism, Our Kids, Our Stories: Voices of Aboriginal Parents Across Australia; Macquarie University’s report “We Look After Our Own Mob”; and other existing research, e.g Indigenous Australians with Autism: A scoping review (Bailey & Arcuili, 2020).

There is also an evidence-base for early-childhood and primary teaching techniques that can be classified as effective classroom or education setting supports and practices for all children, but which provide for children with more complex learning and support needs. These effective teaching and classroom practices within mainstream classrooms can be classified using the multi-tiered system of support framework across Tier1 (for all children), Tier 2 (for some children) and Tier 3 (for a few specifically identified children).

Tier 1 Strategies

Tier 1 focuses on implementing high quality learning environments for all learners and staff and across all settings (OSEP Technical Assistance Center on Positive Behavioral Interventions and Supports, 2015). This approach shifts from deficit models to environments that cater to diverse needs that enhance learning for all students. Such practices foster academic and social inclusion, and celebrate each student’s uniqueness, moving beyond stereotypes and focusing on individual strengths (Chapman et al., 2020; Kapp, 2013).

One such example is Universal Design for Learning (UDL), a planning framework that focuses on making the curriculum accessible to all learners by examining the barriers that might occur in the delivery of teaching and learning activities before teaching commences. This avoids retrofitting or changing instruction at the point of delivery (Chita-Tegmark et al., 2011) which can impact a teacher’s confidence delivering teaching and learning activities to diverse learners. While UDL was originally developed for learners with disability, meta-analyses suggest it is effective for all learners and has been used in all school settings (Capp, 2017). The UDL framework is organised around three principles, multiple means of engagement, representation, and action and expression. When planning, the following curricular components are also addressed. Goals are examined to ensure they are accessible for all learners. Assessments are developed to ensure all learners are being evaluated on what they know rather than other skills. For example, a science assessment that asks a learner with reading difficulties to read a large block of text and then provide responses, may be testing reading ability rather than the learner’s ability to understand scientific concepts. UDL also advocates the use of a range of materials and methods to address a wide range of learning needs.

Recognising developmental and neurological differences like autism as normal variations on a continuum, where different children have different strengths and support needs, can foster

understanding and positive social interactions (Cherewick & Matergia, 2024; Wagland et al., 2025). It also aligns with a differentiated instruction approach. Differentiated instruction uses goal setting, ongoing assessment and tracking of learner progress relative to goals, to adjust instruction according to learner needs (Hassim et al., 2016). As with UDL approaches, Tomlinson (2017) notes that “differentiating instruction means ‘shaking up’ what goes on in the classroom so that students have multiple options for taking in information, making sense of ideas, and expressing what they learn” (p.1). Learners access different avenues to acquire content, process and make sense of ideas, because teachers have responded to learner differences that may vary across readiness, interest, and learning needs (Tomlinson, 2017). In a differentiated classroom, teachers are proactive in their assessment and planning, which leads to learner-centred instruction that blends whole class, group and individualised learning opportunities according to learners’ needs.

More sustainable positive outcomes are related to approaches that prioritise student agency, wellbeing, and authentic expression, and avoiding compliance or normalisation which can cause harm. There is a need to foster environments where all students feel a sense of belonging (AADPA, 2022). Concrete examples are using the following approaches for all children, not just children with additional support needs: interest-based learning, encouraging learners to assess their progress and adjust strategies, fostering independence and supporting varied communication styles that incorporate visual supports such as using images, symbols, or objects to aid understanding and communication (Lerner et al., 2023; Wagland et al., 2025). There is also evidence that reinforcing desired behaviors through praise, rewards, or recognition can promote positive outcomes that support relationships and engagement in learning.

Children with disability are more likely to be involved in bullying—especially as victims—and this begins early. Meta‑analyses and systematic reviews consistently show elevated prevalence and odds for autistic children and for children with intellectual and other developmental disabilities (Maïano et al., 2016; Park et al., 2020; Abregú‑Crespo et al., 2024). The Royal Commission documents widespread peer and institutional harms (bullying, restraint, seclusion) in Australian education, with clear wellbeing impacts (Royal Commission, 2023, Vol. 7). Early peer victimisation is prospectively linked to internalising symptoms (anxiety/depression), social withdrawal, and school disengagement, including in preschool and the early primary years (Godleski et al., 2014; Schacter et al., 2021). These effects are preventable—and the earlier we act in situ (ECEC and early primary), the better the outcomes.

Key drivers identified across studies include: limited staff capability to scaffold peer interactions; environments not designed for sensory/communication diversity; and weak whole‑setting responses that leave bystanders passive and staff reactive rather than preventive (Chang & Locke, 2016). These drivers are modifiable through whole‑school/ECEC climate, explicit social‑emotional/relationship skills and targeted supports.

Tier 2 and 3 Strategies:

Tier 2 strategies are designed for learners who require additional support, over and above Tier 1 and include more focused, intensive, and frequent small group-oriented responses. Similarly, Tier 3 strategies are individualised even further (McKay-Brown & Tutton, 2023). Both frameworks use screening, progress monitoring, and data-based decision making to allow for movement within the tiered model (Pyle & Vaughn, 2012).

While the general principles of individualised support were well supported, it is crucial to consider the core MTSS tenet of alignment across tiers and flexible movement between them (Burns et al., 2005). The MTSS framework is designed to facilitate skill generalisation and transportation across contexts, supporting students’ progression from more structured environments to less restrictive ones (de Bruin et al., 2023). It is important optimise the transition process, maintaining skills in less structured environments, and ensuring that gains made in intensive tiers are effectively translated and sustained in general classroom settings.

Further consideration of alignment across MTSS tiers is fundamental to effective educational intervention, as all students receive Tier 1 support. This alignment facilitates smoother transitions between support levels, enhances stakeholder communication, and promotes a unified approach to diverse learning needs. Crucially, it requires recognising the importance of allied health professionals’ expertise in supporting students needing Tier 3 interventions while also being served in Tier 1 settings. When professional collaboration is supported, insights and strategies can inform and improve support at all levels, including Tier 1. This cross-tier application of allied health expertise fosters a more inclusive educational setting and can better facilitate the generalisation and transference of skills learned in intensive intervention to the broader classroom environment (Chow, 2023).

Research shows that prompting and modelling in classroom settings enhances engagement, communication, and reduces challenging behaviours among autistic students (Waisman-Nitzan et al., 2022). Being participation focused - rather than deficit focused - in supporting children in their everyday settings (like schools and ECEC) means building capacity in the setting and addressing contextual barriers. This is best achieved in partnership among educators, allied health professionals, students and families (Anaby et al., 2022). Approaches need to be guided by a focus on the interaction between the child/student needs and what is provided within the setting. Newly developed approaches, such as the Kindergarten Inclusion Profile (funded by the Victorian Education Department), provide support for identifying where and how to target supports for children and educators (Kamei et al., 2025).

Recommendation: There is a workforce uplift required as a matter of urgency where educators, specialist teachers, allied health professionals, and other stakeholders have the knowledge, skill and capability and resources aligned with evidence-informed practices to support a positive developmental and learning trajectories for autistic students and those whose neurodiverse profile implicate additional learning needs. A specialised approach is required to craft and lead an inclusive learning environment with varied techniques to support diverse needs. Many currently feel uncertain about how best to support diverse learners. There is evidence that collective efficacy may contribute to creating an environment where educational professionals feel more confident and supported in their ability to meet the diverse needs of students (Donohoo, Hattie & Eells, 2018).

Responding to Term of Reference 5: examples domestic and international policy experience and best practice

Domestic examples of practice for supporting neurodivergent children

Within Australia, there are some examples of practice which demonstrate a commitment to supporting autistic students through structured and embedded localised frameworks. We bring to the fore two practice cases from Western Australia and South Australia which could be looked toward for potential practice models.

Specialised Learning Programs (Western Australia)

The Specialised Learning Programs (SLPs) in Western Australia are autism-specific supports embedded within mainstream public schools, intended to provide individualised, neurodiversity-affirming support for autistic students. The SLPs aim to reduce barriers to learning and engagement, and to foster academic growth, social-emotional development, and holistic wellbeing. Students eligible for these programs typically hold a multidisciplinary diagnosis of autism without co-occurring intellectual disability, and are thought to have the capacity, with support, to perform at or near year level academic standards. When students require support with their social, emotional or behavioural regulation, the SLP offers support in organisational skills, social cognition, peer relationships and self-regulation, and aims to scaffold transition back toward fuller participation in mainstream classes.

Across Western Australia, these programs operate in both primary and secondary schools, with numerous host sites. At these host sites, the SLP operates via dedicated “homeroom” settings staffed by specialist teachers and education assistants, collaborating with mainstream class teachers to deliver individualised programs. Students’ time in the homeroom is tailored: some may spend much of their day there while gradually integrating into mainstream classes in areas of strength, whereas others may only attend for specific lessons such as self-regulation or social skills. The aim is for students to progressively transition into more full participation in mainstream settings, with ongoing supports as needed.

Early Years Support for Educators (South Australia)

The Early Years Support for Educators initiative, delivered in South Australia, is a capacity-building program for early childhood educators, learning support staff, and childcare or preschool settings. Its objective is to collaborate with the team around the child (families, educators and allied professionals) to employ evidence-based strategies supporting autistic children. Key areas of focus include supporting transitions, both between activities and into school, identifying strengths and areas for support, accommodating sensory preferences, facilitating participation in group time, supporting safety skills, nurturing self-care skills, and promoting engagement. To access the program, a child must have a formal autism diagnosis and be registered with Autism SA, after which staff from the child’s early childhood setting may request support from Early Childhood Advisors.

The initiative is available across all education sectors, including childcare, preschools and kindergartens, throughout South Australia. In practice, Early Childhood Advisors work directly with educator teams to embed strategies into everyday routines, support transitions, and scaffold participation and self-regulation for autistic children. By intervening early, the program is intended to strengthen inclusive practices in early years settings and provide a

smoother trajectory into school for autistic children, thereby reducing barriers at the earliest stage of formal education.

Access to high-quality early years services and evidence-informed interventions should be available to all children and families, regardless of income, location or ability. In some jurisdictions, this may require expanding access to government-subsidised programs, such as universal preschool (an objective of the Commonwealths Building Early Education Fund). Current evidence supports the view that universal, proportionate early childhood services can address developmental disparities through targeted approaches to engaging diverse children and families (Moore et al., 2015).

Newly published National Best Practice Framework for Early Childhood Intervention

The just published National Best Practice Framework for Early Childhood Intervention (Moore et al., 2025) was developed as part of Australia’s Disability Strategy 2021 -2031 (Targeted Action Plan 2.4) and was designed to address the needs of ALL children with developmental concerns, delay or disability. The Framework provides an integrated set of evidence-informed principles, practices, resources and tools. Implementation of the Framework by ECI practitioners and others working with children with developmental concerns, delay or disability, is designed to build the capacities of families and communities with the experiences and opportunities children need to develop the functional capacities to meaningfully participate in family, community, and early childhood and school settings.

The Framework describes aims, outcomes, principles, and practices for ECI practitioners and others, including ECEC and other educators, who are involved with young children with developmental concerns, delay or disability and their families. This includes services funded by the NDIS, foundational supports recommended by the NDIS Review – now Thriving Kids – and mainstream services. The Framework is therefore designed to ensure that mainstream services become universal, allowing all children to thrive.

The development of the Framework was informed by up-to-date reviews of the evidence as well as by extensive consultations with ECI practitioners; parents, carers and families; young people; Aboriginal and Torres Strait Islander community-controlled organisations and families; other stakeholders, including Early Childhood Education and Care (ECEC) services, professional practitioner organisations and ECI referrers; and researchers.

The Framework is also consistent, and aligned with other national frameworks and strategies, such as the Early Years Strategy and the Early Years Learning Framework. It updates the ECI research base and expands upon previous best practice advice, providing practical guidance to ECI practitioners, families, policy makers and others. It also fulfils recommendations from the Independent Review of the National Disability Insurance Scheme (NDIS, 2023).

International examples of practice for supporting neurodivergent children within school systems

This section of the submission draws on a desktop literature review and interviews with stakeholders in selected jurisdictions, undertaken as part of a broader research review by the experts at the University of Melbourne. Four international case studies are examined, each highlighting a distinct approach to supporting these learners in school settings. By reviewing available research and professional evidence, the case studies demonstrate how policies,

frameworks and practices can be designed and sustained to strengthen inclusion, wellbeing and learning outcomes. These examples are intended to inform evidence-based strategies that may be adapted to the Australian context to enhance supports for all learners.

Four jurisdiction case studies were selected for closer examination. The selection sought to showcase a diversity of approaches to supporting Autistic students and students with ADHD, while retaining sufficient similarity to the Australian context to maximise the relevance of any lessons learned. Additionally, jurisdictions commended as holding valuable lessons for Australia in testimony provided to the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability (Disability Royal Commission) (2023) were prioritised.

Scotland

Scotland has prioritised student wellbeing through system-wide frameworks such as Getting it Right for Every Child (GIRFEC) and the Curriculum for Excellence. GIRFEC offers a holistic and rights-based model that brings together education, health and social care to support the wellbeing of every child. Complementary programs like the Autism Toolbox, the Edinburgh Psychoeducation Intervention for Children and Young People (EPIC), and the Learning About Neurodiversity at School (LEANS) curriculum provide practical resources for teachers and schools. These initiatives reflect Scotland’s efforts to embed wellbeing and inclusion across the system, although evaluations remain limited.

Interview data within the research review emphasised the strength of the GIRFEC framework, particularly its ‘team around the child’ approach, which ensures professionals, families and the child work collaboratively to develop tailored plans (Interviewee A, Scotland). Stakeholders contrasted this with the fragmented supports in more marketised systems like Australia, where services often operate in silos. This suggests that coordinated structures, as seen in Scotland, provide valuable lessons for developing integrated supports.

The LEANS program was also self-evaluated in four primary schools with promising results, showing increases in positive attitudes towards neurodiversity among students and feasibility in delivery for teachers (Alcorn et al., 2023). However, sustainability challenges were noted by the administers of the program due to time and resource demands, raising questions about long-term implementation. Importantly, however, some English interviewees expressed interest in adopting LEANS, underscoring its perceived potential. The key learning from Scotland is that wellbeing-focused frameworks and neurodiversity-informed curricula can advance inclusion but require significant planning, resourcing and evaluation to sustain impact.

New Brunswick (Canada)

New Brunswick is recognised for its legislated model of inclusion, with Policy 322 mandating that all students, including autistic students and students with ADHD, learn alongside their peers in mainstream classrooms. Frameworks such as Response to Intervention (RTI) and Positive Behaviour Interventions and Supports (PBIS) shape practice across the province. These approaches are supported by training initiatives like the Autism Learning Partnership, which delivers Applied Behaviour Analysis (ABA)-informed training to teachers. While this is promising in terms of research evidence, the Autism Learning Partnership has not yet been rigorously evaluated, and much of the available reporting comes from government sources. We also wish to acknowledge that ABA remains highly controversial for many autistic people, and

there are serious questions around the ethics of using ABA-based behaviour modification interventions.

Evidence from studies suggests positive outcomes from PBIS, including improvements in student behaviour, academic achievement, and reductions in bullying (Kelm et al., 2014; Bocquillon et al., 2025). Educators reported increased safety and understanding of expectations within schools. Interview data highlighted that teachers with specialist backgrounds in behaviour and disability provided crucial expertise in developing support plans for students with complex profiles. This underscores the importance of specialist knowledge even within inclusive frameworks.

Challenges remain in ensuring sufficient allied health capacity to complement educational supports, and research/evaluation gaps limit understanding of long-term impact. Nonetheless, New Brunswick demonstrates how inclusive policy can be enacted across an entire jurisdiction. The case illustrates that legislated rights-based frameworks, coupled with structured approaches like RTI and PBIS, provide a strong foundation for inclusive education, but sustainability depends on teacher capacity, allied health support, and ongoing evaluation (Government of New Brunswick, 2024a).

California (United States)

California offers lessons on local empowerment and community input into inclusive education. Through the Local Control and Accountability Plan (LCAP), districts work with families and educators to shape educational priorities, supported by flexible funding through the Local Control Funding Formula. Interviewees from the research review highlighted the benefits of families having a direct voice in influencing policy and provision, particularly for autistic students and students with ADHD (Interviewee from California). However, eligibility limitations mean that some students with disability may not benefit equally.

California also employs Multi-Tiered Systems of Support (MTSS) and proactive screening, aiming to identify learning needs early. Training initiatives such as the California Autism Professional Training and Information Network (CAPTAIN) and Arraya Learning seek to strengthen professional capacity. CAPTAIN training was shown to increase educators’ knowledge and use of evidence-based practices (Suhrheinrich et al., 2022), while Arraya Learning improved knowledge transfer but lacked evidence of classroom implementation (Sears et al., 2021). This reflects a broader challenge in translating professional learning into consistent practice.

California’s case highlights both the promise and limitations of decentralised approaches. On one hand, local flexibility and family engagement create opportunities for responsive provision. On the other, uneven eligibility criteria and variable implementation across districts create risks of inequity. The key learning from the research review was that family voice, strong professional training, and effective translation of learning into practice are critical for sustainable inclusive education. Further, communities of practice and shared learnings as part of a natural experiment are essential to reap wider benefits and overcome problems.

England

England provides a point of comparison due to similarities with Australia’s policy landscape. Reforms such as the Special Educational Needs and Disabilities (SEND) Code of Practice (2015) for children with additional and complex needs sought to create consistent national

expectations, including the use of Education, Health and Care Plans (EHCPs). These statutory documents aim to place the child/learner needs at the centre with high aspirations, clarify teacher accountability, and provide individualised supports. Research highlights significant delays and variability in access, however, with many families facing barriers in obtaining EHCPs (Starkie, 2023). Despite this, EHCPs can deliver substantial resourcing once approved, offering a mixed picture of benefits and challenges.

Whole-school frameworks in England, including low-variance teaching and behaviour management approaches, also provide consistency but may inadvertently disadvantage autistic students and students with ADHD. Evidence shows that rigid compliance models and ‘zero tolerance’ approaches risk pathologising behaviours that are actually coping mechanisms (Skipp & Hopwood, 2017; Connolly et al., 2023). Conversely, approaches in special schools that focus on interpreting behaviour as communication of needs have been shown to be more supportive. This suggests that while consistency has benefits, inflexibility may compromise inclusion.

To sum, lessons from England underline the importance of aligning policy frameworks with adequate resources, training and collaborative mechanisms. Implementation gaps also remain between policy intent and practice, particularly in ensuring reasonable adjustments are embedded effectively across schools. The experiences within England show that strong policies alone are insufficient without mechanisms to support collaboration, timely implementation, and resourcing. This offers a cautionary lesson for systems such as our own in Australia that are closely aligned in policy direction (DfE & DoH, 2015; Ofsted, 2021).

Recommendations

Six overarching recommendations were drawn from the review of the four jurisdictions.

Recommendation: Robust evaluation research is essential for initiatives aimed at support for children with special educational needs and disability inclusing autism. Currently, there is a noticeable gap in high-quality research and evaluation that specifically focuses on these student groups, both in Australia and internationally (see Recommendation for Research Centre of Excellence above). More targeted studies are needed to identify which factors are positively influencing outcomes for autistic students and students with ADHD. A key takeaway is that evaluation should be embedded into the process of monitoring the impact of policies and guidelines.

Recommendation: Accessible, culturally responsive, and ongoing resources and training should be made available through a centralised platform to support autistic students and those with ADHD, based on evidence-informed research. Interviews conducted across four jurisdictions revealed that non-academics often struggle to access high-quality research. To address this, a regularly updated online platform should be developed to provide current, evidence-based resources for autistic students and students with ADHD, as well as their teachers, professional supports, families, and caregivers. This platform could include frameworks, training opportunities, informational sessions, and support services (Government of Canada, 2024). Research indicates that structured professional development can help reduce educator attrition, support teachers who lack autism-specific pre-service training, and ensure that best practices are widely and consistently shared (Odom et al., 2021). Scotland offers a strong example, where accessible frameworks, training, and support are available to educators, students, and families.

Recommendation: Effective policy must lead to tangible changes in practice. The examples shared above demonstrate that there are important overseas examples which could be used exemplars for practice.

Recommendation: Policies and structural supports must be designed to amplify local community voices and provide caregivers with clear, accessible pathways to contribute to their child’s education priorities. It is essential to establish straightforward mechanisms within the Department of Education, school regions, and individual schools that encourage parent and caregiver involvement and advocacy. This advocacy should reflect an understanding of each child’s unique challenges, strengths, interests, and talents, and aim to shape school strategies that offer programs genuinely engaging for young people. Such an approach supports a collective communication style that values family, relationships, and interpersonal harmony, promoting shared decision-making and meaningful dialogue between schools, students, and families (Berman et al., 2024). California’s LCAP serves as one example of this model, though further research is needed to expand and refine these practices.

Recommendation: Exploring existing frameworks, programs, and policies within Australia offers values opportunities to apply and expand upon international insights. There are notable examples of excellence across the country that can be built upon. For instance, Scotland’s Curriculum for Excellence was partly shaped by Queensland’s New Basics Curriculum, trialled between 2000 and 2004 (Queensland Department of Education, 2001). More recently, South Australia and Western Australia have made significant investments in school-based supports. South Australia introduced targeted initiatives for autistic students through its SA Autism Strategy 2024–2029, while Western Australia adopted a broader approach, focusing on supports for all students with disabilities. These funding commitments reflect a strategic effort to implement new programs and offer valuable lessons for other Australian states and territories.

Recommendation: Effective policy and practice require thorough planning prior to implementation. Although each case study presents a unique focus, they share common insights that underscore the importance of integrating multiple elements, such as wellbeing, targeted support, and system-wide consistency. England, for example, highlights the benefits of whole-school approaches and low-variance teaching, while other jurisdictions demonstrate how wellbeing and rights-based frameworks can shape educational practices. Collectively, these examples show that no single model is sufficient on its own. Instead, drawing from a range of approaches can help create a more balanced and inclusive strategy for supporting autistic students and those with ADHD.

Responding to Term of Reference 6: Identify mechanisms that would allow a seamless transition

Ensuring a seamless transition for children with developmental needs requires systemic change backed by robust research frameworks. Evidence from early childhood science and integrated-care models consistently demonstrates that outcomes improve significantly when the relationships between services are routine, well-resourced, and relational, rather than relying on one-off case conferences (Shonkoff & Fisher, 2013; World Health Organization/UNICEF, 2018). Services need to be stacked on the basis of need to deliver better outcomes but also co-ordinated. Particular consideration needs to be given to children living in rural and remote locations, averting the current circumstance whereby they experience long delays in accessing appropriate assessment, diagnosis and therapy or such service are simply not available in these vicinities (Cumming, 2019) A seamless system requires the establishment of ongoing, collaborative, and trust-based partnerships among families, educators, health professionals, and community sectors, and services that are actually available at the point of need. Applying implementation science ensures effective translation of evidence-informed practices into everyday systems of support.

A critical mechanism is the coordination by key workers who serve as central points of contact across multiple services—Maternal and Child Health (MCH), primary care, allied health, supported playgroups, Early Childhood Education and Care (ECEC), and schools (see NDIS Early Childhood Approach). Research indicates that such coordination reduces fragmentation, improves communication, and ensures continuity of care (Drach-Zahavy & Somech, 2020). For instance, a study by Gilligan et al. (2014) demonstrated that coordinated care models lead to earlier identification of developmental delays and more timely interventions.

Shared Privacy-Safe Workflows

Implementing shared workflows that are privacy-compliant and facilitate the smooth referral, screening, adjustment, and transition processes is essential (see points on data-security above). Funding models must allocate dedicated time for educators and clinicians to develop, implement, and adjust individualised plans (Dickinson et al., 2023). This structural support ensures that service responses are consistent, tailored, and responsive to the child’s evolving needs, reducing delays and miscommunications (WHO/UNICEF, 2018). Evidence suggests that when workflows are streamlined, there is a notable increase in engagement and adherence to intervention plans (Laverack, 2021).

Culturally and Contextually Competent Delivery

Embedding First Nations-led and culturally and linguistically diverse (CALD) competent practices into service design is essential for equity and effectiveness (Shepherd et al., 2021; Woolfenden et al., 2015). This includes training and supervising staff in culturally appropriate assessment tools such as the ASQ-TRAK and employing interpreters and community navigators. Such approaches foster trust and better engagement within communities that have historically experienced systemic inequities. A transformative model proposed by Shepherd et al. (2021) emphasizes that services should be designed from the outset to be culturally safe, rather than retrofitted.

Addressing Gender Bias

The Australian ADHD Guidelines Consumer Guide (AADPA) highlights the importance of gender-sensitive assessment and intervention practices to reduce disparities. Research shows that girls and gender-diverse children are often underdiagnosed or diagnosed later, delaying intervention. Ensuring gender-sensitive pathways is thus vital for equitable support.

Integrated, Strengths-Based Service Networks

From the antenatal period onwards, an integrated network rooted in strengths-based and needs-driven principles would support families holistically. Such networks should facilitate clear pathways and options for families to access multidisciplinary support—early intervention, ECEC, and maternal and child health services— each aligned with a shared vision focused on children’s development and well-being (Goldfeld et al., 2019). Research underscores that inter-sectoral collaboration, rooted in mutual respect and shared goals, leads to better developmental trajectories and family engagement (Shonkoff & Fisher, 2013; WHO/UNICEF, 2018).

An example of a model of practice that has a solid evidence-based and could be adapted for seamless transmission of support is the Buurtzorg’s self-managing neighbourhood teams and regional networks for specialised care developed in The Netherlands. This model adopts an integrated neighbourhood approach focused on nurse care and has the following features:

Structure: Small, self-managing teams of up to 12 nurses, predominantly registered nurses, work within a specific neighbourhood.

Focus: Holistic, person-centred care, building trust, and linking patients to community resources.

Philosophy: “Humanity over bureaucracy,” emphasising patient autonomy and empowerment.

This approach, which is increasingly utilised in health settings, could be adapted to families from birth to 8 years across neo-natal, the first 1000 days (3 years), early childhood setting and primary schools. One idea is that the local public primary school at time of birth (that may or may not become the school of choice for families depending on mobility and other factors) could be the institutional entity that drives support systems in the local area. A school co-located “community hub” could facilitate these supported and in the process becomes a more connected community. Such efforts will created connected schools and grow pre-school and primary school and community belonging. Support is offered in a non-stigmatised and universal setting where most communities do access a primary school.

Recommendation: Incentives are needed for a system of support that links families, educators, health professionals, and community services through ongoing, trust-based partnerships. This involves establishing dedicated coordinators and allied health teams across sectors such as maternal and child health, primary care, early childhood education, and allied health to reduce fragmentation, improve communication, and ensure timely, individualised interventions. Further, this also include partnerships with the Aboriginal and Torres Strait Islander community-controlled health sector.

Conclusions

Thriving Kids represents an important opportunity to create a coherent, needs-based system of foundational supports that complements rather than fragments existing services. To succeed, it must be designed and implemented with deep respect for children, families, and educators, and embedded within the systems that families already use. The evidence reviewed in this submission demonstrates that early intervention is most effective when it is high-quality, culturally safe, and strengths-based, and when it addresses the full range of developmental, educational, and social needs. Building capability in the mainstream workforce, ensuring strong evaluation, and embedding family voice throughout will be critical to avoiding the pitfalls of past reforms.

Families will stay with mainstream settings when supports are visible, reliable and respectful of their knowledge and rights, and when educators have the time and backing to enact inclusion. Thriving Kids can build those conditions if it works with, not around, the systems children and families already use. This requires providing sufficient time, resourcing, and in-reach supports so that teachers and early childhood educators can act with confidence, and families can trust that the commitments made to them will be honoured. Evidence from both

domestic and international practice shows that continuity, trust, and respect are the cornerstones of inclusive systems.

Finally, implementation must be attentive to the broader policy landscape and the realities of service delivery. The initiative enters a crowded space of concurrent reforms across education, disability, and health, and must avoid duplication, fragile market arrangements, and the over-burdening of already stretched workforces. If Thriving Kids is to achieve its vision, it must embed equity, inclusivity, and sustainability at its core, enabling every child to thrive in the communities where they live, learn, and grow. In doing so, it can build a legacy of trust and partnership between families, educators, services, and government that endures well beyond its initial roll-out.

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Appendices

Appendix A: Considerations for Thriving Kids within a Changing Policy Landscape - What Can Be Built for Success

Why the landscape is complex

Thriving Kids is being introduced while multiple policy settings are in motion across education, early childhood, disability and data governance. On the education side, the Disability Standards for Education (DSE) Review 2025 proposes stronger consultation and continuity requirements; the Disability Discrimination Act (DDA) Review 2025 canvasses a positive duty to prevent discrimination and a stand‑alone duty to provide adjustments; and the Better & Fairer Schools Agreement (BFSA) 2025–2034 lifts Commonwealth funding contributions tied to equity and workforce reforms (Department of Education, 2025f; Attorney‑General’s Department, 2025; Council of Australian Governments Education Council, 2025).

In ECEC, from 5 January 2026 the 3‑Day Guarantee ensures all CCS‑eligible families can access at least 72 subsidised hours per fortnight; First Nations families will be entitled to 100 subsidised hours per fortnight per child, regardless of activity‑test hours. These are material inclusion levers if delivery capacity is present (Department of Education, 2025a, 2025b). ECEC pedagogy and quality have also moved: EYLF v2.0 is now in place nationally; and the NQF Child Safety Review has led to nationally consistent child‑safety and information‑sharing reforms—both of which shape day‑to‑day inclusive practice and data handling in services (ACECQA, 2023a, 2023b; Department of Education, 2025d).

Inclusion infrastructure is shifting: the Inclusion Support Program (ISP) has a new national fund manager and updated Guidelines v2.6 (October 2025), and the Preschool Outcomes Measure (POM) is being trialled to track child development progress in the preschool year—both potentially useful if they reuse existing planning evidence rather than generating parallel paperwork (Department of Education, 2025c, 2025e). Place‑based systems are expanding: Connected Beginnings now operates at 50 sites, explicitly braiding health, ECEC, family support and community‑controlled leadership to improve school readiness—an architecture Thriving Kids can build on (Department of Education, 2025i; Department of Health and Aged Care, 2025).

Markets and price signals are under active review: the ACCC childcare inquiry final report and the Productivity Commission ECEC inquiry final report recommend stronger, locally responsive levers for affordability, access and inclusion—critical context for commissioning Thriving Kids supports in thin markets (ACCC, 2024; Productivity Commission, 2024). At the disability interface, NDIS “support lists” and related legislative changes commenced in October 2024; and in September 2025 the NDIA announced adoption of I‑CAN v6 as the starting point for the new support‑needs assessment under the NDIS planning framework (staged from mid‑2026). These choices may affect evidence flows between schools/ECEC and the Scheme as some of the indicators are education based and there may be a need for documentation (NDIA, 2024a, 2024b, 2025).

Workforce remains the binding constraint: teacher shortages persist; GP and allied‑health supply is uneven; and governments have introduced a Worker Retention Payment for ECEC alongside fee‑growth caps—useful, but not a capacity panacea (Department of Education, 2022; Department of Education, 2025g; AMA, 2023). Finally, data rights and governance are a

pre‑condition for trust. APP Guidelines (OAIC) and UNCRC General Comment 25 (digital environment) establish rights to view, correct and limit use of children’s data—guardrails that should frame any Thriving Kids data flows across health, ECEC and schools (OAIC, 2022; UNCRC, 2021).

What Thriving Kids changes, and what it does not

Thriving Kids is conceived as foundational supports delivered where children live, play and learn, maternal and child health (MCH), supported playgroups, ECEC and early primary, without a diagnostic threshold, complementing the NDIS Early Childhood Approach (Department of Social Services, 2024; NDIA, 2023). Yet the NDIS remains the de facto threshold for individually funded packages. When certainty, intensity or out‑of‑pocket exposure differs between community supports (including TK) and NDIS plans, incentive gradients arise, and families are pulled toward the more certain route. This is a system risk flagged repeatedly in the Royal Commission and the literature (RC, 2023; Norwich, 2014).

A family is told inclusive supports will be provided in their child’s community preschool via ISP in‑reach and TK navigation. Local supply is thin; the inclusion agency can visit in eight weeks; the NDIA planner meeting can be earlier and the support lists look definite. The family pursues the route that appears guaranteed—because certainty, not principle, drives timely help (NDIA, 2024a, 2024b).

Considerations for resourcing

Put supports where children already are

Allied‑health in‑reach (speech, OT, psychosocial), inclusion coaching for educators, navigator roles, and time for ECEC/school staff to plan with families convert equity dollars into visible capability. This is consistent with BFSA reform intent and with evidence that visible, in‑setting supports build trust in mainstream inclusion (Council of Australian Governments Education Council, 2025; Graham & Spandagou, 2011; Slee, 2018).

Use ECEC levers to stabilise attendance and continuity

The 3‑Day Guarantee (72 hours/fortnight) and the First Nations 100‑hour entitlement can reduce discontinuity driven by activity‑test volatility—if in‑setting supports and allied‑health in‑reach are available to make those hours useful for inclusion (Department of Education, 2025a, 2025b).

Reduce duplication in evidence

Treat IEP/NCCD (school) and EYLF‑aligned planning (ECEC) as the canonical education evidence set for any adjacent process (TK, ISP, POM, NDIS). Guard against bespoke templates that shift educator time from enactment to paperwork (Diehm, 2017; Department of Education, 2025e).

Align with proposed education duties—and NQF obligations

Assume DSE/DDA reforms may be enacted and build TK workflows around proactive consultation, continuity of adjustments and portable obligations across MCH → playgroup → ECEC → early primary. In ECEC, align with EYLF v2.0 practice principles and the NQF Child

Safety reforms (Department of Education, 2025f; Attorney‑General’s Department, 2025; ACECQA, 2023a; Department of Education, 2025d).

Embed data rights and the right of response

Make privacy‑by‑design real: explicit, revocable consent; minimum‑necessary data; role‑based access; auditable logs; and a right to view and correct records. These guardrails convert data from a mistrust source to an enabler of partnership (OAIC, 2022; UNCRC, 2021).

A preschool’s EYLF assessment notes and inclusion plans, plus the child’s school IEP/NCCD, are accepted as the canonical evidence for TK planning and any ISP top‑up. Because external processes reuse these artefacts, the teacher and educator spend time implementing supports rather than repackaging evidence—and the family can see and contest what is recorded (Department of Education, 2025c; OAIC, 2022).

Equity considerations: rural/regional realities, First Nations leadership, CALD inclusion

Thin markets mean providers follow price and certainty. In regional areas, commission pooled in‑reach, enable telehealth with privacy safeguards, and recognise complexity and travel loadings. Leverage Connected Beginnings as the local backbone and ensure First Nations leadership and trained interpreters are embedded, not retrofitted (Department of Social Services, 2024; Department of Education, 2025i; AMA, 2023).

Practical issues in mixed markets

Mixed price signals (NDIS price limits, Medicare rebates, community contracts) shape provider choices. TK should anticipate provider behaviour and back local partnerships (ECEC/schools, MCH, community‑controlled health) so supports remain in situ—especially where the ACCC and Productivity Commission show markets are fragile (ACCC, 2024; Productivity Commission, 2024).

Protocol changes at the NDIS

Reuse IEP/NCCD/EYLF artefacts and embed right‑of‑response when external systems draw on education evidence (NDIA, 2025; OAIC, 2022).

Workforce remains the binding constraint

Teacher shortages and uneven GP/allied‑health supply limit enactment. ECEC Worker Retention Payments and fee‑growth caps help but will not by themselves produce in‑reach capacity. Where staffing is thin, prioritise in‑reach and shared roles, and purchase time for consultation and adjustment follow‑through (Department of Education, 2022; Department of Education, 2025g; AMA, 2023).

Steps to consider

  • Design oversight to reuse existing education evidence: Adopt a “once‑only” evidence principle: IEP/NCCD and EYLF‑aligned documentation are canonical for TK/ISP/NDIS/POM. Avoid parallel templates. (Department of Education, 2025e).
  • Align TK workflows with DSE/DDA and NQF: Make consultation routine and time‑bounded; make continuity portable via a child‑adjustment passport and pre‑transition handovers; and

nominate an inclusion lead per site/service. (Department of Education, 2025f; Attorney‑General’s Department, 2025; Department of Education, 2025d).

  • Invest in the partnerships that deliver: Fund allied‑health in‑reach, inclusion coaching, navigator roles and teacher/educator release for planning with families, with particular attention to First Nations and CALD contexts and to Connected Beginnings backbones where present (Department of Education, 2025i).
  • Anticipate thin markets and mixed price points: Allow local commissioning flexibility and complexity/travel loadings to sustain provider engagement; enable privacy‑safe telehealth and pooled in‑reach where supply is short (ACCC, 2024; Productivity Commission, 2024).
  • Make data rights real: Operationalise APPs: explicit, revocable consent; role‑based access; auditable logs; family right to correction/erasure; independent oversight—before dashboards (OAIC, 2022; UNCRC, 2021).
  • Monitor NDIS‑as‑threshold dynamics: Watch for diagnostic drift when certainty or price diverges across NDIS and TK; when signals rise, increase in‑setting certainty (capacity, navigation, ISP top‑ups) to keep care close to the child (NDIA, 2024a; RC, 2023).

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