Submission 321 — Mrs Kereth Harris — Inquiry into the Thriving Kids initiative

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Submission to the inquiry into the thriving kids program Executive summary

This submission provides a critical analysis of the proposed Thriving Kids initiative, highlighting significant concerns regarding its design, implementation, and potential impact on children with autism and developmental delay. Drawing on over 30 years of

professional and lived expertise, the author outlines seven key areas of concern:

1. Terminology and Eligibility: The use of non-clinical terms such as “mild to moderate autism” lacks diagnostic validity and risks excluding children with complex needs and a lifelong disability.

2. Workforce Capacity: Mainstream systems such as schools, early childhood settings, and primary care are already overstretched and lack the specialised training required to deliver high-quality neuro-developmental support.

3. Systemic Expertise Gaps: Teachers, general practitioners (GPs), and general allied health professionals receive minimal training in developmental conditions, leading to mis or under-diagnosis and missed intervention opportunities.

4. Equity and Access: Culturally and linguistically diverse (CALD), First Nations, and rural families face compounded barriers in accessing culturally safe and accessible services, and the program risks replicating the exclusions already seen under the NDIS.

5. Advocacy and Safeguards: The absence of embedded advocacy mechanisms and transparent appeals processes leaves families even more vulnerable to systemic failure.

6. Misalignment with Early Childhood Frameworks: The proposed model contradicts Australia’s national early childhood standards, which emphasise individualised, strengths-based, and culturally responsive support.

7. Parent Burden: The shift to mainstream-delivered foundational supports places increased advocacy demands on parents, particularly those already navigating

multiple layers of disadvantage.

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The submission calls for a pause in implementation until robust co-design processes, workforce development strategies, and equity safeguards are in place. Without these, Thriving Kids risks becoming another top-down initiative that fails to meet the needs of the very children and families it aims to support.

Introduction

I welcome the opportunity to contribute to the House of Representatives Standing Committee on Health, Aged Care and Disability’s inquiry into the proposed Thriving Kids initiative. The Committee Chair, Dr Mike Freelander MP acknowledged that foundational supports are critical in shaping the developmental trajectories of children with developmental delay and autism, however, while the intent to co-design a responsive and equitable system is commendable, I hold significant concerns about the current direction of the Thriving Kids proposal and the potential for autistic children to lose the very necessary and individualised supports they currently have with the NDIS. These concerns include the lack of clarity around program outcomes and target populations, the risk of further burdening already overstretched services, and the limited expertise within mainstream systems such as schools and Medicare-funded providers to meet the complex needs of this cohort. Parents, particularly those without cultural capital already face immense challenges navigating fragmented support systems. Without robust advocacy mechanisms and culturally safe, community-led design, Thriving Kids risks replicating the same inequities experienced under the NDIS, especially for First Nations and CALD families. This submission outlines these concerns in detail, drawing on research, policy analysis, and lived experience.

Background

Kereth Harris is a clinical developmental educator and autism specialist with over 30

years’ experience supporting neurodivergent children and their families. As an allied health professional, she specialises in evidence informed therapy, developmental and behavioural assessments, and collaborative, family-centred support across home, school, and community settings.

Kereth is the founder of Dovetail Therapy and Support, a practice dedicated to helping

families navigate complex systems and build inclusive, strengths-based pathways for their children. Her work is grounded in a neuro-affirming approach that honours each child’s identity, communication style, and sensory profile.

Currently completing a Doctorate in Education focused on parental involvement in the Individual Education Plan (IEP) process, Kereth also holds postgraduate qualifications in autism, mental health, and education. Drawing on both professional expertise and lived experience as a parent of two neurodivergent children, she is known for her perceptive, compassionate, and empowering approach to therapy and advocacy.

Key concerns and evidence based critique

1. Lack of clarity in program outcomes and target group The Thriving Kids initiative, as outlined in the Terms of Reference, aims to establish a national system of foundational supports for children aged 0–8 with “mild to moderate” developmental delay or autism. This terminology however, is not supported by the DSM-5-TR, which classifies autism based on levels of support required across two domains, social communication and restricted/repetitive behaviours, and not by severity labels such as “mild” or “moderate” (American Psychiatric Association, 2013). Whitehouse, Trembath, and Varcin (2025) note, “mild to moderate autism” is not a recognised diagnosis in contemporary clinical practice and risks conflating autism with developmental delay, which are distinct but sometimes overlapping conditions. This imprecise language creates confusion about eligibility and risks excluding children whose needs do not fit neatly into these undefined categories.

Autism is a lifelong neuro-developmental disability, often accompanied by co-occurring conditions such as ADHD, anxiety, sensory processing differences, and motor coordination challenges. These complexities require individualised, multidisciplinary support that cannot be adequately addressed through generalised or standardised service models. The Thriving Kids initiative, as currently proposed, lacks the scope and depth to meet these needs and must not be positioned as a replacement for the National Disability Insurance Scheme (NDIS).

While the program aspires to deliver a stepped-care model through mainstream services, there is no published implementation framework detailing how supports will be delivered, how outcomes will be measured, or how transitions between Thriving Kids and the NDIS will be managed. This lack of clarity raises serious concerns about whether children with neuro-developmental conditions will retain access to the NDIS. It is essential that Thriving Kids seeks to complement, not replaces the NDIS, and that children with autism and

developmental delay continue to be eligible for individualised funding and support under the scheme.

Crucially, the design and language of the program appear to have been developed without meaningful consultation with the neurodivergent community or their families. This

stands in direct contradiction to the disability rights principle of “Nothing About Us

Without Us”, which asserts that policies affecting disabled people must be co-designed

with them. Without clear definitions, measurable goals, and authentic co-design processes, Thriving Kids risks becoming another top-down initiative that fails to meet the needs of the very children and families it seeks to support (Whitehouse et al., 2025).

2. Existing services are already overstretched Even with access to the NDIS, families face long waitlists and limited availability of qualified providers. The Thriving Kids initiative proposes to shift responsibility for foundational supports to mainstream systems such as schools, early childhood education, and primary care, without a clear plan to address the severe workforce shortages already impacting these sectors. This raises serious concerns about the program’s feasibility, sustainability, and its potential to erode access to the specialised supports currently available through the NDIS.

Australia is currently experiencing a national teacher shortage, with the federal

government forecasting a shortfall of over 4,100 teachers by 2025 (Dao et al., 2024). Early childhood education is similarly under strain, with the Early Childhood Education and Care Workforce Capacity Study identifying critical shortages in qualified educators across all service types, particularly in rural and remote areas (Jobs and Skills Australia, 2024). These shortages are compounded by high attrition rates, casualisation, and limited career pathways, which undermine workforce stability and service quality (Nolan, Robertson, & Bussey, 2025).

The health sector is also in crisis, with Health Workforce Australia projecting a shortfall

of over 100,000 nurses by 2025 and significant gaps in general practice, allied health, and paediatrics (Botha, Tayal, & Bismark, 2024). The disability sector faces entrenched workforce issues, including high turnover, underqualified staff, and a lack of behaviour support practitioners to meet complex needs (National Disability Services, 2024). These shortages are not just logistical, they directly impact the quality, consistency, and accessibility of care for children with autism and developmental delays.

Without a comprehensive workforce strategy, Thriving Kids risks placing additional pressure on already fragile systems. The program’s Terms of Reference acknowledge the need to “identify gaps in workforce support and training,” but no implementation plan has been released to show how these gaps will be addressed. In the absence of significant investment in workforce development, training, and retention, the program may further dilute service quality and widen inequities in access.

Critically, the NDIS was established to provide individualised, needs-based support for people with disability—including children with autism and developmental delays, through a multidisciplinary model that mainstream systems are not equipped to replicate. Shifting foundational supports to generalised services without first strengthening those systems risks undermining the very purpose of the NDIS. Thriving Kids must not become a cost saving mechanism that redirects children away from the NDIS into under-resourced environments. Instead, it should serve as a complementary layer of support, with clear

protections to ensure that children who meet current NDIS eligibility continue to receive

the specialised care they require.

Australia has previously implemented targeted early intervention programs such as the Helping Children with Autism (HCWA) package and the Early Childhood Early Intervention (ECEI) approach under the NDIS. The HCWA package, introduced in 2008, provided up to $12,000 in funding for early intervention services for children under seven diagnosed with autism. Evaluations found that while the package improved access to early intervention and was generally well-received by families, significant disparities remained—particularly for CALD, First Nations, and regional families who faced barriers to registration and service access (ARTD Consultants, 2012; Department of Social Services, 2020). The ECEI approach under the NDIS aimed to streamline early supports through a family-centred, best-practice model. While grounded in strong evidence, implementation challenges, including workforce shortages, service fragmentation, and limited navigation support have hindered its effectiveness, especially for vulnerable families (NDIA, 2016; SDN, 2023; MCRI, 2022). These lessons must inform the design of Thriving Kids, ensuring that foundational supports do not replicate past inequities or dilute the quality of care.

3. Schools and Medicare services lack expertise in autism and developmental delay Mainstream services—including schools, early childhood settings, and Medicare-funded health providers—are not currently equipped with the training or expertise required to

deliver high-quality, evidence-based interventions for children with developmental delay or autism. Research consistently shows that general practitioners, educators, and allied health professionals in mainstream settings receive minimal training in neurodevelopmental conditions. For example, a survey of clinicians found that 93.9% had received fewer than five hours of training in supporting individuals with intellectual or developmental disabilities (Ross & Bhatia, 2023). Similarly, Escudé (2024) highlights that most medical schools do not include mandatory curricula on how to identify or communicate with patients with intellectual or developmental disabilities, leading to diagnostic overshadowing and missed early intervention opportunities.

In education, the situation is equally concerning. A national review found that

mainstream teachers often lack the training to identify and support students with

developmental differences, and that professional development in inclusive education is

inconsistent and underfunded (Gormley et al., 2020; Lynch, 2018). The PRECI

Foundational Supports Discussion Paper (2024) warns that moving children out of the

NDIS and into mainstream systems without first building workforce capacity risks diluting

the quality of supports and undermining developmental outcomes.

My work as a therapist with expertise in autism and an extensive background in education as a teacher, leader, and advisor has consistently found that schools are ill equipped to identify and appropriately support this at-risk cohort of children and young people. An increasing number of children with a neurodevelopmental diagnosis, such as autism, experience ‘school can’t’, and Heimans et al. (2024) suggest that such experiences may reflect systemic challenges within the structure of schooling itself, rather than being solely attributed to the child or their family.

The Thriving Kids initiative proposes a rapid shift to foundational supports delivered

through these same mainstream systems, yet there is no published plan for how the

necessary workforce development will occur in time to ensure continuity and quality of care. Without a coordinated national training strategy, this transition risks replacing specialised, multidisciplinary early intervention with fragmented, under-resourced services that lack the expertise to meet children’s needs.

Autistic children require tailored, evidence-informed supports that reflect their individual profiles, co-occurring conditions, and developmental trajectories. These supports must be delivered by trained professionals within a system that is accountable to families. The

NDIS remains the only national mechanism capable of delivering this level of individualised care. Thriving Kids cannot and must not replace the NDIS for children with autism. Instead, it must be designed to complement existing entitlements, with clear protections to ensure that children who meet NDIS eligibility continue to receive the specialised supports they need to thrive.

The Helping Children with Autism (HCWA) package and the Early Childhood Early Intervention (ECEI) approach under the NDIS were two major national initiatives aimed at supporting young autistic children. While HCWA improved access to early intervention services, evaluations highlighted persistent inequities in uptake and outcomes for CALD, First Nations, and rural families (Department of Social Services, 2020). The ECEI model, grounded in best-practice principles, aimed to deliver family-centred, goal-based supports through mainstream systems. However, implementation challenges—particularly workforce shortages and inconsistent service quality—limited its effectiveness for children with complex or evolving needs (NDIA, 2016).

Autism CRC’s National Guideline for Supporting Autistic Children (2023) synthesises the highest-quality evidence on early intervention and outlines 84 consensus-based recommendations for practitioners, policymakers, and families. The Guideline emphasises that effective supports must be individualised, developmentally appropriate, culturally responsive, and co-designed with families. It rejects one-size-fits-all models and stresses that foundational supports must not replace access to individualised funding through the NDIS for children with lifelong disability and complex support needs (Autism CRC, 2023).

These lessons must inform the design of Thriving Kids. Without safeguards, the program risks replicating past inequities and diluting the quality of care. Foundational supports should complement and not replace the NDIS, and must be delivered within a system that is accountable, inclusive, and responsive to the diverse needs of autistic children and their families.

4. Increased complexity for parents navigating support systems The proposed shift adds another layer of complexity to an already fragmented system. Families accessing the Thriving Kids program will, by definition, be parenting a child with a disability. Yet for many, disability is not the only axis of marginalisation. Families who also experience racism, classism, ableism, or other systemic barriers, such as those from culturally and linguistically diverse (CALD) backgrounds, First Nations communities,

single-parent households, or those with disabilities themselves face compounded discrimination that affects every step of the support journey (Burke, Li, & Rossetti, 2018; Sanderson, 2023).

Accessing Thriving Kids will rely on referrals from mainstream services such as GPs, maternal and child health nurses, early childhood educators, and community health providers (Department of Health, 2025). This, however assumes that families are already engaged with these systems and that those systems are functioning equitably. CALD families often face language barriers, cultural stigma, and limited access to culturally safe and appropriate services, resulting in lower rates of early intervention and NDIS uptake (Settlement Services International [SSI], 2025; Woolfenden et al., 2015). First Nations families have long called for co-designed, community-led models that respect cultural decision-making and avoid one-size-fits-all solutions (First Peoples Disability Network [FPDN], 2023).

These calls have led to promising commitments. The NDIA’s First Nations Strategy 2025– 2030 outlines plans for culturally safe services, power-sharing governance, and alternative commissioning in remote communities (NDIA, 2025). The Disability Royal Commission made 13 recommendations to improve outcomes for First Nations people with disability, including the creation of a First Nations Disability Forum and cultural safety standards (Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability, 2023). The Autism CRC’s (2024) report further reinforces the need for targeted support for rural, First Nations, and CALD autistic children, highlighting that intersectional and culturally responsive care is essential to improving health and mental health outcomes.

The success of Thriving Kids hinges on workforce availability and system readiness, both of which are currently lacking. Remote and regional areas face critical shortages of allied health professionals, educators, and support workers, with up to 78% of providers reporting difficulty recruiting staff (RotaWiz, 2024; National Disability Services [NDS], 2024). Without targeted investment in workforce development and culturally safe service models, families in these areas may be excluded from foundational supports altogether.

Critically, the NDIS has already acknowledged its failure to meet the needs of First Nations and CALD families, describing the lack of culturally appropriate services as a “national crisis” (Royal Commission, 2023; NDIS Review, 2023). Introducing a new program such as Thriving Kids assumes that governments will “get it right” this time,

despite unresolved systemic issues. Rather than layering new systems over broken ones, there is a strong argument for repairing and reforming the NDIS to better serve

marginalised children, while ensuring that children with autism retain access to the

scheme. Thriving Kids must not become a gatekeeping mechanism that redirects

children away from the NDIS into generalised supports that lack the depth, flexibility, and accountability required to meet their needs. For families already navigating multiple layers of disadvantage, losing access to the NDIS would represent a profound setback in their child’s developmental journey.

6. Limited access to advocacy services and the need for stronger parental advocacy Parents currently have minimal access to independent advocacy when services fail. The proposed changes under the Thriving Kids program do not include clear mechanisms for dispute resolution or advocacy support, leaving families vulnerable to systemic failure. This is particularly concerning given that Thriving Kids will not operate as an entitlement based scheme like the NDIS, but rather as a capped, generalised support program delivered through mainstream services such as schools, GPs, and community health (VALID, 2025; Department of Health, 2025).

Unlike the NDIS, which provides individualised funding based on functional needs and participant goals, Thriving Kids will offer standardised supports through existing systems.

This raises critical questions: Who will determine what a child receives? Will it

resemble the U.S. model under the Individuals with Disabilities Education Act (IDEA), where schools, through a team process determine supports via an Individualised

Education Program (IEP)? Under IDEA, schools are legally required to provide a Free

Appropriate Public Education (FAPE), but they also hold significant power in deciding

what constitutes “appropriate,” often leading to disputes between families and education systems (U.S. Department of Education, 2025).

If Thriving Kids adopts a similar model without robust safeguards, Australian families may find themselves with even less control over the types of supports their child receives. The 2023 NDIS Review acknowledged that families need better access to navigation and advocacy supports, especially during transitions and when navigating foundational systems (NDIS Review, 2023). No formal appeal process has been outlined for Thriving

Kids. Without a clear pathway for review or escalation, families may be left without recourse if their child’s needs are misunderstood, minimised, or unmet.

As one parent expressed: “We fight so hard as families with autistic kids [but] he [Minister Butler] doesn’t seem to have any idea. It shows a lack of understanding for the autism community” (as cited in Leach, 2025). This experience reflects a broader pattern of systemic exhaustion and disempowerment among families who must repeatedly advocate for basic supports.

In this new model, parents will need to become even stronger advocates, not only to

access services but to ensure those services are appropriate, timely, and culturally safe. This shift places a significant burden on families, particularly those already navigating multiple layers of disadvantage. Without embedded advocacy, transparent decision making, and a robust appeals process, Thriving Kids risks replicating the very inequities it aims to solve.

Misalignment with Early Childhood Developmental Standards

The Thriving Kids model risks undermining key principles embedded in Australia’s

national early childhood frameworks. Both the Early Years Learning Framework (EYLF)

and the Early Years Strategy Outcomes Framework emphasise individualised,

culturally responsive, and strengths-based approaches to early childhood development.

The EYLF promotes individualised, strengths-based support that recognises each child

as a capable learner with unique abilities, interests, and cultural identities (DEEWR, 2009).

Outcome 4 of the EYLF specifically highlights the importance of cultural competence,

encouraging educators to support children in developing confidence, curiosity, and a strong sense of identity through inclusive and responsive learning environments. Similarly,

the Early Years Strategy 2024–2034 outlines a national commitment to empowered

families and connected communities (Outcomes 7 and 8), and calls for services that

are inclusive, strengths-based, and responsive to children’s diverse needs (DSS,

2024).

These frameworks are grounded in decades of research showing that tailored,

relationship-based support leads to better developmental outcomes, particularly for

children experiencing disadvantage. In contrast, the proposed block-funded, one-size

fits-all approach under Thriving Kids risks diluting these standards. Without mechanisms

for individualised planning, cultural responsiveness, or family-led decision-making, the model may reduce the quality and effectiveness of support for children with neuro developmental conditions.

This is especially concerning for autistic children, whose developmental profiles, co occurring conditions, and support needs vary widely and evolve over time. The NDIS was designed to provide flexible, individualised funding that reflects these complexities and enables families to access multidisciplinary supports tailored to their child’s goals. Thriving Kids cannot replicate this level of personalisation or accountability. If implemented without safeguards, it risks becoming a substitute for the NDIS,particularly for children who are deemed “not severe enough” or with seemingly ‘mild’ or ‘moderate’ autism under vague eligibility criteria.

Rather than aligning with existing developmental frameworks, Thriving Kids appears to prioritise administrative efficiency over developmental integrity. This misalignment could have long-term consequences for children’s learning, wellbeing, and inclusion— particularly those who rely on nuanced, individualised support to thrive. It is essential that autistic children retain access to the NDIS, and that any foundational support model is designed to complement, not replace, the entitlements and protections the NDIS provides.

In light of the concerns outlined in this submission, I urge the Committee to:

1. Pause implementation of the Thriving Kids initiative until a comprehensive co- design process is undertaken with neurodivergent families, First Nations communities, and CALD stakeholders.

2. Guarantee continued access to the NDIS for all children with autism and developmental delay, recognising autism as a lifelong disability with complex and

evolving support needs. Foundational supports must be designed to

complement,not replace NDIS entitlements, and must never be used to divert

children into generalised, capped service models.

3. Develop a national workforce strategy that includes mandatory neuro- developmental training for educators, health professionals, and early childhood staff, with targeted investment in rural and remote areas.

4. Embed culturally safe, community-led service models from the outset, ensuring that foundational supports are responsive to the needs of First Nations, CALD, and trauma-affected families.

5. Establish independent advocacy and dispute resolution mechanisms to protect families navigating foundational supports, with clear pathways for review and escalation.

6. Align the program with existing early childhood frameworks, ensuring individualised, strengths-based, and inclusive support for all children, and avoiding one-size-fits-all approaches that dilute developmental integrity.

Without these safeguards, Thriving Kids risks replicating the systemic failures of previous initiatives and further entrenching inequity. The NDIS must remain a cornerstone of support for autistic children, and any new model must uphold their right to individualised, multidisciplinary care. The opportunity to build a truly inclusive, responsive, and effective foundational support system must not be lost.

I would welcome the opportunity to discuss my submission with you.

Kind regards

Kereth Harris

Developmental Educator (Registration 955) EdD candidate MAutNd, BEd(Sec), BA(Ed), GradCertChild&AdolHlth p: w: dovetailtherapy.au

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