October 2nd, 2025
Dr Mike Freelander
Chair, House Standing Committee on Health, Aged Care and Disability
Parliament of Australia
RE: Submission to the Parliamentary Inquiry into the Thriving Kids Initiative
Dear Dr Freelander,
I write as a General Paediatrician practising across both regional and metropolitan settings, and in both public and private sectors. I hold a PhD in Cognitive Neuroscience and specialise in child development, working daily with families navigating the medical and social support systems available for children with developmental delay and disability. My roles afford me direct insight into the strengths and limitations of the current frameworks, including the National Disability Insurance Scheme (NDIS).
I welcome and commend the Federal Minister for Health, Disability and Ageing’s announcement of the Thriving Kids initiative. Its’ emergence reflects, in part, the recognition that the NDIS is not well-suited for a significant proportion of children with developmental concerns. In designing Thriving Kids, it is imperative that we learn from the evidential shortcomings of the NDIS and ensure that design errors are not replicated. We must avoid digging ourselves a second “bottomless money pit” alongside the first.
In the spirit of contributing constructively to this important Inquiry, I offer seven recommendations for consideration. These relate principally to Terms of Reference (1), (2), and (5).
Recommendations
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Avoid Service Allocation By Severity Stratification.
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Consider Alternative Models of Service Allocation, Such As Allocating A Baseline Package Of Support Per Functional Deficit.
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Where Clinically Appropriate, Utilise Resource-Efficient Group Based Interventions Rather Than Inefficient And Less Effective Solo Interventions.
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Avoid Expanding Teachers’ Roles Into Allied Health Domains.
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Consider The Role Of Thriving Kids In Conjunction With Existing Support Programs Including NDIS and Helping Children With Autism (HCWA).
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Ensure Comprehensive Cross-Sector Consultation Across all relevant sectors including Health, Allied Health, Disability, Education and Early Learning.
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Stage Implementation Of Thriving Kids, Commencing With A Pilot ‘Beta’ Phase.
The rationale for every Recommendation is discussed below.
The recommendations are made in consideration of achieving the goals of:
i) resource-efficient, evidence-informed interventions; ii) minimal administrative burden on clinicians and families; iii) transparent and sustainable funding mechanisms
I thank the Committee for its consideration of these recommendations and for its commitment to improving developmental and disability outcomes for Australian children. I would welcome the opportunity to provide further input, should the Committee deem it helpful.
Yours sincerely,
Dr James Carter MBBS, BA (Hons), PhD, FRACP
General Paediatrician
West Gippsland Healthcare Group
Recommendation 1: Avoid Service Allocation by ‘Severity’ Stratification
It is strongly recommended that the Thriving Kids program avoid allocating services based on severity stratification. Evidence from the implementation of the National Disability Insurance Scheme (NDIS) demonstrates that attempts to categorise children into diagnostic or severity tiers often redirects limited clinical and administrative resources into complex assessment processes, at the expense of timely and meaningful service delivery.
Despite its intention to focus on function over diagnosis, the NDIS has become highly reliant on both diagnostic labelling and subjective severity ratings—neither of which reliably reflect functional need. This has contributed to inequitable access and inefficient allocation of funds. It has also placed considerable administrative burdens on clinicians, families, and the system at large.
Moreover, Thriving Kids appears to be targeting a narrow cohort of children with “mild” to “moderate” developmental concerns. Introducing an additional stratification framework within this already limited group risks replicating the very inefficiencies the program seeks to address. Such a model may also unintentionally incentivise the inflation of functional assessments to access higher service levels, regardless of any attempt at standardisation.
There is a clear opportunity to learn from the structural flaws of both the NDIS and the Medicare-funded Helping Children With Autism (HCWA) package. If service allocation continues to rely on diagnostic or severity-based thresholds, Thriving Kids may merely repeat the same mistakes.
Recommendation 2: Consider Allocating a Baseline Package of Support per Functional Deficit
The Inquiry may wish to consider that a more effective and equitable model may involve allocating a standard baseline package of support based on the child’s identified functional deficits, rather than a subjective assessment of severity.
This model would align resources with need, streamline access, and reduce administrative load. It would also refocus clinicians’ efforts on identifying practical, observable deficits—such as social communication challenges, school refusal, or language delay—rather than assigning children to ill-defined severity bands.
Examples of this approach might include:
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Social Communication Difficulties: Provision of a group-based social activity program over a set number of weeks.
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School Refusal: Enrolment in a short-term, structured program such as Victoria’s In 2 School, supplemented with a limited number of psychological support sessions.
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Specific Learning Difficulties: Targeted school-based intervention programs in addition to parent coaching.
- Language Delay: A set number of assessment sessions followed by evidence-informed intervention, contingent on the outcome of the initial assessment.
This model addresses functional needs directly and removes the burden of severity stratification from clinicians and families. It is also likely to reduce inequities arising from differences in parental advocacy or service navigation skills.
Determining appropriate session numbers per functional deficit would require appropriate cross-sector consultation. Children deemed to be in need of additional services would still be eligible to apply for NDIS funding and their eligibility assessed appropriately.
This approach would represent a more practical, transparent, and sustainable basis for service allocation than severity rating models, for which no robust evidence base exists.
Recommendation 3: Utilise Resource-Efficient Group-Based Interventions Where Clinically Appropriate
Where the evidence supports it, the Thriving Kids program ought to encourage the use of resource efficient group-based interventions for functional challenges that are known to likely to respond well to such approaches.
Group therapy models - particularly those addressing social communication and school refusal - offer cost-effective and scalable solutions without compromising clinical outcomes. In fact, group services are likely to be superior for many such issues.
For example, the In 2 School program delivered through Travancore (Royal Children’s Hospital, Victoria) provides an evidence-informed model for managing school refusal. Similarly, participation in school or community-based group activities may be more effective and appropriate for some children than one-on-one clinical intervention.
Embedding group therapy models into Thriving Kids could substantially improve service access, reduce costs, and expand the reach of qualified professionals.
Recommendation 4: Avoid Expanding Teachers’ Roles into Allied Health Domains
While educators play a critical role in supporting children with developmental challenges, it is important that Thriving Kids not shift responsibilities traditionally held by allied health professionals onto teachers.
Teachers are already under significant workload pressure. Expecting them to deliver targeted therapeutic interventions risks diluting educational outcomes and placing children at further disadvantage. The program should prioritise appropriate referrals and supports within the education system, while clearly delineating clinical responsibilities.
Recommendation 5: Consider The Role of Thriving Kids in Conjuntion with Existing Support Programs Including NDIS and Helping Children With Autism
Although Medicare funding sits outside the direct scope of this Inquiry, a formal recommendation for interdepartmental review would support better coordination between Thriving Kids, the NDIS, and Medicare-funded initiatives.
The introduction of Thriving Kids presents an opportunity to review existing Commonwealth programs, particularly the Medicare-funded Helping Children With Autism (HCWA) package.
Given that Thriving Kids aims to deliver more targeted, efficient, and equitable services to children with developmental needs, it is appropriate to examine whether the HCWA package remains fit for purpose, or whether reforms—such as consolidation, reallocation, or redesign—would better align public funding with contemporary clinical and policy objectives.
Recommendation 6: Ensure Comprehensive Cross-Sector Consultation
To avoid the fragmented implementation that undermined the early years of the NDIS, Thriving Kids must be developed through structured and meaningful consultation across all relevant sectors—Health, Allied Health, Disability, Education, Early Learning, and Government.
Children’s developmental needs do not sit neatly within one portfolio. Ensuring coordinated service design and delivery across sectors is essential to the program’s success. The experience of the NDIS, where limited cross-sector engagement led to access failures and unintended consequences, must not be repeated.
Recommendation 7: Commence with a Pilot (‘Beta’ Phase)
Given the scale and ambition of the Thriving Kids initiative, it is recommended that the program begin with a carefully scoped pilot or ‘beta’ implementation phase.
This approach would allow for identification and remediation of early design flaws, enable meaningful evaluation of effectiveness, and allow for iterative refinement through stakeholder feedback. A phased approach would better position Thriving Kids for long-term sustainability and success.
Summary:
The goals of Thriving Kids ought to include:
- Resource-efficient, evidence-informed interventions;
- Minimal administrative burden on clinicians and families;
- Transparent and sustainable funding mechanisms.
With appropriate design and sector-wide collaboration, the program can offer timely, equitable, and effective support for the children and families who will benefit from the program.
The experiences of the NDIS and Helping Children With Autism provide ample evidence of what has not worked. Thriving Kids should avoid repeating those mistakes. It is my hope that the recommendations above will be of assistance in achieving such appropriate design.
I thank the Committee for its consideration of these recommendations and for its commitment to improving developmental and disability outcomes for Australian children.