Submission to the Thriving Kids Inquiry
Submitted by
Crystel Poggioli
Director & Clinical Lead, Senior Occupational Therapist
The Whole Child Pty Ltd
Date
03 October 2025
About the Author
I have been an Occupational Therapist for 30 years, working across Education, Community Health, Hospitals, and private practice in both metropolitan and rural settings. Since founding The Whole Child in 2011, I have led a dedicated team providing therapy across the Atherton Tablelands and Far North Queensland, including outreach to remote communities.
Supporting children and families is not only my profession, but my life’s passion and mission. Over the decades I have witnessed what truly helps children thrive, and what wastes time, money, and opportunity. My experience spans multiple funding systems — from Better Start and HCWA through to Medicare, CheckUp, and the NDIS — and I have seen first-hand the difference that well-designed programs can make.
About The Whole Child
The Whole Child Pty Ltd is a rural paediatric occupational therapy practice with a holistic, family-centred, and evidence-informed approach. Our team provides therapy in homes, schools, community settings, and our purpose-built clinic, ensuring children are supported in the environments that matter most to them.
Why This Submission Matters
This submission reflects the voices of children, families, and therapists in rural and regional Australia. It offers genuine, on-the-ground insight into what has worked, what has not, and how Thriving Kids can be designed to deliver life-changing outcomes while using taxpayer investment wisely and sustainably.
Contents
1.0 Introduction
2.0 Lessons From the Past
- 2.1 Working Within Different Settings
- 2.1.1 Education Settings
- 2.1.2 Community Health and Hospital Settings
- 2.1.3 Private Practice Setting
- 2.1.4 Delivering Services in Schools as a Private Provider
- 2.2 Working Within Different Funding Systems
- 2.2.1 Lessons from Better Start and Helping Children with Autism (HCWA)
- 2.2.2 Lessons from the NDIS
- 2.2.3 Lessons from Blanket Government Funding Systems
- 2.2.4 Funding Provided to Third Parties 3.0 Access to Services
4.0 Funding Administration Models
5.0 Equity and Intersectionality
6.0 Workforce Support and Training
7.0 Best Practice Principles
8.0 Seamless Transitions Through Mainstream Systems
9.0 Provider Registration and Compliance
10.0 Reporting and Documentation
11.0 Adequate Funding Promotes Excellence in Service
12.0 Summary of Key Lessons
13.0 Recommendations for Thriving Kids
- 13.1 Service Settings
- 13.2 Access to Services
- 13.3 Provider Regulation
- 13.4 Reporting and Documentation
- 13.5 Funding
- 13.6 Workforce and Collaboration 14.0 Conclusion
1.0 Introduction
For the past 30 years I have devoted my professional life to supporting children and families. I have worked with children in the following settings:
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Education Queensland (Cairns, Cooktown to Cardwell region, Atherton Tablelands region)
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Community Health (Atherton Tablelands and Monto/Munduberra Region)
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Queensland Health (Royal Children’s Hospital, Atherton Hospital, Mareeba Hospital)
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Overseas (Vancouver School Districts)
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Private practice (Founder and Director of The Whole Child, est. 2011), Atherton Tablelands and Far North Queensland (including remote outreach work).
Over these decades I have seen what helps children thrive, what wastes money and effort, and what risks driving skilled people out of the workforce. I have worked with the following funding systems:
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Within government organisations (Health and Education in government funded positions)
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CAETI funding
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Better Start and Helping Children with Autism (HCWA) funding
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DVA funding
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MASS Equipment funding
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CheckUp funding (subsidizing services for children and families of Aboriginal and
Torres Strait Islander backgrounds)
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Medicare funding (subsidizing private clients, or bulk-billed when clients are also accessing CheckUp funding)
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Privately funded appointments (with or without rebates)
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NDIS funding I am deeply passionate about ensuring that government investment translates into real, life changing outcomes for children and families. The proposed Thriving Kids program is an important opportunity. I want to offer genuine, on-the-ground feedback from decades of direct experience so that this new system does not repeat the mistakes of the past, but takes the opportunity to transform lives of children with a positive flow-on effect to communities, and reduced long term need for support in their later years.
This submission addresses the Terms of Reference by drawing on evidence from past and current programs and identifying equity and workforce challenges. It also outlines best practice principles and mechanisms for seamless engagement with mainstream services and smooth transitions for children with developmental needs.
2.0 Lessons From the Past
2.1 Working Within Different Settings
Across my 30 years in practice, I have worked within Education systems, Hospitals, Community Health, and now private practice. Each setting has its strengths and challenges. It is important to recognise the differences because Thriving Kids must build on what has worked well, while also addressing the systemic barriers that have limited outcomes for children in the past.
2.1.1 Education Settings
When I worked in government funded positions within Education systems, therapists were committed and caring, but the structures of the system meant we were often very disconnected from families. Our role was mostly to observe and support children in classrooms and to provide advice to teachers about how to best accommodate and support their needs.
This approach made it difficult to create meaningful change for the child because the work was not integrated with what was happening at home. When issues such as dressing difficulties or sleep disruption affected learning/daily routines, there was little scope to address them within an education role. Yet these issues might have a significant impact on a child’s behaviour and presentation at school.
As well, teachers frequently requested that we provide one-on-one direct therapy intervention with a child, but we weren’t able to do this in a fashion that led to meaningful progress towards goals. Our direct intervention primarily focused on splinting, equipment prescription and toileting routines in the school setting. These services are essential and should not be removed, but outcomes were limited by the scope of the role.
2.1.2 Community Health and Hospital Settings
In positions directly funded within Community Health/Hospital systems the model was highly medical and assessment-driven. Families often experienced long waits for appointments, followed by in-depth assessments and reports, frequently for consideration in paediatrician appointments. Practical, ongoing therapy and the establishment of a therapeutic relationship, both essential for meaningful outcomes, were rarely possible. The emphasis was on clinical documentation and following protocols rather than tailoring therapy to real-life needs.
Families would often plead for strategies and support, yet what they received was another assessment. Unsurprisingly, very few families saw the progress they were hoping for, and the child’s developmental trajectory was rarely shifted in a significant way. These services remain essential, as they are often how a family first gains understanding and, at times, diagnosis regarding their child’s needs. They are not, however, a setting designed for intensive, goal-focused therapeutic progress.
2.1.3 Private Practice Setting
In private practice, my team and I are continuously focused on delivering real outcomes, and this is attached directly to funding. Our team know that when we are doing billable work we are directly helping children, so time is used very efficiently.
We also occupy a unique position of being seen as neutral by families, education, and health systems, which allows us to rebuild collaboration when relationships break down.
For example, we recently worked with a child in Kindergarten experiencing significant developmental challenges that led to escalating aggression and a breakdown in communication between staff and parents. Within three sessions, by acting as a neutral facilitator and supporting both the adults and the child, aggression ceased, and communication between staff and parents became open and positive again. The child is also now making positive gains in their play skills and peer relationships.
Private practice also offers flexibility to provide services for children in the setting that will be of best benefit for their needs, which may be at home, school, in the community, or in our clinic. This means we can adapt therapy environments to create safety and the right level of challenge.
One boy we supported had significant toileting issues. At age 10, he was still passing bowel motions in a nappy for four hours each afternoon, terrified of toilets due to past trauma. The school had no idea of his struggles as he held on during the day, refusing to use toilets at school. Because we could see him across settings, we gradually built confidence in multiple environments. After two years of steady, flexible support, he became fully independent with toileting and no longer requires therapy services or continence aids.
These kinds of transformations are only possible in a setting that offers flexibility, continuity, and deep collaboration with families.
2.1.4 Delivering Services in Schools as a Private Provider
Since the introduction of the NDIS, it has become increasingly difficult for private providers to deliver therapy in schools. Local State and non-government schools have added layers of paperwork and compliance that go far beyond what teaching staff themselves require, such as up-to-date CPR, First Aid, and Anaphylaxis certifications for all therapy staff, with access denied even if one certificate is a single day out of date.
Many schools have moved to outright bans on therapists entering, or they insist that all therapy occurs outside of school hours at the clinic. This is unrealistic for families and counterproductive for children, as it prevents therapy from being embedded in the child’s everyday learning environment. Teachers frequently tell us they want support, yet systemic attitudes and red tape block collaboration.
For Thriving Kids to succeed, there must be a mechanism for meaningful collaboration between therapists and schools, with streamlined, reasonable processes that support access rather than restrict it. This includes recognition that allied health professionals already meet strict requirements related to their registration and associated Codes of Conduct.
2.2 Working Within Different Funding Systems
2.2.1 Lessons from Better Start and Helping Children with Autism (HCWA)
The Better Start and Helping Children with Autism programs provided important learning for how access and funding models can shape outcomes.
What worked well was the flexibility given to families in how they used their funding. Claiming processes were relatively simple, and because rates were market-driven rather than capped, families could secure services that met their needs flexibly. Reports were required only for specific purposes such as diagnostic clarification or school transition, which kept the focus on supporting decision making rather than generating unnecessary paperwork.
However, there were also challenges. Linking access to a diagnosis created pressure for diagnostic decisions to be made, sometimes sooner than was helpful, because families knew that services could only be accessed once a diagnosis was in place.
Children with complex needs who required input from multiple disciplines often exhausted their funding quickly, leaving them without sufficient support.
Allowing funding for everyday household items, such as trampolines, iPads, or swing sets, diluted the pool of resources available for therapy.
Another difficulty was the requirement for families to sign approval for every session, which added a burden to parents and slowed down service delivery, particularly when therapy occurred in community settings.
These experiences highlight that flexibility, simplicity, and purposeful reporting can deliver good outcomes, but diagnostic pressure, limited funding caps, and inefficient claiming processes can undermine the intent of a program.
2.2.2 Lessons from the NDIS
The NDIS has been transformative for many children and families. For those who were able to access early and intensive therapy, the results have often been life-changing. In my own practice, I have seen children who began with significant challenges grow to a point where they no longer require any support in adulthood. This is the strongest argument for investing well in children: the long-term costs to the system are reduced when their needs are addressed early.
The NDIS also acknowledged that therapy involves much more than the hour in the room. Funding for non-face-to-face time such as treatment planning, liaising with schools and families, preparing resources, and attending team meetings has been essential.
Similarly, recognising the impact of cancellations and allowing them to be billed has enabled practices like mine to provide secure employment, and remain viable and solvent while serving children with complex needs.
However, the system has also placed enormous strain on providers and families. From the beginning it has been highly bureaucratic and costly to administer. NDIS staff themselves often struggle to interpret the detailed rules, leading to inconsistent decisions that are frequently overturned at tribunal.
Report requirements are excessive, often running to twenty or more pages, and they require a deficit focus that undermines person-centred, strength-based practice. Clinicians learn to use particular language, such as “essential” instead of “recommended,” otherwise supports won’t be seen as necessary, which distorts professional judgement.
This culture has demoralised many in the allied health workforce. Experienced clinicians report feeling undervalued, and many have left the sector entirely. At the same time, schools have introduced additional barriers for external therapists, with layers of paperwork and, in some cases, outright bans on therapy delivered in school hours.
Another challenge has been misunderstanding of costs. The NDIS rate of $193.99 per hour is perceived as high, yet our 2024–25 business costings show that it costs $245 per hour for a junior OT and $265 per hour for a senior OT to deliver a session. The recent OT Australia National survey confirms that more than half of OT practices were not profitable last financial year, with many closing their doors.
Recent cuts to travel funding have overlooked a fundamental reality: when therapists provide outreach in homes, schools, or community settings, they are able to see fewer children in a day than when all sessions occur in clinic. With business finances already extremely tight, these cuts have made it impossible to continue delivering outreach services to rural and remote communities that previously relied on NDIS support. The result is a significant loss of access for First Nations families and other vulnerable families who cannot reasonably travel to a clinic, leaving those who need support most at greatest risk of missing out.
The lessons from the NDIS are clear. Early, flexible, and intensive support changes lives and reduces lifetime costs, but excessive bureaucracy, over-reporting, and under-funding undermine both families and providers, with greatest impacts on First Nations, rural and remote communities.
2.1.3 Lessons from Blanket Government Funding Systems
Another model I have worked within is blanket government funding provided directly to health or education departments. These systems have provided important services for families, particularly in terms of assessment and access to initial diagnoses. However, when funding is absorbed into large departmental budgets rather than being linked to individual services, there is little incentive to maximise caseloads or efficiency. Families often wait long periods for appointments, and even when they are seen, the service delivered can be limited to assessments or brief consultations without the follow-through required for real progress.
From my direct experience, these models rarely resulted in significant breakthroughs for children. Dedicated staff worked hard, but the structural constraints of the system meant
that therapy was often fragmented and slow, with families frequently left feeling unsupported. Importantly, the lack of direct accountability for service hours delivered reduced the focus on outcomes.
These lessons show that while government-delivered services have an essential role, blanket funding to large systems should not be the primary mechanism for delivering therapy under Thriving Kids. Linking funding directly to services provided ensures accountability, efficiency, and a stronger focus on outcomes for children and families.
2.1.4 Funding Provided to Third Parties
In some cases, I have provided services through private practice where the funding was channelled via a third party that received government funds to purchase services. Examples include Kindergartens, the Department of Child Safety, and the previous CheckUp funding model, which at times purchased a full day of our services. This arrangement can work very well, as it creates opportunities for collaboration and ensures that children are supported in settings they already attend.
However, it is important that this is not the only model of funding. Families who do not easily engage with these third parties may fall through the gaps and miss out on timely support. To be effective, Thriving Kids must ensure that third party funding complements, rather than replaces, direct pathways for families to access services.
3.0 Access to Services
Over the past three decades I have seen various models for how children and families gain access to therapy. Each approach carries significant consequences, not just for families, but also for clinicians and the system as a whole.
When access is linked directly to diagnosis, it can create pressure for diagnoses to occur, sometimes in subtle and unintentional ways. For example, when parent-informed assessments are completed, parents may unconsciously frame their responses with the knowledge that the outcome will determine their child’s access to support. Similarly, clinicians may feel tension when they know a family desperately needs help and that only a particular diagnosis will open the door to services. While this does not apply to all children, it is a real and important issue to acknowledge.
One of the strengths of the NDIS is that access for young children has not been tied to a diagnosis. If a child showed delays in two or more areas of development, they could receive support. This was a very positive model. Often it is the provision of support, rather than a diagnostic label, that changes a child’s trajectory. Diagnosis is most useful when it deepens understanding of a child’s needs and guides their support, but in many cases timely intervention is what truly makes the difference.
For the identification of developmental delays, our practice often uses the Ages and Stages Questionnaire (ASQ). This tool can be administered by a range of health professionals and is
straightforward for families to engage with. Importantly, it involves activities completed directly with the child, so it does not rely solely on parent or caregiver report. A version has also been adapted specifically for First Nations families, which supports more culturally appropriate screening. The ASQ is particularly helpful in distinguishing between delays that may resolve naturally and those that require more detailed assessment and intervention. Its main limitation is that it only covers children up to 5.5 years of age, rather than extending to 9 years.
Another important factor is the way families perceive the cost of services. In government funded systems, families often assume therapy is “free.” In reality, these services are expensive and are funded by taxpayers. When families access services through funding packages such as CAETI, Better Start, Helping Children with Autism, or the NDIS, there is greater transparency about the value of what they are receiving. Families who can see the cost of services often demonstrate stronger appreciation and commitment, which contributes to better engagement and outcomes.
4.0 Funding Administration Models
The way funding is administered has a direct impact on access and sustainability. Under the NDIS, families can have funding that is NDIA-managed, self-managed, or plan-managed. This structure was intended to give participants choice, but in practice it has created complexity and frustration for providers.
In our practice, we initially became a NDIS registered provider to serve NDIA-managed clients. However, with only five clients in this category and annual registration costs exceeding $5000, it was not financially viable to maintain registration.
Self-managed clients often create the greatest administrative burden. Payments are frequently delayed, and at times families overspend their budgets, leaving invoices unpaid. It is common for our small practice to carry around 5% of our turnover in outstanding invoices each month, with significant administrative time spent chasing payments.
Plan-managed clients provide the most workable model for small providers. Payments are processed in a timely way, and families still retain flexibility and oversight.
By comparison, previous/other funding systems such as CheckUp, CAETI, Better Start, HCWA, and Medicare also worked well because claiming processes and registration requirements were straightforward, allowing providers to claim directly through simple portals.
Thriving Kids should ensure that funding administration is streamlined, low-cost, and reliable. Families deserve genuine choice, but providers need systems that are workable and sustainable if they are to remain viable and deliver services consistently.
5.0 Equity and Intersectionality
Thriving Kids must be designed to achieve equitable access and outcomes for children who identify as First Nations and for children and families from culturally and linguistically diverse backgrounds, as well as for those living in rural and remote communities.
Practical steps include partnering with Aboriginal Community organisations, resourcing culturally safe services, providing interpreters and translated materials, and ensuring flexible service delivery that respects community priorities, cultural obligations and family routines.
Travel and outreach should be funded so that children in rural and remote areas are not disadvantaged.
Collaboration with trusted local services increases engagement and helps families who may not connect easily with large systems or third parties.
6.0 Workforce Support and Training
Children receive the best outcomes when a stable, skilled workforce is supported to do its work well. Thriving Kids should fund supervision, mentoring and graduate support, and provide practical training in early identification, trauma informed care, autism and developmental practice, family centred coaching and transdisciplinary teamwork.
Reducing unnecessary administration, streamlining registration, and funding non-face-to face-work are essential for retention.
Rural incentives, supported placements and scholarships will help sustain services in regional and remote communities where private practitioners often form the backbone of paediatric care.
Collaborating with allied health professionals in the design and function of Thriving Kids would also help restore confidence in the sector. At present, many therapists are questioning whether they can remain in this work, as they often feel devalued and unsupported despite the critical contribution they make. Unless this issue is addressed, the program risks losing the very workforce it depends on. Thriving Kids will only succeed if the expertise and dedication of therapists are recognised, respected, and supported, so that a stable and skilled workforce can continue delivering life-changing outcomes for children and families.
7.0 Best Practice Principles
Domestic and international best practice consistently highlights early identification, family centred practice, intervention in natural settings, and transdisciplinary teamwork that builds capacity around the child and family. Families also need coordination of care, but in practice
this works best when the clinician most closely involved with the child, often the occupational therapist or another allied health professional, takes the lead role in guiding and supporting parents. External “key worker” or “navigator” models have been trialled, but without close involvement in therapy they can sometimes add layers without real impact. A model that strengthens parents and equips them to carry strategies into daily life is more effective.
Therapy intensity should match need, with clear goals, simple outcome measures, and regular review points. Reporting should be brief and purposeful, and collaboration with mainstream services should be routine and funded. These principles are reflected across the recommendations in this submission.
8.0 Seamless Transitions Through Mainstream Systems
Families need a smooth pathway through maternal and child health, primary care, allied health, early childhood education and care, and schools or other learning settings (including supports for the growing homeschooling community).
Thriving Kids should promote shared plans that can follow the child across settings only with family consent. Coordination works best when led by the clinician who knows the child well, often in partnership with parents, rather than through an external “navigator” role that risks adding bureaucracy without meaningful impact. Families themselves are usually the best constant across services, and they should be supported and respected as the key decision makers.
Practical mechanisms include a simple national template for shared goals and strategies (owned by families and shared at their discretion), a clear consent framework for exchanging essential information, funded time for collaboration between services, and straightforward processes that welcome therapists into education settings so support can be embedded where the child learns.
9.0 Provider Registration and Compliance
Strong safeguards matter. Families deserve safe, ethical, high-quality services, and most providers already meet rigorous obligations through AHPRA or discipline specific bodies, professional codes of conduct, clinical governance, and insurance. When additional registration layers simply duplicate what already exists, they add cost without improving safety. That cost is ultimately carried by families and by the public.
In practice, the NDIS registration framework has often been complex and difficult to interpret. Rules and guidance are long and detailed, and interpretations vary. This creates uncertainty for families, inconsistent decisions for participants, and significant administrative load for providers.
By contrast, systems such as CAETI, Better Start, Helping Children with Autism, and CheckUp applied proportionate, workable registration that recognised existing regulation of allied health professionals.
Fraud must be addressed, however, current methods to investigate fraud within the NDIS are more costly than the fraud itself. Targeted, intelligence led compliance is the right response. Placing heavy, blanket requirements on the vast majority of ethical providers increases costs and reduces access without improving quality.
10.0 Reporting and Documentation
Reporting should be fit for purpose, respectful, and focused on decisions that need to be made. Under several past programmes (Better Start and HCWA), reports were completed for defined reasons such as diagnostic clarification, school transition, or to communicate strategies. That approach kept the focus on outcomes and limited unnecessary paperwork.
In the current environment, reporting has often become lengthy and deficit focused. Very long documents do not reflect best practice or the values of person-centred care. They consume significant clinician time, increase costs for families, and can unintentionally shape practice toward proving need rather than building capacity. Unspoken language rules also create pressure to frame support as essential rather than recommended, which undermines clinical judgement and does not serve families well.
There is also a human impact. Families report feeling demoralised when they must repeatedly emphasise difficulties in order to access help. Clinicians experience high administrative load that competes with direct therapy and collaboration time. A more balanced approach would preserve safeguards while keeping the therapeutic focus on goals, progress, and next steps.
It is usually cheaper and more humane to provide timely supports than to spend months debating eligibility. Families do not seek therapy they do not need. When systems trust professionals, keep paperwork purposeful, and focus on outcomes, the investment reaches children faster and yields better results.
11.0 Adequate Funding Promotes Excellence in Service
The level of funding provided is one of the most important determinants of whether services are accessible, sustainable, and high quality. Well-designed funding promotes excellence, whereas inadequate funding quickly undermines both providers and families.
Linking funding directly to services, as was done under the NDIS, Better Start, and HCWA, has been far more effective than allocating blanket budgets to government bodies. When funding is linked to individual services, there is incentive for providers to maintain full caseloads, deliver efficiently, and focus on outcomes. In contrast, when funding is absorbed
into general service budgets, inefficiencies are more likely and families often wait longer without seeing meaningful change.
To sustain services, funding must also reflect the real costs of delivery. In the 2024–2025 financial year, the cost of providing one hour of therapy by a junior Occupational Therapist in my practice is $245. For a senior Occupational Therapist, the cost is $265 per hour. These figures include the true cost of wages, supervision, administration, travel, preparation, professional development, insurances, therapy supplies, rent and compliance. Despite this, the current NDIS hourly rate is below cost.
OT Australia’s recent surveys confirm that more than half of occupational therapy practices were not profitable in the last financial year, and numerous clinics around the country have already closed. When businesses are not viable, families lose access, particularly in rural and regional areas where private providers form the backbone of service delivery.
Adequate funding also means recognising the full scope of what it takes to support a child well. This includes travel to where the child is, non-face-to-face time for preparation, collaboration, and documentation, and compensation for cancellations, which are common in complex paediatric caseloads. If these essential elements are not funded, the cost burden falls back onto families or providers, both of whom are already under significant pressure.
12.0 Summary of Key Lessons
The evidence from past systems and three decades of direct practice experience is clear. Thriving Kids must not repeat the mistakes of the past, but instead take the opportunity to create a model that genuinely changes the lives of children and families.
To succeed, the program must avoid excessive bureaucracy, under-resourced mainstream models, and the undervaluing of private practitioners who have demonstrated outcomes. It must ensure fair and timely access pathways that are not overly tied to diagnosis. It must apply regulation that is proportionate, rather than duplicating requirements that already exist. It must keep reporting purposeful and respectful, rather than lengthy and deficit focused. Most importantly, it must fund services at a level that reflects the real costs of delivery, including travel, non-face-to-face work, and cancellations, and is adjusted to reflect CPI increases, so that providers remain viable and families do not lose access to essential services.
When these foundations are in place, Thriving Kids will be able to deliver on its promise. It will allow recommendations to be implemented in a way that is sustainable for families, providers, and government alike.
13.0 Recommendations for Thriving Kids
Drawing on lessons from past systems, my direct experience across education, health, and private practice, and the needs of families in rural and regional communities, I recommend the following:
13.1 Service Settings
Thriving Kids must ensure flexibility in where services are provided. Children benefit when therapy can take place in homes, schools, early childhood centres, community settings, and clinics. Services should be designed to meet the child where they are, not force them into rigid models of care.
Thriving Kids should also make it easier for therapists to access community and education settings by removing unnecessary barriers. Therapists must be able to collaborate with teachers and health staff in real time, in the environments where children live and learn.
Recommendations:
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Ensure flexibility in therapy locations, including home, community, schools, and private practice clinics.
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Support therapists to access community and education settings without excessive barriers.
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Foster genuine connections between therapists, families, schools, and health services, recognising the value of private practitioners in bridging these systems.
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Prioritise models of care that are relational, collaborative, and focused on real-life outcomes rather than unnecessary paperwork.
13.2 Access to Services
Access must be based on children’s needs, not on rigid diagnostic thresholds. Early intervention for developmental delays prevents long-term disability, whereas diagnosis linked funding creates pressure for labels and distorts decision-making.
Recommendations:
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Retain and strengthen access pathways for children with developmental delays, without requiring a diagnosis.
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Avoid funding models that tie services exclusively to diagnostic categories.
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Ensure families understand the real value of services by maintaining transparent, individualised funding models.
13.3 Provider Regulation
Families deserve safe and ethical services, but providers are already accountable through AHPRA and discipline-specific professional bodies. Overlapping regulation adds cost without improving quality.
Recommendations:
- Recognise and rely on existing professional regulation wherever possible, avoiding duplication.
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Provide a simple, nationally consistent registration portal and clear guidance that is easy to follow.
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Apply proportionate, risk-based oversight that focuses attention where risk is higher.
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Offer a single source of contact for rules and decisions, and an accessible help channel that gives consistent answers.
13.4 Reporting and Documentation
Reporting must be purposeful, respectful, and fit for purpose. Long deficit-focused reports are harmful, expensive, and demoralising for both families and clinicians.
Recommendations:
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Require reports only where they bring benefit to the child or family, such as diagnostic clarification, school transitions, or communication of strategies.
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Accept clinician recommendations of necessity for common supports, with audits applied by exception.
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Use short, validated outcome measures alongside a succinct progress summary.
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Set defined review points, rather than requiring frequent re-justification when needs are stable.
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Fund non-face-to-face time required to coordinate care and complete essential documentation.
13.5 Funding
Adequate funding is the foundation of effective services. Underfunded services are unsustainable, and when clinics close, families lose access. When children don’t receive essential therapy support in their early years they require higher levels of support in education and community settings in the short and long term.
Funding must reflect the real cost of service delivery, including preparation, collaboration, and cancellations, and must keep pace with CPI.
Recommendations:
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Link funding directly to services delivered, rather than blanket allocations to government bodies.
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Index funding to CPI so that it keeps pace with rising costs.
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Recognise and fund travel, non-face-to-face time, and cancellations as legitimate and essential components of therapy.
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Ensure pricing reflects the real cost of service provision, informed by transparent business costings and workforce data.
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Protect and strengthen the viability of private providers, especially in rural and regional areas, where they are often the only source of skilled paediatric therapy.
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Avoid poor use of funds on everyday household items, instead prioritising therapies and supports that directly build children’s functional capacity.
13.6 Workforce and Collaboration
The Thriving Kids program will only succeed if the workforce is retained, supported, and respected. Private practitioners form the backbone of paediatric services, especially in rural and regional areas. Sustaining their work requires valuing their expertise and enabling collaboration with mainstream services.
Recommendations:
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Trust professionals by respecting qualifications and clinical judgment, and avoid creating “magic word” requirements in reports.
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Support collaboration between allied health providers, schools, GPs, and families by funding time for team meetings and communication.
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Build bridges, not silos, so that all parts of a child’s support network can work together toward shared goals.
14.0 Conclusion
The Thriving Kids program is a rare opportunity to reshape how we support children with developmental needs. If designed well, it can reduce long-term costs, retain a skilled workforce, and most importantly, change the lives of children and families for the better.
I urge you to learn from what has and has not worked. Take the best elements of past systems, avoid their pitfalls, and trust those of us who have been walking alongside children and families for decades.
I would welcome the opportunity to contribute further to the design and consultation process.
I recommend that consultation be undertaken not only with peak bodies such as OT Australia, but also with experienced practitioners who work daily with children and families across diverse settings. Those of us delivering services on the ground hold valuable insights into what truly makes a difference. I am committed to working collaboratively to ensure Thriving Kids is built on strong foundations and delivers the outcomes children deserve.
Yours sincerely,