Occupational Therapy Society for Invisible Disability

CONSULTATION ON THE THRIVING KIDS INQUIRY

September 2025

Contents

Executive Summary 3
Recommendations 4
About OTSi 4
Amplifying Community Voices 5
Response to Terms of Reference 5

o 5.1 Evidence-based information and resources for families

o 5.2 Effectiveness of current programs and initiatives

o 5.3 Equity and intersectional issues (First Nations and CaLD children)

o 5.4 Workforce support and training gaps

o 5.5 Domestic and international best practice

o 5.6 Seamless transitions through mainstream systems

Conclusion 8
Appendix 1: Focused Functional Interventions 8

1. Executive Summary

The Occupational Therapy Society for Invisible and Hidden Disabilities (OTSi) welcomes the opportunity to contribute to the Thriving Kids Inquiry, initiated by the Department of Health, Disability and Aged Care in August 2025.

We acknowledge the Government’s intention to strengthen foundational supports for children with developmental delay and autism. However, we strongly caution against reforms that risk undermining children’s access to therapy and other individualised supports under the NDIS before mainstream systems are prepared and adequately funded to meet need.

Evidence from the September 2025 Every Australian Counts national survey highlights widespread concern. Over 1,000 respondents — families, carers, people with disability, and professionals — reported fears of reduced access to therapies (80%), loss of choice and control (75%), and unclear government communication (70%). Only 18% supported Thriving Kids in its current form. Families warned of children regressing or “falling through the cracks,” while providers highlighted risks to workforce sustainability, particularly in rural and regional areas.

OTSi emphasises that early childhood supports must be ethical, trauma-informed, neurodiversity-affirming, culturally respectful, and rights-based — and available at the right time, in the right place, for every child. Any reform must be co-designed, grounded in human rights, and aligned with existing frameworks such as the National Autism Strategy.

2. Recommendations

Based on OTSi’s expertise and the voices of families and professionals nationwide, we recommend that:

OTSi recommends the establishment of a new, no-gap Medicare item, to ensure children with developmental delay and autism who cannot access the NDIS, can access evidence based therapeutic support from the allied health professional most suited to their needs, including occupational therapy – the right professional, at the right time, at the right place.
Protect children’s rights to individualised supports under the NDIS until foundational supports are fully funded, independently evaluated, and demonstrated to meet need.
Legislate safeguards for genuine co-design with children, families, and people with disability, consistent with CRPD Article 4.3 and the National Autism Strategy.
Build on, not duplicate, the National Autism Strategy, aligning Thriving Kids with existing commitments to strengthen pre/post-diagnosis supports, workforce development, and culturally safe practices.
One size does not fit all - Protect families’ ability to choose the supports and providers that best fit their child’s needs.

Adopt neurodiversity-affirming, strengths-based practice, rejecting outdated or behavioural compliance models that risk harm.
Invest in equity through community-led, culturally safe supports designed in partnership with Aboriginal and Torres Strait Islander and CaLD communities.
Strengthen and sustain the allied health workforce, including small and independent OT practices, through fair commissioning, incentives for rural/regional practice, and funded mentoring and supervision.
Guarantee seamless transitions across early childhood, education, and health systems, ensuring children are never left without support due to eligibility cliffs or jurisdictional gaps.
Recognise children as an investment, not a burden, funding early individualised supports that improve long-term outcomes and reduce downstream costs.

3. About OTSi

OTSi is a national society enabling occupational therapists who work alongside people with invisible and hidden disabilities to reduce barriers to full participation as active citizens. We focus on ensuring access to resources, opportunities, and supports for people with invisible disabilities across the lifespan. OTSi has a strong voice in systemic advocacy, policy reform, and practical implementation, bringing real-world expertise in functional capacity and support needs assessment.

4. Amplifying Community Voices

Community perspectives are critical to shaping reform. The September 2025 Every Australian Counts survey revealed deep anxiety about Thriving Kids. Families described fear that their children would regress without therapies, while carers highlighted the mental health toll of uncertainty. Providers warned that block funding could destabilise small, local services — the backbone of community support.

Key messages from the survey include:

Supports must remain individualised and flexible.
Choice and control are fundamental disability rights.

Reforms must be co-designed with lived experience at the centre.
Language matters: deficit-based labels such as “mild/moderate” are dated and harmful.
Families are calling for transparency, fairness, and continuity of support.

5. Response to Terms of Reference

5.1 Evidence-based information and resources for families

Families require accessible, plain-language, strengths-based resources that validate children’s differences and avoid deficit framing.
Co-designed resources, informed by autistic adults and people with disability, ensure accuracy, affirmation, and cultural safety.
Parents need balanced information about available supports, delivered in multiple formats and languages, and accessible for families with psychosocial or invisible disabilities.
Developmental screening should be routine in early childhood health checks, with pathways to early intervention that do not depend solely on diagnosis.
Families need clarity on their rights in mainstream and education settings, alongside timely access to allied health services supporting executive function, sensory regulation, and everyday participation.
OTSi cautions against intensive interventions focused on compliance and normalisation, which risk harm.

5.2 Effectiveness of current programs and initiatives

OTSi recommends the establishment of a new, no-gap Medicare item, to ensure children with developmental delay and autism who cannot access the NDIS, can access evidence based therapeutic support from the allied health professional most suited to their needs – the right professional, at the right time, at the right place.
Generic programs such as playgroups or parenting workshops often exclude children with additional needs without adequate training in neurodiversity or trauma-informed care.
Allied health input and escalation pathways are essential for children with fluctuating or complex needs.
Evidence shows children thrive with strengths-based supports, embedded in everyday settings, that promote wellbeing and autonomy rather than “fixing” difference.
Families report frustration with long waits, inconsistent access, and reliance on diagnosis before intervention.
Programs must be evaluated not only on reach but also on whether they meet the needs of children with complex or multiple barriers.

5.3 Equity and intersectional issues (First Nations and CaLD children)

First Nations children face barriers including distance, service shortages in remote areas, and mistrust of government systems.
CaLD families face barriers such as lack of translation, stigma, and services that do not reflect cultural values.
Both First Nations and CaLD children are more likely to be identified as developmentally vulnerable at school entry. Preschool attendance reduces this vulnerability, but attendance remains lower in some communities and services are not always culturally safe.
Thriving Kids must partner with Aboriginal Community Controlled Organisations and fund bilingual and bicultural staff to deliver trusted, community-led supports.
Programs must prioritise intersectionality, recognising the compounded impact of disability, poverty, and remoteness.

5.4 Workforce support and training gaps

The allied health workforce, particularly sole traders and small OT practices, is at risk of being overlooked in commissioning. These providers are critical in rural and local communities.
Families and providers warn that block funding could destabilise small businesses, leading to workforce shortages and inequitable access.
Workforce development must include training in: o Neurodiversity-affirming practice o Trauma-informed care o Cultural safety and humility o Disability rights and ethics (aligned with CRPD/CRC) o Sensory processing and executive functioning.
Supervision, mentoring, and reflective practice should be funded and embedded.
Governments should support cooperative or consortium models to enable small providers to collaborate without losing autonomy.

5.5 Domestic and international best practice

Internationally, tiered support models (e.g., in Canada and the UK) provide scalable supports without forcing children into rigid eligibility thresholds.
Evidence shows families reject behavioural compliance programs not led or co-designed by the community. Thriving Kids must adopt neurodiversity-affirming, strengths-based models.
Best practice requires independent evaluation, measuring outcomes by participation, wellbeing, and family empowerment.

5.6 Seamless transitions through mainstream systems

Families need confidence that supports will not be withdrawn until equivalent mainstream supports are fully available.
Thriving Kids should establish clear referral pathways, transition-to-school protocols, and integrated service hubs linking health, education, and disability.
Eligibility criteria must be flexible to prevent children from “falling off cliffs” when needs change.
Schools must be resourced and accountable for delivering identified supports.
Policies must explicitly include children in alternative education or homeschooling.
Families must not navigate systems alone: funded navigators and warm referral pathways are essential.
The program must align with mental health supports, ensuring holistic care for children and families.

6. Conclusion

The Thriving Kids Initiative has the potential to make a positive difference, but only if reforms build on what works, protect children’s rights, enable timely access to occupational therapy and other allied health interventions, and are developed in genuine partnership with the disability community. Without these safeguards, the risk is regression, family burnout, and erosion of trust. With codesign, cultural safety, evidence-based practice, and investment in a sustainable workforce, Thriving Kids could lay the foundations for children to thrive in families, schools, and communities.

APPENDIX 1 – see attached