Health Services Union
Submission to the House of Representatives Standing Committee on Health, Disability and Ageing
Inquiry into Thriving Kids Initiative
October 2025
About the HSU
The Health Services Union (HSU) is one of Australia’s fastest growing unions with over 100,000 members working in the health and community services sector across the country.
Our members work in aged care, disability services, community health, mental health, alcohol and other drugs services, private practices and hospitals. Members are health professionals, paramedics, scientists, disability support workers, aged care workers, nurses, technicians, doctors, medical librarians, clerical and administrative staff, managers, cleaners, security staff and other support staff and health workers.
You can find us at hsu.net.au
For questions regarding this submission, please contact:
Jackson Reynolds
National Policy and Campaigns Officer
Health Services Union
e: redacted
m: redacted
Introduction
The Health Services Union (HSU) welcomes the opportunity to contribute to the inquiry by the House Standing Committee on Health, Disability and Ageing into the newly proposed Thriving Kids Initiative (TKI). This $2 billion commitment, which is set to commence in July 2026, aims to establish a system of supports — outside of the NDIS — of foundational supports for children aged 8 and under with mild to moderate developmental delay and autism¹.
Our submission will focus on the Terms of Reference for the Inquiry on addressing gaps in workforce support and training required to deliver TKI, and on the implementation arrangements and mechanisms needed to allow for a seamless transition through mainstream systems for children accessing it.
We firstly acknowledge the critical objective behind the Australian Government’s development of the TKI, as restoring the NDIS to its original purpose and fulfilling Recommendation 1 of the Independent NDIS Review — to invest in the wider disability ecosystem to create fairness, balance, and sustainability across the sector.² However, we note that the success of the TKI is wholly dependent on immediate, mandated, and structural investment in the Allied Health and Early Childhood Intervention (ECI) workforces tasked with delivering these critical services.
We are concerned about a dangerous misalignment between the ambitious scope of the TKI and the fragility of the workforce expected to deliver it. Currently, the disability and allied health workforce operates under conditions of acute crisis, marked by chronic instability, burnout, and insufficient remuneration, posing an existential threat to the scheme’s viability. Without sector stabilisation and mandated training, the TKI risks becoming a significant investment in a system unable to deliver the required quality outcomes.
Our workforce data reveals the disability support sector is characterised by crippling and ongoing instability: 74% of disability workers report that their pay does not reflect their skill, responsibility, and emotional labour; while a staggering 55% have considered leaving the sector in the past year.³ The TKI risks exacerbating this mismatched capacity. The government has suggested that implementation and rollout can be done through the leveraging of existing mainstream settings such as schools, GPs, and community health centres; however the workforce numbers in these settings, including Allied Health Assistants and Disability Support Workers, is currently insufficient, and many will lack the mandatory specialised training and clinical supervision required for quality Allied Health and evidence-based ECI models.
Further, we are concerned about the risks of the policy timeline proposed by government. Foundational Supports, of which TKI will form part of a wider suite of yet-to-be-announced measures, are slated to roll out starting in July 2026, ahead of broader changes to NDIS access arrangements in mid-2027. This 12-month transition window is insufficient to address the deep-seated industrial and capacity deficits required to absorb the incoming volume of participants without a catastrophic collapse in quality standards.
1 Australian Government | Department of Health, Disability and Ageing (DHDA). Thriving Kids — Fact Sheet. https://www.health.gov.au/resources/publications/thriving-kids-fact-sheet?language=en
2 DHDA. Foundational Supports for People with Disability. https://www.health.gov.au/our-work/foundational-supports-for-people-with-disability
3 Health Services Union. https://hsu.net.au/portfolio/new-survey-shows-crisis-as-disability-workers-flag-exits-burnout-and-understaffing/
A Crisis in the Disability Workforce
The current state of the disability and care workforce—the essential foundation upon which TKI must be built—is one of acute instability. Data collected by the HSU highlights that this workforce is already burnt out, underpaid, and under-resourced:
- Seventy-four percent (74%) state their pay does not reflect their skill, responsibility, and emotional labour.
- Sixty-two percent (62%) report experiencing frequent or constant burnout.
- Fifty-five percent (55%) have considered leaving in the past year, with 91% having thought about it occasionally.⁴
This pervasive instability has direct and demonstrable consequences for service quality and safety. Forty-nine percent (49%) report often or always lacking enough staff for safe, quality care, and 71% confirm that shortages have already negatively impacted their ability to provide quality care. Applying this critically unstable, under-resourced workforce pool to a new, highly sensitive ECI system guarantees that the supports delivered will be poor, failing to achieve the necessary developmental outcomes required to meet the TKI’s strategic sustainability goal.
The low pay and poor conditions, exacerbated by the market basis of the NDIS, have undermined workforce stability. Eighty-six percent (86%) of workers fear wages could be cut without government action, underscoring the deep insecurity felt across the sector.
A Critical Dependence on Allied Health
Models of ECI that could serve as a blueprint for the TKI rely heavily on providing early intervention services on-site. These services include specialised care like speech, occupational, and feeding therapy. The delivery of these therapies and related support will likely require a large cohort of VET-trained Allied Health Assistants (AHAs), whose roles are crucial for implementing therapeutic strategies and supporting therapists in community health centres.
The TKI explicitly states it will leverage primary care systems that the Commonwealth funds and supports in community health centres, which is the primary employment setting for many VET-trained HLT staff.
The VET Qualifications List highlights the roles that underpin this sector:
- Certificate III in Allied Health Assistance (HLT33015): This is a core qualification needed to support the delivery of services in community settings.
- Certificate III in Health Services Assistance (HLT33121): This qualification, listed as “Low Fee”, provides foundational skills often utilised in various health support environments, including primary care.
- Diploma of Practice (Primary Health Care) (HLT57715): This is a higher-level qualification in the HLT sector, also listed as “Low Fee”, which provides the necessary skills for coordinating and managing complex care within the existing primary health systems the scheme aims to utilise⁵.
4 Ibid. 5 HumanAbility. Workforce Plan 2025. https://humanability.com.au/research---workforce/workforce-plan-2025.aspx
The design of TKI is critically threatened by a profound failure in the training pipeline. Data for the Certificate III in Allied Health Assistance (HLT33015) demonstrates high enrolment but low completion: The course enrolled 8007 students in 2023, but only recorded 1254 completions that year⁶. This suggests an attrition rate of approximately 85%, indicating that simply offering the training (even if it is Fee-Free) is not generating the necessary workforce supply. For a national program like Thriving Kids, which needs to ramp up services rapidly by July 2026, relying on a system that produces low completion numbers is a high-risk strategy.
We believe the core reason for the inability to retain and upgrade the existing health workforce is the absence of targeted funding. For example, the Certificate III in Allied Health Assistance (HLT33015) is designated as Fee-Free for new entrants and jobseekers. However, the crucial problem is that this qualification has no Existing Worker Traineeship (EWT) funding.
The implication of this funding arrangement is that workers already employed in community health centres or primary care settings who wish to upskill and acquire the specialised AHA skills that will be needed to support TKI are required to pay the full fee.
Further, the core evidence base for effective ECI and developmental intervention rests heavily on the expertise of Allied Health Professionals (AHPs), including Speech Pathologists, Occupational Therapists, and Physiotherapists. Gaps in allied health workforce capacity and access are already well known and pervasive across the NDIS, health, and aged care sectors. TKI is likely to exponentially increase the demand for AHPs to provide direct services, supervision, and consultation to mainstream generalist staff.
ECI practice requires complex skills: it must be capacity-building, family-centred, collaborative, culturally responsive, and evidence-informed. These demanding practices cannot simply be layered onto the existing duties of generalist staff who are already struggling with severe staff shortages and burnout. Targeted funding must be provided to create specialist Allied Health Assistant and support worker roles within these settings, guaranteeing the quality of intervention will meet necessary standards.
A Dedicated Workforce Plan
The government must prioritise a comprehensive, dedicated National Allied Health Workforce Plan, distinct from the general NDIS plan, to map workforce gaps and implement strategies specifically targeting recruitment and retention for ECI. The Federal Government released a draft of the National Allied Health Workforce Strategy for consultation in early 2025. This strategy must be urgently finalised and resourced to specifically address TKI-related ECI needs. We note that the Strategy appears to be stalled and believe it must be urgently revisited. The Government should instruct the Health Workforce Taskforce to ensure the revised Strategy includes Allied Health Assistants (AHAs) and considers the specific workforce initiatives like the TKI. The re-drafted Workforce Strategy must then be released for consultation without delay.
A key strategy must involve rapidly increasing the supply and specialisation of AHAs and Disability Support Workers. To ensure retention and quality, the Government must mandate the development of a nationally standardised Career Framework for AHPs and AHAs in the disability sector, covering Capability standards and clear Progression Pathways.
6 Ibid.
In order to ensure the quality of this Foundational Support programme, the TKI funding must explicitly subsidise mandatory, paid professional development for all AHAs and DSWs who deliver or interact with foundational supports. This training must move beyond general awareness and focus on ECI best practice, non-verbal communication techniques, supporting diverse and complex needs, and autism-specific strategies. Without mandated, funded PD, service providers will inevitably rely on existing, time-poor staff to acquire new complex skills without compensation, leading to poor morale and ultimately, inadequate support for children. The government must mandate that funding covers the cost of this paid training time to ensure quality.
Further, to mitigate the risk posed by a highly mobile workforce employed across different providers and modalities, the TKI implementation must consider and recommend a form of portable leave, especially Long Service Leave, to improve retention and security across the care and support sector.
In addition, as the sector moves towards greater regulatory oversight, the Government must ensure the TKI implementation is carefully referenced and considered as part of the National Registration and Accreditation Scheme (NRAS) review. Specifically, given the proposed criteria for registration, it is likely that the roles within the TKI, such as AHAs, will meet the criteria for inclusion in the proposed registration scheme. Integration of health, ageing and disability professions regulation is a critical goal, and the TKI presents an opportunity to ensure this crossover workforce is appropriately regulated.
Seamless Transition and Service
The TKI’s implementation arrangements must also explicitly address the service integration issues currently plaguing the disability sector. A key example is the ongoing difficulty with NDIS participants in hospitals, where the NDIS often will not fund support workers for clients in hospital, and hospitals will not allow external support workers to work with inpatients. This fundamental lack of service integration creates significant continuity of care issues and causes distress for service recipients and their families.
Given that the TKI aims to support children with mild to moderate developmental delay and autism, the sudden change in support modality during a hospital stay is likely to cause immense distress and confusion for this cohort. Robust service integration is essential for continuity of care.
Integration with Mental Health and Family Support
While TKI is primarily disability and allied health focused, there is a clear and often overlooked intersection with Mental Health (MH) services. The current system results in a large number of young children presenting to Emergency Departments (EDs) during times of crisis. Due to a lack of immediate, targeted intervention, these children are often directed to MH services for assessment but ultimately sent home without added interventions. This leaves young people to deteriorate until their needs are deemed acute enough for intervention, rather than accessing preventative or bridging services. The TKI must be designed to include a crisis response for families who are not yet eligible for NDIS or other services, acting as a vital interim support while wider workforce development is undertaken.
Furthermore, many young people accessing the TKI will have overlapping Mental Health and Neurodiverse/Developmental considerations, a complexity that is poorly addressed by current services. The Government must invest in and promote Specialist Dual Disability services (as distinct from Dual Diagnosis). These specialist services offer incredible benefits both by saving families the
high costs of engaging both paediatricians and specialist child psychiatrists (which can exceed $300 per 45-minute session)⁷, and by providing truly focused early intervention.
Finally, the success of the TKI is intrinsically linked to the support networks for parents and carers. Families supporting young children with developmental delays often face exhaustion, burnout, and anxiety, which can lead to their own mental health struggles due to the intense focus on the child. Increasing direct supports for families is therefore just as vital as improving access to services for the children. By providing the right training and recognising the close relationship between Mental Health and Disability – that one cannot be addressed without supporting the other – Allied Health and Disability staff can become leaders in true dual disability-focused care.
⁷ Australian Psychological Society. How much does seeing a psychologist cost? https://psychology.org.au/psychology/about-psychology/what-it-costs