Submission 399 — MedHealth — Inquiry into the Thriving Kids initiative

MEDHEALTH
NDIS SERVICES

Executive Summary

MedHealth Pty Limited (MedHealth) welcomes the opportunity to be an active participant in this Inquiry into the Thriving Kids initiative to the House Standing Committee on Health, Aged Care and Disability.

The introduction of the Thriving Kids initiative presents a unique opportunity for the disability ecosystem to return to an appropriate balance between the NDIS, ‘Foundational Supports’ and Mainstream services and to ensure all people with disability, including children, have consistent access to necessary supports and services.

The focus of the announcement for Thriving Kids initiative was ensuring that the NDIS returned to its original intent of supporting people with significant and permanent disability. Consequently, Thriving Kids initiatives would result in children with developmental delay or ‘mild to moderate’ autism already on the NDIS being shifted to services outside of the scheme. Whilst this is a key pillar of ensuring the long-term viability of the NDIS, the proposed Thriving Kids initiatives must ensure that all children with support needs are captured by either the NDIS or Thriving Kids in an intergrated ecosystem of supports and services. Noting that the final report of the NDIS Review found that:

Support for children with disability or developmental concerns outside the NDIS is lacking. In 2021, 22 per cent of Australian children were developmentally vulnerable on one or more domains of the Australian Early Development Census by the time they reached school. This represents one in five children. The inadequacy of mainstream and foundational supports outside the NDIS results in poor outcomes for families and children and drives many to seek access to the NDIS because there is nowhere else to go. Situating early supports inside the NDIS disconnects children from mainstream services that promote positive child development.

As such, having taken the lead in development of the Thriving Kids initiative, the Australian Government should work with states and territories to ensure national consistency and a shared purpose in the implementation of the initiative. MedHealth supports this nationally led approach which works with all states and territories across the disability, health, education, and justice sectors to ensure:

• Consistency in the continuum of care, regardless of national or state and territory led supports, to assist children and families navigate the support and services available.
• Access to the same high standards of support, services and inclusion to the child with disability regardless of where they live.
• Establishment of clear roles, responsibilities and accountability mechanisms for all parties involved.
• Collaboration and-sharing of best practices and resources between all levels of governments and service providers.
• Measurement of cost benefit to demonstrate effective outcomes of early intervention and subsequent reduced reliance of future support needs.

The Thriving Kids announcement has many unknowns and in turn has led to questions which MedHealth hopes this inquiry will assist in resolving. These include:

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• Entry Criteria: who qualifies under Thriving Kids as opposed to NDIS? The terminology of development delay and mild to moderate autism does not provide clarity of the entry pathways to these schemes- or the exit criteria for current NDIS participants. Effective screening and assessment processes will improve clarity of which children qualify for the NDIS however prior to NDIS acceptance the child must have access to relevant Thriving Kids initiatives to ensure no delay in provision of critical supports.
• Service and program consistency: what supports and services will be the responsibility of federal versus state governments. If state led, how will national consistency be achieved across jurisdictions?
• Integrated ecosystem: how will the Thriving Kids initiative ensure effective collaboration across all sectors and providers in the ecosystem?
• Equity of Access: how will Thriving Kids ensure equity of access for all Australian children regardless of where they live, their cultural background and their socio-economic status?
• Funding: how will funding of programs be developed to ensure affordability for all children and families in need, while also ensuring sustainability for providers delivering supports and services?
• Workforce: how do we ensure there is adequate workforce across all disciplines who are effectively trained in the broader integrated ecosystem and the expertise to deliver quality outcome-focussed services?
• Clear workplan: how do we ensure clear workplans with timeframes are established to ensure services can be prepared to deliver when and where required?

These questions and our key recommendations below create a significant opportunity for ongoing consultation and codesign. MedHealth would welcome the opportunity to participate in any future engagement as either part of broader community engagement or through direct consultation to ensure Thriving Kids achieves its potential benefit to children in need.

MedHealth Background

MedHealth supports thousands of people each year to achieve disability, health and employment outcomes, thereby improving their ability to live a full life. We are a people-oriented business who are passionate about helping others and the communities in which we live and work. We do this through our unique combination of strengths, capabilities, and resources, which span healthcare management (including allied healthcare service delivery in early childhood, therapeutic and behavioural support to NDIS participants), medical opinion, advisory, clinical, employment, health and business technology, rehabilitation and return to work services.

Supporting and empowering people, including children, with disability, mental illness and complex injuries is a particular focus of our business. In addition to being a registered NDIS provider we operate in and across all of the service delivery models of Australia’s personal injury schemes (including the Department of Veterans’ Affairs and associated Military Compensation Acts, Workers Compensation, Compulsory Third Party, Life Insurance) and we are also a Disability Employment Service provider. Our deep experience in these diverse schemes, ensures we understand best practice service delivery models and that investment in appropriate services in a timely manner, will assist in building capacity and thus supporting value for spend, less reliance on often more expensive supports and sustainability into the future.

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Our Disability Services Approach

MedHealth’s Disability Division is comprised of 7 organisations, each of which delivers early childhood, therapeutic, and/or positive behaviour support services across all states and territories nationally across all participant age groups with approximately 4800 being children aged 0-8. Across our Disability division we support people with disability under the NDIS and through private and other funding models, along with Aged Care, Department of Veterans’ Affairs and private sectors.

In our practice we generate positive outcomes for children with disability every day. Our principles align with those of the inquiry, whereby we strive to promote the delivery of high-quality innovative supports, deliver consistent outcomes and provide value for money for all people with disability including children.

We have a strong understanding of the systemic, structural, and service-level issues that continue to challenge delivery of supports within the NDIS and therefore acknowledge a key intent of Thriving Kids- to promote the sustainability of the NDIS. MedHealth is committed to ongoing support of people with disability nationally and continue to invest beyond day-to-day service delivery in areas such as workforce development and training, clinical excellence with an outcomes focus and quality and safeguarding, including child safety.

Larger providers, such as MedHealth, make up a small although critical % of the overall disability provider market. It is providers like MedHealth that attract candidates to the sector, have the quality training programs in place to see employees develop in line with sector requirements and the measures to determine return on investment. These providers represent a safe pair of hands for the Thriving Kids initiative with regards to risk, governance, compliance and data protection to ensure children and families and their records are treated with the utmost care and protection. They also often bring knowledge and experience in other healthcare and insurance environments that can be transferable to Thriving Kids.

In this submission, we address the provided Terms of Reference and suggest the following key components for the success of this initiative:

1. The Continuum of Care:
   • Central Pathways Team and Local Thriving Kids Navigators
   • Service Delivery:
     • Early Childhood Screening
     • Assessment and Diagnosis
     • Ongoing Supports and Services including Allied Health in health, community and education settings.
2. Workforce training and support: attraction of a quality workforce to service the initiatives, induction and training in best practice early childhood services and educational support to the broader Thriving Kids ecosystem
3. Funding considerations: participant affordability and provider sustainability
4. Appropriate Registration and Regulatory Controls

Terms of Reference

• Examine evidence-based information and resources that could assist parents identify if their child has mild to moderate development delay and support parents to provide support to these children.
• Examine the effectiveness of current (and previous) programs and initiatives that identify children with development delay, autism or both, with mild to moderate support needs and support them and their families. This should focus on community and mainstream engagement, and include child and maternal health, primary care, allied health playgroups, early childhood education and care and schools.
• Identify mechanisms that would allow a seamless transition through mainstream systems for all children with for children with mild to moderate support needs.

What do Thriving Kids support services look like?

As per the diagram above, MedHealth recommends that all Thriving Kids initiatives must have the child, family and broader support networks at its core and that all external stakeholders must form part of an interconnected system of supports and not operate in silos of expertise.

All supports and services should have common goals of:

• Building daily living skills.
• Enhancing communication and social connection.
• Supporting mental health and emotional regulation.
• Creating safe environments at home, work and in the community.

The initiatives should begin by assuming that not all families and support networks have health literacy so Thriving Kids should be underpinned by meeting families where they are, walking alongside and assisting families to negotiate services.

Thriving Kids creates an opportunity to apply an integrated ecosystem of disability supports to the child and family through:

• Multi-disciplinary teams: the initiative presents the opportunity for multi-disciplinary teamwork where navigators, medical practitioners (GPs and specialists), allied health professionals (Speech Pathologists, Occupational Therapists, Physiotherapists, Psychologists) and educators (early childhood educators and teachers) work in a connected team and coordinate a service wrapped around a child and their family.
• Delivery in community-based, natural environment settings.
• Upskilling of primary caregivers and staff in community settings: building confidence in their own capacity as key people in the young person’s life.
• Priority of access: indicators implemented as a rule are given the highest priority and the first access to:
  • Aboriginal and Torres Strait Islander children
  • children under Guardianship of the Minister/ engaged with the Child Protection System
  • children of parents with disabilities and families with multiple children with delays/disabilities
  • children experiencing significant socio-economic disadvantage

Thriving Kids Continuum of Supports

Step One: Accessing Thriving Kids

The first step under the inquiry into the Thriving Kids initiative is to provide clarity on eligibility for Thriving Kids versus the NDIS.

Terminology

Current Issue: The reference in the Minister’s announcement to ‘mild to moderate autism’ has created confusion as this is not a diagnosis, or terminology used in contemporary practice regarding autism.

From a clinical perspective, autism is a lifelong neurodevelopmental condition that influences the way a person understands and interacts with other people and the world around them. Developmental delay is a term used when a child is behind their peers in one or more aspects of development, such as motor skills, communication, or cognition. Many autistic children have a developmental delay, but not all.

Recommendation: Sector feedback has suggested a clearer way would be to refer to children with developmental delay as the target group for Thriving Kids, noting it will include many, but not all, autistic children.

Access Pathways

MedHealth understands children will enter Thriving Kids through two pathways:

1. NDIS Exits

Current Issue: While there has been broad discussion and consultation by federal and state governemnts on the need for a broader ecosystem of supports outside of the NDIS, including state-funded services, there are significant concerns that current changes to the NDIS are resulting in some children who need support already being deemed ineligible or being exited from the scheme.

For these children and young people there may be no other suitable services or support accessible, available or affordable outside the NDIS. This includes a lack of access to critical programs meaning that some children with developmental delay or autism may already be missing out on vital and time-limited opportunities to access key supports, such as allied health services, for their development and long-term function and wellbeing.

Recommendations:

• We strongly recommend that the Department ensures that the NDIA is not exiting children requiring ongoing supports from the scheme until a new ecosystem of Thriving Kids supports and services are funded and readily available nationally.
• Additionally, on commencement of Thriving Kids services there must be a clear transition process for children who are exiting the scheme. This would include a priority consultation with the Central Pathways Team and a Local Thriving Kids Navigator (see below) with the child and family to outline the new supports available and key contacts and processes to access these supports.

2. New Entrants

Current Issue: The current disability ecosystem currently has many different players supporting people with children and families in navigating the NDIS and disability services more broadly. Having this role split across so many disconnected functions creates both gaps and duplication and creates confusion, especially where children and their families are concerned.

Recommendations: The Thriving Kids initiative presents an ideal opportunity to introduce the Navigator function as recommended by the NDIS review (October 2023). When a family, or part of their support network, identifies developmental concerns in a child it is critical they have access to a centralised, easily accessed first point of contact to commence their Thriving Kids journey. This would be the role of the

Navigators and this function ensures all information, resources and supports has the child and family firmly at the centre.

Navigators

Thriving Kids Navigators would be designed to assist families in:

• Understanding the information and supports in the community
• Accessing mainstream services,
• Engaging with their communities
• Utilising Thriving Kids support and services.

MedHealth proposes a two-tiered Navigator function for Thriving Kids:

• Central Pathways Team: to ensure simplicity for the family at their first exposure to Thriving Kids it is recommended a national call centre service is created. It would provide the family with an overview of the initiative, the possible supports and services available and where to access general information. This role is critical in assuring the family that there is a structured and integrated system of supports available and that at all times the child and family will be the central point of that system. Having undergone an initial intake and been provided with relevant information and guidance on next steps the family would be referred to the relevant Local Thriving Kids Navigator, if required, who assumes responsibility of the next stage of supports.
• Local Thriving Kids Navigator: deeply connected to local communities and maintain extensive knowledge of both disability and mainstream supports. Specific resources enable Navigators to reach people in rural and remote areas, providing in-person support when needed. They also build capacity within mainstream services to better support people with disability.

Previously the peak bodies National Disability Services (NDS) and Disability Advocacy Network Australia (DANA) created a paper titled ‘Navigator Principles Executive Summary’ https://nds.org.au/policy-library/guiding-the-way-building-common-principles-for-navigators.

MedHealth supports the recommendation to establish common principles to create a consistent framework that ensures Navigators work independently, focus on the individual, and support broader human rights objectives. They would be independent from:

• NDIS funding
• Service provision: support from a Navigator is separate from a person’s service provision and not an additional service.
• Advocacy: Navigators do not provide advocacy services but refer people to appropriate advocacy organisations. Advocacy services must receive adequate funding to manage referrals.

Key Navigator Principles as applied to Thriving Kids

1. Connected As outlined MedHealth proposes a two-tiered Navigator function for Thriving Kids consisting of a Central Pathways Team and Local Thriving Kids Navigators

2. Child and Family-centred

Thriving Kids Navigators would respect the values, rights, and autonomy of the child and their family and support networks, empowering control of the supports and services while fostering self-determination and dignity.

3. Human-rights focused The model acknowledges disability as a natural part of human diversity and promotes inclusion in communities, recognising the need for both barrier removal and personalised support.

4. Culturally safe Thriving Kids Navigators would ensure individuals from diverse cultural backgrounds feel respected and valued. They engage in self-reflection, ongoing learning, and respect historical and social contexts.

5. Trauma-informed Thriving Kids Navigators would recognise trauma’s impact and provide trauma-sensitive options to ensure service engagement.

6. Collaborative Thriving Kids Navigators would work closely with families, service providers, and stakeholders to coordinate seamless support through formal networks and shared information systems.

7. Choice and control Thriving Kids Navigators would empower individuals to make informed decisions, providing wrap-around support to enhance choice and facilitate transitions.

8. Inclusive By connecting individuals with both mainstream and foundational services, Thriving Kids Navigators would promote inclusion and reduce reliance on disability-specific supports.

9. Responsive and flexible Thriving Kids Navigators adapt their approach based on individual needs, scaling support up or down as required.

10. Transparent Clear, accurate, and timely information builds trust and ensures individuals can make informed choices.

11. Accountable and continuously improving Regular training, manageable caseloads, and adherence to practice guidelines ensure effective service delivery. Thriving Kids Navigators would be accountable to performance indicators and seek feedback for continuous improvement.

12. Promotes employing people with disability as Navigators Hiring individuals with lived experience enhances trust, inclusion, and service quality.

If implemented effectively, the Thriving Kids Navigator role has the potential to simplify access to services, reduce administrative barriers, and provide personalised, holistic support. Navigators will enhance coordination, promote independence, and foster self-advocacy among children with disability and their families.

Keys to Navigator Success

The following elements are critical to the successful creation of the Navigator functions and subsequently the Thriving Kids initiative:

• Establishing a robust roadmap, including clear guidelines, phased rollouts, and pilot programs.
• Comprehensive training and professional development to equip Navigators with essential skills.
• Collaboration across sectors to ensure seamless integration with existing supports.
• Targeted resources for rural and remote areas to address unique challenges and ensure equity.

Looking forward, the successful integration of Navigators into the Thriving Kids landscape will require continued collaboration among governments, service providers, and advocacy groups. Key areas of focus should include:

• Securing sustainable funding models,
• Ensuring widespread availability in rural and remote areas
• Refining training and accountability mechanisms for Navigators.
• Ongoing consultation with people with disability, their families, and service providers

General Foundational Supports

A key platform of sharing information and supports to the child and family is addressed by the proposed introduction of General Foundational Supports as recommended by the NDIS Review. To date development of these supports have focussed on ages 9 and over however there is significant need and opportunity to ensure these supports are available for Thriving Kids children and families.

In July 2025, the Department of Health, Disability and Ageing, published two grant opportunities to deliver supports that will be ‘progressively replacing supports provided through the current ILC program’ and form the ‘building blocks for General Foundational Supports.’

Information, advice and referrals grant

The first grant was for the information, advice and referrals program which aims to:

• Improve the accessibility of information and advice for people with disability, primarily between the ages of 9-64. Including by making information more accessible for people with disability with intersectional identities.
• Expanding the reach of information and advice to a wider audience.
• Updating and expanding existing information and advice resources.

Individual and family capacity building grant

The second grant focused on individual and family capacity building, with services designed to support people with disability aged 9-65 to understand their disability, build connections, advocate for themselves and participate in the community. As well as helping family members and carers to support their loved one and advocate on their behalf.

The objectives of these grants were to:

• Provide capacity building support to young people during key life transition points.
• Give family members and carers the practical knowledge and skills they need to support people with disability to make choices, grow independence and engage with opportunities.
• Improve existing capacity building supports to make them inclusive of people with intersectional identities and accessible to people living across Australia.

While noting that both these initial grants refer to ages 9 and above the application for Thriving Kids initiative would be to:

• Identify if the tools are suitable for the 0-8 age group and if yes, include as an available resource for children and families to be directed to
• Modify these tools or release new grant opportunities if not deemed suitable

Step Three: Early childhood health and development screening

Children with emerging developmental concerns need to be identified early in life so that they can access the appropriate supports. This can be achieved through early childhood health and development screening. These screens should be available to all Australian children as it will increase the rate of early identification of issues and therefore the success of early intervention.

The benefits to undertaking early screenings include:

• Early identification of concerns enabling early intervention for better long-term outcomes and improvements.
• Development of improved tailored support for child and family.
• Reduction in risk for ongoing issues for child.
• Stronger engagement with family.

Current Issues: Early childhood assessment and intervention has been specifically noted as of key importance to the Thriving Kids initiative. The NDIS review found that ‘children with disability and developmental concerns are not being consistently identified early in life’. Children can miss out on supports during the unique period of rapid brain development that plays a critical role in shaping a person’s life trajectory.

Current barriers to access routine health and development screening include:

• Lack of Information: lack of appropriate information for parents regarding the reasons for and the value of attending for health and developmental screening.
• General workforce shortages: resulting in long waitlists for screening.
• Location of services: creating difficulties with transport options
• Funding: where no formal program funding is available private assessments incur a cost to the family or preclude those without the financial means to complete.
• Trust of the professional: can be a significant barrier when there is no established relationship. There can be a fear of judgment resulting in a lack of sharing of relevant information. This aspect is compounded for First Nations people and CALD communities.

• First Nations communities. often developmental screening is undertaken by people who are not ‘trusted’ in the communities which results in parents not attending clinics. First Nations families can be reluctant to attend appointments at large institutional settings e.g. hospitals.

• Rural and remote: the tyranny of distance and isolation for families:

  • Transport: families often have barriers of access to transport whether it is personal or public transport.
  • Digital divide: compounds the difficulties with often limited access to technology e.g. no funds on phone, no access to internet, lack of mobile reception.
  • General workforce shortages: are compounded in rural and remote settings with lack of appropriate staff to undertake checks and large distances to travel to service need face-to-face appointments.

Recommendations: to remove gaps in screening opportunities, including those in rural and remote communities, Aboriginal communities, and culturally and linguistically diverse communities requires:

• First Connection: strengthen the first connection for childhood screening during the maternity and hospital period. This will enable early establishment of key relationships with families and identify any specific needs for example families experiencing vulnerability, or of CALD status, or Indigenous families.
• Community Supports: proactive approach with home visits, telehealth and/or transport to community health centres for health and development screening.
• Tracking: proactive approach to track child and families so that they don’t fall through the gaps and miss critical health and development checks. The technology solution can play a key role in this.
• Review of developmental screening protocols: to ensure there is consistent and high-quality assessment of family members health and well-being. The screen needs to be holistic not just medical and therefore be a combination of GP and allied health components.

Screening Process

MedHealth recommends that there are screenings undertaken at regular intervals during childhood. The below table lists the stages and the proposed delivery approaches.

Stage	When	Who	What	Where
Early Childhood	- 6 weeks - 3 months - 6 months - 12 months - 18 months - 2 years - These are in line with existing checks or vaccinations: form part of the ‘blue-book’	Early childhood nurses working alongside either Allied health or GP.	Screening of communication, social skills, behaviour, feeding, fine and gross motor skills	GP/ Allied Health Clinics Community Centre Playgroups Telehealth

| Pre-school Screening | In the year prior to starting school | Speech Pathologist or OT. | ‘School readiness” screen to check speech, language, social skills, pre-literacy skills, fine and gross motor skills | At pre-school or relevant location if not enrolled in pre-schools/kindergarten | | School Screening | Term 4 of first year of schooling | Allied Health professional and Teacher | Check speech, language, social skills, early literacy skills, fine and gross motor skills, behaviour and attention skills | At school |

Step Four: Assessment and Diagnosis

MedHealth recommends that where screening identifies area of concerns referrals are made for more formalised assessment and diagnosis. As with early screening, the benefits to undertaking early detailed assessments where issues are identified include:

• Early diagnosis allowing for early intervention for better long-term outcomes and improvements.
• Development of improved tailored support for child and family.
• Reduction in risk for ongoing issues for child and family.
• Stronger engagement with family.
• Improved coordination of ongoing services.

Current Issues: the current issues for assessment and diagnosis align with those listed in the previous ‘Screening’ section.

Recommendations: currently at MedHealth we undertake assessments to formally evaluate the child’s development, cognitive, social-emotional, and/or behavioural functioning in order to develop:

• A diagnosis (if appropriate).
• A functional profile exploring strengths and support needs.
• Recommendations for intervention, support plans and funding.

The assessments are undertaken by Lead Assessors with the following clinical backgrounds:

• Psychologist: for cognitive, emotional and behavioural concerns, diagnostic assessments.
• Paediatrician: for medical, developmental history, diagnostic oversight.
• Psychiatrist: for complex behaviour and/or mental health concerns.

The Lead Assessors may be supported by the following Collaborating Professionals:

• Speech Pathologist: for language, communication and social communication.

• Occupational Therapist: for cognitive, sensory, motor and functional (daily living) skills.
• School/Early Childhood Educators: for observational and functional skills.
• Parents/Carers/Family: informants of development, behaviours and concerns through interviews, questionnaires and historical data.
• GP: referrer and care coordinator.

Assessment Format and Process

It is critical that the assessments follow a consistent, quality controlled and time-specified process to ensure timely diagnosis and progression to appropriate interventions. The assessments typically include:

• Detailed case history- key information relating to possible diagnoses
• Informal and formal assessment of the child with possible tools including:
  • Cognitive - WISC-V, WPPSI-IV, Stanford-Binet.
  • Autism - ADOS-2, MIGDAS-2.
  • Behaviour/ADHD - Conners-3, BASC-3.
  • Adaptive functioning - ABAS-3, Vinelands.
  • Executive functioning - BRIEF-2.
  • Sensory - Sensory Profile, Sensory Processing Measure.
  • Motor - Movement ABC, BOT.
  • Developmental – DP4.

Having completed the assessment components the assessor(s) then complete a single report for the paediatrician and family. The paediatrician then conducts an assessment in person and utilises the information from the assessing team report to make accurate diagnoses.

Following the assessment and diagnosis a feedback session is undertaken by the primary assessor with the family to discuss results, what it means to the family and direction of where to for services/ongoing support

Step Five: Ongoing Supports and Services

Having established a formal diagnosis or identified the need for ongoing supports it is critical that the Thriving Kids initiatives provide a formal, integrated program of supports for the child and family. At present outside of the NDIS where services do exist they operate in silos, for example community supports, medical and allied health interventions and education programs operate independently with little, or no, multi-disciplinary collaboration.

MedHealth believes that Thriving Kids represents a significant opportunity to rectify this and create a truly integrated ecosystem of supports and services that maintain the child and family at its core at all times. As outlined the use of Local Thriving Kids Navigators supported by technology solutions should maximise the collaboration of all stakeholders thus keeping the child and family at the core of the ongoing supports and services

Allied Health

As a large national provider of allied health services the below summarises how MedHealth believes allied health services form a critical part of the multi-disciplinary approach.

The benefits to provision of ongoing allied health services include:

• Better long-term outcomes and improvements for the child.
• Better tailored support for the child and family.
• Reduction in risk for the child.
• Stronger engagement with family and improved parenting skills.
• Improved mental health and family relationships.
• Improved support service coordination.

Current Issues:

• Lack of available funding resulting in families paying privately or missing out on services.
• School access issues (see below).
• Parent availability due to working.
• Workforce issues resulting in long waitlists.
• Access issues to service delivery locations eg lack of transport.
• Coordination challenges with non-allied health services.

Stage	What	Who	Where
Information and Supports	- Therapy support and information about therapy benefits - Individual parenting support and group information sessions - Playgroup, daycare, community centre therapy support and information sessions for families and staff - Kindy, Preschool and school information sessions - Information sessions- individual and group- in other settings eg libraries	Allied Health clinicians: - Occupational Therapists - Speech Pathologists - Physiotherapists - Psychologists - Exercise Physiologists	Thriving Kids Support Centres (see below): - Playgroup, daycare, community centre - Kindy, Preschool and school - Allied Health Clinics - Home
On Going Services	- Individual allied health therapy	Allied Health clinicians: - Occupational Therapists	Thriving Kids Support Centres (see below): - Allied Health Clinic

| | - Case management - Family and Child Connect
- Parenting Programs
- School readiness program | - Speech Pathologists
- Physiotherapists
- Psychologists
- Exercise Physiologists | - Telehealth
- Playgroup, daycare, community centre
- Kindy, Preschool and school
- Home |

Beyond the continuum of supports the below sections represent other considerations for the success of the Thriving Kids initiatives

Technology

All stages of the Thriving Kids program would benefit from effective use of technology solutions to:

• Capture relevant information regarding the individual child and family. The ability to enable the child and family to ‘tell their story once’ by using a technology platform to capture the background, medical diagnosis and status would alleviate significant burden and fatigue for families and ensure consistency of information sharing.

  The platform should capture the initial core information across a range of medical, functional and personal fields and then become an ongoing repository of shared consented information such as consult and session summaries accessible to all approved stakeholders. In doing so it creates an integrated ecosystem of information to improve quality of supports and services.

  It should be controlled by the family or nominated stakeholder to ensure privacy is maintained and shared information is appropriate.

• Create links to relevant information and resources to expand knowledge and improve access to find and choose appropriate services more easily. The Navigator could identify and direct families to appropriate online resources relevant to their circumstances for example a resource webpage for families linked to existing parenting advice such as Raising Children Network.

• Resource for stakeholders: similarly a centralised library of resources for any stakeholder engaged with a Thriving Kids participant and in doing so will ensure consistency of information and expanded knowledge for those professionals engaged with the child at any interval.

Thriving Kids Support Centres

In order to ensure all children with support needs have access to Thriving Kids supports and services there must be a range of available venues for these services to be delivered from. Where a child is already engaged with a service (eg allied health clinic, playgroup, pre-school, school etc) the services

should be delivered from the familiar environments. However, there will remain a significant cohort who are not already engaged in formal settings who will need to informed of, and given access to, alternatives such as community centres, local service providers etc. All locations should be labelled as a Thriving Kids Support Centre to allow ease of identification for children and their families. In some circumstances delivering supports in the home environment would be considered most appropriate and would be utilised following relevant safety checks.

The NDS submission to the Inquiry into Children and young people with disability in New South Wales educational settings highlighted that the early childhood education and care sectors have a critical role to play in the ecosystem of supports for children and families and must be equipped to support all children, including those with development delays and disability, through inclusive practices, skilled educators, and sustainable funding.

Current Issues: there are challenges where supports are provided in facilities already offering other services:

• In the NDIS children have individual plans with individual practitioners. This results in large numbers of early intervention staff coming to centres daily to provide NDIS funded individual supports presenting logistical challenges and access issues.
• Stories of families turned away from centres due to their child’s needs suggesting a support, skill and funding gap.
• Sector capacity building program does not offer effective support to early learning centres.

Recommendation: It is critical to the success of the Thriving Kids initiative that all children and families who require supports and services have access to locations that are accessible, appropriate and engaging to achieve the goals.

Playgroups and Early Education Centres

Supported playgroups, daycare and early educational centres are ideal examples of familiar locations that should become approved Support Centres to enable delivery of additional supports and services eg allied health to child and family.

Recommendations:

• Strengthen resourcing of these services as approved Thriving Kids Support Centres including but not limited to:
  • Ensuring the facilities are physically equipped to deliver the full scope of services
  • Ensuring formal procedures and service level agreements are established for external contractors delivering at these locations
  • Providing training to existing staff in the scope of services to be delivered and in how they can enhance the effectiveness of the initiatives in their day to day engagements with child and family

Community Centres

If the child is not engaged with such services then there should be accessible Thriving Kids Support Centres within community centres. The Child and Family Learning Centres in Tasmania have a proven

model to enable children and families to access a range of supports. As per their stated vision it aims to give children the best possible start in life that can be adopted nationally:

• Working in partnership with families and communities to improve the health, wellbeing and learning outcomes for children in their early years, from pregnancy to five years.
• Providing a safe, inclusive, and welcoming place where families can access a range of integrated services and wraparound supports in their local community.
• Building on the existing strengths of families and communities and build capacity through partnerships with parents, caregivers, families, communities, and service providers.
• Increasing access and participation in quality early learning and support connections between families and schools, facilitating school readiness and successful transition to school for children and their families.
• Providing innovative child-focused environments, tailored to early childhood learning, where children, families and communities can learn, play, and grow together.

The services are delivered in purpose-built indoor and outdoor play spaces that help families build connections and belonging within their local community. While there would be an investment in replicating or modifying existing programs to establish a nationally consistent framework there would be a clear measurable return on investment through improved early intervention outcomes requiring less expenditure by other services such as within the education and health systems.

Libraries

Libraries represent another existing community centres that could become Thriving Kids Support Centres. For example. at MedHealth, libraries have proven to be a successful form of Community Centre hubs due to activities such as ‘mum and tots groups’. Through working with the libraries to education of librarians the staff identified a number of children with developmental delay concerns. This led to our Occupational Therapists conducting sessions with families on signs to look for and strategies to address and are now recurring sessions every two months in a number of facilities.

Schools

Early childhood education centres and schools should be more inclusive and allow children to fully participate in education with their peers. This includes appropriate access to therapy services in the educational setting. It is critical that classroom environments form part of the Thriving Kids Support Centre networks to enable supports and services to be delivered in a key natural environment. However, through our experiences with NDIS participants MedHealth recognises the impacts and challenges this may have on learning environments

Current Issues 1: Lack of access to services in schools and classrooms. As a provider of Allied Health services to NDIS participants we frequently encounter barriers to gaining access to schools to provide services. The policies adopted by all states leaves entry at the discretion of the Principal and many Principals subsequently refuse entry or create significant barriers to do so. This limited access is particularly noted for terms 1 and 4 with frequent restrictions of only 1 therapist per child and room hire fees being applied. These barries make service delivery in these schools impractical and financially unviable for the provider.

There is a frequent misunderstanding of the goals of school therapy and therefore a lack of understanding of the outcomes that can be achieved not only to the child receiving therapy but to the classroom environment as a whole

Additionally, classroom teachers often feel their role is being impinged on whereas therapists are not looking to teach them how to teach but rather are looking to work with teachers on strategies to support the child and the classroom environment.

Recommendations:

• School Access: Under the Thriving Kids initiative, establish a national review of school access for allied health therapists and ensure state and territory Education Departments develop consistent approaches to access and facilitate collaborative approaches to service delivery.
• Educating the Educators: allied health professionals delivering training to educators at all schools to improve understanding and benefits of therapy delivered in the school environment and establish mutually beneficial collaborative approaches. This can be achieved through:
  • Principal Education: addressing how to best schedule sessions to minimise disruption to classroom operations and the benefits expected in classroom environments
  • Teacher Education: supporting teachers to identify developmental or behavioural areas of concern, what support the therapist can offer and what the goals are.

Current Issues 2: Unnecessary duplication and inefficiency in disability service provider probity checks at each school Some approval checks are centralised in the education system, however many schools are asking disability service providers to repeat probity checks at each school unnecessarily in addition to providing insurance certificates and signing individual agreements to undertake services. This produces inefficiencies in increasing administrative workload for disability service providers that could be more effectively spent on service delivery.

Recommendations

• Establish nationally consistent school access requirements that allow schools to access pre-populated information such as employer insurances, Working with Children Checks and acknowledgement by the provider they have reviewed necessary school procedural documentation. Such processes currently exist in Victoria through Sam4Schools and NSW through the Specialist Allied Health and Behaviour Support Scheme.

Funding

Thriving Kids presents an opportunity to introduce new and innovative pricing models that meet the two key criteria of affordability for families and provider sustainability. However, it is essential that pricing, in the first instance, enable providers to remain viable by covering the business-critical costs of wages, regulatory and governance activities and standard business expenses such as rent and IT.

Funding models must address:

• Simple, viable pricing models
• Transparent decision-making around model development
• Regional pricing flexibility
• Recognition of investment in quality service provision and governance
• Recognition of investment in workforce quality and retention

Recommendations

• Collaboration: That state and federal governments work together to create a harmonised and simplified policy and funding system for Thriving Kids initiatives. This would reduce complexity for families and providers, particularly when navigating disability-related supports.
  • Coordination: better coordination of funding to reduce complexity and ensure the needs of children with disability can be met appropriately by service providers.
  • Funding model: design the funding model to provide adequate funding to support high quality, best-practice support, flexibility, and capacity building.
• Benchmark prices: use appropriate benchmarking to ensure that services are adequately funded.
• Consultation: to develop a successful and sustainable Thriving Kids pricing model it is imperative that close, direct consultation with service providers occurs. The importance and value in engaging with providers, such as MedHealth, who have a proven track record of working both within this scheme and also other insurance schemes will enhance the strength of reviews such as this.
• Location: there are significant challenges in servicing regional and remotes communities in particular the lack of a local workforce to provide supports and services. For a provider with metropolitan or large regional bases to justify delivering services to a remote community using its existing workforce there needs to be a sufficient volume of participants to disperse the travel costs or a pricing model that accommodates the cost of travel for small participant volumes.
• Service complexity must be a consideration. For example the skills, experience and training required to for early childhood specialisation are a cost to any provider.
• Quality: MedHealth is committed as a large provider to attracting new clinicians to the disability sector by providing extensive induction and training for all clinical staff , monitoring service quality and in maintaining a comprehensive governance system and resources. All of this benefits the sector and people with disability greatly however comes at considerable expense which should be captured within funding models.
• Governance: ensuring quality and safeguarding requires adherence to regulatory (and likely registration) requirements and should be a consideration in development of pricing models.
• Administrative Burden: under NDIS services administrative costs are incorporated into the hourly rates for services. However, our experience indicates the scheme has an extraordinary overlay of non-billable administration requirements compared to other insurance schemes that MedHealth operates within. This has a direct resource cost in addition to a financial cost. To address this, Thriving Kids Programs should minimise administration requirements for therapy providers- simple booking processes and minimal documentation requirements for clinicians.
• Medicare : if as indicated Medicare is to be used more widely in funding Thriving Kids services then the rates assigned to the new codes must be reflective of the costs of service delivery and not require the addition of a gap fee as commonly occurs with current allied health services. Pricing that facilitates a gap fee would isolate a significant portion of Thriving Kids children and families and

subsequently reduce the effectiveness of the initiative and increase the cost burden to the economy in future years.

Regulation

MedHealth is a registered NDIS provider. Given the mix of our services and our sustained growth, developing the governance and compliance frameworks is something that we, as a large organisation with a commitment to quality and care, would have completed regardless of specific scheme registration requirements. Our registration across various schemes and our ISO 9001:2015 - Quality management systems certification has us well placed to understand the benefits and challenges that come with effective regulation.

There is an opportunity at the outset with Thriving Kids to ensure the regulatory framework learns from the experiences of the NDIS. This would ensure it is proportionate, consistent and responsive to the needs of children, families, and providers when supporting these children. It should include

• Mandatory registration of all providers.
• Appropriate registration requirements and obligations- clear guidelines to reduce subjectivity and ensure a focus on outcomes rather than administrative preferences.
• National consistency regardless of state led programs. This should include transition to a National Working with Children Check.
• Timeliness and efficiency: minimise administrative delays in regulatory processes by reviewing internal workflows and resourcing to ensure timely decision-making.

Early Childhood Regulatory Obligations

MedHealth acknowledges the higher level of risks associated with providing early childhood supports, in particular child safety, and in turn our obligations for children, families and our clinicians increase. This includes:

• Obtaining the required working with children checks for all staff.
• Conducting mandatory reporting requirements of child safety incidents.
• Undertaking annual audits.
• Developing and implementing a competency-based framework for our clinicians.
• Maintaining an additional layer of clinical support and governance.

While we would continue to adhere to all requirements under the various jurisdictions, MedHealth would recommend that the introduction of Thriving Kids presents an opportunity to create a nationally consistent early childhood regulatory framework.

Avoid Duplication of Registration Requirements

Similarly, there are several areas whereby the requirements to meet our various registration obligations are duplicated with other organisation and individual employee certifications:

• ISO Audits: As part of the MedHealth group of companies we hold ISO 9001:2015 - Quality management systems certification to ensure we have consistent and compliant quality across all organisations in the Group. There is already duplication of the quality measurements in ISO audits and NDIS audits which could be eliminated and reduce audit costs and time by identifying and

crediting these items. We would recommend that any Thriving Kids registration requirements avoid similar duplication.

• Professional Registration: as allied health professionals our clinical staff are required to maintain annual professional registration. In obtaining qualifications and maintaining this registration these clinicians are bound by professional standards and compliance. Additionally all clinicians hold current state based Working with Children checks. It is recommended that no additional checks are required for clinicians under Thriving Kids and current approvals can be applied.

Recommendations

• Registration should be simple, centralised and follow a transparent process that is consistent across the board yet is not onerous from a governance perspective. In doing so it will achieve the necessary quality and safeguarding for participants whilst reducing the cost burden.
• Concessions should be explored to reduce registration requirements for organisations holding ISO 9001 certification ensuring overlapping audit requirements require one review.
• Worker Registration: where duplications exist with professional registrations these should have mutual recognition.
• WWCC- we strongly recommend the introduction of a national Working with Children Check especially as a national organisation we frequently have staff working across multiple states and territories.
• Panel Arrangements: improvements in quality regulation and pricing to reward quality would result in a reduction in volume of poor providers and result in better outcomes for participants and financial viability of the scheme. The introduction of panel arrangements would improve quality focus and enhance participant informed choice and control.

Terms of Reference

Identify equity and intersectional issues, in particular, children who identify as First Nations and culturally and linguistically diverse.

First Nations

MedHealth is aware the First Peoples Disability Network (FPDN) have written to the Minister to outline their position on Thriving Kids and we support their recommendations as per below. The FPDN noted that the federal debate about “foundational supports” is occurring while progress on Closing the Gap remains off track for most targets and children continue to experience unacceptable inequities. National child and family organisations and Aboriginal community leaders have called for better measurement and accountability on outcomes that matter for children, not only program inputs.

They highlight several key areas to ensure Thriving Kids minimises the risk of inequity and intersectional issues:

• Co-design: engage k with First Nations people to ensure the Thriving Kids initiatives are designed with First Nations people with disability, to make sure that it meets the needs of First Nations children with developmental delay and autism“.
• Diagnostic assessments:

• Affordability: should ensure access to the relevant assessments regardless of socioeconomic status.
  • Accessibility: there is a high rate of under-diagnosis as First Nations children often live in rural and remote areas, and even regional places where these services aren’t available to them.
• Services:
  • Affordability- “under the NDIS, people who are getting NDIS supports are getting some really good services, which they would never be able to afford by themselves, and we hope that that kind of support and service isn’t taken away”.
  • Availability of services- the FPDN state “What happens when our kids do get diagnosed? What services are available to them? There are all those issues. kids still have individualised supports where it’s required. And we also hope that any Thriving Kids program doesn’t limit the amount of supports that they can receive.”
• Child Protection concerns: the FPDN state “A lot of our mob are worried and have very valid concerns that if their kids get a diagnosis of any kind of disability, then they’ll be brought to the attention of the child protection system. Because we do know that more of our kids with disabilities are taken away from their families and put into foster care for a variety of reasons. And that’s not often got to do with the family environment or their ability to look after their babies.”

The Network is seeking five commitments to make Thriving Kids work:

1. A “no child loses out” guarantee. Children keep current NDIS supports until alternative services are operating in their community, independently verified for quality and cultural safety.
2. First Nations co-design and leadership. Ring-fence funding for Aboriginal Community Controlled Organisations (ACCOs) to design, deliver and evaluate Thriving Kids supports, consistent with Closing the Gap Priority Reforms. Joint governance with peak First Nations bodies should be embedded from day one.
3. Choice and control protected in practice. Foundational supports must add options, not replace rights. Where clinically indicated or due to complex family circumstances, individualised packages should remain available. Navigation support must be funded so families can choose culturally safe providers.
4. A credible workforce transition plan. Stabilise local allied health and family support services, with targeted measures for regional and remote communities, and for women-led practices that predominantly support neurodivergent children. Avoid sudden funding shocks that break therapeutic relationships.
5. Transparency and accountability. Publish a national implementation timeline, state and territory co-funding arrangements, coverage maps, and quarterly dashboards showing outcomes by Indigeneity, region and gender, aligned to Closing the Gap reporting.

Culturally and Linguistically Diverse

As an large national provider of allied health disability services MedHealth delivers services to a diverse ethnic mix of participants and appreciates the challenges English language proficiency and socio-economic disadvantage create for children and families dealing with development delay and ‘mild to moderate autism.

The development of Thriving Kids initiatives must ensure feedback from leading multicultural organisations is heard as a key part of consultation and codesign. For example in response to the Thriving Kids announcements SSI and National Ethnic Disability Alliance (NEDA) have both raised key issues as outlined below:

1. SSI: the leading refugee resettlement and multicultural services provider has encouraged the government to ensure culturally and linguistically diverse (CALD) children with disability and their families are included in the Thriving Kids program’s design, implementation and monitoring.

SSI Executive General Manager Service Delivery Eric Harper said it was critical to include CALD children with disability to ensure no child was left behind. Mr Harper said SSI’s Policy Brief – based on joint SSI/UniSA research – found that Australian children from CALD backgrounds were already disadvantaged in relation to early interventions for developmental delays and autism.

“This research shows that CALD children in the pre-school age group are around half as likely to access early support such as speech or occupational therapy as other Australian children,” he said. “As a result, these children miss out on important early interventions that address developmental issues from an early age. Socio-economic disadvantage and English language proficiency contribute to this, meaning it’s very important to include the voices of CALD parents and children in all phases of the new program.” Mr Harper said “These reforms have the potential to deliver more appropriate, accessible and evidence-based support for children and their families. But the principle of ‘nothing about us without us’ must extend to all Australians with disability, regardless of their cultural or linguistic background.

2. The National Ethnic Disability Alliance (NEDA) has expressed concerns about the potential impact of Thriving Kids on children with mild to moderate needs, advocating for proper consultation, co-design, and a longer, more inclusive rollout to ensure no families are left unsupported. NEDA’s concerns include:

• Consultation & Co-design: NEDA is concerned that the program’s design is not adequately informed by the lived experiences of multicultural communities, calling for more comprehensive consultation with disability organizations.
• Inclusion: There are worries that the program may not be culturally sensitive and that children over nine years old could be excluded.
• Implementation: NEDA advocates for a longer rollout timeline, including a trial period and ensuring alternative supports are fully in place before any families are moved from the NDIS.
• Affirming Design: There’s a strong push for Thriving Kids to be neuro-affirming and disability-affirming, avoiding harmful historical approaches.

Recommendations:

• The NDIS has developed a Cultural and Linguistic Diversity (CALD) Strategy 2024-2028 aiming to meet the cultural and language needs of all our participants. Having co-designed the CALD

Strategy with over 800 people from CALD backgrounds it should be utilised as a contributing tool for use in development of a Thriving Kids CALD strategy..

• Training and education for all stakeholders in key cultural practice considerations including:
  • Family relationships (e.g. multiple generations living in the one house), roles and naming conventions (e.g. all older, female extended family members and female friends of the family are “aunties”) may extend from the immediate family to the community the family are engaged with.
  • Personal space and physical contact norms vary across cultures (e.g. handshakes between men and women is not appropriate in some cultures).
  • Days of celebration or remembrance may impact a participants availability for sessions or requirements for sessions (e.g. activities while fasting).
  • Beliefs about disability (e.g. viewing it as a gift or curse), help seeking and experiences of service access and outcomes (including legal, health and education) may vary across cultures.

Several resources already exist for service providers including, but not limited to:

• Cultural and Linguistic Diversity Strategy, National Disability Insurance Scheme (NDIS)
• Working with Culturally and Linguistically Diverse (CALD) Adolescents, Australian Institute of Family Studies
• Working with Interpreters, Victorian Government
• Integrated Trauma Recovery Service Model, Foundation House
• Working with Refugees, New South Wales Refugee Health Service
• Engaging CALD communities in the NDIS, Flinders University

Terms of Reference

Identify gaps in workforce support and training required to deliver Thriving Kids.

Current Issues: Workforce shortages are challenging for the disability sector and particularly acute for allied health professionals.

Recruitment and retention of allied health professionals to deliver Thriving Kids therapy in a tight labour market with high wage growth will be a significant operational challenge and cost burden for all providers, including MedHealth. As summarised in the NDIS Annual Pricing Review report:

Data on economic conditions suggest strong demand for health and disability services, a tight labour market for health and disability related workers, as well as higher costs given high general inflation and wage inflation. The transferability of skills and qualifications across the care and support economy and the HCSA sector means that NDIS providers need to compete for workers with aged care, health care and childcare services. This competition is influenced by various factors such as relative wages.

Recommendations:

1. Workforce supply: to improve supply, increase capacity to service participants and enable providers to reduce recruitment costs, there simply must be an increase in university intake of students studying allied health courses to meet current and future demand.

2. Training: to ensure quality service provision across all Thriving Kids initiatives it is critical that there is an adequate workforce supply who are well trained in best practice early childhood service delivery. Such quality comes at a cost to the employer so it is recommended funding models allow for implemetation of workforce initiatives such as:
   • Work with universities and accrediting bodies to ensure the Best Practice Guidelines for Early Childhood Intervention, including the Key Worker model, are a requirement of the curriculum.
   • Provide subsidies to incentivise targeted training for new graduates for their first two (2) years of employment.
   • Invest in the development and delivery of post-graduate accredited training in the Best Practice Guidelines for Early Childhood Intervention, including the Key Worker model.
   • Develop a clear workforce strategy for early intervention and allied health to complement other existing workforce strategies.
3. Staff wages: competitive pricing is critical for attracting and retaining qualified staff, especially as wage inflation and shortages show no signs of abating. If wages are not adjusted in line with these increases, providers will be unable to maintain the quality and availability of services, particularly in rural and regional areas where the demand for therapeutic services often outstrips supply.

Other Stakeholders

Health

It can be challenging for medical practitioners and specialists to stay across the range of supports and services within what will will become the Thriving Kids sector.

It is crtitical that these medical practitioners are provided consistent education and ongoing information regarding all Thriving Kids initiatives. This would also ensure an understanding of their key role in the ecosystem of supports and services. It would be expected they would have access to a consistent centralised resource library of information and material to provide families accessing Thriving Kids.

Education

Ensure all State Education Departments undertake workforce initiatives to ensure the success of Thriving Kids such as:

• Training and support: Provision of ongoing funding for mandatory training and support for educators and service providers to build inclusive practices and confidence in supporting children with disability in early childhood education and care (ECEC) settings. Capacity building for all stakeholders across the ecosystem may require consultation with Allied Health team members to improve understanding of their key role in the continuum of care.
• Professional Development: Create continuous professional development and clearer career pathways to attract and retain skilled professionals.
• Qualifications and Training Reform: Reform qualifications and training packages to reflect the evolving needs of children and the workforce.

Terms of Reference

Draw on domestic and international policy experience and best practice.

The Thriving Kids initiative presents a unique opportunity to collate best practive policy and service delivery modelling both within Australia and internationally. There is a signficant range of information available across a diverse range of topics so we have chosen to provide input from a select number of these resources that best aligns with the proposed models and key focal areas as outlined above.

Domestic Policy Experience and Best Practice

1. Australian Child and Family Supports Alliance (ACaFSA) Theory of Change for Foundational Supports for Early Childhood.

ACaFSA’s vision is for every child with disability, developmental delay, or concern to thrive, supported by equitable, accessible, and timely services. Their principles—focused on equity, accessibility, child-centred approaches, empowered families, timely and outcomes-focused supports, meaningful inclusion, and strong partnerships—are critical to ensuring families receive the support they need to nurture their children and foster community participation.

ACaFSA’s approach emphasises:

• Equity and access: Ensuring that all children, particularly those in underserved areas or from vulnerable cohorts (e.g., Aboriginal and Torres Strait Islander and culturally and linguistically diverse families), can access high-quality and culturally safe services.
• Integration and coordination: Establishing interconnected systems that streamline navigation for families, reducing administrative burdens and ensuring no gaps in service delivery.
• Workforce development: Building a sustainable, skilled workforce to deliver evidence-informed supports tailored to the needs of children and their families.
• Family empowerment: Strengthening families’ capacity to make informed decisions and advocate effectively for their children.

2. NDS’s submission, ‘Building Stronger Foundations for Inclusive Disability Supports’ (submitted to the Department of Social Services Fopundational Supports review,5 December 2024),

This submission highlighted the urgent need for a comprehensive foundational supports framework, as recommended in the NDIS Review. This framework includes:

• Reducing reliance on the NDIS: By strengthening non-NDIS supports, such as early intervention, peer support, and navigation services, we can better serve families before their needs escalate.
• Equity in access: Ensuring services are culturally competent and accessible to underserved populations, including Aboriginal and Torres Strait Islander families, CALD communities, and those in rural and remote areas.
• Sustainability: Creating a sustainable, outcomes-focused system with clear accountability, workforce development, and continuous improvement mechanisms.

3. NDS submission to Inquiry into foundational and disability supports available for children and young people in NSW NSW schools, early learning centres, and other services should be part of the ecosystem of supports for children, young people, and their families.

• Address the barriers for early intervention supports accessing schools to provide best-practice capacity building supports (including imposition of access fees).

• Review New South Wales Education Standards Authority (NESA) requirements to account for teachers providing early childhood intervention in the community.
• Review the Educational Services (Teachers) Award to account for teachers providing early childhood intervention in the community.
• Strengthen resourcing of supported playgroups as part of connected ecosystem of foundational supports in NSW ensuring these are accessible across the state.
• Implement workforce initiatives to strengthen the workforce in early intervention, youth support, and family support services.
• Provide subsidies to incentivise targeted training for new graduates for their first two (2) years of employment.
• Invest in the development and delivery of post-graduate accredited training in the Best Practice Guidelines for Early Childhood Intervention, including the Key Worker model.
• Develop a clear workforce strategy for early intervention and allied health to complement other existing workforce strategies.
• Work with universities and accrediting bodies to ensure the Best Practice Guidelines for Early Childhood Intervention, including the Key Worker model, are a requirement of the curriculum.

4. AHPA submission to NSW Inquiry into Foundational and Disability Supports for children and young people in NSW

The submission by Allied Health Professions Australia (AHPA) to the Select Committee Inquiry into foundational and disability supports for children and young people in New South Wales (NSW). highlights the critical role of allied health services in supporting the development, health, and wellbeing of children and young people with developmental delays or disabilities.

AHPA emphasizes the importance of allied health services in addressing gaps in disability supports, both within and outside the NDIS. Role of Services: Foundational and disability supports are essential during critical developmental windows. Allied health professionals provide assessments, interventions, and capacity-building for families and caregivers.

Key points include:

• NDIS Exits: Concerns are raised about children being deemed ineligible for NDIS services without alternative supports available.
• Service Availability: Access to services is insufficient, especially in rural and remote areas. Workforce shortages and high costs further limit access.
• Diagnostic Services: Timely identification and assessment are crucial for better outcomes. Streamlined pathways to allied health professionals are needed.
• Best Practices: The New Best Practice Framework for Early Childhood Intervention should guide service models.
• Workforce Issues: Workforce shortages impact service quality. Models of care should leverage the expertise of allied health professionals and ensure flexibility to meet individual needs.

Recommendations: AHPA advocates for a comprehensive, inclusive, and well-connected ecosystem of supports, emphasizing the importance of allied health professionals in delivering evidence-based care across diverse settings.

• Establish a coordinated and expanded ecosystem of supports in NSW, aligned with a nationally consistent framework.
• Ensure continuity of services during reforms to the disability sector, including changes to NDIS access.
• Engage allied health professionals in the design and delivery of foundational and disability services.
• Guarantee access to sufficient supports for all children, families, and caregivers, with choice in service providers.
• Utilize diverse workforce models to involve private sector allied health providers.

5. Additional National and NSW Reports

There are common findings across three major reports regarding children with disability in early childhood education and care (ECEC):

• IPART Final Report – Review of Early Childhood Education and Care (December 2023),
• Final report: Working together to deliver the NDIS from the NDIS Review December 2023), and
• Productivity Commission’s Final Report “A Path to Universal Early Childhood Education and Care” (2024).

These reports collectively highlight persistent barriers, the need for inclusive practices, funding alignment, workforce training, and system coordination.

Key Findings and Comments on Children with Disability:

The key themes are access, inclusion, funding, workforce, and system coordination.

• Access- All three reports identify significant barriers for children with disability in accessing ECEC services. These barriers include lack of inclusive practices, insufficient support for educators, and inadequate funding for necessary adjustments.
• Inclusion- The reports emphasise the importance of targeted supports and inclusive practices to ensure children with disability can participate fully in ECEC. Recommendations include early identification and support, foundational supports in everyday settings, and improved service navigation.
• Funding- There is a call for better alignment and adequacy of funding systems to reduce complexity and ensure services can meet the needs of children with disability. This includes proposals for foundational supports outside the NDIS and streamlined access to funding. It also suggests that regulatory and funding systems should be designed to better accommodate the needs of children with disability, including clearer pathways for support and service navigation.
• Workforce- Workforce training and capability are highlighted as critical to supporting children with disability in ECEC. Reports recommend investing in professional development, reducing administrative burden, and implementing national workforce strategies. The report notes that regulatory compliance contributes to workforce stress and administrative burden, especially for smaller providers. It suggests that the NSW Department of Education take a more active leadership role in implementing the National Workforce Strategy and refreshing its own workforce strategy
• System Coordination- IPART recommends a digital service and data strategy to help families—including those with children with disability—find and choose appropriate services more easily. Improved data collection, digital tools, and service navigation are recommended to enhance system coordination. These measures aim to provide better information for families, support decision-making, and ensure accountability and continuous improvement. The report calls for a more

coordinated and simplified policy and funding approach across state and federal governments to better support inclusion.

• Regulatory Complexity and Duplication: The report highlights that ECEC providers face overlapping and complex regulatory requirements, particularly when navigating both state and federal systems. It recommends that state and federal governments work together to develop a more harmonised and simplified regulatory and funding framework
• Transparency and Accountability: While not directly critical of the ECEC Regulatory Authority, the report implies a need for greater transparency and coordination in how regulatory decisions and funding are communicated and implemented. These supports would be delivered in mainstream settings, including preschools and childcare centres, and would be funded outside the NDIS
• Service Navigation: The Review recommends the introduction of navigators to help families find and access services across the NDIS, foundational supports, and mainstream systems like ECEC

6. Productivity Commission’s Final Report “A Path to Universal Early Childhood Education and Care” (2024)

The Productivity Commission’s Final Report (2024) titled “A Path to Universal Early Childhood Education and Care” makes several key recommendations to improve the inclusion of children with disability in ECEC settings. These recommendations are part of a broader strategy to build a universal, high-quality, and inclusive ECEC system by 2036.

Key recommendations and observations regarding children with disability in the ECEC sector.

1. Universal Access Must Include Children with Disability:

• The report emphasises that a universal ECEC system must be inclusive of all children, including those with disability.
• It states that inclusion is a core principle of universal access and that children with disability should have the same opportunities to participate in high-quality ECEC as their peers

2. Barriers to Access:

• The Commission identifies that children with disability face significant barriers to accessing ECEC, including:
  • Lack of inclusive practices in some services
  • Insufficient support for educators
  • Inadequate funding for inclusion-related adjustments

3. Foundational Supports and Workforce Capability:

• The report supports the development of foundational supports (aligned with the NDIS Review) to be delivered in mainstream settings like ECEC.
• It also recommends investing in workforce training and capability to ensure educators are equipped to support children with disability

4. Funding Reform:

• The Commission calls for better alignment of funding systems (e.g., NDIS, Inclusion Support Program, state-based funding) to reduce complexity and ensure services can meet the needs of children with disability

5. Data and Accountability:

• It recommends improved data collection and reporting on the participation and outcomes of children with disability in ECEC to ensure accountability and continuous improvement

7. Extracts from recent article by: David Trembath-head of autism research and senior principal research fellow with the Kids Research Institute Australia, Andrew Whitehouse- deputy director of the Kids Research Institute Australia and Kandice Varcin- a senior research fellow in autism research with the Kids Research Institute Australia.

Best practice for autistic children

Australia’s national guideline sets out recommendations for supporting the learning, participation and wellbeing of autistic children and their families. The guideline puts forward a principles-based approach that places children and families at the centre, and includes recommendations for goal-setting, selecting and delivering supports, monitoring outcomes and safeguarding.

The goals for supporting autistic children are no different from those for all children. They need love, opportunities to learn through everyday activities, and strong connections with family, culture and community. The difference comes when children are struggling, and the question shifts to what additional supports will help. Keeping this broader understanding front of mind makes every other decision about extra support clearer and more consistent.

A stepped care approach

The guideline states support should be personalised for each child and family. There is no blanket approach to supporting autistic children that will be equally beneficial for each child and family.

At a system level, it means a stepped-care model of support in which the right type of support is delivered at the right time and in the right amount to match the child’s age, developmental level, strengths, needs and family circumstances. This is best practice internationally and something we should strive for.

Let’s say a parent takes their child to a routine visit with a maternal child health nurse or GP, and there are signs of developmental delay. Perhaps the child is behind in terms of motor skills and communication.

In a stepped-care model, the nurse or doctor can listen, ask questions, and understand any concerns the parents may have. If some additional support is needed, the “next step” depends on exactly what was learned. For one parent, the “next step” might be some information and strategies to encourage their child’s development, for another it might be connection to a community playgroup, and for another a referral for some further assessment.

If difficulties emerge in childcare or school settings, the most effective approach is usually to strengthen the capability of educators to include and support children. There may also be scope for targeted specialist input, such as speech pathology, physiotherapy, or psychology, when needed.

The point is that the “steps” match the needs, and will be different for each child and family.

As professionals, we can support parents to make decisions by encouraging them to ask: “is this the best next step for my child and family?” This approach helps prevent the over-servicing that can happen when families are directed straight to the highest level of support.

What should happen next?

The new Thriving Kids program represents a genuine opportunity to transform how Australia supports children with mild to moderate developmental delays, including many autistic children.

Done well, it could become the stepped-care model of support that families desperately need. Get it wrong, and it becomes another well-intentioned policy that fails the children it’s meant to help.

Stepped-care models require deliberate design, sustained investment and careful attention to implementation details.

The key to getting this right lies in genuine co-design with the people who matter most: children and families themselves. They understand what works and what doesn’t, and where the gaps are.

International Policy Experience and Best Practice

United States of America

There are three key elements to the USA approach to developmental concerns:

1. Checklists: parents are encouraged to complete developmental monitoring using freely available checklists.
2. Screening: the American Academy of Pediatrics (AAP) also recommends developmental screening for all children during regular well-child visits at least at these ages:
   • 9 months
   • 18 months
   • 30 months
3. Autism Screening: in addition, AAP recommends that all children be screened specifically for autism during regular well-child visits at:
   • 18 months
   • 24 months

Developmental monitoring and screening

| Developmental Monitoring | WHO: Everyone – families, other caregivers, and anyone working with young children

WHAT: Looks for developmental milestones

WHEN: Early childhood, especially from birth to 5 years

WHY:
To help:
- celebrate a child’s development
- talk about a child’s progress with doctors, childcare providers, teachers, and other professionals |

| | - learn what to expect next
- identify any concerns early

HOW: With easy-to-use, free checklists available at www.cdc.gov/Milestones | | Developmental Screening | WHO: Healthcare and early childhood professionals trained in screening

WHAT: Looks for developmental milestones

WHEN:
- Developmental Screening at 9, 18, and 30 months of age
- Autism Screening at 18 and 24 months of age
Additional screenings can be done for concerns

WHY:
To find out:
- if a child needs more support
- if further evaluation is recommended

HOW: With a formal, validated developmental screening tool | | Early intervention and follow-up | When a developmental concern is identified, further evaluation through the relevant state’s early intervention system is often the next step. Healthcare providers, and anyone who works with young children, can refer families to early intervention for assessment. Families can also refer themselves directly.

Each state and territory has their own system for children who are eligible.
- State early intervention programs usually provide developmental services for children from birth to 3 years of age, with some states also serving older children
- Local public school systems typically provide developmental services and support for children age 3 years and older |

Source: https://www.cdc.gov/act-early/about/developmental-monitoring-and-screening.html

Canada

Canada has a provincially based approach and the below applies to the approaches utilised in Quebec

Act Early Program:

At 18 months of age, all children are eligible for a free 1 hour appointment with a nurse to discuss child development using a tool called ‘ABCdaire 18 mois +’ (linked with 18 months vaccination). If concerns

identified, families can access the Act Early Program to receive support. This may include a screening of the child’s sleep, language, motor skills, cognition and social emotional development. Following the screening, 3 outcomes possible:

• No concerns, no further action
• Early intervention services via community organisations, groups, etc.
• Further Assessment

Families can benefit from the Act Early Program until the child is 5 years old to give them the best possible start and support a smooth and successful transition to school.

Source: https://www.quebec.ca/en/famille-et-soutien-aux-personnes/enfance/developpement-des-enfants/outils-ressources-developpement-enfants/the-agir-tot-program-early-screening-to-better-address-childrens-needs

Comment: MedHealth is of the opinion this is preferred to the proposed 3 year old well-being visit referenced in Minister Butler’s speech as it is an earlier intervention and captures the critical window to support the child’s development prior to them starting school.

For children with specific diagnoses or disability, they can access free blocks of therapy provided by allied health.

Source: https://kidsnewtocanada.ca/screening/child-development