SUBMISSION REGARDING THE PROPOSED THRIVING KIDS INITIATIVE
Prepared by Kids I Can
Suite 2 84 – 86 Fitzmaurice Street Wagga Wagga NSW 2650
Phone: 0269 171 471
Email: admin@kidsican.com.au
27th September 2025
Terms of reference
- Examine evidence-based information and resources that could assist parents identify if their child has a mild to moderate developmental delay and support parents to provide support to these children.
Developmental delay is typically identified when a child does not reach developmental milestones at the expected times in one or more domains (motor, cognitive, language, social- emotional, or adaptive skills)
Moderate developmental delay is commonly defined as performance that is between 2 and 3 standard deviations (SD) below the mean on standardized developmental assessments, or more than 2 SD below the mean in one or more developmental domains. A child 5 years of age with a moderate developmental delay would be performing at the level of a 2.5 to 3 year old.
Mild developmental delay, while not universally standardized, often refers to functioning approximately 1.5 to 2 standard deviations below the mean on standardized developmental assessments, or an IQ in the range of 50–70 for intellectual functioning.
The identification of developmental delay within NSW has been reliant on:
- Parents being concerned and contacting private or public services (such as community health) to determine whether a delay exists. This has relied on the parents having knowledge of developmental milestones and the means to access these supports. Access to community health is reliant on a medical referral and often involves significant wait times. There is often an upper age limit that children can access these supports, such as 8 years of age.
- Early Childhood Education and Care settings. The identification of children requiring support is reliant on the skill of the staff being able to identify the child not meeting their developmental milestones. In more recent years many centres in regional areas have had
difficulty attracting staff to the sector and hence staff may not have the skills required to provide this support. Not all families choose to access this support and therefore this may not capture all children requiring support
- Early Childhood Nurses. Whilst screening checklists are completed this does not ensure that all children having needs are identified. Due to limited resources this support is limited and similarly not all families choose to access this support.
- General practitioners are another source of identification, however not all general practitioners have a comprehensive knowledge of child development and may not identify this need. With the costs associated accessing this support it may not be accessed by all families. If a referral is made to a paediatrician there is often significant wait times that may delay identification by 18 months to 2 years.
- School staff. Once again this Is reliant on teachers having the time and knowledge to support the identification of a child that needs additional support.
“Does this child need help” is a program that has been rolled out to support the identification by professionals of children with developmental delays. Access to this program has been limited and is dependent on people living within areas where the training has been provided to the professionals in services the child accesses.
Ages and Stages has been used by the NDIS and services to assist in the identification of children with developmental delays across the domains of development. This is completed by the parents/carers as a questionnaire. It is reliant on the parent/carer accurately completing the questionnaire. In order to access the questionnaire the parent/carer first needs to identify that the child is experiences delays in their development.
Thriving Kids
There has not been a release of information regarding how children will be identified. There has been a reliance on observations and screening tests in the past. This has often been reliant on parents accessing supports that can complete these observations and screeners. This does not ensure equity of access to a scheme open to children with mild to moderate developmental delays.
Nor has there been information provided regarding the skilling up of the workforce to ensure that those making the observations or completing screening assessments have the skills needed to do so.
Ideally the access to Thriving Children should be through the use of a standardised assessment to ensure that children are all considered equally, and the skill of the assessor observing the child or the parental knowledge is not a determining factor as to whether the child does/does not have a developmental delay.
Currently both the education and allied health sectors experience staff shortages. Where is the staffing to be found to provide this essential component of the scheme. Currently many NDIS plans go unspent or underspent due to a lack of services. The introduction of another scheme will increase the bureaucratic expenditure associated with administering the scheme without having the supports on the ground that will make a difference to the children and families it purports to support.
- Examine the effectiveness of current (and previous ) programs and initiatives that identify children with developmental 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.
Department of Education employed therapists: This support was traditionally limited to Schools for Special Purposes. There was a lack of consistency across the state regarding which schools had funding for this and those that could attract staff. It was a support limited to school and therefore parental involvement was not existent. Parent coaching has strong evidence regarding supporting their child with developmental delays through embedding strategies into routines across the day. The provision of supports in schools does not facilitate this. The child was often withdrawn from the classroom to provide this support. There was a focus on doing therapy to the child to “fix” a deficit rather than on inclusion and participation.
Department of Ageing Disability and Home Care employed therapists: Across NSW there was an abundance of supports in some areas (especially on the North Shore of Sydney), and other areas had a paucity of services. In regional areas the paucity of services was related to a lack of funding and difficulty attracting staff. The support in these areas was therefore tokenistic with many children and adults having extremely limited or no access to these supports.
Parent run Early Intervention Centers: Many parent groups across the state of NSW participated in fund raising activities to enable them to establish Early Childhood Intervention Centers. These centers often had very limited staffing (often educators with an Early Childhood background) and very limited capacity to provide supports.
Block funding for Early Childhood Intervention Centers: Over time the parent run Early Childhood Intervention Centers were successful in attracting government funding through the Department of Aging Disability and Home Care. The capacity of these centers was limited and often families experienced long waiting times to access these supports. It did provide publicly funded support, both educator and allied health supports, to children. This provided the opportunity for families to have a more wholistic approach to their child’s needs. Variable funding across the state and attracting appropriate staff to many areas impacted access of children and their families to this support.
Helping Children with Autism and Better Start Packages: These programs provided $14000 support spread across 2 years for children that met the criteria for these schemes. This created significant discontent in the sector with children fitting the diagnostic criteria having greater access to supports than those that didn’t. For example, a child with Spina Bifida that was reliant on a wheelchair for mobility was not able to access the scheme but a child with Cerebral Palsy with similar support needs could.
Community Health: Community Health has limited capacity due to the level of funding. There is often a waitlist and supports may have an upper age limit which further restricts access. Each allied health discipline is a separate department and these supports may or may not work in an integrated manner. With children who access supports to address delays across multiple developmental domains integration and coordination of these supports is an essential component of addressing the child’s needs in a wholistic manner.
Private Practitioners: Access to private practice supports is dependent upon the family’s capacity to access these services. To address developmental concerns multiple practitioners are often needed to be accessed across an extended period. Financially this places a significant strain on families and limits access for many people. Access to this type of support is not guaranteed across the state with many regional areas not having sufficient private practitioners to support the needs of the community. As a result, families often experience significant wait times.
Enhanced Primary Care Plans: For children with chronic conditions such as developmental delay they can access an Enhanced Primary Care Plan which enables them to access a Medicare rebate for a total of 5 sessions. If the child needs to access multiple providers, the access to support is limited. As previously stated this is dependent on the family capacity to pay for supports as these services often attract a gap payment. It is also dependent on private providers being available with capacity. Not all services are willing to accept the EPC as the reporting requirements are not funded and this cost is worn by the practitioner/business.
Department of Social Services Playgroup Funding: This funding was tendered and provided parents with developmental concerns access to playgroups that could provide strategies to support their child’s development. Access to these playgroups was limited due to staffing and funding and was dependent on families being aware of the playgroup and their child’s developmental needs.
NDIS: The NDIS has improved equity of accessing supports for children with developmental delay. This is an investment into the future, with Early Childhood Intervention having significant evidence regarding the impact on neuroplasticity and development. This removes the financial barrier to accessing supports and provides greater equity to children from all backgrounds. This allows children to have an individualized approach that meets their needs across their developmental profile. Similarly a lack of services in some areas impacts wait times for supports as does the length of time from having access accepted to plan implementation (which at times has been reported as being 2 years).
- Identify equity and intersectional issues, in particular, children who identify as First Nations and culturally and linguistically diverse
The impact of generation trauma impacts both groups. Services have not always had training in culturally appropriate support. Issue regarding the understanding of development delay in the context of culture is lacking and this impacts the willingness of these groups to access supports. Relationship underpins the impact of support and without this as a foundation supports will be ineffective.
For a family that is linguistically diverse their ability to navigate the system without support is limited and even in the presence of funding support may be limited due to the difficulty of accessing support.
- Identify gaps in workforce support and training required to deliver Thriving Kids.
Thriving Kids is still in the design phase however some information has been released. What we know so far is:
- Inklings and PACT programs will be delivered through Early Childhood Education and Care Centers
- Enhanced Primary Care plans will be available for families to use with Speech Pathologists, Occupational Therapists and Psychologists.
Inklings and PACT are both social communication programs. There are 5 developmental domains (motor, cognitive, language, social-emotional, or adaptive skills), however these programs are focusing on only one developmental domain. These programs are not individualised but are designed to be rolled out as a generalised program. This is not best practice and does not account for individualised needs or development across the developmental domains. Development is complex and it is only through addressing development across all of the developmental domains, through understanding the interplay and impacts of each area of development on the other areas of development that developmental delays and neurodivergence can be supported.
Parent coaching has long been recognised as best practice with strategies embedded within routines across the day. The delivery of these programs through Early Childhood Education and Care Centres and school does not support the parent learning strategies that can support their child’s development.
The provision of an enhanced primary care plan for speech pathology, occupational therapy and psychology discounts the role that educators, physiotherapists, dieticians etc play in supporting the development of the young child. It once again puts the onus on the family to pay for supports and this will put these supports out of reach of many.
The provision of Early Childhood Intervention has long been recognised as a being the gold standard in reducing the impact of delays on future disability and functional capacity. Through inadequate funding and ill informed practices the burden of funding will be shifted from the present to the future as lifelong impacts for this group of children impact their development and their future functional capacity.
It is unacceptable to gamble with the future capacity of our children. Access to support should not be determined by your socio-economic status in a civilised society.
All children deserve to have the support that they require to maximise their capacity and live a full and meaningful life.
Thriving Kids is a step backwards and the people that will be impacted are our children, our most precious resource.
- Identify mechanisms that would allow a seamless transition for all children with mild to moderate support needs.
It is not possible to role out a program that provides a seamless transition in the timeframes outlined.
The program is in the development stage. It is not ready to be rolled out.
The workforce to support this program does not exist. There is insufficient people within the sector currently. Diverting people to this scheme will further exacerbate this.
The costs associated with accessing supports through private practitioners (with or without an EPC) will mean that these supports are out of reach of many.
The Department of Social Services recently commissioned Monash University and PRECI to develop a Framework for the Provision of Best Practice Supports in Early Childhood Intervention. This had sector wide consultation and outlines how Early Childhood Intervention supports should be provided. Prior to the development of Thriving Kids this should be consulted and when the supports offered under Thriving Kids are not inline with this framework the question has to be asked as to why it would be funded.
QUESTIONS
What are the strengths and limitations of current models?
Budgetary difficulties with the cost of NDIS increasing significantly since its inception – The provision of capacity building supports to children aged 0 to 8 years is an investment in the future. There is wide acknowledgement the provision of Early Childhood Intervention improves long term outcomes reducing the need for future supports. Cutting early childhood intervention supports is likely to impact the future functional capacity of children with a moderate developmental delay or those with autism. This is likely to increase the need for supports in the future.
Wait times with NDIS. From the time a child is approved for access to the NDIS to the time that the plan is implement varies widely. For some children this time is relatively short and can be measured in weeks for other children timelines as long as two years have been reported.
Access to providers varies across the state. There is a lack of providers in regional, rural and remote areas that impacts the child’s access to supports. This causes children to have to wait for access to supports. This has had a positive effect on service delivery models with many models of supports arising to meet this need for families in remote locations without needing to travel long distances to access supports.
The workforce within the sector does not match the need. With price freezes and a decrease in the rates within the latest NDIS Price Guide and Pricing Limitations providers have left the sector which further impacts the provision of supports.
Families have choice and control and can access the type of supports that resonate with them and their family.
The provision of supports is not dependent on the family having the means to financially funding them. This provides greater equity of access.
The Framework for Best Practice in the Provision of Early Childhood Intervention supports provides for consistency in the delivery of high-quality supports.
What barriers do families face in accessing timely care?
Identification of the need for support. This continues to be reliant on parent’s understanding of development. For those children accessing Early Childhood Education and Care settings the staff may highlight challenges but this is dependent on their knowledge of development.
Not all families access Maternal and Child Nurses. This support can not capture all children.
General practitioners do not all have a comprehensive understanding of development and may adopt a wait and see approach.
In regional areas there are significant wait times to access paediatricians. This may be up to 2 years in some areas.
Not all families have supports in their local area the cost of travelling for support and accessing specialist services delays access and diagnostic services.
Having supports that a culturally appropriate for Frist Nations Children and Culturally and Linguistically Diverse families can impact their willingness to access supports.
What workforce or system supports would make the biggest difference?
Consistency in the approach. Currently the NDIS lacks consistency. There is significant variation in the timeframe from initial acceptance to access the NDIS to plan implementation. There is also inconsistency in the timeframe for eligibility assessments with some children receiving notification on their 6th birthday and others continuing closer to 9 years of age without having their eligibility questioned.
Increasing the workforce capacity to decrease waiting times. To do this the Price Guide and Pricing Limitations needs to reflect the sector pricing. The price freeze needs to be stopped and the price reductions for some allied health practitioners reversed. The cut to travel costs for practitioners needs to be reversed to ensure practitioners can support rural communities.
Children accessing the Early Childhood Approach should remain on the NDIS to 8 years of age without having their eligibility questioned to ensure that early intervention capacity is maximized.
Thriving Kids does not address these issues and is unlikely to provide better outcomes for children.
SUMMARY: QUESTIONS THAT NEED TO BE ANSWERED
- What is the referral pathways to Thriving Kids?
- What assessments will be used to determine the extent of the developmental delay across all domains of development?
- What evidence will be used to determine the validity and reliability of the assessment tools?
- Who will administer the assessments?
- How will training be provided in the administration of the assessments?
- What is the definition of a mild and moderate developmental delay used by the Thriving Kids Initiative and is the definition supported by the evidence?
- Who will deliver supports under Thriving Kids?
- How will supports be individualized to meet the complex developmental needs of children?
- How will the effectiveness of the program be monitored?
- How will parents be supported to provide supports to their children?
- How will disadvantaged groups be supported to access supports that incur a cost?
- Where will the workforce come from to implement the program?
- How does this program adopt the principles of the Framework for Best Practice in the Provision of Supports for Early Childhood Intervention?
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Donalee Gregory
Physiotherapist
Janine Tout
Educator
Sarah Lilburne
Occupational Therapist
Laura Le
Speech Pathologist