Submission 68 — Independent Schools Australia — Inquiry into the Thriving Kids initiative | External submission

ISA SUBMISSION

October 2025

ustodians of country throughout >
and community. We pay respect to
iliation.

T: 02 6282 3488 | W: www.isa.edu.au | E: isa@isa.edu.au

INDEPENDENT SCHOOLS AUSTRALIA

ABOUT ISA ……………………………………………………………………………………………………………………………………………. 4
INTRODUCTION ……………………………………………………………………………………………………………………………………. 5
RECOMMENDATIONS …………………………………………………………………………………………………………………………… 6
THRIVING KIDS INITIATIVE – FEEDBACK AND COMMENTARY ………………………………………………………. 7 ACCESS AND EQUITY …………………………………………………………………………………………………………………………………….. 7 NAVIGATING COMPLEXITY…………………………………………………………………………………………………………………………… 8 QUALITY AND CONSISTENCY ……………………………………………………………………………………………………………………… 9 RESOURCING …………………………………………………………………………………………………………………………………………………. 10 INSIGHTS FROM THE SYCAMORE SCHOOL, QLD ……………………………………………………………………………….. 10
CONCLUSION ………………………………………………………………………………………………………………………………………… 12

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1. ABOUT ISA

Independent Schools Australia (ISA) is the national peak body for Independent schooling in Australia. ISA represents the sector on national issues and engages with the Australian Government, national agencies, media, key stakeholders, and the wider Australian community.

Working with the eight state and territory Associations of Independent Schools (AISs), ISA represents almost 745,000 students, 1,230 schools and a workforce of over 128,600 people.

Independent schools are long-established partners in Australia’s education system, alongside government and Catholic schools. They make a valuable contribution to society and the learning and wellbeing of Australian children.

The Independent school sector is diverse, and schools serve a wide range of communities. The latest available data shows that more than one in six Australian school students attends an Independent school. For secondary students, it is over one in five.

Students at Independent schools reflect the full diversity of Australian society – including those who experience one or multiple forms of disadvantage. These students include:

high-needs students with disability attending special schools
Aboriginal and Torres Strait Islander students attending remote 100 per cent Indigenous schools
students living in regional, rural and remote locations
highly disadvantaged and disengaged young people attending Independent special assistance schools.

Most families with children enrolled in Independent schools are middle-to-low-income earners, increasingly from culturally diverse backgrounds, and residing in outer-suburban and inner-suburban communities. Many of these families are currently facing economic stress and are making substantial sacrifices for their children’s education.

According to the most recent data, the majority of Independent schools charge annual fees of less than $6,000, and there was a greater number of schools charging less than $1,200 per year than those charging over $20,000. Some Independent schools charge no fees at all. More than half of the sector’s recurrent income comes from parents and families.

Many Independent schools provide a religious or values-based education. Others promote a specific educational philosophy or alternatively recognised curriculum. Some have been established by community groups seeking to meet particular needs or to reflect the religious values of a community.

Independent Catholic schools are a significant part of the sector, accounting for eight per cent of the Independent sector’s enrolments.

Most Independent schools are set up and governed independently on an individual school basis. However, some schools with common aims and educational philosophies are governed and administered as systems, for example, Lutheran schools. Systemic schools account for 20 per cent of schools in the sector but the majority of schools in the sector are autonomous non-systemic schools.

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2. INTRODUCTION

Independent Schools Australia (ISA) prepared this submission in response to the Australian Government Standing Committee on Health, Aged Care and Disability’s inquiry into the Thriving Kids initiative.

Due to changing student cohort traits, Independent schools are increasingly required to support students with a diverse range of learning needs.

According to the Australian Early Development Census, in 2024 23.5 per cent of Australian children were developmentally vulnerable in one or more areas including communication skills, language and cognitive skills, social competence, emotional maturity, and health and wellbeing. Indigenous and Torres Strait Islander children, those living in remote or very remote areas, or those experiencing socioeconomic disadvantage are more likely to be developmentally vulnerable than their peers.[1]

Between 2021 and 2024 there was a decrease of almost two per cent in children who were developmentally on track across all domains.[1]

There is a significant intersection between students experiencing developmental vulnerability, and those living with disability. According to the Australian Bureau of Statistics, in 2022 more than two-thirds of children and young people aged 0-24 years with disability needed assistance with at least one activity of daily life, and the most commonly reported disabilities for this cohort included Autism Spectrum Disorders (18.5 per cent) and behavioural, cognitive and emotional problems such as Attention Deficit Hyperactivity Disorder (17.3 per cent).[2]

The number of children and young people living with a reported disability is also increasing, having grown from 8.3 per cent in 2018 to 12.1 per cent in 2022.[2]

To best support Australian children, the need for change is clear. The current supports delivered through initiatives such as the National Disability Insurance Scheme (NDIS) are not adequately removing barriers for learning in schools for students living with disability, or those who are developmentally vulnerable due to other factors. ISA supports initiatives which provide schools the support they need to create equitable learning environment for all students, regardless of their background or context.

When preparing this submission, ISA consulted with the AISs, the Australian Parents Council, the Queensland Independent Schools Parent Network, and The Sycamore School founder Cindy Corrie.

___[1] AEDC Nation report, 2024, https://www.aedc.gov.au/resources/detail/2024-aedc-national-report

[2] Children and young people with disability, Australian Bureau of Statistics, https://www.abs.gov.au/articles/children-and-young-people-disability-2022

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3. RECOMMENDATIONS

ISA makes the following recommendations on the design and implantation of the Thriving Kids Initiative:

No child should be worse off under the Thriving Kids Initiative. The level of support offered to children with mild to moderate developmental delays and autism should be equal to or exceed the supports currently offered though the NDIS. While direct comparison of services may not be possible due to the revised approach being taken by Thriving Kids, a ‘better off overall’ test should be applied to ensure that Australian children experiencing delay or disability have every chance to thrive.
The launch of Thriving Kids should be supported by a short-to-medium term transitional program for children already on the NDIS whose supports are expected to be migrated to be delivered under Thriving Kids. This group of children should not be used to test the program for later improvement.
During the design and implementation of the Thriving Kids initiative, consideration should be given to how it will operate effectively in different contexts – a national ‘one size fits all’ approach will result in continued inequitable outcomes for some of our most disadvantaged students. This initiative is an opportunity to better address existing cultural and systemic inequities in access to developmental supports.
Any additional responsibilities for schools in assisting with the delivery of the Thriving Kids Initiative should be supported by adequate additional funding for schools. This funding should be sector-blind and commensurate with the additional expectations being placed on schools. If a school-based deliver model is selected, a significant, recurrent increase in the direct employment of school-based allied health staff (speech pathologists, occupational therapists, school psychologists, etc.) to deliver services within the school and train teachers will be needed.
Any new model for support delivery based in schools should be piloted prior to national implementation. Pilots should be held in a range of schools across various local contexts. This will allow for refinement in the approach, and for lessons learned to be shared with all schools.
When determining funding and resource allocation under the Thriving Kids Initiative, state and territory governments should work closely and transparently with their jurisdiction’s Association of Independent Schools. The AISs are best placed to both support Independent schools across a wide range of contexts, and to identify where efficiencies can be gained when allocating resources to schools.
The Australian Government should consider portability issues when a child moves from one jurisdiction to another to ensure a child receives comparable or improved foundational supports in the new school setting, resolving the issues of jurisdictional inconsistency occurring under the NDIS.
The Australian Government should work closely with parent bodies and disability centered community groups to consult on the design and implementation of this initiative. Significant attention will need to be given to clearly communicating and justifying which service pathway is appropriate for any given child depending on their support needs.

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4. THRIVING KIDS INITIATIVE – FEEDBACK AND COMMENTARY

The Thriving Kids initiative represents a significant shift in how services will be funded and delivered for children with mild to moderate developmental delays and autism.

The proposed Thriving Kids initiative is an opportunity to address several critical issues that have emerged within the current NDIS system. These challenges relate to the availability of supports, the efficiency of access, and a need to reduce complexity for families.

The NDIS was originally estimated to cost $13.6 billion per year for 411,000 participants. It is now forecast to cost $64 billion by 2029 with over 740,000 participants. Children under 15 make up nearly half of all NDIS participants, and half of all new entrants are under nine.[3]

As a part of its review of the NDIS, the Australian Government found that there are more children entering the NDIS than originally forecast due to a higher than expected rate of disability and delay among young people, and insufficient supports being made available for children with disability in mainstream settings.[4]

While the importance of effective early intervention to support young people with developmental delays is widely known, it has not been consistently delivered through the NDIS. The following passage from the NDIS Review: Final Report captures the issues:

“With so few supports outside the NDIS, it is not surprising that parents are fighting to get their children with developmental concerns or disability into the NDIS. After receiving early intervention supports, they are reluctant to leave the scheme for fear of being left without support. In addition, early intervention has not always been based on best practice and there has been too little support for families. All have combined to produce poor outcomes for children and families. These failings have also placed financial pressure on the scheme.”[5]

Further, following the introduction of the NDIS, many state and local services for early intervention were wound back, leaving parents with few options other than to apply for NDIS funding. This has created a system where the NDIS is often the only way to access support.[6] Additionally, the current NDIS system for younger children can be confusing and difficult to navigate for families, involving long waitlists and complex processes.

Thriving Kids represents an opportunity to address these flaws in the current service delivery model, and to provide earlier, more accessible school and community-based support.

ISA’s submission provides feedback on the proposed Terms of Reference for the Thriving Kids Initiative, as well as feedback from Independent school stakeholders on broader challenges and concerns relating to this initiative.

ACCESS AND EQUITY

Stakeholders have raised significant concerns regarding how the Thriving Kids model will operate in regional and remote areas. In many areas of Australia, there are Independent schools and families who already struggle to access the necessary specialist support staff, allied health providers and physical aids to support the wide range of needs within their student populations. Even when developmental support services can be accessed, families in regional and remote areas often face:

long waitlists for allied health professionals

___[3] M. Butler, Speech from Minister Butler, National Press Club – 20 August 2025, Australian Government Department of Health and Aged Care, 2025.

[4] NDIS Review: Final Report, Australian Government, 2023

[5] NDIS Review: Final Report, Australian Government, 2023, page 27

[6] NDIS Review: Final Report, Australian Government, 2023, pages 57-58

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limited or no choice in provider
unclear diagnostic and referral pathways for families who need additional support
financial barriers restricting access, especially where out-of-pocket costs are required for assessments or therapies.

These issues are compounded where a child is vulnerable to multiple intersecting equity issues, such as students who are experiencing disadvantage due to their socioeconomic status, those who are culturally and linguistically diverse (CALD), or Aboriginal and Torres Strait Islander children.

For Aboriginal and Torres Strait Islander families, there are additional barriers which need to be addressed. Current diagnostic tools are often inappropriate for Aboriginal and Torres Strait Islander children, and do not reflect cultural norms or lived experiences. Without culturally adapted assessments and community-led engagement, these children risk being misdiagnosed or excluded entirely from accessing developmental supports. Historical trauma and discrimination also create mistrust in equity groups, making some families hesitant to engage with services that do not feel safe or respectful.

Similarly, for CALD families a lack of interpreters or culturally responsive services limit access and accessibility.

While the funding and service delivery model of the Thriving Kids Initiative is yet to be determined, concern has been raised from parent bodies about the possible move to school-based supports becoming the primary delivery mechanism. This approach risks eroding family choice. Under the current NDIS model which provides individualised funding packages, parents have both choice and control over which providers/therapists they select for their child and where these supports are delivered (e.g. in-home, or at a clinic). There is concern from parents that the new initiative may restrict the choice in therapists to only those employed by their child’s school, resulting in supports being standardised rather than tailored to the child’s specific needs. Additionally, it may create accessibility issues for students unable or unwilling to attend school on a regular basis, such as those experiencing school refusal.

ISA recommends that during the design and implementation of the Thriving Kids initiative, consideration is given to how it will operate effectively in different contexts – a national ‘one size fits all’ approach will result in continued inequitable outcomes for some of our most disadvantaged students. This initiative is an opportunity to better address existing cultural and systemic inequities in access to developmental supports.

NAVIGATING COMPLEXITY

The Australian Government, along with the state and territory governments, need to work closely with schools and families to ensure the current frustrations felt when trying to navigate the NDIS are not continued or exacerbated. These include:

opaque eligibility criteria and policies which are not written for families or staff to easily understand
inconsistent support, which differs by provider or jurisdiction
a lack of coordination between the myriad stakeholders involved in the delivery of supports, including all levels of government, health providers and education bodies
confused or unclear messaging and communication, resulting in misinformation.

The Terms of Reference of the Inquiry into the Thriving Kids initiative mentions the need to engage with schools and early childhood education and care providers when examining the effectiveness of current (and previous) programs and initiatives that identify children with development delay and/or autism, with mild to moderate support needs. ISA strongly supports this direct engagement and consultation, as it will ensure that the Thriving Kids initiative is designed for the audience it serves.

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Following the Hon. Mark Butler MP’s announcement of the Thriving Kids initiative, ISA’s stakeholders reported anxiety and uncertainty in the school-based autism community, with specific concerns raised about the effectiveness and resourcing of school-based supports. Parent bodies have also voiced concerns to ISA about the removal of choice from families, and the risk of communal support services being less effective than the current model.

To assuage these parties, ISA recommends that the Australian Government works closely with parent bodies and disability centered community groups to consult on the design and implementation of this initiative. Significant attention will need to be given to clearly communicating and justifying which service pathway is appropriate for any given child depending on their support needs.

QUALITY AND CONSISTENCY

Concerns have been raised by ISA stakeholders about the impact on service quality and consistency as children are migrated from NDIS to Thriving Kids:

A core part of therapy delivery for students with developmental delays or autism is the involvement of their families. Approaches and tools learned in therapy need to be actively reinforced at home to be effective. If supports are primarily delivered in-school, there is a significant risk that this will remove the opportunity for families to be educated on how best to support their child.
Continuity of service is important for families and schools. This is already difficult for families who are required to relocate interstate for work on a frequent basis (e.g. Defense personnel), as the level of support offered differs between jurisdictions. Stakeholders of ISA have described this as “postcode-based inequity”. This inconsistency means that the quality, availability, and specific nature of support (e.g. the amount of time a child receives with a school-based allied health professional) could be vastly superior in one state or territory compared to another. The design of Thriving Kids needs to ensure that young people are offered consistent, high-quality interventions which are appropriate for the child’s needs, no matter where they are located. Clear national protocols on information sharing and continuity planning between jurisdictions would be of value to families and schools.
The launch of Thriving Kids should be supported by a short-to-medium term transitional program for children already on the NDIS whose supports are expected to be migrated to be delivered under Thriving Kids. This group of children should not be used to test the program for later improvement.
Further, no child should be worse off under the Thriving Kids Initiative. The level of support offered to children with mild to moderate developmental delays and autism should be equal to or exceed the supports currently offered though the NDIS. While direct comparison of services may not be possible due to the revised approach being taken by Thriving Kids, a ‘better off overall’ test should be applied to ensure that Australian children experiencing delay or disability have every chance to thrive.

Schools already face unique challenges when supporting students who are accessing the services of allied health professionals. Students with regular appointments with health professionals such as physiologists or speech pathologists will often miss class to attend these appointments during school hours. Where schools are able to facilitate hosting these sessions on campus, there are additional concerns such as room design, child safety and scheduling. For special schools who cater primarily to students with disability, these problems are compounded due to the significant proportion of their student population who receive therapeutic supports. The absence of policy or funding intersection between NDIS and education makes it challenging for schools to coordinate therapy and academic programs, risking student outcomes in both domains.

ISA recommends that any new model for support delivery based in schools is piloted prior to national implementation. Pilots should be held in a range of schools across various local contexts. This will allow for refinement in the approach, and for lessons learned to be shared with all schools.

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RESOURCING

ISA’s stakeholders have expressed concern that schools which are already time poor and balancing rising education delivery cost with limited revenue growth will be positioned as central delivery hubs for the Thriving Kids initiative. ISA recommends that any additional responsibilities for schools in assisting with the delivery of the Thriving Kids Initiative are supported by adequate additional funding for schools. This funding should be sector-blind and commensurate with the additional delivery requirements being placed on schools.

When determining funding and resource allocation under the Thriving Kids Initiative, state and territory governments should work closely and transparently with their jurisdiction’s Association of Independent Schools. The AISs are best placed to both support Independent schools across a wide range of contexts, and to identify where efficiencies can be gained when allocating resources to schools.

Currently, school staff (both teaching and non-teaching) are required to provide a range of supports for their student population which falls outside of the traditional role of schools. Especially in regional and remote areas, schools function as community hubs which provide students with disability or delay support before, during and after diagnosis and medical intervention. For many teachers, this goes far beyond their scope of practice.

Caution must be exercised around a growing expectation for educators to manage therapeutic interventions without clinical support. Outside of special schools and other unique contexts, teachers are not trained allied health professionals.

Blurring the lines between education and therapy not only undermines professional boundaries but also places unrealistic expectations on teachers. Without dedicated funding to embed allied health professionals within school settings, collaboration remains ad hoc and inconsistent.

There is an opportunity for the Thriving Kids initiative to prioritise workforce development, fund integrated models, and protect the integrity of both education and clinical practice. This will result in improved outcomes for both students and the school staff who support them.

INSIGHTS FROM THE SYCAMORE SCHOOL, QLD

ISA met with Cindy Corrie, founder of The Sycamore School in Queensland, to discuss her perspectives on the Thriving Kids Initiative and offer reflections on the successes and failings of the NDIS in a Special Schools context.

Founded in 2017, The Sycamore School provides specialist support and education to people on the autism spectrum, their care networks, and the community. Rather than just focusing on curriculum outcomes, the school aims to empower its students to advocate for themselves and to be involved in the decision-making processes of their lives.[7]

The school was founded in response to Cindy and her husband Cameron being unable to find a suitable school for their son who had been diagnosed with autism.

Operating from prep to Year 10, alumni from the school have successfully transitioned to mainstream year 11 and 12, vocational education, university, or TAFE, demonstrating positive long-term outcomes.

___[7] Our Story, The Sycamore School

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Cindy noted that after years of collecting data and family stories, the school can now demonstrate that its approach to focused support has positively changed developmental and academic trajectories for their students.

In the past, The Sycamore School had been able to offer initiatives such inviting teachers from other schools participated in professional learning experiences at Sycamore, shadowing curriculum leads and working through case studies to build capacity in supporting autistic students. To give back to the community and improve outcomes for students beyond The Sycamore School, Cindy sees an opportunity for Sycamore to function like a teaching hospital for educators, building workforce capacity to support students who struggle in mainstream settings.

Supporting teachers in building their capabilities to implement autism-specific strategies in their classrooms will become more critical as the Thriving Kids initiative is implemented. The Sycamore School is well positioned to deliver these supports to schools across all sectors and is open to working partnerships. However, changes to federal and state government funding policy have hampered the school’s ability to expand these professional learning opportunities. Limited government funding continues to restrict Sycamore’s ability to fund the school-wide supports it requires, or extend its supports into the wider community.

Previously, The Sycamore School was able to hire its own in-school therapists to support their students in a contextually appropriate and intentional manner. However, as NDIS service provision became a more lucrative option for therapists, it became financially unfeasible for the school to maintain this capacity in-house. The school continues to advocate for additional funding to support its teacher/student ratios and school-wide supports.

For Cindy, the need for change is clear. The Sycamore School wants to do more for its students and community, but is inhibited by both funding availability and the design of the NDIS. Thriving Kids represents a possibility for positive change, however its announcement was met with significant concern from the school community. Families are fearful that their child will receive reduced assistance and intervention, and there are concerns about the impact this could have on the school’s ability to foster a positive educational environment.

If students supported under Thriving Kids receive reduced supports and fewer opportunities for early intervention than they would have under the NDIS, Cindy is concerned that new students might be less prepared for social and academic environments, potentially placing additional demands on the school’s existing resources.

“We know that kids who have had really tricky beginnings, who have intense early intervention before coming into school, designed in a way that’s meaningful and produces outcomes, can find success in our school and then go into mainstream schooling for Year 11. Not every kid’s outcomes will look that way, but without those powerful early interventions, it’s certainly not going to get that far. So, it is important. The Sycamore School needs to be enabled to do this, and we’ve lost some of those mechanisms that help us to deliver the outcomes we want for our students.”
– Cindy Corrie

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5. CONCLUSION

The Thriving Kids initiative presents a good opportunity to reshape and improve how developmental supports are delivered to children experiencing mild to moderate developmental delays and autism across Australia. However, to achieve its intended impact, the initiative must be designed with a deep understanding of the diverse contexts in which children learn and live, particularly in regional, remote, and culturally diverse communities.

ISA’s stakeholders have strongly voiced that the Australian Government should refrain from adopting a one-size-fits-all approach, as this could exacerbate existing inequities and standardise support delivery in ways that fail to accommodate the unique needs of each child.

Should the Thriving Kids initiative employ a school-based model for providing supports, it is essential to ensure that schools are not tasked with delivering therapeutic interventions without sufficient and appropriate resourcing to recruit staff with relevant clinical expertise.

By piloting models before national rollout, ensuring that no child is worse off than they were under the NDIS, and leveraging the deep connections which the Associations of Independent Schools have with their member schools, the Thriving Kids initiative can positively impact a group of Australian children who are at risk of being left behind.

ISA would be happy to discuss our submission or be involved in further consultation.

Contact details

Joanna Mackie

Director, Education Policy, ISA

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