AEIOU Submission: Thriving Kids Initiative, October 2025

Submitted by: David Doxey Acting Chief Executive Officer of AEIOU Foundation

redacted

Statement on language

AEIOU acknowledges that people use different words to talk about autism, and that preferences vary across individuals, families, and communities. Some prefer identity-first language (e.g., “autistic person”), while others prefer person-first language (e.g., “person with autism”).

For this submission, AEIOU will use both “children on the autism spectrum” and “autistic children” interchangeably, depending on context. This reflects the diversity of perspectives across the autism community while also recognising clinical terminology and the way policy discussions are commonly framed. Where relevant to describing children with the highest support needs (Level 3), we will use the term Profound Autism Spectrum Disorder (as defined in DSM-IV).

Introduction

AEIOU Foundation welcomes the opportunity to provide a submission to the Senate Inquiry into the Thriving Kids Initiative. We strongly support the Initiative’s objective to strengthen early identification and provide accessible, evidence-based supports that enable all children to thrive.

At the same time, we recognise community concerns about the transition from the NDIS to Thriving Kids. There is anxiety that children and families may lose access to vital supports during the handover period, there is uncertainty around how “mild to moderate” developmental delay or autism will be defined, and apprehension about whether services and workforce capacity will be in place quickly enough to meet growing demand. Families have expressed that they cannot afford further delays or disruptions during the most critical years of a child’s development.

Our submission draws on AEIOU Foundation’s 20 years of experience delivering intensive, autism-specific early intervention in Australia. We highlight the barriers faced by families, the demonstrated effectiveness of our model, and the workforce and equity issues that must be addressed to ensure the success of Thriving Kids.

We are committed to sharing our research, evidence, and lived experience to inform policy that delivers continuity of care, equitable access, and improved outcomes for children and families.

About AEIOU Foundation

AEIOU Foundation is Australia’s leading provider of autism-specific early intervention for children under six years of age. With centres located across southeast Queensland, regional Queensland, South Australia, and the Australian Capital Territory, AEIOU supports approximately 300 children each year. For 20 years, AEIOU has equipped thousands of children with the foundational life skills required to increase their social, educational, and economic participation in the community.

At the heart of our model is an expert transdisciplinary team of clinicians and educators who work in close partnership with families. Together, they share responsibility for assessing, planning, delivering, and evaluating each child’s individualised program. AEIOU teams are comprised of speech pathologists, occupational therapists, behaviour analysts, teachers, early childhood educators, early intervention specialists, and allied health assistants.

The service integrates therapy with an educational curriculum that meets the Early Years Learning Framework (EYLF), an approved kindergarten program, and care within a holistic, naturalistic setting. Children who may otherwise experience exclusion and isolation in mainstream settings are supported in inclusive environments where they can actively participate, engage, and achieve their individual goals.

Our mission is to enhance the lives of autistic children and their families by delivering evidence-based early intervention programs and practical supports. We believe that:

• Children have a right to early intervention.
• Therapy should be tailored to individual needs.
• Children learn in different ways and at different rates.
• Every child is unique, with their own personality, strengths, needs, and interests.
• Flexible routines are essential to meet individual developmental needs.

• Early intervention must be evidence-based and supported by appropriate assessment.
• Programs must bridge the gap between home, AEIOU, and the wider community.
• Collaboration between families and the AEIOU transdisciplinary team is critical to achieving the best outcomes.

We also believe families have the right to receive support, so that all members of the family unit can participate in community life, including employment and education.

National Context and Sector Concerns

Australia is at a critical juncture in the delivery of early supports for children with developmental delay and autism. The federal government’s proposed Thriving Kids Initiative intends to redirect many children, particularly those with so-called mild to moderate needs (often associated with Level 1 and Level 2 autism), out of the NDIS and into a new foundational support program.

While this change is framed as improving sustainability, it has raised significant concern across states, service providers, and families. The language of mild and moderate autism does not reflect lived experience. Families consistently report that children with these classifications face substantial functional challenges that require structured, multidisciplinary support. Redirecting these children solely into mainstream systems—already overstretched and under-resourced—risks exclusion, extended waitlists, and poorer long-term outcomes.

Disabled People’s Representative Organisations (DPROs) have reinforced these concerns, noting that reforms promising sustainability may instead reduce early supports, increase family stress, and risk breaching Australia’s obligations under the UN Convention on the Rights of Persons with Disabilities (CRPD). AEIOU shares this perspective and emphasises that reforms must be co-designed, evidence-based, and rights-driven.

At the same time, AEIOU recognises the intent of government to strengthen foundational supports and improve equity of access. We agree that mainstream systems—child health, primary care, early education, and schools—must play a stronger role in supporting children with developmental needs. However, reforms must not reduce or remove access to individualised, intensive supports at the very time they are most needed. True sustainability will only be achieved if mainstream systems are resourced appropriately, professional expertise is protected, and seamless transition pathways are guaranteed.

In the sections that follow, AEIOU responds directly to the Terms of Reference for this Inquiry, drawing on nearly two decades of practice, independent evaluation, and family partnership to outline what works, where the risks lie, and what action is required to ensure Thriving Kids delivers on its promise.

Definitions and Eligibility

It is important to note that broad diagnostic labels such as mild, moderate, and severe autism do not adequately capture the diversity of needs experienced by children and their families. Functional ability and support needs vary significantly, and reliance on diagnostic category alone risks denying children access to the supports they require. Families often report that so-called “mild” autism still presents profound challenges in communication, social participation, and learning.

AEIOU advocates for a more objective and evidence-based approach to determining eligibility for Thriving Kids versus NDIS-funded intensive early intervention. This position is supported by the

AEIOU Assessment Proposal (Paynter, 2014), which recommends the use of validated assessment tools including the:

• Autism Diagnostic Observation Schedule (ADOS)
• Vineland Adaptive Behavior Scales (VABS)
• Mullen Scales of Early Learning (MSEL)
• Preschool Language Scale (PLS)
• Developmental Behavior Checklist (DBC-P)

Under this model, a Developmental Quotient (DQ) threshold of 70 provides an objective benchmark for allocating supports:

• DQ ≥ 70: Children may initially access Thriving Kids foundational supports, which provide structured, multidisciplinary assistance in mainstream settings.
• DQ < 70: Children should be eligible for intensive, individualised early intervention funded through the NDIS, reflecting the significant functional support needs associated with Profound Autism Spectrum Disorder.

Importantly, AEIOU supports a tiered and interconnected model, where children are not permanently locked into one stream. If a child accessing Thriving Kids is not making progress, they must be able to transition into NDIS-funded intensive supports. Likewise, children making gains in intensive programs should be supported to transition into Thriving Kids, with continuity of care and transition planning embedded across pathways.

This approach ensures that supports are allocated transparently, equitably, and in line with functional need rather than simplistic diagnostic labels. It also upholds the original intent of the NDIS: to provide individualised supports where they are required most, while building stronger mainstream and community-based systems to support all children on the autism spectrum.

(The original AEIOU Assessment Proposal, authored by Dr Jessica Paynter in 2014, is attached as a supporting document to this submission.)

ToR 1: Examine evidence-based information and resources to assist parents to identify developmental delay and provide support

Early identification is crucial to ensure children receive timely intervention during the developmental window when supports are most effective. Parents, however, frequently report uncertainty and long delays before securing an assessment or therapy. The current system relies heavily on families knowing where to go, navigating waiting lists, and affording private assessments.

Evidence-based screeners and developmental surveillance tools already exist in Australia, including the Parents’ Evaluation of Developmental Status (PEDS), Ages and Stages Questionnaire (ASQ-3), Modified Checklist for Autism in Toddlers, Revised with Follow-up (M-CHAT-R/F), and the Social Attention and Communication Surveillance — Revised (SACS-R). These can be delivered by GPs, child health nurses, and early childhood educators. Yet access is inconsistent, and there is no guarantee that a flagged concern leads to an active referral.

AEIOU’s experience demonstrates that when families are guided through screening and referred promptly, children access therapy earlier and outcomes are stronger. From the point of entry, even prior to diagnosis, AEIOU provides parent coaching to equip families with practical strategies in

communication, sensory regulation, and daily routines. Parents consistently report reduced stress and increased confidence when they are supported to embed strategies in everyday life.

However, AEIOU also cautions that broad diagnostic labels such as mild, moderate, or severe autism do not adequately reflect functional need. Families often report that so-called “mild” autism can still present significant barriers to participation and communication. To ensure equity and transparency, AEIOU recommends an objective eligibility framework for Thriving Kids and NDIS-funded supports, as outlined in the AEIOU Assessment Proposal (Paynter, 2014). This includes a suite of validated tools such as the Autism Diagnostic Observation Schedule (ADOS), Vineland Adaptive Behavior Scales (VABS), Mullen Scales of Early Learning (MSEL), Preschool Language Scale (PLS), and the Developmental Behavior Checklist (DBC-P).

Within this framework, a Developmental Quotient (DQ) benchmark of 70 is used to allocate supports:

• DQ ≥ 70: Children may initially access Thriving Kids foundational supports, providing structured multidisciplinary assistance in mainstream contexts.
• DQ < 70: Children should be eligible for intensive, individualised early intervention funded through the NDIS, reflecting the significant support needs associated with Profound Autism Spectrum Disorder.

This objective, tiered approach ensures children are not excluded based on simplistic diagnostic labels and provides families with confidence that supports will be matched to functional need.

Recommendations (linked to AEIOU’s 10 Key Points):

• Guarantee early supports, not reduce them – Adopt a nationally consistent, objective eligibility framework for Thriving Kids and NDIS pathways, grounded in validated assessment tools and functional benchmarks (Key Point 1).
• Strengthen family supports – Expand access to parent coaching and fund navigation supports so families are not left to bridge system gaps alone (Key Point 2, Key Point 10).
• Move away from deficit labels – Retire outdated severity terms (“mild,” “moderate,” “severe”) and replace with functional, neuroaffirming, evidence-based criteria (Key Point 9).

ToR 2: 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.

Australia has trialled multiple programs for early identification and support, spanning universal health checks, playgroups, allied health services, and early childhood education. While some initiatives have demonstrated positive outcomes, most lack scale, consistency, and integration. Families continue to describe “postcode lotteries” in access to early support.

System-level challenges:

• Child and maternal health: Universal health checks vary by state, with inconsistent use of tools like PEDS and ASQ. Too often, flagged concerns result only in “watch and wait” rather than active referral.

• Primary care: GPs remain critical gatekeepers but frequently lack training in developmental surveillance. Referrals to paediatricians are delayed by long waitlists, compounding family stress.
• Allied health and playgroups: Community-based models, such as play-based parent coaching groups, show promise but remain small-scale and under-resourced.
• ECEC and schools: Educators are often the first to identify red flags, yet training and confidence in supporting developmental needs is variable. Schools are rarely resourced to provide early supports before diagnosis.

AEIOU’s contribution:

AEIOU provides a proven, integrated model that combines therapy, kindergarten, and early education within a single program. Independent evaluation demonstrates:

• Significant gains in communication, daily living, and social skills.
• Reduced reliance on restrictive practices.
• Improved family capacity and employment participation.
• Economic evaluation showing a 6:1 return on investment (ROI) and lifetime savings of $423,000 per child to the NDIS.
• Despite this evidence, programs like AEIOU remain rare, and many children—particularly those with Level 1 and 2 autism—risk being excluded from such evidence-based supports under Thriving Kids if eligibility is determined by diagnostic labels rather than functional needs.

AEIOU’s position:

• The effectiveness of early programs is directly linked to intensity, multidisciplinary collaboration, and continuity of support. Thriving Kids must not replace individualised supports with generic, under-resourced services.
• Eligibility should be determined using an objective assessment framework (Paynter, 2014), with a Developmental Quotient (DQ) threshold of 70 distinguishing those who need intensive, NDIS-funded intervention from those who can benefit from foundational supports.
• A tiered, interconnected model is essential: children who are not making progress in Thriving Kids must be able to transition into NDIS supports, and vice versa, ensuring no child is left without adequate help.

Recommendations (linked to AEIOU’s 10 Key Points):

• Guarantee early supports, not reduce them – Ensure Thriving Kids supplements, not replaces, access to NDIS supports, and apply objective, functional eligibility criteria (Key Point 1).
• Invest in inclusive, sustainable services – Expand models like AEIOU that integrate therapy and education, ensuring children on the autism spectrum are included in, not excluded from, mainstream settings (Key Point 3).
• Prioritise efficient use of taxpayer funding – Invest in programs with proven outcomes and economic benefits, such as AEIOU’s independently evaluated model (Key Point 4).

ToR 3: Identify equity and intersectional issues particularly for First Nations children and children from culturally and linguistically diverse (CALD) backgrounds.

Equity and access remain major barriers in Australia’s early intervention and developmental support systems. Children from First Nations, culturally and linguistically diverse (CALD), and regional or remote communities are consistently less likely to receive timely assessment, diagnosis, and intervention. The result is delayed supports, reduced school readiness, and entrenched disadvantage.

Barriers to access:

• First Nations families: Families in rural and remote areas often face limited or no access to specialist services. Where supports exist, cultural safety is inconsistent. Families report that autism is not always recognised or understood within mainstream health and education systems, leading to under-diagnosis and poor engagement.
• CALD families: Language barriers prevent equitable access to developmental screeners, therapy resources, and school communication. Many rely on informal community networks for information rather than being supported through formal referral systems.
• Regional and rural families: Even in metropolitan centres, paediatrician and allied health waitlists are long; in rural and regional areas, these barriers are magnified. Workforce shortages further reduce access to timely, appropriate support.

AEIOU’s contribution:

AEIOU operates centres across metropolitan and regional areas (including Camira, Townsville, and Adelaide), enabling more families to access services. However, families consistently report that face-to-face, specialist-led intervention remains essential, particularly for children with significant functional needs. AEIOU also provides resources translated into community languages and employs staff trained in cultural responsiveness to ensure services are safe, inclusive, and accessible.

AEIOU’s position:

• Thriving Kids must not exacerbate inequities by assuming universal services alone will be sufficient. Families from marginalised communities are least equipped to navigate fragmented systems and most likely to be excluded if reforms reduce access to funded, individualised supports.
• Eligibility frameworks must be applied transparently and equitably across populations. Use of objective, multidisciplinary assessments (ADOS, VABS, MSEL, PLS, DBC-P) with a DQ threshold of 70 provides clarity and consistency, preventing decisions from being shaped by postcode, workforce shortages, or cultural bias.
• A tiered, interconnected model of supports is essential to ensure children from disadvantaged communities are not permanently locked out of intensive services if initial placements in Thriving Kids do not meet their needs.

Recommendations (linked to AEIOU’s 10 Key Points):

• Strengthen family supports – Ensure supports are culturally safe, accessible, and embedded with navigation assistance, especially for families at greatest risk of exclusion (Key Point 2).
• Invest in inclusive, sustainable services – Resource both specialist and mainstream systems to reduce postcode lotteries and expand access for First Nations, CALD, and regional families (Key Point 3).

• Uphold children’s rights under the CRPD – Guarantee the right of all children to inclusion, family life, and education, ensuring that Thriving Kids reforms do not entrench inequity or systemic exclusion (Key Point 5).

ToR 4: Identify gaps in workforce support and training required to deliver Thriving Kids.

Workforce capacity is the linchpin of successful reform. Current shortages in key professions—including speech pathology, occupational therapy, and behaviour support—already constrain access to early intervention. Without targeted investment, Thriving Kids risks further straining the workforce and diluting specialist roles, particularly if generalist keyworker models replace discipline-specific expertise.

Recruitment challenges:

• Rural and regional areas face chronic shortages of allied health professionals.
• Graduate supply is insufficient to meet projected demand, particularly in autism-specific practice.

Retention challenges:

• High caseloads, administrative burden, and professional isolation contribute to burnout and attrition.
• NDIS pricing instability and funding uncertainty further limit workforce stability.

Training gaps:

• Mainstream educators, GPs, and early childhood staff are often the first to observe developmental concerns, yet many lack autism-specific knowledge and confidence to act.
• Without upskilling, universal systems will remain ill-equipped to meet the needs of children on the autism spectrum, particularly those with significant functional challenges.

AEIOU’s contribution:

• Robust supervision frameworks for early career clinicians, ensuring safe practice and workforce retention.
• Graduate support programs to build capacity and provide structured pathways into specialist practice.
• Ongoing professional development in autism-specific interventions, including augmentative and alternative communication (AAC), behaviour supports, and sensory regulation.
• A transdisciplinary model that safeguards specialist roles while fostering effective collaboration across disciplines.

AEIOU’s position:

• Thriving Kids must avoid de-professionalisation. Children with complex profiles—including co-occurring apraxia, sensory processing differences, and social-communication barriers—require input from trained specialists.
• Eligibility frameworks (such as those proposed in AEIOU’s 2014 Assessment Proposal) must be supported by a workforce capable of applying assessments and tailoring interventions. This cannot be achieved through generalist or diluted roles.

• A sustainable workforce requires parallel investment in specialist pipelines and autism capability across mainstream services.

Recommendations (linked to AEIOU’s 10 Key Points):

• Protect professional autism expertise – Safeguard the roles of speech pathologists, occupational therapists, behaviour practitioners, and psychologists, ensuring Thriving Kids builds on—not replaces—their expertise (Key Point 6).
• Embed multidisciplinary collaboration – Fund and mandate team-based models of care so Thriving Kids supports retain the full depth of professional input, rather than relying on generic coordination (Key Point 7).
• Invest in inclusive, sustainable services – Build workforce capacity across both specialist services and mainstream systems to ensure equitable access, particularly in rural and regional areas (Key Point 3).

ToR 5: Draw on domestic and international policy experience and best practice.

International and domestic policy provide strong lessons for Thriving Kids and demonstrate the importance of rights-based, evidence-informed reform.

International evidence:

• NICE (UK): Early intervention supports children’s participation and development but does not “cure” autism, cautioning against overstated claims or deficit framings.
• Canada/US: Blended models that combine therapy with inclusive education demonstrate strong outcomes when properly resourced and sustained.
• CRPD obligations: Australia is bound by the UN Convention on the Rights of Persons with Disabilities, which requires governments to ensure inclusion, protect the right to family life, and embed genuine co-design with disabled people and their representative organisations.

Domestic evidence:

• Disability Royal Commission (2023): Found that underfunded mainstream systems perpetuate segregation and long-term harm, highlighting the need for strong investment in specialist capability.
• Autism CRC National Guideline (2022): Establishes evidence-based, family-centred, neuroaffirming practice as the benchmark for high-quality autism supports.
• AEIOU evaluation: Demonstrates measurable developmental gains, reduced restrictive practices, stronger family capacity, and a 6:1 return on investment with lifetime savings of $423,000 per child.

AEIOU’s contribution: For nearly two decades, AEIOU has adapted international evidence to the Australian context, delivering a model that aligns with best practice principles:

• Evidence-based and outcomes-focused.
• Family-centred and inclusive.
• Multidisciplinary, with professional autism expertise safeguarded.
• Flexible delivery across therapy, education, and school readiness pathways.

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• AEIOU further emphasises that best practice also requires clear, objective eligibility criteria. International frameworks consistently stress that supports must be matched to functional needs, not deficit-based labels. AEIOU’s proposed eligibility framework (Paynter, 2014; DQ threshold of 70) ensures access is transparent, equitable, and rights-based.

Recommendations (linked to AEIOU’s 10 Key Points):

• Guarantee early supports, not reduce them – Ensure Thriving Kids supplements, not replaces, NDIS-funded supports, and avoid overstated claims about “preventing” or “curing” autism (Key Point 1).
• Uphold children’s rights under the CRPD – Align Thriving Kids with Australia’s international obligations, ensuring inclusion, family life, and education rights are protected (Key Point 5).
• Strengthen parent capacity and embed neuroaffirming practice – Ensure Thriving Kids is grounded in the Autism CRC Guideline principles of family-centred, strengths-based, and neuroaffirming practice, including structured parent coaching (Key Point 10).

ToR 6: Identify mechanisms for seamless transition through mainstream systems for all children with mild to moderate support needs.

Transitions into kindergarten and school are high-stakes for children on the autism spectrum and their families. Without structured planning, specialist input, and teacher capability, children risk exclusion, behavioural escalation, and learning regression.

Current challenges:

• Schools report limited preparation and inadequate training for autism-inclusive practice.
• Transition plans are inconsistent, with families often left to drive the process themselves.
• Mainstream systems frequently lack embedded specialist input during the critical transition period.

AEIOU’s contribution:

• Transition planning begins months before school entry, involving families, educators, and therapists.
• Tailored strategies and resources are developed for each child and shared with schools.
• The AEIOU School Support Service provides coaching, consultation, and practical tools to teachers and staff.
• Families consistently report smoother transitions, better school engagement, and reduced exclusion when supported through this model.

AEIOU’s position:

• Seamless transitions require both specialist and mainstream systems working together, with multidisciplinary input embedded in transition planning.
• Thriving Kids must adopt a tiered, interconnected model of supports: if a child is placed in foundational services but fails to make progress, there must be a pathway into NDIS-funded supports. Likewise, children who succeed in intensive intervention should be supported to transition into mainstream schooling through Thriving Kids.

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• Without structured transition supports, reforms risk undermining the very outcomes they seek to improve, leaving children excluded at the point of school entry.

Recommendations (linked to AEIOU’s 10 Key Points):

• Invest in inclusive, sustainable services – Resource models that bridge the gap between early intervention and schools, ensuring children are prepared and supported (Key Point 3).
• Embed multidisciplinary collaboration – Guarantee that transition planning involves speech pathologists, occupational therapists, behaviour practitioners, and teachers working together (Key Point 7).
• Support flexible delivery models – Ensure families can access transition support across clinic, school, and community contexts, tailored to each child’s needs (Key Point 8).

AEIOU Foundation has responded to each of the Terms of Reference by drawing on nearly two decades of service delivery, independent evaluation, and the lived experiences of children and families. Across all areas, a consistent theme emerges: while Thriving Kids presents an opportunity to strengthen early supports, it risks leaving children and families worse off if reforms reduce access to funded, individualised therapy, weaken workforce expertise, or fail to resource mainstream systems adequately.

To ensure Thriving Kids delivers on its promise, AEIOU presents the following Key Points and Recommendations, which synthesise our evidence and outline the reforms required to achieve inclusion, sustainability, and better outcomes for children and families.

Key Points and Recommendations

AEIOU Foundation supports the vision of the Thriving Kids Initiative but stresses that its success will depend on robust investment, continuity of care, and genuine co-design with children, families, and service providers. In alignment with broader sector priorities and advocacy across the disability and early childhood fields, we recommend:

1. Guarantee early supports, not reduce them

   • Promise: Thriving Kids aims to deliver early supports through foundational services.
   • Problem: Moving autistic children with “mild to moderate” needs (Levels 1 & 2) out of the NDIS risks cutting funded therapy during critical years.
   • Evidence:
     • AEIOU cost–benefit evaluation: 6:1 ROI, $423,000 lifetime savings per child.
     • NICE (2021), Murray et al. (2023): early intervention supports participation but does not “cure” autism.
   • Breach: Reforms reduce access to funded therapy at the point of greatest need.
   • Recommendation: Guarantee funded, individualised supports for autistic children. Foundational services must supplement, not replace the NDIS.

2. Strengthen family supports

   • Promise: Thriving Kids commits to helping families navigate services.

   • Problem: Families already grappling with complexity and challenges face fragmented systems, fewer resources, and risk of crisis or child protection involvement.

   • Evidence:

     • Disability Royal Commission (2023) and Dowse et al. (2016): lack of supports linked to family breakdown and child removal.
     • AEIOU practice shows parent coaching reduces stress and improves outcomes.

   • Breach: Families risk being disempowered and isolated.

   • Recommendation: Embed family-centred practice, coaching, respite, and navigation supports.

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• Disability Royal Commission (2023) and Dowse et al. (2016): lack of supports linked to family breakdown and child removal. - AEIOU practice shows parent coaching reduces stress and improves outcomes.
  • Breach: Families risk being disempowered and isolated.
  • Recommendation: Embed family-centred practice, coaching, respite, and navigation supports.

3. Invest in inclusive, sustainable services

   • Promise: Mainstreaming supports is framed as sustainability.
   • Problem: Redirecting children with Level 1 and Level 2 autism solely into mainstream health, education, and community systems undermines inclusion. These systems are already overstretched and lack the specialist capability required to meet complex needs.
   • Evidence:
     • Disability Royal Commission (2023): underfunded, segregated systems entrench exclusion.
     • AEIOU: integrated therapy + education supports successful transitions.
   • Breach: Mainstream-only pathways for children with higher support needs risk perpetuating segregation, exclusion, and crisis.
   • Recommendation: Resource both mainstream and specialist services. Build on proven multidisciplinary models that provide the opportunity for children with Level 2 + 3 Autism to access specialist early intervention services to build the foundational skills required for them to access mainstream supports when they enter the education system. The specialist service can also provide appropriate and individualised support to equip teachers with tools and strategies that will optimise a student’s transition into school.

4. Prioritise efficient use of taxpayer funding

   • Promise: Reforms presented as containing NDIS growth.
   • Problem: Removing children from the NDIS shifts costs to other systems.
   • Evidence:
     • Per Capita (2021): $1 NDIS spending → $2.25 return.
     • Goldman Sachs (2025): removing autistic children would reduce GDP growth by 0.1% annually.
     • AEIOU: $423,000 lifetime savings per child.
   • Breach: Long-term costs increase.
   • Recommendation: Invest in evidence-based early intervention with proven ROI.

5. Uphold children’s rights under the CRPD

   • Promise: Thriving Kids should align with CRPD obligations.
   • Problem: Reforms risk breaching Articles 7, 19, 23, 24.
   • Evidence:
     • CRPD General Comment No. 7 (2018): requires genuine co-design.
     • AEIOU: neuro affirming, rights-based practice improves inclusion.
   • Breach: Fiscal restraint risks violating rights.
   • Recommendation: Ensure reforms are rights-based and uphold CRPD commitments.

6. Protect professional autism expertise

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• Promise: Thriving Kids aims to streamline access and make supports easier for families to navigate.
  • Problem: Simplified or generic workforce models risk overlooking the unique and complex needs of autistic children. Autism expertise can be diluted when specialist disciplines are replaced with generalist roles.
  • Evidence:
    • Autistic children often experience co-occurring apraxia, sensory processing differences, and communication challenges that require discipline-specific expertise.
    • AEIOU’s transdisciplinary autism model shows that outcomes are strongest when speech pathology, occupational therapy, and behaviour supports collaborate, each bringing their autism-specific professional expertise.
    • Families consistently report that individualised, autism-specific therapies enable progress in communication, social interaction, and emotional regulation.
  • Breach: De-professionalisation risks autistic children receiving supports that are generic and insufficient, leading to poorer developmental, educational, and social outcomes.
  • Recommendation: Safeguard access to discipline-specific autism professionals and mandate their involvement in early intervention, ensuring Thriving Kids builds on—not dilutes—autism expertise. Ensure there are opportunities for specialist training, coaching and clinical collaboration with staff chosen to support the thriving kids model of practice.

7. Embed multidisciplinary collaboration

   • Promise: Thriving Kids highlights the importance of service coordination for families.
   • Problem: Without dedicated resourcing, coordination can default to generic supports, with autistic children missing out on the depth of input needed from multiple disciplines.
   • Evidence:
     • Autistic children often require concurrent support across communication, sensory regulation, behaviour, and social-emotional development.
     • AEIOU’s transdisciplinary autism model shows best outcomes occur when speech pathology, occupational therapy, and behaviour therapy work together, co-designing with families and the early education and care sector.
     • Families value team-based approaches that prevent gaps and reduce the burden of navigating siloed systems.
   • Breach: Over-reliance on keyworker models risks them being used as substitutes for specialist input, leaving autistic children with fragmented or diluted supports.
   • Recommendation: Fund and mandate team-based collaboration so Thriving Kids delivers truly multidisciplinary autism intervention, safeguarding the role of each discipline in supporting complex needs.

8. Support flexible delivery models

   • Promise: Thriving Kids commits to community-based supports.
   • Problem: A one-size-fits-all approach risks excluding autistic children who require intensive, structured, or clinic-based therapy alongside community and home supports.
   • Evidence:
     • Autistic children often benefit from therapy delivered across multiple environments — clinic for structured skill-building, home for embedding daily routines, and community/early education settings for generalisation.

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• AEIOU’s flexible autism service model demonstrates that outcomes are strongest when delivery is tailored to the child’s individual profile and family circumstances. - Families consistently report that flexibility reduces barriers to access and enables real-world skill transfer.
  • Breach: Restricting delivery models undermines accessibility and limits autistic children’s opportunities to participate and thrive across settings.
  • Recommendation: Fund flexible, family-driven delivery options that allow therapy to be provided in clinic, home, and community contexts, ensuring Thriving Kids meets the diverse needs of autistic children. Community and clinic-based group supports for autistic children offer a range of developmental, emotional, social and practical benefits. They are designed to provide learning opportunities in a more naturalistic and peer-driven environment which can complement individual and home-based therapies.

9. Move away from deficit labels

   • Promise: Thriving Kids aspires to be inclusive and responsive to all autistic children.
   • Problem: Deficit-based categories such as “mild,” “moderate,” and “severe” autism stigmatise individuals and misrepresent their needs. These labels do not capture the complexity of support required, and they risk dismissing children who present with less visible challenges.
   • Evidence:
     • Families frequently report that “mild autism is not mild at all,” highlighting the gap between labels and lived experience.
     • Research supports neuro affirming and strengths-based approaches, which better recognise the diversity of autistic experiences and reduce stigma.
     • While AEIOU’s origins have been grounded in supporting children with higher support needs (“classic autism”), our experience demonstrates that autism is not linear, and families across the spectrum require tailored, individualised supports.
   • Breach: Retaining severity labels perpetuates exclusion, minimises needs, and risks children being denied access to intervention and education supports.
   • Recommendation: Remove severity labels from policy frameworks. Replace with a strengths-based, neuro affirming approach that recognises diversity and prioritises individualised supports.

10. Strengthen parent capacity and embed neuro affirming practice

    • Promise: Thriving Kids seeks to empower families as partners in their child’s development.
    • Problem: Without structured, ongoing parent coaching, families are left to navigate complex systems alone and miss chances to embed strategies in daily life.
    • Evidence:
      • Parent-mediated coaching improves child communication, engagement and participation when delivered in everyday routines.
      • Neuro affirming, relational practice aligned with Australia’s Autism CRC National Guideline and Early Childhood Intervention Australia (ECIA) Best Practice Principles (family-centred, capacity-building, inclusive, collaborative) fosters belonging and reduces stigma.
      • Behaviour supports should follow NDIS Positive Behaviour Support principles (proactive, least-restrictive, dignity and autonomy).

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• Breach: If parent capacity-building and neuro affirming practice aren’t embedded, services default to deficit-focused, ad-hoc support, increasing family stress and exclusion. - Recommendation: Make parent coaching and neuro affirming practice core pillars. Fund structured coaching blocks, supervision for fidelity, and resources co-designed with families and the early education and care sector to ensure child outcomes can be optimised across settings.

Conclusion

The Thriving Kids Initiative presents a significant opportunity to strengthen early supports for children with developmental delay and disability. However, without robust investment, continuity of care (including funded navigation), and genuine co-design, there is a real risk that autistic children and their families will be left worse off.

AEIOU Foundation’s evidence shows that intensive, autism-specific early intervention delivers measurable benefits for children, families, and the economy. Our experience also demonstrates that early supports must be multidisciplinary, flexible, neuroaffirming, and grounded in family partnership, with strong collaboration across home, clinic, community, and early education and care settings.

To realise this vision, Thriving Kids must:

• Supplement, not replace, the NDIS for young children with developmental needs.
• Protect professional expertise and embed multidisciplinary collaboration (speech pathology, occupational therapy, behaviour support, psychology) with adequate resourcing.
• Strengthen parent capacity and support family wellbeing through structured, coached, neuroaffirming practice.
• Respect children’s rights to inclusion, communication, education, and family life under the CRPD, using the least-restrictive approaches.
• Invest in evidence-based, cost-effective models with clear outcomes, data sharing, and demonstrated long-term savings to the community.
• Guarantee continuity of care and funded navigation so families are not left to bridge system gaps alone.

With the right design and resourcing, Thriving Kids can achieve its promise: a system where children are supported early, families are empowered, and communities benefit from inclusion and participation. Without these safeguards, it risks widening gaps and compounding disadvantage.

AEIOU Foundation stands ready to contribute our expertise, data, and practice insights to help shape Thriving Kids into a reform that delivers on its name: a future where all children can truly thrive.

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ets

for children with autism

AEIOU Assessment Proposal

Submission to the National Disability Insurance Agency

This submission proposes National Disability Insurance Scheme (NDIS) funding of good practice (Prior & Roberts, 2012) early intervention for children with autism spectrum disorders through support item “Specialised group early childhood interventions” with hours delivered and funded under full-time (20 hours per week) and part-time (10 hours per week) models based on child need. This submission outlines how child need will be defined.

The submission identifies ascertainment and follow-up assessments to be delivered by AEIOU (pre-program and 12-monthly assessment): Autism Diagnostic Observation Schedule (ADOS), Vineland Adaptive Behavioral Score (VABS), Mullen Scales of Early Learning Standard Score (MSEL), Preschool Language Scale (PLS), and the Developmental Behavior Checklist (DBC-P). Requirement for full-time placement includes ADOS severity score in the clinical range, and below average score on one or more of the VABS, MSEL, or PLS. Requirement for part-time placement includes ADOS in the clinical range, but may be average range on VABS, MSEL and PLS, but with behaviours or social impairments presenting significant barriers to mainstream participation. Children with all measures in the non-clinical range would be ineligible for this funding stream.

Dr Jessica Paynter, Research and Psychology Manager, AEIOU Foundation
27/03/2014

Contents

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Rationale for Assessment

1. Need to evaluate child fit to program, intensity and outcomes
2. Good practice guidelines (Prior & Roberts, 2012) recommend that comprehensive assessment should be completed prior to any intervention program
3. Important to collect data to demonstrate we are meeting our program goals and features
4. Specific measures chosen based on best practice, previous intervention evaluations, minimising burden on children and families, and match to our program goals/features

Rationale for Areas to Assess

Multidisciplinary Assessment

Multidisciplinary assessment is a key area of good practice in early intervention in autism spectrum disorders (Prior & Roberts, 2012) and would include interviews with parents and caregivers, questionnaire assessment with parents, and standardised assessment of children. Assessment will cover verification of diagnosis and ASD features and core program features (see below), and would be completed before (pre-test), during (12 months), and at the end of the program (at transition). The assessment process would include Speech Pathology, Psychology and Occupational Therapy assessments as described overleaf.

Summary of Program Features

1. Social interaction and play skills
2. Cognitive development
3. Self-help tasks of everyday life
4. Communication
5. Fine and gross motor skills
6. Reduction of challenging behaviours

Proposed Assessments Areas and Links to Program Features

Assessment	Program Feature
Parent Interview
Structured intake interview	All areas
Parent Questionnaires
1. Adaptive behaviour	1. Social interaction and play skills 3. Self-help tasks of everyday life 4. Communication 5. Fine and gross motor skills
2. Challenging Behaviour	6. Reduction of challenging behaviours
Child Assessment (2 hours)
1. Verification of diagnosis	1. Social interaction and play skills 4. Communication
2. Language and communication assessment	4. Communication
3. Cognitive/Developmental Assessment	2. Cognitive development 4. Communication 6. Fine and gross motor skills

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Proposed Assessments

Parent or Caregiver Completed Questionnaires

Parents would be asked to complete a set of questionnaires following their initial referral that would function as a screen for eligibility. These questionnaires would include the Vineland Adaptive Behaviour Scales (VABS) and the Developmental Behaviour Checklist.

1. Adaptive behaviour: Vineland Adaptive Behaviour Scales. (VABS: Sparrow, Dominic, Cicchetti, & Balla, 2005). This measure assesses communication, social interaction, daily living skills, and motor skills. It has been shown to have strong psychometric properties in terms of validity and reliability with a wide range of populations, including children with ASD (Sparrow, et al., 2005). Its survey form can be completed by parents at home, and has been widely used in early intervention settings and schools. Its wide age range (2-18 years) means it is a useful assessment to measure changes over time and it yields valuable information to inform schooling options. It is also commonly used to assess for intellectual impairments (in conjunction with a cognitive assessment) and will thus support a child’s transition to a special school if required.

2. Challenging behaviour: Developmental Behaviour Checklist - Primary Carer Version (DBC-P: Einfeld & Tonge, 2002). The DBC-P is a parent questionnaire which assesses the presence of behaviour problems and emotional disturbances in children with an intellectual or developmental disability in five areas (disruptive/anti-social behaviour, self-absorbed, communication disturbance, anxiety and social relating). It also yields a total behaviour problem score. This measure has good psychometric properties, was developed in Australia and is sensitive to the behaviours common in children with ASD. This measure will be helpful in highlighting additional behavioural needs of children, common in children with ASD, which may form barriers to their participation in mainstream settings. In addition, repeated administration of the DBC-P will provide an effective means of following changes in children’s behaviour over time.

Child Assessment

1. Verification of diagnosis: Autism Diagnostic Observation Scale-Generic (Lord, Rutter, DiLavore, & Risi, 2001). The Autism Diagnostic Observation Scale - Generic (ADOS), is a semi-structured standardised observation (examiner and child) that measures autism symptoms in social relatedness, communication, play, and repetitive behaviours. It takes approximately 30 to 45 minutes to administer with children. It is widely accepted to be the “gold standard” for diagnosis of ASD. It also provides a direct observational measure of children’s social and communicative behaviour which can then be compared over time to assess improvements in ASD-specific symptoms. A revised scoring algorithm that generates a severity score from 1 to 10 with scores greater than 3 indicating the presence of an ASD (Gotham, Pickles, & Lord, 2009) will be used to monitor progress and to inform eligibility.

2. Language and communication: Preschool Language Scale (Zimmerman, Steiner, & Pond, 2003). The Preschool Language Scale, Fourth Edition (PLS) is a diagnostic instrument designed to measure the language development of young children. The PLS can be used to assess children from 2 weeks up to age 6:11 as such it will capture the full spectrum of abilities children are likely to present with to AEIOU. It has been widely used in early intervention studies with children with ASDs as a measure of treatment outcome (e.g. Dawson et al., 2010; Green et al., 2010). It would usefully inform speech and language goals during the program, and would also provide a key indicator of improvement over time.

3. Cognitive /Developmental: Mullen Scales of Early Learning (Mullen, 1995). The Mullen Scales of Early Learning (MSEL) is a standardised assessment of language, motor and perceptual abilities of children

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aged from birth to 68 months. T-scores, percentile ranks, and age equivalent scores can be calculated for scales in gross motor, visual perception, fine motor, expressive and receptive language together with an early learning composite. The Mullen has proved a useful instrument for assessing a range of skills in children with ASD in previous research (Akshoomoff, 2006).

Threshold for Service and Eligibility

Full-time Program

Previous research has used the above measures as measures of outcome in early intervention and these have been found to be robust, sensitive to change over time, and have good psychometric properties (e.g., Green, et al., 2010; Paynter, Scott, Beamish, Duhig, & Heussler, 2012; Vivanti, Barbaro, Hudry, Dissanayake, & Prior, 2013; Vivanti, Dissanayake, Zierhut, & Rogers, 2013). In particular the Vineland Adaptive Behaviour Scale (VABS: adaptive behaviour), Preschool Language Scale (PLS: language development), and the Mullen Scales of Early Learning (MSEL: cognition) have been key outcome measures showing these skills are amenable to change in intensive early intervention programs of 20 hours or more per week following programs similar to our own (Paynter et al., 2012 is an evaluation of our own program). Thus, we propose that eligibility criteria for the intensive full-time program should include below average scores on one or more of these measures combined with an ASD diagnosis that has been verified using the Autism Diagnostic Observation Scale (ADOS; i.e. in clinical range on these measures using accepted scoring criteria). See Table 1 overleaf for an overview of score cut-offs.

Part-time Program

For the part-time program (10 hours per week) we would propose that children attain scores in the average range on the PLS, VABS or MSEL, but have a verified ASD diagnosis as above, and identified needs in other areas of functioning such as social skills (e.g., as measured on the ADOS) or challenging behaviour (e.g., as measured on a standardised measure such as the Developmental Behaviour Checklist) which present significant barriers to participation in mainstream less-intensive settings. Our recent evaluation (currently in preparation for publication) found that social skills and behaviour also improve in our program. Children’s individual programs and goals would be based on these identified needs.

Ineligible

Where measures failed to identify clinically-significant needs, children would be deemed ineligible for a full-time or part-time program. No clinically-significant needs would be defined as scoring within the average (MSEL, VABS, PLS) or non-clinical range (ADOS) across all measures. Similarly, if at follow-up assessment a child no longer showed significant needs this would signal program completion.

Monitoring of Progress

Each child will have an individual plan (IP) developed following their initial assessment which will be monitored regularly with a review when a child has met their goals, after 6 months, or on parent-request (whichever occurs first). Daily monitoring in learning centres will also occur to monitor each child’s progress on individual goals (e.g., toilet training, writing, etc). In addition, children will complete yearly assessments to look at overall progress.

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Table 1 Clinical Cut-Offs (Grey Shading) for VABS, PLS, MSEL, and ADOS

Score Range	Low	Moderately Low	Adequate	Moderately High	High
Standard Deviation (SD)	-3 SD	-2 SD	±1 SD	+2 SD	+3 SD
Clinical cut-off	Below Average (Clinical Range)	Average	Above Average
VABS SS	≤ 50 < 70	70 < 85	85 115	> 115	≥ 130
PLS SS	≤ 50 < 70	70 < 85	85 115	> 115	≥ 130
MSEL SS	≤ 20 < 30	30 ≤ 40	40 60	> 60	≥ 70
ADOS SS	10 < 6	6 > 3	3 1

*VABS SS = Vineland Adaptive Behaviour Scales — II Standard Score; MSEL = Mullen Scales of Early Learning Standard Score (T Score); PLS SS = Preschool Language Scale 5 Standard Score, ADOS Calibrated Severity Score (Gotham, 2009): note higher scores indicate more ASD symptoms

Transition/Program Completion

Child assessments including monitoring will be used to ascertain a child’s progress towards their goals set at intake. If children have made substantial progress, as suggested by daily monitoring of IP goals, at their 6-month IP meeting, the assessment set may be completed at this point to ascertain whether a child should reduce to part-time or transition. For all children, the same standardised assessments will be used at 12-months to determine if a child continues to require the same level of support (e.g., 20 hours) or whether they have made sufficient progress to be able to reduce their level of support, for example beginning transition to school or mainstream settings. This would be based on the same criteria as for entry above, leading to one of three outcomes:

1. If a child enters the average or non-clinical range across measures then transition would occur.
2. If a child continues to show needs in one or more areas, but substantially improves in cognition, language or adaptive behaviour then a reduction in program intensity would be recommended.
3. If a child continues to show substantial needs across one or more core areas then continuation of the intensive program (where child age permits) would be recommended.

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References

Akshoomoff, N. (2006). Use of the Mullen Scales of Early Learning for the Assessment of Young Children with Autism Spectrum Disorders. Child Neuropsychology, 12(4), 269 - 277.

Dawson, G., Rogers, S., Munson, J., Smith, M., Winter, J., Greenson, J., et al. (2010). Randomized, Controlled Trial of an Intervention for Toddlers With Autism: The Early Start Denver Model. Pediatrics, 125(1), e17-23. doi: 10.1542/peds.2009-0958

Einfeld, S. L., & Tonge, B. J. (2002). Manual for the Developmental Behaviour Checklist: Primary Carer Version (DBC-P) & Teacher Version (DBC-T) (2nd ed.). Clayton, Melbourne: Monash University Centre for Developmental Psychiatry and Psychology.

Gotham, K., Pickles, A., & Lord, C. (2009). Standardizing ADOS scores for a measure of severity in autism spectrum disorders. Journal of Autism and Developmental Disorders, 39(5), 693-705. doi: 10.1007/s10803-008-0674-3 [doi]

Green, J., Charman, T., McConachie, H., Aldred, C., Slonims, V., Howlin, P., et al. (2010). Parent-mediated communication-focused treatment in children with autism (PACT): a randomised controlled trial. The Lancet, 375(9732), 2152-2160. doi: Doi: 10.1016/s0140-6736(10)60587-9

Lord, C., Rutter, M., DiLavore, P., & Risi, S. (2001). Autism diagnostic observation schedule. Los Angeles, CA: Western Psychological Services.

Mullen, E. M. (1995). Mullen Scales of Early Learning (AGS ed.). Circle Pines, MN: American Guidance Service Inc.

Paynter, J., Scott, J., Beamish, W., Duhig, M., & Heussler, H. (2012). A pilot study of the effects of an Australian centre-based early intervention program for children with autism. The Open Pediatric Medicine Journal, 6, 7-14.

Prior, M., & Roberts, J. (2012). Early Intervention for Children with Autism Spectrum Disorders: ‘Guidelines for Good Practice’. Retrieved from http://www.fahcsia.gov.au/sites/default/files/documents/11 2012/early intervention practice guidelines.pdf

Sparrow, S., Dominic, V., Cicchetti, D. A., & Balla, D. A. (2005). Vineland Adaptive Behavior Scales (2nd ed.). Circle Pines, MN: American Guidance Service.

Vivanti, G., Barbaro, J., Hudry, K., Dissanayake, C., & Prior, M. (2013). Intellectual Development in Autism Spectrum Disorders: New Insights from Longitudinal Studies. [Original Research]. Frontiers in Human Neuroscience, 7. doi: 10.3389/fnhum.2013.00354

Vivanti, G., Dissanayake, C., Zierhut, C., & Rogers, S. J. (2013). Brief report: Predictors of outcomes in the early start Denver model delivered in a group setting. J Autism Dev Disord, 43(7), 1717-1724. doi: 10.1007/s10803-012-1705-7 [doi]

Zimmerman, I. L., Steiner, V. G., & Pond, R. E. (2003). Preschool Language Scale (4th ed.). San Antonia, TX: PsychCorp.

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