Every Australian Counts believes Thriving Kids should strengthen, not replace, children’s rights to individualised disability support, and must be co‑designed with Autistic and neurodivergent people and families.

Plain language summary

Thriving Kids is a proposed new program to give children with disability earlier support in their communities.

That could be a positive step, but it must not replace the NDIS.

Children with disability still need the right to individual NDIS support. Taking children out of the NDIS and putting them into a general program could mean less support and less choice.

Families are also worried about losing control. If governments choose services instead of families, it could mean:

• fewer choices
• longer wait times
• the wrong supports

This is especially risky for families in rural areas and for children who need specialised or culturally safe support.

Thriving Kids must be designed with people with disability and families. Their voices need to lead the decisions.

For this program to work, it must:

• protect access to the NDIS
• give families choice and control
• provide free, local supports
• be shaped by lived experience

EAC’s position

Foundational supports are welcome, but cannot replace the NDIS. Thriving Kids has the potential to expand early, community‑based supports – including no‑diagnosis entry, no‑gap allied health via the Medicare Benefits Schedule (MBS) Child Development Plans, and delivery “where children live, learn and play” – but these changes must operate alongside, not instead of, individualised NDIS funding. Children with permanent and significant disability must retain their entitlement to NDIS supports under sections 24 and 25 of the NDIS Act, now and after the delayed access changes commence. Removing one cohort of children from the NDIS and funnelling them into a general program is discriminatory and risks breaching Australia’s obligations under the United Nations Convention on the Rights of People with Disability (UNCRPD) and the United Nations Convention on the Rights of the Child (UNCRC).

The commitment that children with significant and permanent disability will “continue to be supported through the NDIS” is positive, but vague promises are not enough. How access is interpreted and operationalised, particularly for Autistic children, will determine whether rights are protected or quietly eroded.

Block funding, choice and equity

Every Australian Counts strongly opposes a return to block-funded, state-run models that do not provide families with an individual budget or genuine choice of provider. Under Thriving Kids, supports will be commissioned by States and Territories rather than purchased by families, creating real risks of repeating pre-NDIS problems: limited choice, long waits, patchy quality and postcode lotteries, particularly in rural and remote areas.

While commissioning can, in theory, help address thin markets, experience shows that block funding can actually increase service gaps for some communities. Where funding is directed to a small number of large providers or generic programs, smaller community-led, culturally specific and specialist services often struggle to survive. This can disproportionately affect:

• First Nations children and families who need culturally safe, community-controlled supports;
• Children and families from culturally and racially marginalised (CaRM) backgrounds who require language-appropriate and culturally responsive services; and
• Neurodivergent and disabled children who need neuro-affirming or specialist approaches not available through standardised programs.

When only one or two providers are funded in a region, families who need culturally specific or specialist support may be left with no appropriate option at all. In these contexts, block funding can deepen inequity by concentrating resources in mainstream services while culturally grounded and community-based organisations remain under-resourced or excluded.

Block funding can also weaken safeguards. Where families depend on a single commissioned provider, they may feel unable to raise concerns or are unable to change to a more suitable provider, particularly in small or rural communities. Claims that block funding is the primary solution to “thin markets” do not match lived experience or the evidence from EAC’s survey, where families and providers consistently warned that block funding risks increasing inequity, instability and service gaps.

True equity means free, local, culturally safe, neuro-affirming supports with no gap fees — but also the power for families to choose who provides them, to change providers if needed, and to access individualised support when group or standardised programs are not appropriate or not enough. Commissioning models must therefore complement, not replace, individual budgets and choice, and must actively invest in community-led, culturally specific and specialist services to ensure no child is left without appropriate support.

Autism, neurodiversity and co‑design

Thriving Kids is explicitly targeted at children aged 0–8 who are Autistic or have with Developmental Delay, yet key recommendations fail to mandate co‑design with Autistic people and autism‑specific organisations. This omission is unacceptable and inconsistent with UNCRPD Article 4.3 and the co‑design principles already embedded in the National Autism Strategy.

Every Australian Counts rejects deficit‑based narratives that autism is “over‑diagnosed”, “over‑serviced” or neatly divided into “low to moderate” categories. These labels are not clinically accurate, erase the fluctuating nature of functional capacity, and are widely experienced as tools to justify restricting support rather than recognising need.

All aspects of Thriving Kids – policy, design, governance, service models and evaluation – must be co‑designed with Autistic and other neurodivergent people, families and representative organisations. The program must align with, and build on, the National Autism Strategy and its First Action Plan, not create a parallel, less‑rights‑based system for Autistic children.

Evidence, programs and implementation risks

The new detail on Thriving Kids – including multiple referral pathways, delivery “where children live, learn and play”, a 3‑year‑old MBS health check, and a commitment to evaluation – is welcome. However, the design still leans heavily towards clinical and programmatic responses without sufficient analysis of effectiveness, harms or community acceptability for specific programs.

Families and Autistic adults have raised serious concerns about Applied Behaviour Analysis (ABA) style and behaviour‑change programs, describing them as non‑neuro‑affirming, likely to increase masking and distress, and out of step with contemporary evidence and human rights standards. Any use of such programs under Thriving Kids is unacceptable unless they are fundamentally redesigned and governed by Autistic‑led co‑design.

Workforce development is correctly identified as critical, but training alone is not enough. Without changes to leadership, staffing levels, time, resources and system design in schools, health and early childhood services, responsibility will simply be shifted onto already over-stretched front‑line workers who do not have the structural conditions needed to implement inclusive practice. This risk is acute in regional and remote areas where workforce shortages are already severe.

Rights, safeguards and governance

Thriving Kids must not be used as a budget measure or a “back door” gateway to restrict access to the NDIS for Autistic and disabled children who meet existing eligibility criteria. EAC strongly oppose any changes to NDIS eligibility requirements.  A well-designed and high quality Thriving Kids program will naturally lead to fewer children entering the NDIS.

Safeguards must include legislated requirements for genuine, ongoing co‑design – including with First Nations and CaLD communities – strong national governance, independent evaluation, and a clear parliamentary review point, all informed by lived experience.

Children and families must retain choice and control over which providers they see, how and where supports are delivered, and how they move between Thriving Kids, mainstream systems and the NDIS. This includes: no out‑of‑pocket costs, accessible supports in local communities, interpreters and travel assistance, and an explicit right to individualised support where group or generic services are not sufficient.

Transition points are particularly high‑risk. There must be clear, rights‑based pathways into, through and out of Thriving Kids – including at age nine and at any point where a child’s needs escalate – so that no child falls through the cracks due to shifting program boundaries.

Key messages for advocacy

Thriving Kids should build on what works: early, individualised, neuro‑affirming supports embedded in inclusive mainstream settings, delivered alongside – never in place of – the NDIS.

Nothing about us without us: Autistic and neurodivergent children and adults, families and disability communities must lead Thriving Kids’ design, governance and evaluation at every level.

A return to block‑funded, state‑run models without individual budgets risks taking Australia backwards to the very systems that the disability community fought so hard to move away from.

If Thriving Kids is to succeed, governments must commit to genuine co‑design, protect existing rights, invest in workforce and system capacity, ensure free and local access with no gap fees, and publicly demonstrate improved outcomes before making any changes to NDIS access.