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foundational supports

Small NDIS allied health providers: keep moving, and don’t give up

David Kinnane · 28 November 2025 · Leave a Comment

State of play:

As at the end of November 2025, NDIS reforms include lots of parts, uncertainty, and complexity. 

Unknown unknowns:

Small allied health providers must plan for 2026. But how can we make decisions about strategy, services, marketing, recruitment, training, compliance, resources, and finances with so many balls up in the air?    

Chessboard fallacy:

More than 250 years ago, Adam Smith warned us not to look at policy reforms as a game in which governments rearrange people like chess pieces. We make better decisions if we accept that every person and organisation affected by NDIS reforms has their own goals, incentives and biases (including us). 

Not about us, or “us versus them”:

It sometimes feels like small providers have been targeted for elimination. But the stakes are much higher for participants. And we shouldn’t assume governments, regulators, the media, large providers or others are acting with malice. We all want better value services and outcomes for people with disability. We all want the NDIS to survive.  

So what do we expect in  2026, and why?

1. Increased NDIS allied health funding pressures as:

  • participants lose scheme access through eligibility reassessments;
  • children with ‘mild and moderate autism or developmental delay’ are diverted to Thriving Kids (see below);
  • the early intervention pathway is abolished for most kids;
  • new plans are approved with tighter funding controls;
  • I-CAN support needs assessments roll out for participants aged 16 and over (perhaps with algorithmically-determined funding); 
  • the permanent definition of “NDIS supports” is released and implemented;
  • the NDIS Evidence Advisory Committee’s Capacity Building and Therapies Subcommittee scrutinises the cost-effectiveness and quality of evidence for different therapies (including dosages);
  • recommendations emerge from the therapy pilot (commencing in January 2026) to “better understand costs and characteristics of quality service delivery”. (Controversially, this was commissioned through a closed, non-competitive tender that locked out small providers); and
  • additional/differential pricing limits are imposed for different types of therapy, and travel (e.g., the new price limits for music and arts therapists from 24 November 2025).

2. Continued government and media narratives about “dodgy providers” and “unregistered cowboys” 

  • Politicians conflate “unregistered providers” with bad actors and fraudsters to maintain public and taxpayer support for urgent reforms. 
  • Large registered providers – with very real profitability challenges – continue to run the “unregistered = dodgy cowboy” line because it helps them lobby for special pricing arrangements, mandatory registration of all providers, and taxpayer bailouts. They know these changes would drive more small allied health providers out of the sector and reduce competition – and participant choice.  
  • Allied health professionals are regulated. Duplicative rules increase costs and distract from service delivery, which is why we endorse the NDIS Provider and Worker Registration Taskforce 2024 recommendation to “deem registration” of allied health providers based on existing allied health regulations plus worker checks.

3. More small providers will exit the sector, but others will adapt and keep going 

  • On 24 November 2025, the NDIA said that, as the market matures, some providers will decide to stop delivering all or some sorts of NDIS supports. 
  • In June 2025, the Independent Pricing Committee predicted much the same thing, recognising that pricing limits make it difficult for small allied health clinics with staff to remain viable (see links). 
  • We are not powerless pawns. Lots of small providers are advocating for “reforms to the reforms”, making submissions to consultations, meeting with MPs, working with peak bodies, unionising, and/or supporting disability advocates and  affected participant groups. 
  • No one is going to bail out insolvent small allied health providers – and nor should they. Over the last 18 months, many providers have worked hard to reduce their dependence on NDIS funding. Unavoidably, this has reduced access to therapy for participants in some areas.

4. Families will be underwhelmed by Thriving Kids programs and outcomes

  • Thriving Kids, not yet agreed, looks like a return to block-funded programs, general strategy-sharing, parent training, and (possibly) short interventions, perhaps in groups. 
  • Evidence-based early intervention programs, like Inklings, show promise. Outcome data for school programs are much less compelling (see links). 
  • We don’t know who will deliver Thriving Kids programs ‘on the ground’, although we expect large registered providers (with subcontractors), and/or state government employed workers. 

5. New allied health service gaps will emerge

  • Public disability, health and education systems in many states are under stress.
  • Funding systems are built on the false premise that people’s disability, health and education needs are unrelated:
    • If you have a disability or have worked for a person with disability or delay – an autistic toddler, a dyslexic teenager, a young adult with cerebral palsy, an older adult with Parkinson’s disease, for example – you know this is untrue.
    • Health, education and disability systems and budgets are interdependent, which explains, in part, why governments have handcuffed Thriving Kids to the 5-year public hospital deal negotiations.  
    • State governments, like NSW, continue to consult on “Foundational Supports” (talking about the same cohort of kids as Thriving Kids). Thriving Kids may look very different state-to-state, region-to-region. 
  • Overall demand for allied health services remains high. But the allied health workforce is limited, especially in rural and remote settings. 
  • Many allied health providers work across multiple systems and will split their resources based on client demand, professional interests and skills, and system incentives. In states like NSW, health and education bureaucracies don’t always get along, and working between systems is inefficient, with access and other real world logistical challenges. 
  • A large chunk of the allied health workforce with disability experience is employed in the private sector because of the way the NDIS used to work. As the model changes, the workforce and employers will adapt. But this will take time, and new service gaps will emerge. 

6. Provider legal and compliance risks and costs will increase

  • Legal and compliance risks for providers, owners and managers have steadily increased over the last two years.
  • If enacted, the new NDIS reform bill (released on 26 November 2025) will further increase risks for all providers (not just the “fraudsters and cowboys”). 
  • Expect insurance premiums to rise, too.

7. A flight to quality?

Regardless of funding models and business pressures, we can’t cut corners if we want to succeed:

  • Clients deserve excellent services: including safe, timely, evidence-based, client-centred, convenient, and high quality services.  
  • Our staff deserve respect: Professionals want to learn, to belong, to create, to grow, and for their work to have an impact. They need to be trained and supervised properly. They need the right resources to deliver great services that produce real outcomes for clients.   

Bottom line:

Small allied health providers that deliver quality services to participants while supporting teams should feel proud of their hard work this year and take heart. As 2026 approaches, we should back ourselves to compete on quality and outcomes with large providers, and to provide participants with real choice and control. 

Go deeper: 

The Chessboard Fallacy

Thriving Kids Advisory Group Communique – November 2025 | Australian Government Department of Health, Disability and Ageing

Foundational Supports for Children | NSW Communities and Justice

Not-for-profit disability services are closing due to untenably low price caps, NDIS architect warns

NDIS providers’ losses double, more taxpayer bailouts likely (paywalled)

New tool to deliver simpler pathway to disability supports | NDIS

NDIS Evidence Advisory Committee | Australian Government Department of Health, Disability and Ageing

Quality supports program tender | NDIS

Updated NDIS Pricing Arrangements and Price Limits 2025-26

Professionals Australia NDIS Allied Health Union

Allied health providers and pricing controls: independent providers that employ, train, and supervise staff are caught in the middle, and might not survive (and the NDIA knows it)

NDIS Supports rules | engage.dss.gov.au

Independent Pricing Committee | NDIS

Small allied health NDIS providers: should we all be registered?

Thriving Kids: will ‘targeted supports’ deliver what children and families need?

Thriving Kids in Schools: Will it Work?

Thriving Kids: will ‘targeted supports’ deliver what children and families need?

David Kinnane · 20 November 2025 · Leave a Comment

State of play:

On 7 November 2025, the Thriving Kids Advisory Group held the second of what will be three meetings to advise the Government on the design of Thriving Kids. 

Zoom in:

Among other things, the group is considering targeted support models, including:

  • “what opportunities are provided to expand universal, [Medicare] health and development check, and community and Allied Health services”; and
  • the need for supports that “respond to complexity of children’s developmental and social needs, and the well-being of parents and families”.

Zoom out:

For thousands of children with “mild and moderate” autism and developmental delay, Thriving Kids is intended to replace NDIS-funded, individualised supports. 

Friction Points:

  • The stakes are high. Many children need targeted help but will no longer be able to access it under the NDIS. Even with improved universal information services, targeted supports will be crucial for many autistic children and children with developmental delay.  
  • Timelines are tight. The Government requires the group to finalise its advice on the design of Thriving Kids “in early December 2025”.  
  • The states are pushing back:
    • Media reports on 20 November 2025 suggest negotiations between Federal and state governments on funding are not going well.
    • In parallel, some states (like NSW) are consulting on “foundational supports”, which may or may not be completely consistent with Thriving Kids.

The goal: 

  • The advisory group wants Thriving Kids targeted supports to be “inclusive, strengths-based, neuro-affirming…trauma informed and effective in identifying children who may benefit from additional support”.  
  • Identifying kids who need additional support is of course important. But, naturally, many families want to know what specific supports will be provided to their child.

Use what we know:

  • Lots of work has already been done to outline what’s needed to improve outcomes for young autistic people. 
  • In December 2022, AutismCRC published a National Guideline for supporting the learning, participation and wellbeing of autistic children and their families (Guideline). The Guideline:
    • was developed by a group that included autistic people, families, researchers, and health professionals; and
    • includes 84 consensus-based, evidence-informed recommendations that explain how to work with autistic children and their families in ways that are “safe, effective, and desirable”.
  • While the Guideline’s scope is limited to helping autistic children, many of its recommendations apply to children with developmental delay.

Reality check:

The Guideline gives us a framework to evaluate any proposed targeted supports for children.

What we’re watching*:

In line with the Guideline, Thriving Kids targeted supports should be:

  • Child and family-centred (1);
  • individualised for each child and family (2);
  • ethical (7);
  • evidence-based (10);
  • delivered only with the informed consent of parents (12);
  • delivered by people who:
    • are properly qualified and supervised, and engaged in continuous professional development (13); or
    • (if not regulated health professionals) have:
      • the appropriate knowledge, skills, experience, training and regulation; and
      • adequate supervision and support from the professional who has overall responsibility for the delivery of supports (51); 
  • timely and accessible (16);
  • focused on family-led goals, with support from practitioners and other relevant people (22);
  • meet the child’s sensory needs across activities, interactions, and settings (28);
  • delivered in setting(s), formats, and dosages likely to lead to the most meaningful and sustained increase in the child’s learning, participation and wellbeing (53, 54 and 56);
  • designed to:
    • allow children and families to give feedback and make complaints(78); and
    • require providers to inform the child and family about any potential or actual conflicts of interest in providing supports or making referrals(79). 

Bottom line: 

  • There’s an awful lot we don’t know about Thriving Kids; and its funding is uncertain. But, whatever happens, we all want better outcomes for autistic children and children with developmental delay. 
  • The Guideline distills years of research and multiple perspectives into specific recommendations to achieve better outcomes. It should be used to help finalise the design of targeted supports under Thriving Kids – and to evaluate whether they are likely to help the  kids who need them.    

Go deeper:

Thriving Kids Advisory Group Communique – November 2025

Fiscal Fisticuffs Turn into Health Funding Brawl (The Australian, 20 November 2025)

Supporting Autistic Children Guideline – AustismCRC

Thriving Kids in Schools: Will it Work?

Thriving Kids Programs Part 1: Inklings

Thriving Kids Programs Part 2: Mental Health in Primary Schools (MHiPS)

Thriving Kids Programs Part 3: Positive Partnerships

Breaking news: “Thriving Kids” – more than just a new name for Foundational Supports for children?

*References to numbers are to Guideline recommendations.

Breaking news: “Thriving Kids” – more than just a new name for Foundational Supports for children?

David Kinnane · 20 August 2025 · Leave a Comment

“Thriving Kids”, announced by Minister Mark Butler on 20 August 2025, is the snappy new name for Foundational Supports for children.

But is it more than that?

We don’t have a lot of details right now. But it sounds different from the original proposal for Targeted Foundational supports (discussed in 2024), and a lot more like what the Grattan Institute recommended (back in June 2025 – see below):

  • The Federal Government to take leadership of the new national system (to avoid eight different State systems).
  • Limiting NDIS access for children to only those children with significant and permanent disability (i.e. children who are likely to need lifelong support).
  • Funded programs, like Inklings, MHiPS and Positive Partnerships for children with mild and moderate developmental delay or autism to be delivered in mainstream settings, like community health centres, supported playgroups, and schools. 
  • Increased scrutiny over consistent pricing and value for money of allied health and other services across disability, health and aged-care sectors.

If this is right, the new system may mean:

  • the end of the early intervention NDIS pathway and individualised supports for most children who would otherwise qualify for the NDIS under current rules; and 
  • the creation of new (block-funded?) programmed services to be delivered in mainstream settings, like early community childcare settings and schools.

There was also talk of creating a new Medicare bulk-billed item for GPs to check 3-year-olds for developmental issues, and providing access to new Medicare allied health items.

Of course, we’re yet to hear from the States, who will be paying for half of it. (Some States like NSW have been working and consulting on the earlier Foundational Supports proposal.)

This new system is due to start rolling out from 1 July 2026, with major NDIS access changes flagged for sometime in 2027.

We await more details! 

But, in the meantime, there is already a lot for us all to work through as we think about choice and control and service delivery models for children with developmental delay or disability and their families. 

Related reading:

In deep water: paediatric allied health NDIS providers should read the Grattan Report

Targeted Foundational Supports consultations: an “idea salad” with more questions than answers for allied health providers?

Speech from Minister Butler, National Press Club – 20 August 2025

In deep water: paediatric allied health NDIS providers should read the Grattan Report

David Kinnane · 2 July 2025 · Leave a Comment

The Big Picture:

On 29 June 2025, the influential Grattan Institute published a 108-page report with proposals to save the NDIS (link below).

Many allied health providers were distracted by financial year-end and compliance tasks to comply with the (now live) Pricing Limits for 2025-26.

But the report is well worth a read – particularly for paediatric allied health providers who own or work out of clinics.

Attention-grabbers:

The report authors, led by former NDIA senior policy advisor Dr Sam Bennett, propose several very significant changes:

  • Abolish the early intervention pathway (i.e. section 25 of the NDIS Act) (pp57, 83).
  • Abolish individualised funding for all children under 18 who are or would have otherwise been supported through the early intervention pathway (pp31, 57).
  • Redirect funds to replace the early intervention pathway with “muscular” Foundational Supports (pp56-59):
    • general supports: information and education; and
    • targeted supports, including “low-to-mid-level allied health supports to improve the long-term capabilities of children” (p13).
  • Governments to co-commission Foundational Supports:
    • with 3-5 year contracts (pp49, 71), including for “evidence-based services” to “encourage providers to offer higher-quality programs” (p57); and
    • from “lead providers” that have the capacity and systems to manage a group of sub-contractors (pp50, 73).
  • Adopt a Key Worker model to help families navigate options (p54).
  • 5-year transition to avoid service gaps and give providers “sufficient time to prepare” but with the transition to start from 1 July 2026 (p60).
  • All Foundational Supports – and thus all early intervention therapies – for children to be delivered in natural environments – not clinics – including in “supported playgroups, early childhood education settings, health and community hubs, libraries, and family- and community-led organisations” (pp30, 57).
  • No mandatory registration of allied health providers to provide Foundational Supports. Recognition of AHPRA registration/regulation by a professional body (p75).
  • Better national sharing of provider information, and better integration of provider registration and worker screening checks (pp75-76).
  • Retain individualised plan funding for children with lifelong and severe disability (i.e. for children who meet the disability requirements under s 24 of the NDIS Act) (p57).

Reality check:

These are proposals from a think tank – not government policies. But the report is well-researched and written, and is likely to get the attention of policy decision-makers, as well as media and social media critics of the NDIS.

Bottom line:

Participant and disability advocacy groups will have a lot more to say about the report and the implications for access, and for choice and control over allied health early intervention services.

But paediatric allied health providers should also consider the report when reviewing their business strategies and risks for 2025-26 and beyond.

If implemented, the Grattan proposals would:

  • transform early intervention allied health service-delivery across Australia; and
  • accelerate the sector-wide shake-out of paediatric allied health service providers.

Go deeper:

Bennett, S., Jessurun, M., and Orban, H. (2025). Saving the NDIS: How to rebalance disability services to get better results. Grattan Institute.

Election-mode engaged: allied health NDIS providers must keep an eye on federal health, education and disability policy priorities to support people with disability – and to anticipate service-delivery changes

David Kinnane · 25 March 2025 · Leave a Comment

Big Picture:

Many allied health providers straddle and navigate three imperfect systems to support clients: health, education and disability. Ahead of the Federal Election, the Grattan Institute has published its helpful 2025 Orange Book, setting out what it sees as policy priorities for each of these systems, regardless of who wins. Here are some takeaways:

Context:

  • To maintain systems and to improve living standards for Australia, we need productivity growth. 
  • To improve productivity, the government needs to strengthen our foundations, including health and education for all Australians, including for people with disability.

Health:

  • More focus on preventing chronic disease (including incentives to encourage better diets, more exercise, fewer drugs and less alcohol, and more social connection).
  • Fund Primary Health Networks to create more multidisciplinary primary care teams – especially in under-served areas – with implications for scope of practice, workflows, supervision, teamwork, and business models/fees.
  • More support for GPs, including a shift away from “fee-for-service” service payments and better access to specialist advice.
  • More transparency on fees charged by specialists. 

Education:

  • Lift our game to ensure more students leave schools with essential skills, like reading and numeracy: currently ⅓ of students – 1.3 million students – are at risk of leaving school without essential skills.
  • Set more ambitious targets, e.g. that at least 90% of students reach proficiency in reading and numeracy.
  • Mandate phonics checks across all schools in Year 1, with a Year 2 re-sit for at-risk students.
  • Invest more in:
    • research to identify best practices in real world school settings (e.g. like the Australian Education Research Organisation’s work on secondary literacy instruction); and
    • an independent, non-government, not-for-profit body to quality assure curriculum materials (like EdReports in the USA).
  • Support teachers with evidence-informed guidance, and professional development and training, starting with reading and maths instruction, linked to practical materials (e.g. off-the-shelf curriculum materials and assessment tools) so all teachers have access to high quality materials including teachers working in disadvantaged schools.

Disability: 

  • Stay the course on NDIS reforms to realise the original vision of a multi-tier scheme with different levels of coverage, clear eligibility criteria, data-led resource allocation, and proper operational risk management.
  • Implement a fair, objective, and consistent method for allocating NDIS support packages (including, controversially, a standardised assessment and planning framework). 
  • Re-think Section 10 and interim rules about NDIS Supports, which constrain participant choice and control. 
  • Empower the NDIA to become a more active steward to encourage innovation, intervene when markets fail (e.g. by commissioning services directly), and create a network of regional hubs mirroring the Primary Health Networks.
  • Invest seriously in Foundational Supports (including by redirecting some NDIS funds) so that the wider population of disabled Australians have their needs met, while reducing pressure on the NDIS.
  • Integrate and deliver Foundational Supports in mainstream settings.

Bottom Line: 

  • The major parties – and most of us – want a healthier, more prosperous Australia that allows everyone to live a good life. But times are uncertain, resources are limited, and current systems are imperfect. 
  • Because of our work, allied health providers are in a unique position to:
    • understand the interdependence of health, education and disability systems; and 
    • recognise that changed policy settings in one system can have significant, sometimes unintended, knock-on effects to other systems.
  • To help support participants and other clients, governments should prioritise a new National Disability Agreement clarifying how mainstream health systems, the NDIS, Foundational Supports, mainstream childcare, education and other systems will work together to:
    • support Australians, including people with disability and developmental delay; and 
    • give at least a bit more certainty to the allied health providers who support them, so we can make investment, recruitment, service mix, and other business decisions needed to stick around.

Go deeper:  

Orange Book 2025: Policy priorities for the federal government – Grattan Institute (Errors of interpretation and emphasis in this summary are my own.)

Unleashing the Potential of our Health Workforce – Scope of Practice Review Final Report

Australian Education Research Organisation

EdReports (USA)

More from us:

Allied health NDIS providers must face facts, and make painful – but necessary – changes to survive

Allied Health NDIS Providers: Keep your eye on the ball in 2025!

Allied health NDIS providers: back yourself to try new things, and help more people: a case study

NDIS “ins and outs” for participants seeking “mixed” disability, health and education supports: mind the gaps between NDIS and mainstream services

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  • Thriving Kids in Schools: Will it Work?
  • Thriving Kids Programs Part 3: Positive Partnerships
  • The Key Worker Model for young children with developmental delay or disability: does it actually improve child outcomes? 

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