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New NDIA Therapy Guideline: 11 things allied health NDIS providers should do now to check compliance

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On 13 October 2025, the NDIA published their guideline on therapy supports (the Therapy Guideline). 

The Therapy Guideline outlines how the NDIA makes decisions about therapy supports for children aged 9 years and older. But it contains some guidance for therapists working with younger children, too.

NDIS providers – registered and unregistered – need to review the guide to ensure they comply with it (see link below).

Numbers in brackets below refer to page numbers of the Therapy Guideline.

Things to do now:

  1. Review the NDIA’s special meaning of “evidence-based” therapy supports (2-3): For example, it includes whether the therapy uses the “most up-to-date and reliable research studies” and whether it is “value for money compared to the supports available from other mainstream systems, like health or education”.  
  2. Review your outcomes measures (4, 18, 20): The requirement to measure and report therapy outcomes is a recurring theme in the Therapy Guideline. 
  3. If you are providing early childhood supports to children younger than 9, review the National Best Practice Framework for Early Childhood Intervention (6) (see link): Pay special attention to guidance on professionals working together as a team to support young children and their families.
  4. Confirm all your therapists are qualified allied health professionals for the purpose of the Therapy Guideline (6-7, 8-14): Check they are AHPRA registered, or accredited by a recognised peak body referred to in the Therapy Guidelines (8-14). For example, speech pathologists must be Certified Practising Speech Pathologists approved by Speech Pathology Australia (14). 
  5. Make sure you are not claiming NDIS funds for work done by allied health students on unpaid student placements (8): You can claim for some of the supervising therapist’s time supervising the student’s delivery of therapy to a participant – but only with the agreement of the participant. (It’s not entirely clear which supervision costs you can claim, but we assume they must be related to the therapy delivered to the relevant participant.)
  6. Check that your therapy supports meet the NDIS funding criteria specific to the type(s) of therapy you provide(8-14): This includes taking steps to…
  7. …Ensure all your services to participants are NDIS supports (15-16, 19): In addition to staying on top of the current definition of NDIS Supports (see link below), pay close attention to any:
    • Group programs (16, 19): In principle group sessions may be OK (19), but make sure there is enough evidence they are effective (e.g. the NDIA does not consider Lego therapy, yoga, art and music lessons, and drama groups to be effective therapy supports).
    • Home programs or ‘therapy in a box’ and kits (16): The NDIA does not consider therapy kits or therapy-at-home programs, once-off or ongoing subscriptions, or programs posted out by allied health practices to be NDIS supports because they are not individually tailored or evidence-based programs, and they are not overseen or delivered by a qualified therapist with a measurable outcome. 
  8. Check that your client-participants aren’t working on the same goal with you and another therapist (17): The NDIA won’t fund two therapists working on the same goal.
  9. Review your assessment report templates and practices (17, 18): They need to include recommendations for NDIS supports, dosage (including how often they are delivered), and rationales. They also need to include information about how gains or expected outcomes will be measured, and expected timeframes to achieve goals.  
  10. Review your therapy planning tools (19): For example, do they contain strategies and recommended supports to help participants build or maintain skills, that participants might want to share with other providers and informal supports?
  11. Review progress report templates and practices (19-20): For example, progress reports should include the information referred to in pages 19-20 of the Therapy Guideline, including any measurable, functional gains, and best-practice recommendations for further therapy (if relevant).

Further reading: 

Supports funded by the NDIS

‘NDIS Supports’ definition: who’s confused?

National Best Practice Framework for Early Childhood Intervention | Australian Government Department of Health, Disability and Ageing

Thriving Kids Programs Part 1: Inklings

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In his National Press Club Address of 20 August 2025, Minister Mark Butler name-checked some programs that might be scaled up and block-funded under Thriving Kids. In this series, we’ll take a brief look at them. 

We’ll start with a program called Inklings.

Context:

Over time, Thriving Kids is intended to replace the NDIS early intervention pathway for children with mild and moderate autism and developmental delay. It’s meant to be funded 50:50 by the Federal Government and the States. (As of now, Thriving Kids has yet to be agreed with the States.) 

Overview:

Inklings is a very early parenting support program for children aged 6 months+ and in the first 2 years of life who are showing behavioural signs of possible autism.* 

History:

Inklings was adapted from a program called iBasis-VIPP, which was itself adapted from a Dutch program called Video Interaction to Promote Positive Parenting (VIPP). 

Who ‘owns’ it?

The Kids Research Institute Australia and the University of Manchester co-own the intellectual property in the iBASIS manual (2023). 

Goals:

Inklings supports (amongst other things):

  • social interaction and communication development for babies with early developmental delays; and
  • parents’ communication with their baby.

What does it involve?

  • It takes 5 months.
  • A trained therapist delivers Inklings directly to parents and their infant. 
  • It’s delivered in family homes.
  • It’s 10-12 therapy sessions long:
    • The first two sessions focus on baby behaviour.
    • The 3rd and 4th sessions, look at parent behaviour. 
    • The 5th and 6th sessions focus on more complex chains of social interactions.
    • The program is rounded out with 5 or so ‘booster’ sessions to consolidate learning.

Core features:

  • Child-led, helping parents learn to follow their baby’s natural interests. 
  • A focus on social interactions and communication between the baby and the parents.
  • In each session, parent-baby interactions are videoed and reviewed, with therapist feedback, including on positive examples of sensitive interactions.
  • Therapist observations, supporting parents’ self-reflection, and focusing on behavioural changes.
  • 15 minutes of daily home practice interacting with their infant in natural situations (e.g. play, mealtimes) using newly-learned skills. 

Evidence:

Inklings has been shown to be effective by two randomised controlled trials involving more than 150 babies (see below). At the age of 3 years, children who received the treatment as 9-month+ aged babies showed a statistically significant reduction in the severity of their autistic behaviours, and were less likely to meet the diagnostic criteria for an autism diagnosis.

Controversy:

Some autistic adults have concerns about some aspects of the treatment and point out that autism cannot be prevented or cured. In recent years, Inklings researchers have actively consulted with autistic adults to understand different perspectives on acceptable supports for babies and toddlers (see below), and to embrace neuroaffirming language (e.g. in the 2023 iBasis manual and other program materials). 

Bottom line:

Inklings is an evidence-based, very early family support program for children from age 6 months in their first 2 years of life who are showing early signs of autism. Compared to some other autism therapies, it’s a relatively ‘low dose’ and low cost program, making it appealing for governments looking to fund a program to help families at scale.

Further reading:

*Important note: When looking for very early signs of possible autism, researchers and health professionals look at multiple behaviours, including spontaneous eye contact, so-called “protodeclarative pointing” (where the child points to an object or event to direct another person’s attention to it), social gestures, imitation, and response to name. A lack of one or more of these behaviours does not of itself mean a child is autistic. If you are concerned about your child, speak with a health professional.

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

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“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

Allied Health Providers: The NDIA Just Told Us the Truth (Again)

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What They Said

“The NDIA does not directly fund providers, but allocates funding to NDIS participants and business decisions, including whether to continue offering services through the NDIS, are a matter for individual organisations.”

(NDIA spokesperson, quoted in “NDIS providers evacuate market after pricing review,” by Sarah Ison, The Australian, 10 August 2025)

In plain English: The NDIS pricing decision was not an accident. It was designed to restructure the market. No one is coming to save providers who won’t or can’t adapt.    

So, we have a choice.

Low Agency Responses

  • Complain
  • Wait for better conditions (they’re not coming)
  • Accept razor-thin margins or losses
  • Blame the NDIA when things get worse

High Agency Responses

Ask different questions:

  • How do we build a business that thrives regardless of – or despite – the NDIA?
  • How can we turn constraints and gaps into a competitive advantage?
  • What would we do if failure literally wasn’t an option?
  • How would someone from a completely different industry solve this challenge?
  • How would we handle this if no government funding existed at all?
  • What are participants begging us NOT to change about our services? 
  • What’s the smallest step we could take today that moves us toward sustainability?
  • If we only had 6 months of funding left, what would we prioritise?
  • What would we regret not trying if we looked back in 5 years?
  • If we locked our three smartest colleagues in a room for 2 hours to work on this problem, what would they come up with?

Take small actions now:

  1. Map dependencies – Where are you most vulnerable?
  2. Diversify revenue – Who else needs the value you provide?
  3. Build efficiencies – How can we deliver better outcomes, more quickly?
  4. Create loyalty – How do we make ourselves less generic, more useful, and more sought after?
  5. Add to choice and control – Can we deliver more and better services in different ways to increase participant choice?

Bottom line:

The NDIA’s statement isn’t a threat – it’s another reminder that things have changed. They’ve just told us exactly where we stand.

The truth is hard to take, but we can do it: 

  • Our opportunity: Providers who adapt to reality > providers waiting for rescue.
  • Our choice: Victim of policy or architect of our own solutions?

Need a 30-minute pep talk to get the creative juices going? Check out this terrific essay by George Mack.

Curious about how to actually apply high-agency principles in your practice or workplace? On 25 August, we’re releasing our Courage Playbook – available only for our Banter Booster Premium subscribers. Sign up here.

‘NDIS Supports’ definition: who’s confused?

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On 30 July 2025, the Government published its report on the August 2024 ‘Consultation on Draft Lists of NDIS Supports’.

The report is very late.

The report and its timing may confuse some participants and providers.

Here is a quick recap:

The Government published its draft “in” and “out” lists to define NDIS Supports on 4 August 2024 – almost a year ago.

The consultation period was very short: 4-to-25 August 2024.

Participants, providers, advocates and others found the time to respond to the consultation: the Government received more than 7,000 responses and submissions.

The Government imposed its transitional rules for NDIS Supports on everyone on 3 October 2024 – almost 10 months ago.

Until 30 July 2025:

  • it was unclear whether the Government had listened to anyone who responded or made submissions;
  • some participants and providers thought that:
    • they had wasted their time responding to the consultation paper; and/or
    • the Government had ignored their submissions; and/or
    • there was no real consultation about the NDIS support lists – the Government had already ‘made up its mind’ when it published the lists.

As predicted by many people who responded to the consultation, the “in” and “out” lists have been difficult to apply in practice.

The report shows that the Government knew about many of the problems with the lists, including:

  • the application of black-and-white inclusion and exclusion rules to “grey areas” at the intersection between disability-related supports and mainstream health care and mental health care (e.g., pp 13, 29-32);
  • the practical effects of excluding particular supports for a person with disability when there are well-known, significant gaps in early childhood, health, education, aged-care and other mainstream supports and systems for people with disabilities (e.g., pp 10, 13, 33-35);
  • the practical challenges of establishing whether an individual’s specific need in a given case may relate to their disability, healthcare, educational attainment, or employment (e.g., pp 10, 33-34);
  • the meaning and scope of ‘evidence-based’ therapeutic supports (e.g., pp 17-18); and
  • confusion about how the rules apply to the funding of various specialist and standard products and equipment, and different assistive technologies, and communication devices and information equipment (e.g., pp 11, 20, 25).

On 16 June 2025, the Government launched another consultation on the definition of NDIS Supports – this time to replace the transitional rules with a “final definition”.

This second consultation closed on 27 July 2025.

We look forward to reading the next consultation report.

Hopefully, this time the Government will give participants, providers and other stakeholders an opportunity to see and comment on the proposed new definition well before the new definition comes into effect.

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