NDIS

Another week, another consultation paper. And, as an independent speech pathology clinic owner who sees many children with developmental delays and/or disability, this one did not speak to my inner optimist.

1. But, first, a bit of context

Back in late September 2024, we wrote about the first Foundational Supports Consultation, looking at a consultation paper and webinar about General Supports. 

A second paper – Foundational Supports for children with developmental concern, delay and/or disability and their families, carers and kin Consultation Paper – has been released. It’s dated October 2024. But I only found out about it last week; and only then by accident while looking for something else.  

It’s more ambitious than the General Supports paper, and includes a discussion of “Targeted Foundational Supports” for children with developmental delay and their families who need more assistance than General Supports and mainstream services.

2. For strategy and business planning, paediatric allied healthcare providers need to understand what’s proposed

Targeted Foundational Supports are intended to include some allied health services, and so are of interest to paediatric allied health providers (like me), as we look to evaluate our service-delivery models to adapt to new systems of supports made up of three connected tiers:

• mainstream early childhood education and school supports;
• Foundational Supports, including Targeted Foundational Supports; and
• a (yet-to-be developed) new early intervention pathway in the NDIS for children with the highest level of needs.

The idea seems to be that some families will access a combination of these supports, and perhaps different combinations of these supports at different stages as children’s needs change. 

The key challenges for allied health providers are how to work within and across such complex systems to deliver quality, evidence-based services to children while keeping staff satisfied with their work – and staying solvent!

3. Reality check: On the ground, funded supports for children with developmental delay and/or disability through the NDIS are shrinking

On a first read, page 9 of the paper caught my eye:

“The recent ‘Getting the NDIS Back on Track” changes to the NDIS Act do not change a child’s participant status or remove their access…Nothing is changing now.”

These statements are hard to reconcile with recent news stories, like this, with journalist Rick Morton reporting that:

• the NDIA is sending out more than 1,000 eligibility reassessment letters each week;
• in the last six weeks, almost 7,500 eligibility reassessments have been performed – 78% of which are on children aged up to 8 in the early intervention scheme – with 48% of the total being removed from the NDIS, and 20% being asked to provide more information (so-called “general evidence”) within 28 days if they “think they still meet the NDIS eligibility requirements and wish to continue with the NDIS”; and
• the NDIA is completing around 1,250 eligibility reassessments per week, aided by 95 new dedicated staff.

“Nothing is changing now”? Many families and health care providers would disagree.

4. Two predictions, and a comment

A. Allied Health Targeted Foundational Supports will not be provided in clinics

According to the authors of the consultation paper:

• the 2023 Independent Review of the NDIS found that, under the current system:
  • “supports for children with emerging developmental concerns and disability are too focused on a clinic-centred model of support and not enough on functional and support needs”; and
  • there was “not enough focus on supporting children in everyday settings where they live, play and learn” (see page 13);
• decisions on how to deliver Targeted Foundation Supports are yet to be made by governments. But the options to be considered:
  • will look to use existing services and infrastructure to deliver supports to where children live, learn and play;
  • may be provided in group settings (helped by an allied health worker or a multidisciplinary team) or individually in a child’s natural environment;
  • mark a change of approach that “shifts away from a mostly one-to-one therapy model in clinical settings, which is not seen as best practice early intervention for most children”; and 
• a child may have access to allied health:
  • through a referral to a group with other children getting similar supports “helped by an allied health worker or a multidisciplinary team”; or
  • individually in the child’s natural environment (page 18).

B. Allied Health Targeted Foundational Supports:

a. will be more limited than under the ‘former’ NDIS; and 

b. may not always be delivered directly by allied health professionals 

The paper’s authors state that some children could be eligible to get one or more of:

• low intensity or periodic child and and family-centred allied health supports, including from speech pathologists, physiotherapists, psychologists, occupational therapists or other allied health specialists;
• more intensive, one-to-one capacity-building from a (not specified) “suitably qualified and experienced worker” who could provide coordination and help families get appropriate supports. This support may be delivered jointly with allied health supports (page 17);
• a one-off, low-cost assistive technology consultation to increase independence at childcare, school or home (page 18); and/or
• extra supports if the child is “identified” as having concerns across a number of developmental areas, delivered by a “qualified and experienced person with child development expertise”. It’s not clear who will identify the concerns, or what qualifications, experience or child development expertise will be required (page 18). 

C. A closing comment

The consultation period appears to end at midnight on 5 December.

Based on what happened with the NDIS supports consultation, a cynic might suggest that the Federal Government has already decided what it wants from Foundational Supports and will now work with the states to make it happen, regardless of what families or allied health providers think or say.  

I don’t know. But it’s hard to justify spending significant time or resources responding to consultation papers when we have so many clients needing help, when so many changes are happening at once, as we approach calendar year-end and have already weathered so much change in such a short period.

But we can’t ignore the changes, either. 

Paediatric allied health clinic owners must start to think about whether they want to deliver Targeted Foundational Supports, recognising that:

• adding Foundational Supports to service-mixes may:
  • increase business risks and complexity;
  • take away resources from other services and projects; and
  • affect staff satisfaction with our workplaces;
• one-to-one or in-clinic models are unlikely to work;
• therapy dose constraints may reduce outcomes;
• service-delivery constraints may reduce control over service quality; and
• cost-effective access to mainstream and other ‘natural’ settings may be difficult in some states and regions for logistical, compliance, or financial reasons.

We must also remember that proposed changes will be hard to navigate and deliver for other stakeholders, too, including educators in childcare settings and schools, and governments. 

As the authors of the paper note, effective, early child- and family-centred care, through the delivery of strength- and evidence-based services, can lead to significant improvements for children across developmental domains. We all want systems that deliver good outcomes for children and families.

One other thing we must not forget: the stakes of getting this right are life-changingly high for children with developmental delays and/or disability and their families – particularly for children who are (or become) ineligible for the NDIS, but who need more help than is and will be available through mainstream services. 

Read more: 

Allied health providers: get up to speed on the key NDIS reforms that will affect your practice (a free resource)

Allied health providers must review services for young participants to ensure they’re NDIS supports

Will NDIS reforms and foundational supports trigger the end for many paediatric allied health clinics?

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