On the 14/1/2025, DSS Minister Rishworth and the federal government released ¾ of its National Autism Strategy (NA¾S)^[1]. While we welcome the limited progress planned, we note that the 4th part of a full strategy, the so-called Health Roadmap for Autism, is missing. Also, DSS officials who wrote the ¾-Strategy failed to address many fundamental issues that need urgent action. In its current form, the NA¾S is deeply disappointing to say the very least.

The National Autism ¾-Strategy is a major missed opportunity. The NA¾S falls well short of what the Senate Autism Inquiry recommended; surely the Committee’s members are quite disappointed. Gaping gaps need to be closed immediately. 

From the outset, the diversity of the autism spectrum was going to be a challenge. DSS and the Minister made the problem worse by refusing to include representation for the more severe/profoundly autistic Australians. This lack of representation of a major and critical part of the autism spectrum can be seen in the absence of their issues from the section on “Key themes emerging from the consultation process”.

While the NA¾S claims

The Strategy was co-designed with the National Autism Strategy Oversight Council …

It was written by a secretariat of DSS staff, members of Australia’s deeply disappointing public service ‒ see https://www.canberratimes.com.au/story/8874636/jack-waterford-public-service-integrity-questioned-in-australia. The secretariat lacked real understanding of the autism spectrum, they did not share submissions, and neglected consultation with autistic members of the oversight and working groups. 

Apparently, the process of developing the NA¾S avoided input from Australia’s autism sector unless the views of the carefully curated Oversight Committee/Council autistic members happened to coincide with what bureaucrats wanted in its NA¾S. Notably, the government’s choice of autistic voices for its so-called Oversight Committee or Council excluded the voice of severely and profoundly autistic people - more about this below. The NA¾S admits:

People said the Strategy needs to be underpinned by action and must be upheld, with ‘measures that mean something to Autistic people’ and where there is accountability and ‘consequences for failures to uphold the Strategy.’

However, the NA¾S and its associated Action Plan fail to:

• Require baselines for meaningful measurement and reporting, and
• Mention any consequences for failure … though there is an implication (no explicit mention) that the consequences for failure are especially bad for autistic Australians. 

The lack of real consultation and representation in the development of the NA¾S inevitably led to its unsatisfactory outcome. For example, the NA¾S’s authors refused to use the term “severe and profound autism”, a term preferred by many in that part of the autism sector. Instead, the NA¾S describes “Autistic people with very high support needs” in its glossary. However, when it came to the crunch, the NA¾S’s authors added a broader category of all (possibly non-autistic) “People with very high support needs”, apparently as an afterthought at the end of their list of Priority Cohorts. 

Using the “high needs” term clearly perpetuates and emphasises the government’s and mainstream media’s false mantra that the NDIS is unaffordable - see No, the NDIS is not ‘strangling’ the economy. Economic advice[2] indicates that funding early intervention for severely autistic children is an investment, not a cost – 

for every $1 invested in delivering intensive EI to the AEIOU cohort, a societal return of $6.16 is derived. It is also noteworthy that of this total, $4.58 is direct cost saving for the NDIS.

Severe and profound autism is a major part of the full autism spectrum. The Australian Bureau of Statistic has regularly reported that most autistic Australians have severe or profound disability or at least report substantial “core limitations”. Their latest report on 2022 data said, “almost three quarters (73.0%) of Autistic people had a profound or severe disability.” But DSS does not trust information like this – in its NA¾S First Action Plan, it plans to spend “$2.8 million over 4 years” to check on this. 

An especially notable feature of the NA¾S is its neglect of the NDIS. There are massive problems with autism in the NDIS; these include the following.

• The NDIS Act fails to recognise the triad of impairments that are autism; the legislation suggests autism is not a disability. Autism is usually described as social, communication and behaviour impairment. Autism is the biggest primary disability type in the NDIS yet the government omitted all three of autism’s triad of impairments from the NDIS Act’s impairments lists in S24 & s25.
• In its almost 12 years of existence, the NDIA has repeatedly failed to develop effective approaches for autistic children. The NDIA’s most recent consultation on the subject closed on 14 May 2021 but A4 is not aware of any outcome.
• The NDIS wilfully misunderstands autism and its severity ratings ‒ see https://a4.org.au/node/2647
• The NDIA’s fraud/integrity processes target autistic participants with high needs, the last of the NA¾S’s Priority Cohorts ‒ see https://a4.org.au/node/2682
• The NDIS targets autistic children generally ‒ see https://a4.org.au/node/2686
• The NDIA Scheme Actuary expressed expectations that autism numbers would stabilise. This is contrary to all evidence, gross misinformation, and a completely false foundation for NDIS to policy and program development for autistic NDIS participants.
• The NDIA’s approach to evidence-based supports is cruel and completely contrary to the UN CRPD because the ART is a serious barrier to accessing essential disability supports for severely autistic children. The NDIS marginalises severely autistic children and their families have to argue their case against an oppositional and aggressive government at the ART (see https://a4.org.au/node/2567 and https://a4.org.au/node/2640). The NDIA developed its ABA Case Management Guidelines without clinical advice, consultation or co-design. The NDIA was meant to review the guideline at 6 months, but the NDIA stopped the belated review when it started and gave responsibility for the conduct of the review to the original author of the document. It has still not been reviewed. The NDIA does not follow its own case management guidelines - their legal representative recently informed an ART case conference that any request for Applied Behavioural Analysis (ABA) as a support would result in the Respondent, the NDIA’s lawyers, requesting a report from an Independent Medical Examiner (IME), and action that implies progression towards an ART Hearing.
• There are many more issues with the NDIS’s treatment of autistic NDIS participants, their Informal Supports, their representatives, clinicians and disability advocates.
• NDIS data access requests about autistic participants are often undelivered or denied ‒ we expect there are major issues in SIL and SDA and substantial unmet support need for high needs autistic NDIS participants
• The NDIS and DSS refuses to recognise and address the enormous and increasing problems in external clinical workforce seriously deficient capacity and capability
• There is a chronic lack of the individual advocacy that growing numbers of severely or profoundly autistic people need to engage with the NDIS, especially those with severe/profound disability. Government funded disability advocacy is expected/required to be neuro-affirming (or similar^[3]) thus denying the existence of severe/profound disability due to autism thereby avoiding their need for individual advocacy support.

It is inexcusable that these ASD-specific issues with the NDIS are not even recognised in the NA¾S. And the First Action Plan for the NA¾S does not even mention early intervention. The NA¾S is seriously incomplete. 

The NDIS expects many autistic Australians to access Foundational Supports, but no one really knows what those supports are or where they will come from. The DSS websites says:

Foundational Supports are specific supports that would be outside the NDIS to help people with disability, and their families and carers.

In 2007, Prime Minister Howard created the Helping Children with Autism (HCWA) package because other foundational supports were fragmented at best, inconsistent, and unreliable. In addition, the ALP created 6 ASELCCs. By all reports, the 6 only ASELCCs were limited but successful. Since then, the NDIS annihilated both HCWA and the ASELCCs as predicted in 2012 - see https://a4.org.au/node/628 

DSS is responsible for the long-standing Carer Allowance (child) which is, by definition, a Foundational Support. Minister Shorten complained for years about people not accessing non-NDIS supports while he did nothing about declining access to Carer Allowance (child), a long-standing Foundational Support that was his responsibility. DSS’s inability to maintain, or even care about, Carer Allowance (child) shows that it is incapable of overseeing meaningful Foundational Supports. The disability sector can have no confidence in DSS’s part in Foundational Supports.

As others have highlighted (here for example), the NDIS is kicking autistic children off the NDIS when Foundational Supports are still a very long way away. 

While Australian governments expect Foundational Supports will support many autistic children in Australia, the NA¾S does not even mention them. Commitment 19, on page 55 of the First Action Plan instead refers to “disability supports outside the NDIS” which is what Foundational Supports are supposed to be. Presumably DSS officials avoided saying Foundational Supports to avoid the timeframes set for introducing Foundational Support later in 2025. 

The NDIS denies many autistic NDIS participants necessary disability supports that they require. Increasingly, for severely autistic children, the NDIS does not have a proper planning process, instead leaving families to pursue high and/or complex needs via the Administrative Review Tribunal (ART). The ART system is not a fair process for these cases. 

Behaviour support is an area of particular concern. DSS, the NDIS and the NDIS Quality and Safeguards Commission simply refuse to address quality issues in relation to behaviour support for autistic Australians. Their NA¾S in another case where government agencies just ignore this issue when it needs serious attention – see https://a4.org.au/node/2649. 

There are chronic problems in the quasi-legal processes that are part of severely autistic children accessing necessary disability supports. ART Members hearing cases often ignore issues raised and evidence provided by Applicants. They make little or no provision for unrepresented Applicants or accommodations/adjustments for autistic people involved in hearings. They allow the NDIS to delay cases, and autistic children spend major proportions of their lives in extended litigation while the ART and the Respondent (NDIS) squander the child’s only opportunity for early intervention. The ART allows, even encourages, the NDIS to engage so-called Independent Medical Experts (IMEs) in autism-related matters contrary to guidance from the High Court of Australia that decries holding contests of experts in Tribunal matters. The conduct of AAT/ART matters is unfair in relation to autistic Applicants. The consequent unnecessary costs resulting from this unfair legal system is enormous. 

Notably, funding for the NA¾S is said to be $42m over 5 years while the NDIS spends way over $46m per year pursuing NDIS participants in the ART. 

The employment sections of the NA¾S say nothing about autistic people who simply cannot compete in the open labour market. 

The NA¾S focuses on, even limits itself to, being neuro-affirming. There is nothing neuro-affirming about severely autistic children who are denied effective toilet training or essential skill development. While we should definitely encourage, even celebrate, neurodivergence, we also need to recognise that an autism diagnosis by definition identifies dysfunction that needs attention and skill development; autistic children’s severe dysfunction must not be ignored. This NA¾S is simply not credible because essential parts of the strategy are missing. 

ASD diagnosis is a problem. The NA¾S says

The average age of diagnosis in children in Australia is about 3-4 years of age, with the most frequent age for diagnosis being 5.9 years.

An A4 report[4] provided to inform NA¾S development showed these estimates are wrong: the average age of diagnosis is over 7 years of age. The cited data[5] was only for children aged 0-7 years. It is also apparent from NDIS data that autistic children are older than this before they access services for their ASD. The diagnosis part of the ¾-Strategy is not based on accurate information, so it cannot be expected to address the issue properly. 

The NA¾S does not address basic workforce issues. The number of autism diagnoses is increasing at 9% per annum. There are questions about the capability of much of the workforce responsible for and delivering the diagnoses. There are even bigger questions about the capacity of the workforce that is not growing at 9% p.a. 

The first actions response to the diagnosis issue refers to the so-far unreleased Health part of the strategy. But the Health working group was told DSS’s diagnosis working group was handling it. The bureaucrats have avoided key diagnosis issues completely. 

The especially poor education outcomes reported for autistic children (too many are not even in school) lead to especially poor outcomes for autistic adults in Australians. DSS officials were unable to provide much real education strategy or actions in their NA¾S. The minimal education component in the NA¾S is a serious failure.

As Australians, we cannot be surprised that a nation, and especially the government’s Department of Social Security, who instigated Robodebt and now oversees the NDIS, treats people with disability, Informal Carers, and clinicians as likely funding cheats and fraudsters. DSS’s entrenched culture demands immediate implementation of DRC Recommendation 5.6[6]; Australia must have a separate Department of Disability with Ministerial level oversight at the Cabinet level. After all, in respect of bureaucratic appreciation of autistic Australians remaining in the hands of DSS officials …

You can knock on a deaf man’s door forever.

In addition to departmental culture issues, the scale of the NDIS Budget demands disability be separated from DSS. The National Autism ¾-Strategy that DSS officials wrote completely ignores the chronic issues with the National Disability Advocacy Program that fails to support autistic children seeking advocacy support especially when they are denied evidence-based early intervention that they are requesting on clinical advice. Nor does the NA¾S recognise that autistic Australians are usually denied legal aid in ART review processes. 

As was said above, the National Autism ¾-Strategy is a massive missed opportunity. The abysmal gaps in the ¾-Strategy need to be filled immediately. 

Bob Buckley
3/2/2025