Dear EAC Board

Autism Aspergers Advocacy Australia (A4) is disappointed and alarmed that EAC took a side on the issue of ABA (presumably meaning EIBI), a therapeutic application of Applied Behaviour Analysis (ABA), through it's recent publication of anti-ABA articles authored by Ms Sarah Langston. In particular, we refer to https://everyaustraliancounts.com.au/thriving-kids-position-statement/ that says misleadingly:

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.

Ms Langston's articles are misinform about ABA and are one-sided in their approach to this long-running issue in the autism sector. While some families raise concerns about programs that called themselves "Applied Behaviour Analysis (ABA) style and behaviour‑change programs", descriptions of these programs indicate that bad outcomes occurred where  programs were not run by professionally registered behavioural clinicians ... so it is not surprising that adverse outcomes occurred. This is a failure of regulation, not of ABA. The same is currently observed in the NDIS's PBS supports and other areas of NDIS registration.

A4 agrees that intensive behavioural intervention is likely to be less appropriate for children that Thriving Kids is meant to target: intensive programs for severely/profoundly autistic children belong in the NDIS if it can start to do its job properly for these children. However, we doubt that the NDIS can distinguish autistic children properly. 

Internally, the NDIS, like Ms Langston, have a misinformed and erroneous view of ABA. They oppose families choosing EIBI as therapy for autistic children despite overwhelming evidence of substantial benefits for many autistic children, especially those who are most impaired by their autism. NDIS staff lie to NDIS participants claiming "the NDIS does not fund ABA": this is completely and demonstrably false (EIBI, ESDM/NDBI, PECS and PBS are all types of ABA therapy that the NDIS funds ... it works with the Q&SC in regulating the PBS part of this - and often adds PBS into autistic children's NDIS Plans without relevant goals, being requested of clinical advice). And NDIS officials often ignore their own Case Management Guidelines, Document 10 at  https://a4.org.au/node/2567 (link near bottom of the page) that says:

The NDIA is likely to fund up to 20 hours per week of ABA therapy where it is considered likely to be effective and beneficial.

The Tribunal has never found that EIBI (ABA) is not "considered likely to be effective and beneficial" for a severely or profoundly autistic NDIS participant despite the NDIS's repeated unsuccessful attempts to convince the Tribunal otherwise. The NDIS has repeatedly opposed funding numerous children at well under 20 hours per week of EIBI/ABA therapy - contrary to its own guidelines - in numerous expensive and unsuccessful ART matters.

The ART has very confused interpretation of the evidence ... however, suffice it to say the ART, despite persistent opposition from the NDIS, has found consistently that EIBI/ABA meets s34(1) requirements of the NDIS Act 2013. EIBI/ABA must be regarded as a choice and control issue for the autism sector.

EIBI/ABA is a divisive issue in the autism sector; A4 suggests that it is very inappropriate for EAC to take sides and asks that steps be taken immediately to rectify this situation.