Partners need to be able to undertake specialised front end service delivery and provision of short term early childhood intervention (ECI) support services for children who do not require an NDIS individualised reasonable and necessary support plan. To undertake this support Early Childhood Partners need experienced qualified staff that can undertake clinical assessments and make recommendations about the appropriate supports required. The use of inexperienced non-specialist staff in generalist services, even with some early childhood training or early childhood intervention experience is risky without appropriate clinical governance that provides appropriate staff supervision, guidance and professional development in contemporary early childhood intervention best practice.

## Conflict of interest, workforce issues and thin markets

There is in some quarters, including the NDIA, a concern that there is a perceived conflict of interest arising when an NDIS registered Early Childhood Intervention provider also provides the ECEI approach in the same region or as an organisation. The tension of providing high quality ECEI support services and managing perceived conflict of interest remains an issue of concern. Current workforce supply issues will almost certainly require partners delivering the ECEI approach to also be providers of support services.

A number of thin markets have been identified in the Issues Paper (Draft Finding 6.1) in considering a market based model for disability supports and the Paper acknowledges that these will persist for some time. These markets include participants who:

- o in outer regional, remote and very remote areas o in outer regional, remote and very remote areas
- o with complex, specialised or high intensity needs, or very o with complex, specialised or high intensity needs, or very challenging behaviours
- o have an acute and immediate need (crisis care and o have an acute and immediate need (crisis care and accommodation).
- o Aboriginal and Torres Strait Islander Australians o Aboriginal and Torres Strait Islander Australians
- o and linguistically diverse backgrounds. o and linguistically diverse backgrounds.

Using the arguments around thin markets as the only reason for allowing Early Childhood Partners to also provide early childhood intervention supports through purchasing under NDIS is a very narrow and short sighted one. The Issues Paper notes that in the absence of effective government intervention, such market failure is likely to result in greater shortages, less competition and poorer participant outcomes. p 58.

The impact on the ECI workforce at a macro level, if the NDIA pursues the strategy of only allowing the ECEI approach to be delivered by generalist services, apart from in thin markets could result in:

- o dilution of support services with the expertise and structures in place o dilution of support services with the expertise and structures in place to achieve the outcomes intended in the ECEI approach.
- o of available and experienced early childhood intervention o of available and experienced early childhood intervention providers if a number choose to do only Early Childhood Partner supports.