Autism Assessment and Intervention Pathways Protocol

Sections 7-13 of the Disability Act 2005 confer a statutory right to an Assessment of Need (AON) for any person with a disability, place a duty on the HSE to deliver the AON within six months, and require a Service Statement based on the AON. The Act is the principal domestic statute against which the Protocol is read: the Protocol is explicitly NOT the AON, but assessment outputs from the Protocol 'may be used to inform an AoN if appropriate' (HSE).

The Autism Assessment and Intervention Pathways Protocol was developed over a five-to-six-year arc from 2019/2020 to 2025 by a multidisciplinary working group within the HSE Service Improvement Programme for the Autistic Community (Gráinne Morrisson, named autistic lived-experience working-group member, attests in the 19 March 2025 consultation report to having been 'involved in the development of the autism assessment & interventions pathway protocol since 2019', which fixes the start of the development arc earlier than the Sharon Barry HSE poster's 2020-2025 framing) — described by the HSE as 'the first integrated services project within the HSE'. The working group was initiated from the 2017 HSE Report of the Review of the Irish Health Services for Individuals with Autism Spectrum Disorders. Its composition: clinicians across Primary Care, Disability and Mental Health services; three lived-experience members; and senior management representatives. The working group designed a three-tier model in which the intensity of assessment is determined by clarity of presentation: Tier 1 (Autism Assessment — clear presentations), Tier 2 (Autism Extended Assessment — unclear presentations, differentiating between autism and co-occurring conditions), Tier 3 (Autism Continuing Assessment — continuing unclear presentations / very complex cases). The Protocol was piloted across four former Community Healthcare Organisations covering 255 assessments, with independent evaluation by the Centre for Effective Services and oversight by a separate independent Expert Advisory Group comprising lived experience, clinical and academic expertise. The pilot results published by Sharon Barry (HSE) at the Lenus research repository show the actual tier distribution observed: 39% of assessments at Tier 1, 60% at Tier 2, and only ONE assessment at Tier 3 — a distribution that the professional bodies subsequently cited as evidence that Tier 1 was carrying more cases than the model's 'clear presentations' framing was designed to accommodate. Barry's poster also acknowledges that 'practitioners took some time to feel confident and competent using Tier 1, with some remaining cautious of them' and that 'some assessments commenced with Tier 2, as permitted by the protocol' — i.e. clinicians at the working-group's own pilot sites were already routing away from Tier 1 in practice.

Minister Norma Foley TD and Minister of State Hildegarde Naughton TD published the Autism Innovation Strategy in July 2024 — Ireland's first cross-departmental autism strategy. The Strategy committed to a national standardised autism assessment pathway and to addressing the absence of a public adult assessment route; the Protocol launched in May 2026 is the principal HSE-side deliverable under this Strategy.

On 22 November 2024 the Psychological Society of Ireland — Ireland's professional body for psychology, representing 5,000+ members — wrote to the HSE Autism Assessment and Intervention Pathway Project Team setting out 'significant concerns about the current proposed Autism Assessment and Intervention Pathway, specifically regarding the tiered assessment model'. The letter was drafted by Dr Louise Higgins (PSI Council), Dr Sarah Cassidy (2025 PSI President-elect; Autistic Psychologist), Dr Eithne Ní Longphuirt (PSI Council), Lorraine Madden (Chair, PSI Special Interest Group in Neurodiversity), Dr Mitchel Fleming (PSI Past President) and Dr Elaine Walsh (Chair, PSI Special Interest Group in Autism). The PSI signalled that the Protocol fell short of the PSI's own 2022 'Professional Practice Guidelines for the Assessment, Formulation, and Diagnosis of Autism in Children and Adolescents' as well as the SIGN and NICE international standards, and warned of 'significant financial risks to the Irish Government' from misdiagnosis. The PSI cited the recent HSE Preliminary Team Assessments (PTAs) precedent — 'almost 10,000 assessments having to be repeated' at an estimated cost 'approximately €20 million' — as the canonical Irish example of the kind of fiscal damage a sub-threshold assessment model can produce. The PSI's proposed alternative is a 'Neurodevelopmental Assessment and Therapeutic Pathway' organised by stage (Initial Screening → Primary Developmental and Diagnostic Assessment → Complex or Advanced Assessment) rather than by tier of intensity. The letter also recommends review of the Disability Act 2005, mandatory standardised diagnostic tool use (ADOS, ADI-R, DISCO, MIGDAS), formal ongoing collaboration with professional bodies, and explicit rejection of non-validated tools (e.g. BOSA — Brief Observation of Symptoms of Autism). PSI representatives subsequently attended a consultation meeting with the HSE on 17 December 2024 alongside other professional bodies. The letter was published by the PSI on its advocacy page on 13 December 2024.

In January 2025, the PSI Special Interest Group in Autism (SIGA) — the PSI sub-group responsible for writing and promoting the discipline's professional practice guidelines for autism — submitted a separate, more sharply-worded response to the HSE Autism Assessment & Intervention Pathway Project Team. Where the parent PSI letter (November 2024) was framed as constructive professional-body engagement, SIGA's framing was direct: 'a primary concern is the risk the current draft model poses for a vulnerable population' and 'Tier 1 assessments fall short of good professional practice for our discipline'. SIGA's substantive points: (i) overreliance on screening measures will lead to children and young people being 'incorrectly denied assessment', particularly socially-motivated and socially-masking presentations; (ii) clinicians can opt into Tier 1 'based on their own understanding of their own competencies' with 'no way of regulating practice' — 'this legitimises bad practice in both the private and public sector'; (iii) the Protocol's openness to non-validated tools such as BOSA contradicts both international guidance and the mandatory-standardised-testing approach the HSE itself adopted in the Maskey ADHD pathway ('why one neurodivergence should be held to a minimum standard of assessment with mandatory use of standardised testing in the HSE, and not another, is incomprehensible'); (iv) the Protocol is 'written from a deficit based and disorder model of autism' that 'jars' with the neuroaffirmative commitments of the 2024 Autism Innovation Strategy; (v) the Protocol has 'failed to incorporate / consider the emerging published research describing the lived experience of the autistic community accessing services'. Bottom line: 'Overall, the current Protocol exponentially increases the risk of poor assessments. This has long-lasting impacts on family functioning and wellbeing, service provision, and identity formation.' SIGA also flagged IASLT and AOTI submissions broadly aligned with its position.

On 19 March 2025 the HSE Service Improvement Programme for the Autistic Community held its FIRST consultation for civil society on the draft Protocol — an online webinar, two months and three days before the in-person Clayton Hotel follow-on. Attendance: 10 organisations invited (5 nominees permitted each, cap 50); 7 of 10 organisations actually nominated representatives (3.7 average); 37 registered; 27 attended on the day = '73% attendance rate'. The meeting ran 101 minutes against a 90-minute schedule. Three panellists named: John Fitzmaurice (Programme Board Chair), Mac MacLachlan (Subcommittee Chair), and Gráinne Morrisson (Public Health Nurse, lived-experience representative, autistic, mother of two autistic sons, on the working group since 2019). Six polls were conducted in-presentation; response rates 18-20 per poll. The substantive signal — Q2 'Do these features of the protocol seem appropriate to you?' — recorded approximately 50% Unsure, 25% No, only 25% Yes. The 68 questions submitted during Q&A were categorised by topic: Protocol Queries (13), Clinical (13), Tiered Assessment (11), Wider HSE (10), Further Input/Review (9), Liability/Legal (3), Evaluation (3), Interventions (2), Best Practice (2), Mental Health Involvement (1), School Supports (1). MacLachlan answered most in-meeting; the rest were responded to in writing under his name in the published report. Verbatim attendee free-text comments (Q6, eight selected and surfaced in the published report) included the most sharply-worded civil-society objection on the protocol's public record: 'This was a poor example of poor consultation. Difficult questions were completely avoided. Unacceptable. An exercise in propaganda. So very disappointed. It feels as if the HSE do not actively wish to engage with grass roots campaigns and are prioritizing funded NGOs. The presentation was inaccessible if one did not have a certain level of education and understanding of the existing systems. I am more confused about this protocol than I was previously. Genuinely feels like this has been designed to evade the Disability Act 2005.' Other verbatim comments: 'Two parents are too few. We need proper co design'; 'This was good information, but this felt quite curated and not a consultation but more of an informational webinar'; 'Mac mentioned 6 services that were consulted I think, I don't think that is enough to represent country wide feedback'. MacLachlan's response to the propaganda accusation: 'I'm sorry this has been disappointing. I am happy to answer any questions and have certainly not sought to avoid any. It is to no one's advantage to avoid difficult questions! Certainly, this is not an attempt to evade the Disability Act.' MacLachlan's response to the 'curated' comment: 'I accept that it was quite curated – we wanted to do it virtually to make it widely accessible across the country and we wanted people to be able to ask questions without necessarily having to publicly identify themselves. Sometimes certain individuals or organisations can dominate a more open discussion.' The 19 March report also records (for the first time on the public record) the protocol's stated 'evidence base' position: MacLachlan grounds the tiered model in Bishop & Lord (2023) — 'requiring the use of specific tools, without exception, is discriminatory and damaging' — and Penner et al (2018) — 'systematic review is the first to demonstrate inconsistencies in recommendations pertaining to all aspects of the ASD diagnostic assessment'; argues the protocol is MORE stringent than NICE / SIGN (both of which use 'consider' / 'may', not mandate) given it requires standardised instruments at Tier 2 and Tier 3; notes 'none of the instruments routinely used in autism assessment in Ireland have Irish norms, most are insensitive to masking, and just about all are gender and ethnicity biased due to sampling legacy. There are no norms for adult autism assessment'; and characterises the professional bodies' 'best practice' claims as 'illusory, and perhaps inadvertently, misleading'. The CES pilot found 47 different methods/instruments in use across pilot sites — i.e. there is no settled domestic best practice the protocol could have aligned with. Of ~200 assessments in pilot data, only 2 were done in mental health (NOT CAMHS). Tier distribution confirmed: 39% Tier 1, 60% Tier 2, 1% Tier 3.

On 22 May 2025 — one year and four days before the Ministerial launch — the HSE Service Improvement Programme for the Autistic Community held an in-person consultation for civil society on the draft Autism Assessment and Intervention Pathways Protocol at the Clayton Hotel Liffey Valley, Dublin. This was the SECOND consultation; the first had been held online in March 2025. The consultation was facilitated by Geraldine Prunty (independent chair, registered Social Worker with CORU, 25+ years in disability services). Attendance: 61 organisations were invited, each permitted to nominate 2 attendees (notional invited pool ~122); 15 people registered; 12 attended on the day — Prunty's report records this as a '9.8% attendance rate'. The agenda comprised an Opening Key Address by John Fitzmaurice (Chair, Service Improvement Programme Board for the Autistic Community), an overview presentation by Professor Mac MacLachlan (Chair of the Autism Protocol Subcommittee), a recorded presentation on protocol piloting and evaluation by David Martyn of the Centre for Effective Services (the independent external evaluator), two group-discussion rounds, plenary Q&A, and an end-of-day anonymous survey (12/12 response rate). Survey signal: only 3 of 12 attendees answered 'Yes, very much so' to 'Do you feel that the independent evaluation of the protocol was conducted appropriately?'; only 3 of 12 said 'Yes, very much so' to 'Do you feel that your questions have been answered during this consultation?'. Verbatim attendee free-text comments on the general approach of the Protocol included: 'Representation appears tokenistic and this seems like a box ticking exercise'; 'Neuroaffirmative does not equal nondisabled'; 'Not enough engagement with service users & autism services nationwide who would have more engagement than AsIAm'; 'It still feels very rushed to fix AON issues and risks watering down assessments again'; 'MDT assessment a must'; 'The missed generation who did not get a childhood diagnosis needs to be acknowledged and adult assessments and supports need to be looked at and provided'. Group-discussion themes raised by attendees: masking risk under single-clinician Tier 1 assessments; need for a clear second-opinion / appeals process; uneven regional implementation (urban / rural disparity); CDNT staffing vacancies; cross-sector buy-in from Mental Health and Primary Care; centrality of parents and autistic people in any annual protocol review. Prunty's report also identifies the Protocol's governance structure: Fitzmaurice (Programme Board Chair, IHA Manager Sligo/Leitrim/South Donegal/West Cavan, 23 years HSE), MacLachlan (Advisor to the Programme Board AND Chair of the protocol-development subcommittee, formerly Clinical Lead NCPPD), Prunty (independent facilitator) and Martyn (external evaluator, Centre for Effective Services). The protocol's two stated underlying recommendations (as Prunty records them, traced to the 2017 HSE Review of Irish Health Services for Individuals with Autism Spectrum Disorders): (1) 'Introduce an assessment pathway determining whether Autism is present or absent', (2) 'Introduce a tiered approach to assessment whereby the required intensity of assessment is determined by the clarity of presentation'. Fitzmaurice's Opening Key Address acknowledged 'lived experience representatives who are both Board Members and separately those with lived experience who are Working Group members who have developed the protocol' — but no lived-experience or autistic representative is named in this report's governance section, which lists Fitzmaurice, MacLachlan and Prunty only. Cross-referencing the 19 March 2025 online consultation report fills the gap: **Gráinne Morrisson** — Public Health Nurse, autistic, parent to two autistic sons, working group member since 2019 — was named alongside Fitzmaurice and MacLachlan as a panellist at the first (online) consultation. Morrisson is therefore the one named autistic representative on the protocol-development team across the primary-source set. The remaining structural finding stands: the senior named governance chain (Fitzmaurice, MacLachlan, Prunty, Martyn, Barry) is non-autistic, and the other two working-group lived-experience members (per the Barry poster) and the Board's lived-experience representatives (per Prunty) remain anonymised. This more-nuanced representation gap is what the verbatim attendee comment 'Representation appears tokenistic and this seems like a box ticking exercise' addresses.

On 15 September 2025 the HSE announced it would establish a Bespoke Panel Arrangement with private service providers to deliver multi-disciplinary autism diagnostic assessments using a 'neuro-diverse affirming approach', compliant with HIQA standards and the Independent Assessment of Need Protocols. HSE CEO Bernard Gloster said: 'Meeting the increasing demand for Assessments of Need is challenging and to help address this we are putting in place a Bespoke Panel Arrangement with suitable Panel Approved Providers.' The Panel was procured via eTenders for an initial one-year term, extendable for a further year subject to demand and budget approval. This is the procurement vehicle through which the €20m AON private-assessment funding (confirmed in December 2025) flows.

Minister Norma Foley TD and Minister of State for Disability Emer Higgins TD announced the package of reforms to the AON process under the Disability Act 2005 following the 2025 High Court ruling that the existing HSE methodology was unlawful. The package committed: €20 million for up to 6,000 clinical assessments by private providers (continuing into 2026); 11 new autism in-reach teams comprising 44 staff in total (each team: 1 psychologist, 1 speech and language therapist, 1 occupational therapist, 1 administrator) to provide clinical guidance to Assessment Officers; introduction of a Single Point of Access system from 2026; retention of the statutory 6-month timeline and parental application rights; and rollout of the Autism Assessment and Intervention Pathways Protocol from February 2026. Foley said: 'I know that families have been enduring incredible stress and unacceptable delays in receiving AON reports'. INTO general secretary later criticised the package as a 'profound breach of trust' over its implications for education-based assessments.

In early February 2026 HSE CEO Bernard Gloster told the Oireachtas Joint Committee on Health that 'the new autism protocol goes live for use in the health service' on 9 February 2026. That date was missed; the Protocol remained 'in the final stages of approval' as of 16 March 2026 according to an HSE spokeswoman. The slippage is the first publicly recorded delay against the December 2025 implementation commitment and is the principal reason the formal Ministerial launch did not occur until 26 May 2026.

Irish Examiner reporting (16 March 2026) recorded 20,209 people awaiting AON beyond the statutory six-month timeframe, a 42% increase from 14,221 in the previous reporting period. AsIAm's separately reported average AON waiting time was 27 months (against a six-month statutory limit). The HSE's piloted tiered approach had completed approximately 40% of autism assessments at Tier 1 (the least-intensive level); the HSE noted Tier 1 'take[s] less time than routine assessments but are not necessarily aligned to the complexity of presentation'. Dr Niall Muldoon, Ombudsman for Children, separately called for urgent change in the assessment processes.

On 26 May 2026 Minister for Children, Disability and Equality Norma Foley TD launched the Autism Assessment and Intervention Pathways Protocol alongside an easy-read companion document, 'About a Manual for Autism Assessment and Support'. The launch was preceded by a Cabinet memo brought jointly by Minister Foley and Minister for Health Jennifer Carroll MacNeill TD. The Protocol delivers, for the first time, a standardised autism assessment for children and adults across the HSE and HSE-funded agencies, was developed in consultation with autistic people, clinicians and HSE staff across disability, primary care and mental health services, and enables an autism diagnosis and access to services without an Assessment of Need. National rollout is scheduled to commence in July 2026, beginning with the recruitment of the 11 autism in-reach teams confirmed in the December 2025 reforms package. Minister Foley's public statement at launch (via Instagram, @normafoleytd): 'Today we launched the first ever standardised approach for carrying out autism assessments across the HSE. It will allow children to get an autism assessment in a faster way. It is also the first time that adults can get an autism assessment. This represents a significant step forward in how we support Autistic people in Ireland.' The Protocol document launched on this date is the deliverable of the subcommittee chaired by Professor Mac MacLachlan (Maynooth University) sitting under the HSE Service Improvement Programme Board for the Autistic Community chaired by John Fitzmaurice — see the 22 May 2025 civil society consultation milestone for the documented governance structure.

1. HSE Headquarters, Dr Steevens' Hospital, Dublin· waypoint— Protocol authoring and approval centre; HSE CEO Bernard Gloster's office is the principal accountability point for the missed February 2026 go-live and the May 2026 launch.
2. CHO 1 — Donegal / Sligo-Leitrim / Cavan-Monaghan· waypoint— Northwest. Largest geographic catchment of any CHO; longest-distance-to-service population for both children's CDNTs and adult autism assessment under the Protocol.
3. CHO 2 — Galway / Mayo / Roscommon· waypoint— West. High Section 39 provider density (Brothers of Charity, Ability West) delivering Protocol-aligned assessments under contract.
4. CHO 3 — Mid-West (Clare / Limerick / North Tipperary)· waypoint— Mid-West. CDNT structures here were among the first to pilot the tiered assessment model that informs Protocol Tier 1.
5. CHO 4 — Cork / Kerry· waypoint— South. Cope Foundation and Enable Ireland as principal Section 39 providers; Cork-based families are the largest single AON-waitlist cohort outside Dublin.
6. CHO 5 — South-East· waypoint— South-East. Regional inequities in CDNT staffing flagged by Inclusion Ireland — Protocol delivery depends on in-reach team recruitment landing in this CHO.
7. CHO 6 — Dublin South-East / Wicklow· waypoint— Greater Dublin. Highest absolute AON waitlist; Protocol Tier 1 capacity will be tested here first.
8. CHO 7 — Dublin South-West / Kildare / West Wicklow· waypoint— Greater Dublin and Kildare. Adult-assessment demand expected to be heavy here given commuter-belt demographics.
9. CHO 8 — Midlands / North-East· waypoint— Midlands and North-East. Lowest population density of CHOs with significant disability-services pressure.
10. CHO 9 — Dublin North / North-West / North-East· waypoint— North Dublin. St Michael's House and Daughters of Charity as the largest Section 39 providers delivering Protocol-aligned children's assessments.

As of March 2026, 20,209 people were awaiting an Assessment of Need beyond the statutory six-month timeframe set out in the Disability Act 2005 — a 42% year-on-year increase from 14,221 in the previous reporting cycle. AsIAm's separately reported average AON wait time was 27 months. The Protocol is the principal operational instrument the HSE proposes to use to shorten this backlog, but AsIAm CEO Adam Harris's public assessment is that the Protocol 'is not going to make a difference to waiting times' on its own without parallel investment in CDNT and Primary Care assessment capacity.

Adam Harris (AsIAm) and Irish Examiner reporting both noted that Ireland has been 'somewhat of an outlier in a European context, in that there is no public pathway when it comes to the assessment of adults'. Under the new Protocol, adults can self-refer or be referred by a guardian where there is a question of autism. The Protocol therefore creates, for the first time, a State-funded route to adult autism diagnosis — but national rollout is scheduled for July 2026 and no published HSE estimate of latent adult demand has yet been issued.

Environmental impact assessment not yet published.

The Protocol introduces a tiered assessment model in which lower-complexity presentations may be assessed at Tier 1 without a full multi-disciplinary panel. The HSE's piloted experience completed ~40% of assessments at Tier 1, but acknowledged Tier 1 assessments 'are not necessarily aligned to the complexity of presentation'. The Psychological Society of Ireland's Special Interest Group in Autism (December 2024), IASLT and AOTI submitted formal consultation responses flagging evidence-base concerns about the tiered approach: in particular, the risk that Tier 1 mis-triages co-occurring presentations (intellectual disability, ADHD, anxiety, language disorder) requiring a multi-disciplinary diagnostic formulation. These concerns are unresolved at the May 2026 launch.

Environmental impact assessment not yet published.

Two HSE-published consultation reports (19 March 2025 online; 22 May 2025 in-person, both Geraldine Prunty / HSE Service Improvement Programme) are the primary-source evidence for the protocol's consultation-legitimacy gap. Cross-consultation quantitative findings: (i) MARCH 2025 ATTENDANCE — 10 orgs invited, 5 nominees permitted each (cap 50), 7 of 10 orgs nominated (3.7 average), 37 registered, 27 attended = 73% rate; (ii) MAY 2025 ATTENDANCE — 61 orgs invited, 2 nominees permitted each (notional pool ~122), 15 registered, 12 attended = 9.8% rate; (iii) 65-PERCENTAGE-POINT DROP-OFF between the two consultations, with the second's attendee count (12) lower in absolute terms than the first's (27) despite a six-times-larger invited pool. Substantive-endorsement signal from March: poll Q2 'Do these features of the protocol seem appropriate to you?' = ~50% Unsure, ~25% No, ~25% Yes — only a quarter of polled attendees endorsed the protocol features when asked directly. Substantive-endorsement signal from May: 3/12 (25%) said 'Yes, very much so' to evaluation appropriateness; 3/12 (25%) said 'Yes, very much so' to questions answered. A 'one in four' endorsement signal recurs across both consultations. Representation finding: the named senior governance chain across every primary-source document in this case study (Fitzmaurice as Programme Board Chair, MacLachlan as Subcommittee Chair, Prunty as Independent Facilitator, Martyn as External Evaluator, Barry as HSE poster author) is non-autistic. One named autistic representative — Gráinne Morrisson, Public Health Nurse and working-group member since 2019 — has been on the panel since the first consultation. The other two working-group lived-experience members (per the Barry poster) and the Board's lived-experience representatives (per Prunty) remain anonymised across all reports. The verbatim attendee comments 'Representation appears tokenistic and this seems like a box ticking exercise' (May 2025) and 'This was a poor example of poor consultation… An exercise in propaganda… Genuinely feels like this has been designed to evade the Disability Act 2005' (March 2025) are the direct civil-society articulation of the gap. The HSE's own reports are therefore self-documenting the legitimacy issue.

Bernard Gloster told the Oireachtas Health Committee in early February 2026 that the Protocol would go live on 9 February 2026; that date was missed and the Protocol remained in final-stages-of-approval as of 16 March 2026. The Ministerial launch eventually occurred on 26 May 2026 — a 15-week slip on the original commitment — with national rollout now scheduled for July 2026. The €20m AON funding (December 2025) was time-limited 'continuing into 2026', so the slippage compresses the window in which procured private-provider capacity can clear AON backlog. There is no published HSE re-baselining of the funding profile against the new timeline.

The Irish National Teachers' Organisation (INTO) characterised the December 2025 AON-reform package — of which the Protocol is the principal operational deliverable — as a 'profound breach of trust' on the basis that the reforms reduce the value of school-mediated assessments for accessing Special Education Teacher (SET) hours and Special Needs Assistant (SNA) supports. The dispute connects the Protocol back to the parallel Special Education Classes case study in this dataset, because the supply of School-Inclusion-Model and CDNT-aligned in-class supports depends on a stable assessment pathway upstream.

The HSE has a statutory duty to deliver an Assessment of Need within six months of application under sections 7-13 of the Disability Act 2005, and to issue a Service Statement based on the AON. The Protocol explicitly does not replace the AON — but assessment outputs from the Protocol may be used to inform an AON. The Protocol must therefore be designed to be at least equivalent to AON requirements in cases where the Protocol's output is used as the basis for an AON Service Statement.

If breached: Judicial review (the 2025 High Court ruling that the HSE's previous AON methodology was unlawful is the principal recent example); Disability Appeals Officer findings; Ombudsman complaints.

Article 25 (Health) requires States Parties to ensure access to the same range, quality and standard of free or affordable health care and programmes as provided to other persons, including early identification and intervention. Article 26 (Habilitation and Rehabilitation) requires States Parties to organise habilitation and rehabilitation services, including supports beginning at the earliest possible stage and based on multidisciplinary assessment. Ireland ratified the CRPD on 20 March 2018 but has not ratified the Optional Protocol.

If breached: UN CRPD Committee Concluding Observations on Ireland's State Report. Domestic courts use the CRPD as an interpretive aid under the Constitution and the Equal Status Acts.

The HSE's September 2025 Bespoke Panel Arrangement explicitly requires private providers to deliver autism diagnostic assessments compliant with HIQA standards and the Independent Assessment of Need Protocols for Assessors. The Protocol's national rollout therefore inherits the HIQA evidence-quality baseline, including requirements for multi-disciplinary input, documented diagnostic formulation and parental/guardian involvement.

If breached: HIQA inspection findings and unannounced visit reports; risk of HSE de-paneling of non-compliant providers; loss of professional indemnity cover.

The Equal Status Acts prohibit discrimination in the provision of services (including health services) on grounds including disability and impose a duty to provide reasonable accommodation under section 4. The duty is engaged at every stage of the Protocol pathway, in particular for adults seeking assessment for the first time.

If breached: Complaints to the Workplace Relations Commission and IHREC; compensation orders.

Adam Harris, CEO of AsIAm (Ireland's national autism charity), characterised the Protocol as 'a first step' but rejected any framing that it would clear the AON backlog on its own. His three substantive points: (i) 'this is not a legislative or statutory tool' — i.e. the Protocol does not create new statutory rights and remains subject to whatever resources are allocated to deliver it; (ii) 'it's not going to make a difference to waiting times' without parallel investment in CDNT and Primary Care assessment capacity; (iii) the absence of a published adult-assessment workforce plan means the headline 'first time adults can be assessed' is at risk of being mainly aspirational at rollout.

The Irish National Teachers' Organisation described the December 2025 AON-reform package — of which the Protocol is the principal HSE-side deliverable — as a 'profound breach of trust', on the basis that the reforms reduce the value of school-mediated assessments for accessing Special Education Teacher (SET) hours and Special Needs Assistant (SNA) supports. INTO's substantive objection is structural: classroom teachers are the first to identify learning, language and behavioural concerns in young children, but the Protocol's tiered model channels those concerns into Primary Care / CDNT pipelines rather than the educational supports pipeline that schools rely on day-to-day.

The PSI's 22 November 2024 letter (published 13 December 2024) is the formal professional-body objection against which the Protocol's evidence base must be read. PSI represents 5,000+ members and the letter was signed by six named senior clinicians (Drs Louise Higgins, Sarah Cassidy, Eithne Ní Longphuirt, Lorraine Madden, Mitchel Fleming, Elaine Walsh — covering PSI Council, the 2025 President-elect, the SIG-in-Neurodiversity Chair and the SIG-in-Autism Chair). The letter's substantive case: (i) the tiered assessment model is 'contrary to' PSI's 2022 'Professional Practice Guidelines for the Assessment, Formulation, and Diagnosis of Autism in Children and Adolescents' and to SIGN and NICE international standards; (ii) the model creates 'significant financial risks to the Irish Government' through misdiagnosis (both false positives and false negatives) — PSI explicitly draws the parallel with the HSE Preliminary Team Assessment (PTA) precedent in which 'almost 10,000 assessments [had] to be repeated' at an estimated cost of '€20 million' — i.e. the model the HSE is now proposing is structurally similar to the model that just cost the State an estimated €20 million; (iii) sub-threshold assessment 'poses a risk in relation to recruitment and retention of psychologists to work in Primary Care and CDNTs'; (iv) the Protocol's reliance on screening risks under-diagnosing children with subtler presentations who socially mask; (v) the Protocol fails to define 'appropriate experience' precisely enough for single-clinician assessments; (vi) the Protocol's openness to non-validated tools (BOSA — Brief Observation of Symptoms of Autism) is incompatible with diagnostic accuracy; (vii) 'failure by the HSE to require professionals to comply with their professional bodies' practice guidelines for the assessment and diagnosis of autism may leave them open to challenges of poor practice'. PSI's constructive alternative: replace the tiered approach with a 'Neurodevelopmental Assessment and Therapeutic Pathway' organised by stage (Stage 1 Initial Screening → Stage 2 Primary Developmental and Diagnostic Assessment with multidisciplinary input → Stage 3 Complex or Advanced Assessment), mandating standardised diagnostic tools (ADOS, ADI-R, DISCO, MIGDAS) at Stage 2, formalising professional-body collaboration, addressing workforce capacity, establishing a national training fund, and reviewing the Disability Act 2005 (the EPSEN Act 2004 having already been reviewed for the same purpose). PSI representatives attended a consultation meeting with the HSE on 17 December 2024 alongside other professional bodies. The PSI letter's appended prevalence-rate appendix (Republic of Ireland NCSE 2022: 3.38% school population; Northern Ireland 2022/23: 5% — Rodgers and McCluney 2023) is the principal contextual data both sides of the debate cite on demand projection.

SIGA's January 2025 response is the most direct professional-body objection on the public record. Where the parent PSI letter (November 2024) was framed as constructive professional engagement, SIGA's framing is unambiguous: 'a primary concern is the risk the current draft model poses for a vulnerable population', 'Tier 1 assessments fall short of good professional practice for our discipline', and the model 'legitimises bad practice in both the private and public sector' because 'there is no way of regulating' which clinicians opt into Tier 1. SIGA cites the inconsistency between the HSE's autism approach and the HSE's own Maskey ADHD pathway in which standardised testing is mandatory: 'why one neurodivergence should be held to a minimum standard of assessment with mandatory use of standardised testing in the HSE, and not another, is incomprehensible'. SIGA also identifies a contradiction between the Protocol's stated neuroaffirmative aspiration (and the 2024 Autism Innovation Strategy commitment to neuroaffirmation) and the Protocol's actual text, which SIGA characterises as 'written from a deficit based and disorder model of autism'. SIGA's bottom-line assessment: 'Overall, the current Protocol exponentially increases the risk of poor assessments. This has long-lasting impacts on family functioning and wellbeing, service provision, and identity formation.'

Sinn Féin Disability and Carers Spokesperson Pauline Tully TD, jointly with health spokesperson David Cullinane TD, called for the HSE to accept the 2025 High Court ruling that its existing AON methodology was unlawful and to end appeals. Tully has been the most consistent Opposition voice on AON / Protocol issues since the Capacity Review publication in 2021, framing the AON backlog as a structural rights breach rather than a delivery delay. Sinn Féin's substantive ask is for legislation tightening the statutory remedy where the six-month AON window is breached, not merely operational reform via a Protocol document.

Social Democrats Leader Holly Cairns TD has used Dáil time and Private Members' Motion procedure repeatedly to argue that AON / Protocol shortfalls are a rights breach (UN CRPD Articles 19, 25 and 28) rather than a delivery shortfall. Cairns's March 2024 Motion on Supporting People with Disabilities and Carers sought binding commitments on assessment capacity and Personal Assistance hours; the Protocol does not, by itself, deliver the binding-commitment element of that ask. Cairns also consistently uses identity-first language ('disabled people') in this debate.

The HSE-commissioned Prunty Report (22 May 2025) records the verbatim free-text comments of the 12 civil-society attendees who took the anonymous end-of-day survey (12/12 response rate). The comments are filed here as a single citizen-objection record because they are the most direct first-person civil-society response to the Protocol on the public record before launch, and because the HSE itself published them. Verbatim selection: 'Not enough engagement with service users & autism services nationwide who would have more engagement than AsIAm'; 'Drafts should be offered in advance, not sent long enough in advance'; 'Very sheltered information'; 'Representation appears tokenistic and this seems like a box ticking exercise'; 'Tiered assessment whilst potentially beneficial may oversimplify complex cases especially in co-occurring conditions'; 'Neuroaffirmative does not equal nondisabled'; 'It still feels very rushed to fix AON issues and risks watering down assessments again'; 'Still hesitant and nervous about implementation'; 'Still have concerns over masking individuals, time taken to diagnose at tier 3, staffing shortages in certain areas, co-occurring conditions missed, transition into adult services, mechanisms for children as they age'; 'MDT assessment a must'; 'The missed generation who did not get a childhood diagnosis needs to be acknowledged and adult assessments and supports need to be looked at and provided'; 'Pay parity for therapists to encourage retention and entering the service'. Three structural critiques recur across the comments: (i) the consultation process itself is too narrow and rushed; (ii) the Protocol oversimplifies complex / co-occurring / masking presentations; (iii) the Protocol's claimed neuroaffirmative orientation is at odds with the lived-experience reality that being autistic is a disability. The 'tokenistic / box ticking' comment is the principal civil-society articulation of the named-governance-chain-vs-anonymised-lived-experience gap.

Filed as a structured-counter-position record so the case study renders both sides of the evidence-base dispute fairly. The HSE-published March 2025 consultation report is the principal place MacLachlan articulates the State's positive defence of the tiered model against PSI / SIGA / IASLT / AOTI / F.U.S.S. critique. His substantive points: (i) on professional-body 'best practice' claims — 'I believe that references to deviating from best practice are illusory, and perhaps inadvertently, misleading and may be very worrisome for service users'; (ii) on the international evidence base — cites Bishop & Lord (2023) Journal of Child Psychology and Psychiatry: 'There are many situations in which the use of any given tool might not be possible. As such, requiring the use of specific tools, without exception, is discriminatory and damaging', and Penner et al (2018) Autism: 'This systematic review is the first to demonstrate inconsistencies in recommendations pertaining to all aspects of the ASD diagnostic assessment'; (iii) on NICE vs SIGN — 'NICE (relating to psychometric instruments uses the term consider using) and SIGN (relating to psychometric instruments uses the term may use) — neither require the use of psychometric instruments at any level, while our Protocol does require their use at T2 and T3. Our protocol may therefore be considered more stringent than other guidelines'; (iv) on Irish norms — 'none of the instruments routinely used in autism assessment in Ireland have Irish norms, most are insensitive to masking, and just about all are gender and ethnicity biased due to sampling legacy. There are no norms for adult autism assessment'; (v) on the CES pilot finding — 47 different methods/instruments were in use across pilot sites, evidencing 'no settled domestic best practice' to depart from; (vi) on the international parallel — 'A tiered assessment approach — matching the intensity of assessment to the clarity of presentation — is used in other countries, such as Scotland and Australia, too', citing the 'National Guideline for the assessment and diagnosis of autism in Australia (2023)' which 'incorporates a degree of flexibility that enables the process to be tailored based on the complexity of the client's individual clinical presentation'; (vii) on the Wieckowski et al (2021) Autism Research evidence base for clinician-rapid-recognition — 'for almost 1 in 5 children, clinicians felt extremely confident that they could identify autistic children within 5 minutes, with this presentation being subsequently confirmed by a multidisciplinary team assessment'; (viii) on the 5P formulation framework that the protocol uses — 'Presentation, Predisposing factors, Precipitating factors, Perpetuating factors, and Protective factors, and this aligns well with a more neuroaffirmative, rights-based and social model of disability'. The case study carries this record because the dispute between the State (MacLachlan) and the professional bodies (PSI / SIGA / IASLT / AOTI) is genuine on both sides of the evidence base: each side has peer-reviewed academic citations, each side has internationally-recognised precedents, and neither claim should render the other invisible.

The most load-bearing single thread in the entire consultation record is the question of whether the Autism Assessment and Intervention Pathways Protocol is, in effect, designed to operate around the Disability Act 2005's Assessment of Need pathway. The thread surfaces in two specific, verbatim primary-source moments — both from the same HSE-published 19 March 2025 report. (i) ATTENDEE: verbatim free-text Q6 comment #8 — 'This was a poor example of poor consultation. Difficult questions were completely avoided. Unacceptable. An exercise in propaganda. So very disappointed. It feels as if the HSE do not actively wish to engage with grass roots campaigns and are prioritizing funded NGOs. The presentation was inaccessible if one did not have a certain level of education and understanding of the existing systems. I am more confused about this protocol than I was previously. Genuinely feels like this has been designed to evade the Disability Act 2005.' (ii) MACLACHLAN RESPONSE: on the 'autistic but not disabled' tension — 'I wouldn't see this as a move, at least I am not aware of any directive to that effect. This is a very difficult and I appreciate upsetting situation for some people. The AoN definition of disability requires a substantial restriction by reason of an enduring impairment. As the diagnosis of autism has become more acceptable and indeed positively valued by some, and as we have tried to move away from negative impairment type language, this may have changed the basis on which some clinicians give this diagnosis. For instance, the Northern Ireland study which recently reported a prevalence of 5% for autism among children and young people, also reported that 18% of them did not have any educational special needs. Also at least some people given an autism diagnosis do not report substantial restriction in their capacity to carry on a profession, business or occupation in the State or to participate in the social or cultural life of the State and as such would not meet the AoN criteria. I agree that we need to give more clarity to this and that is one of the things that hopefully the protocol will do. To my knowledge legal advice has not been sought on this — there are many conditions in ICD and DSM where a diagnosis does not imply a disability, as diagnostic classification systems are not designed to determine disability per se.' The thread is live because: (a) the MacLachlan response confirms that the Protocol does carry a substantive policy position on autism-diagnosis-without-disability-status; (b) it concedes that legal advice has not been sought on the AoN-statutory-interplay; (c) the F.U.S.S. Ireland verbatim 'overrides children's rights' framing (May 2026 launch-day statement) and the INTO 'profound breach of trust' framing both implicitly target the same operational question. The Disability Act 2005 reform / clarity question is the principal unresolved legal-policy thread the Protocol will produce in the rollout phase.

F.U.S.S. Ireland — a parent-led organisation founded by parents of neurodivergent and disabled children whose stated mission is to improve access to disability services and appropriate educational settings, and which explicitly does not advocate for the use of ABA/PBS — issued a statement on launch day (26 May 2026) voicing 'absolute opposition' to the Protocol. Their substantive case: that they have engaged at every stage of the consultation over more than two years, that the model 'overrides children's rights and dilutes professional standards', that previous attempts at cutting AON waitlists have caused harm to children, and that 'professional regulatory bodies are united in their opposition'. They commit to continued advocacy for a 'rights based model that is appropriately resourced and grounded in independent research and a strong evidence base'. The statement aligns substantively with the prior PSI / IASLT / AOTI consultation responses on the tiered model's evidence base, and adds the lived-experience parent dimension that the Protocol's user-acceptance ultimately depends on.

On launch day, AsIAm CEO Adam Harris characterised the Protocol as a 'first step' while shifting his substantive critique from the legislative-tool framing to the resourcing question: 'The protocol will succeed or fail based on the resourcing.' This is the post-launch evolution of his pre-launch 'not a legislative or statutory tool / not going to make a difference to waiting times' framing (see separate objection record): the new framing concedes the design but locates the entire risk in the staffing, training and capacity provision required to deliver it. The framing matters because HSE CEO Anne O'Connor's same-day acknowledgement that workforce pressures remain — 'all graduates are offered jobs' with 'very significant uptake' — confirms the workforce constraint is real and not yet quantified against the Protocol's tier-1 throughput target.

Gráinne Morrison, an autistic person who served on the Protocol working group, framed the launch as necessary but conditional. Her substantive point — 'A pathway, no matter how well designed, requires commitment, investment and on-going evaluation' — places the lived-experience-of-design-from-inside voice alongside the lived-experience-of-receipt-from-outside voice of the F.U.S.S. Ireland parents, with both converging on the same risk: that the Protocol document and the Protocol-in-practice will diverge unless funded delivery and continuous monitoring close the gap. Including a working-group member's caveat as a citizen-objection record (rather than as Government-side actor narration) makes the structural point explicit: the people inside the process have the same concern as the people outside it.