Title Australian Education Act 2013—National School Resourcing Board—Review of the loading for students with disability—Final report, December 2019
Source Both Chambers
Date 24-08-2020
Parliament No. 46
Tabled in House of Reps 24-08-2020
Tabled in Senate 24-08-2020
Parliamentary Paper Year 2020
House of Reps Misc. Paper No. 14760
Senate Misc. Paper No. 80
Paper Type Government Document
Disallowable No
Journals Page No. 2051
Votes Page No. 1032
House of Reps DPL No. 251
System Id publications/tabledpapers/24a5775c-cadb-4d8f-a12c-1344d90429e4


Australian Education Act 2013—National School Resourcing Board—Review of the loading for students with disability—Final report, December 2019

National School Resourcing Board

Review of the loading for students with disability: Final report | December 2019

National School Resourcing Board

Review of the loading for students with disability: Final report | December 2019

Board members

Mr Michael Chaney AO (Chair)

Emeritus Professor Denise Bradley AC (Deputy Chair) Professor Natalie Brown Professor Greg Craven AO Mr William (Bill) Daniels AM

Professor Stephen Lamb Professor Ken Smith Dr Alison Taylor

Review of the loading for students with disability: Final report © Commonwealth of Australia 2019

ISBN

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Disclaimer

As this is an independent review authored by the National School Resourcing Board, the report does not necessarily reflect the views of the Australian Government.

This document, when attributed, must be titled as Review of the loading for students with disability: Final report.

The Hon Dan Tehan MP Minister for Education Parliament House CANBERRA ACT 2600

Dear Minister

In November 2018, you commissioned the National School Resourcing Board (the Board) to undertake a review of the current settings for the loading for students with disability under the Australian Education Act 2013 (the Act).

The terms of reference require the Board to consider, provide findings and make recommendations relating to the current settings for the loading for students with disability. The Board was also asked to consider and, where appropriate, provide recommendations on the Australian Government Department of Education’s assurance processes for information provided to calculate a school’s Australian Government funding entitlement for students with disability.

As such, the Board has not considered how funding provided through the loading for students with disability is used or the appropriateness of the Nationally Consistent Collection of Data on School Students with Disability (NCCD) as an input for calculating a school’s Australian Government funding entitlement for students with disability. The Board has also not assessed how students are categorised in the NCCD.

In undertaking the review, the Board consulted widely to seek information and share perspectives. The Board sought stakeholder, expert and independent advice through a number of channels and commissioned a range of work to inform its deliberations. The Board received 33 submissions in response to its consultation paper, and also held two policy roundtables, a practitioner workshop and targeted face-to-face consultations with a range of not-for-profit, government, independent and Catholic peak bodies.

The Board has found that there is insufficient evidence to suggest that a change to the settings for the loading is required at this time. Given the quantum of the Australian Government’s funding for students with disability, a program of work to produce more nuanced estimates of the cost of adjustments for students with disability would be prudent. The Board also believes that the assurance processes in place for the loading are sound and their continued refinement will support confidence in the Australian Government’s school funding arrangements. With this in mind, and on behalf of the Board, I am pleased to present our final report and recommendations to you.

In thanking my Board colleagues, I would like to draw particular attention to the students with disability loading review Sub-committee. Professor Ken Smith, Chair, and Professors Stephen Lamb and Greg Craven AO, who made substantial contributions to this review. I would also like to thank the Expert Panel members for their research work and the Secretariat for their support for the Board.

Yours sincerely

Mr Michael Chaney AO Chair, National School Resourcing Board

Contents Glossary i

List of exhibits iv

Executive summary v

Recommendations ix

Findings x

Introduction 1

Review context 3

Part 1: Current settings of the loading 16

1.1 Approaches to quantify the cost of schooling can be used to cost adjustments to support students with disability 16

1.2 Each approach has limitations and will produce different results 16

1.3 Drawing on these approaches, the Board commissioned three research projects to validate the loading settings 17

1.4 Project 1: There are some limitations to the original study on which current estimates are based 18

1.5 Project 2: Professional judgement using a panel of experts can help estimate costs but needs to cover a wide range of adjustments 22

1.6 Project 3: Targeted programs provide a useful point of comparison with the current loading settings but do not account for all System spending on students with disability. 26

1.7 There is insufficient evidence to determine the adequacy of current loading values for students with disability 31

1.8 The cost of adjustments is affected by the context in which they are made 34

1.9 Further evidence is required to determine refinements to the loading settings 37

1.10 The work program should be implemented over a two-year period as an Education Council priority 41

Part 2: Assurance of Australian Government funding for students with disability 43

2.1 The Australian Government has an ongoing and essential role in ensuring public confidence in schools funding arrangements 43

2.2 The Australian Government Department of Education’s assurance framework for school funding is risk-based 44

2.3 Context and circumstance are important factors in defining potential risks 45

2.4 Capability building is an important component of assurance 46

2.5 There is a need for ongoing capacity building 48

2.6 Post enumeration is the main assurance activity undertaken by the Australian Government Department of Education 52

2.7 Stakeholders have identified areas for further refinement of the post enumeration processes for the NCCD 53

2.8 Assessing and reporting compliance outcomes 55

2.9 The Australian Government Department of Education’s process for assessing the quality and accuracy of NCCD data is sound 56

2.10 Transparency can improve the quality of NCCD data over time 57

Appendix A—Terms of reference 59

Appendix B—Review process 61

Appendix C—Policy roundtables 63

Appendix D—Practitioner workshop 66

Appendix E—Targeted consultations 69

Appendix F—Public submissions 70

Appendix G—References 72

i

Glossary Term Definition

Adjustments A measure or action taken to assist a student with disability to participate in education and training on the same basis as other students. Adjustments reflect the assessed individual needs of the student; they can be made at the whole-school level, in the classroom and at an individual student level.

Allocation The public funding provided by governments to Approved System Authorities.

Approved Authorities Legal entities that can receive Australian Government recurrent funding for one or more schools.

Approved System Authorities (Systems) Approved Authorities for more than one school that distribute funding according to their own needs-based funding arrangement.

This includes State and Territory governments.

Assurance The act of giving confidence and comfort that policies, procedures, controls or activities are effective and relative to the risk profile and operating environment.

Compliance An activity or action undertaken to provide proof/verification of an outcome.

Distribution Public funding that Systems (including State and Territory governments) provide to schools.

Educational assistant An individual who assists a teacher with instructional responsibilities; also known as a teacher’s assistant or teacher’s aide.

Moderation Calibration of teacher judgements to enhance the consistency, reliability and defensibility of decisions about NCCD levels of adjustment and category of disability. Moderation is not a deterministic exercise but rather refers to capability building.

Nationally Consistent Collection of Data on School Students with Disability (NCCD)

An annual collection of information about Australian school students who receive an adjustment to address disability.

ii

Term Definition

NCCD level—quality differentiated teaching practice

Students at this level of adjustment are supported through active monitoring and adjustments that are not greater than those used to meet the needs of diverse learners. These adjustments are provided through usual school processes, without drawing on additional resources, and by meeting proficient-level Teaching Standards (Australian Institute for Teaching and School Leadership).

Adjustments are made infrequently as occasional action, or frequently as low-level action such as monitoring.

NCCD level—supplementary Students at this level of adjustment are provided with adjustments that are supplementary to the strategies and resources already available for all students within the school.

Adjustments occur for particular activities at specific times throughout the week.

NCCD level—substantial Students at this level of adjustment, who have more substantial support needs, are provided with essential adjustments and considerable adult assistance.

Adjustments to the usual educational program occur at most times on most days.

NCCD level—extensive Students at this level of adjustment, who have very high support needs, are provided with extensive targeted measures and sustained levels of intensive support. These adjustments are highly individualised, comprehensive and ongoing.

Adjustments to the regular educational program occur at all times.

Non-Government Schools Census An annual collection by the Australian Government Department of Education of information on students and staff from all

non-government establishments that have, as their major activity, the administration or provision of full-time primary, secondary and/or special education.

Post enumeration An annual process to verify the accuracy of information provided by non-government schools in the Non-Government School Census that is used to calculate the school’s Australian Government funding entitlement.

Publicly funded share of the Schooling Resource Standard (SRS)

The proportion of the SRS that the Australian Government and State and Territory governments have agreed to fund.

Public funding Recurrent funding provided by the Australian Government and State and Territory governments.

iii

Term Definition

Reasonable adjustment Has the same meaning as in section 3.4 of the Disability Standards for Education 2005. An adjustment is reasonable in relation to a student with a disability if it balances the interests of all parties affected.

Relativities Refers to the relative levels of funding between each funded NCCD level of adjustment.

Setting of the students with disability loadings A percentage of the base amount of the SRS used to calculate dollar values of students with disability loadings each year.

Targeted program A State or Territory funding program for a known set of students, generally with moderate to high needs, who are identified using specific disability criteria and evidentiary requirements.

Total public funding The sum of the Australian Government’s and State and Territory governments’ shares of the SRS.

iv

List of exhibits The Schooling Resource Standard (SRS) 6

Evolution of Australian Government funding for students with disability 9

Number of students in the NCCD has been increasing since 2015 10

Total student enrolments have also increased since 2015 11

Students included in the NCCD as a proportion of the total number of students in each sector in 2018 12

Number of students included in the NCCD by sector in 2018 12

Proportion of students in each NCCD level of adjustment by sector in 2018 13

The loading for students with disability was the second largest SRS loading in 2018 14

The loading for students with disability increases according to the level of adjustment (2019 figures) 15

Distribution of per-student adjustment costs for Project 1: Review of original additional resourcing analysis that informed the current settings 20

Relativities of SRS loading for students with disability in 2019 21

2019 SRS loading relativities compared to the review of original additional resourcing analysis that informed the current settings 21

Case studies used to inform Project 2: Cost estimates of best-practice reasonable adjustments based on professional judgement 23

Range of professional judgement cost estimates by funded adjustment level 24

Professional judgement average cost estimates compared to the SRS loading 24

2019 SRS loading relativities compared to professional judgement 25

Average per-student expenditure aligned to System distribution 28

Average per-student expenditure aligned to NCCD levels of adjustment 28

2019 SRS loading relativities compared to average per-student expenditure relativities (aligned to System distribution) 29

2019 SRS loading relativities compared to average per-student expenditure relativities (aligned to NCCD) 29

Proportion of the NCCD population funded under targeted programs for government schools 30

2019 SRS loading relativities compared to all project relativities 33

Key research questions 41

v

Executive summary Australian Government recurrent funding for schooling is needs-based and operates within the framework of the Schooling Resource Standard (SRS), which is made up of a base amount and six loadings, including a loading for students with disability. This loading provides a contribution to schools and Systems delivering additional assistance to enable students with disability to access and participate in education on the same basis as other students.

Since 2018, the Nationally Consistent Collection of Data on School Students with Disability (NCCD) has been used to calculate a school’s Australian Government funding allocation. This represents an important change in the way funding for students with disability is allocated by the Australian Government. Previously, funding was based on whether students met state-specific definitions of disability (linked mainly to medical diagnoses). Australian Government funding is now based on the estimated cost for reasonable adjustments that schools make to meet students’ needs.

The broader definition of disability under the NCCD has significantly increased the number of students with disability attracting Australian Government funding. The growth in student numbers, along with the three funded loading amounts differentiated by level of adjustment (supplementary, substantial and extensive), means funding for students with disability will continue to increase. On average, growth in the loading over the period 2018−2029 is predicted to be 5.1 per cent per year.

Recognising the significance of this change, the Australian Government Minister for Education commissioned the National School Resourcing Board (the Board) to make findings and recommendations relating to the:

• Current SRS settings for the loading for students with disability. • Australian Government assurance processes to support the accuracy of information provided to calculate funding entitlements for students with disability.

While the change in funding arrangements is relatively recent, a review is timely given:

• The size of the loading—in 2018 it was the second largest loading after socio-educational disadvantage. • The rate at which the loading is growing—overall, it is the third fastest growing loading and the fastest growing in dollars allocated per student. • The subjective nature of the data underpinning the loading—unlike the other SRS loadings, which

are based on objective criteria.

In undertaking this review, the Board has been mindful that its recommendations may need to be considered in conjunction with any broader changes arising from the findings of the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability, as well as the 2020 review of the Disability Standards for Education 2005 (Disability Standards).

The full terms of reference for the review are at Appendix A.

The review was informed by the work of an Expert Panel and significant consultation

Given the technical nature of the review terms of reference, the Board established an Expert Panel to support its work. The Expert Panel comprised members with expertise in students with disability policy, education system administration, and economic and financial modelling. In addition to general advice, the Expert Panel completed three research projects, each using a different approach, to test the validity of the current loading settings.

vi

In testing the validity of the settings, the research projects examined both the dollar value of the loading for each funded level of adjustment and the relative difference between the dollar amounts at each level.

The Board also commissioned a fourth research project to review Australian Government assurance processes for the students with disability loading.

The research projects did not examine the impact of external factors such as school context on the cost of making adjustments. Instead, insights on the effects of these were sought via the Board’s targeted consultations, including: 33 submissions received in response to the review consultation paper, targeted face-to-face consultations with representatives from 19 stakeholder groups, and two policy roundtables with representatives from State and Territory education departments and non-government school peak bodies.

A stronger evidence base is needed to inform changes to the loading settings

Overall, the evidence gathered by the Board is not definitive enough to recommend specific changes to the loading settings at this time. The three research projects show significant variation in cost estimates and funding relativities, depending on the approach used. Stakeholder feedback is also mixed, although the Board notes there is some consensus among stakeholders that funding at the substantial and extensive levels could be enhanced.

Both the research projects and stakeholder feedback reveal overlap in costs across all three funded NCCD levels of adjustment, as well as wide variation in student need represented at each level of adjustment. The Board also found the cost of adjustments varies depending on school context.

While the Board is unable to recommend specific changes to the loading settings at this time, it believes additional targeted investigation is warranted. The Board recommends establishing a forward work program to produce more nuanced estimates of the cost of adjustments for students with disability.

The Board is of the view that a mix of approaches—incorporating a professional judgement element, estimation of costs, and a focus on student outcomes via successful schools and programs—may offer a more nuanced method for determining the cost of adjustments and relativities.

Given the impact on all governments and sectors of any change to SRS settings, and the fact that the students with disability settings have only been in place from the beginning of 2018, the Board recommends the work be undertaken as an Education Council priority, in collaboration with the Catholic and independent sectors.

The Board recommends retaining the current loading amounts while the evidence base regarding their appropriateness is tested more thoroughly and then developed. This should be completed within two years in order to introduce any changes to the loading settings from 2023.

vii

The Australian Government Department of Education process for assessing the quality and accuracy of NCCD data is sound

The Board’s review examined the process for assuring the quality and accuracy of reported NCCD data. Overall, the Board found that the assurance process compares favourably with best practice and is commensurate with the Australian Government’s investment in the loading for students with disability.

While the process is sound, there is room for ongoing improvement. The Board recommends continued investment in capacity building and post enumeration processes, along with a renewed focus on the transparency of NCCD data.

Building capability is an important component of assurance

The Board heard positive feedback about the work undertaken to build schools’ capabilities to administer the NCCD, in particular the collaborative approach taken by the Australian Government Department of Education and the Joint Working Group to Provide Advice on Reform for Students with Disability (JWG).

Despite this, the Board found further work is required to help teachers determine the appropriate NCCD level of adjustment for individual students and meet the related evidentiary requirements. The need for additional capacity building is not surprising given the recent shift from medical diagnosis to teacher judgement as the basis for funding.

To this end, the Board recommends that the Australian Government continue to invest in comprehensive training and development to support consistency in NCCD data collection and moderation until at least 2023. Specifically, the Board is of the view that a national moderation process, which enables moderation across sectors, could help improve existing processes in individual schools, sub-systems and Systems.

It was also evident to the Board that non-systemic schools face particular challenges in administering the NCCD, as they lack the centralised support services available within Systems. The Board recommends that the Australian Government provide ongoing support to allow non-government representative bodies to build the capacity of non-systemic schools to implement the NCCD to

ensure their student cohorts are not disadvantaged in comparison with systemic schools.

While noting that the JWG will not continue beyond 2019, the Board strongly supports the continuation of a national cross-sectoral approach to all future capacity building activities.

The post enumeration process for NCCD data should be consistent and responsive to school context

The Board found that while stakeholders accept the need for rigorous assurance processes, the 2018 post enumeration process was applied inconsistently across participating schools and was not responsive enough to different school contexts. The Board also found there was a general desire for greater clarity and consistency on the post enumeration process and the types of information requested during the process.

While noting the work underway by the Australian Government Department of Education to develop guidance related to NCCD evidentiary requirements, the Board recommends that the Australian Government refine the design and delivery of the post enumeration process for assurance of the NCCD to ensure it is consistent and responsive to school context.

viii

Transparency can improve the quality of NCCD data over time

Currently, NCCD data is reported to the Australian Government at the individual school level but is made available publicly—through the Report on Government Services and the annual National Report on Schooling in Australia—in aggregated form.

Greater transparency could help to improve NCCD data quality over time by driving compliance and ongoing improvement through greater public and school community scrutiny.

The Board considers it timely for Education Ministers to again consider publishing school level NCCD student numbers (by adjustment level) on the My School website, with due regard to privacy considerations.

ix

Recommendations Recommendation 1

The Australian Government should retain the settings for the loading in the short term while further work is undertaken to evaluate the validity of the settings.

Recommendation 2

The Australian Government, in collaboration with State and Territory governments, should invest in the development of a strong evidence base (over two years) to inform a refined costing model for the students with disability loading.

This costing model should inform the settings for the loading from 2023.

Recommendation 3

The work program to develop an evidence base to inform a refined costing model should be an Education Council priority; supported by a reference panel comprising representatives from all States and Territories, and the Catholic and independent sectors.

Recommendation 4

The Australian Government should continue its current level of investment in comprehensive training and development to support consistency in the collection and moderation of data under the Nationally Consistent Collection of Data on School Students with Disability until at least 2023. This should include the Australian Government taking a leadership role in a national cross-sectoral approach to moderation.

Recommendation 5

The Australian Government should ensure, in its provision of support funding through the Choice and Affordability Fund and the Non-Government Reform Support Fund, that there is ongoing support and resources to build the capacity of non-systemic schools to implement the Nationally Consistent Collection of Data on School Students with Disability.

Recommendation 6

The Australian Government should refine the design and delivery of the post enumeration process for assurance of the Nationally Consistent Collection of Data on School Students with Disability to ensure it is consistent and responsive to school context.

Recommendation 7

As part of its assurance processes, the Australian Government should use data analytics to identify variations in the Nationally Consistent Collection of Data on School Students with Disability data from past years and between jurisdictions, sectors and schools.

Recommendation 8

The Education Council should pursue publishing school-level Nationally Consistent Collection of Data on School Students with Disability student numbers (by adjustment level) on the My School website, in line with the other Schooling Resource Standard inputs, having due regard for privacy issues.

x

Findings Finding 1

Cost estimates vary across the research projects and there is insufficient evidence to determine whether the current loading settings are the most appropriate inputs for the Schooling Resource Standard.

Finding 2

The degree of overlap in cost estimates at all three levels, particularly the substantial and extensive levels, suggests a need for better differentiation.

Finding 3

Funding relativities differ according to the method used to cost adjustments and there is insufficient evidence to determine whether the current relativities are appropriate or not.

Finding 4

Approved System Authorities’ funding allocations for students with disability from targeted programs show:

− variation in funding provided to students within the same Nationally Consistent Collection of Data on School Students with Disability levels of adjustment − divergence between the numbers of

students reported in the Nationally Consistent Collection of Data on School Students with Disability and those funded under targeted programs.

Finding 5

Stakeholders have reported that the cost of adjustments varies according to school context and stage of schooling.

Finding 6

There is insufficient evidence to determine changes to the current loading settings without further research to build the evidence base for change.

Finding 7

Any further research should be undertaken using a range of approaches to quantifying the cost of schooling in order to inform an updated estimate of the cost of reasonable adjustments.

Finding 8

A cross-sectoral approach has contributed positively to building the capacity of Approved System Authorities and schools to implement the Nationally Consistent Collection of Data on School Students with Disability.

Finding 9

The Australian Government’s contribution to building capacity to administer the Nationally Consistent Collection of Data on School Students with Disability at the national and Approved System Authority level has been well received and stakeholders have called for it to continue alongside compliance efforts.

Finding 10

Stakeholders have reported that the Australian Government’s post enumeration process for the Nationally Consistent Collection of Data on School Students with Disability was applied inconsistently and did not take school context into account in 2018.

Finding 11

Australian Government assurance processes for determining the accuracy of data reported under the Nationally Consistent Collection of Data on School Students with Disability compare favourably with what is considered best practice.

Finding 12

The Australian Government assurance processes are commensurate with the Australian Government’s funding contribution for students with disability.

1

Introduction The task

The Board is responsible for reviewing different parts of the Australian Government school funding model under the Australian Education Act 2013 (the Act). These reviews help ensure public confidence in the funding model.

On 15 November 2018, the Hon Dan Tehan MP, Australian Government Minister for Education, commissioned the Board to consider, provide findings and make recommendations relating to the current settings for the loading for students with disability. The Board was also asked to consider and, where appropriate, provide recommendations on the Australian Government Department of Education’s assurance processes for information provided to calculate a school’s Australian Government funding entitlement for students with disability.

The focus of the review is primarily the Schooling Resource Standard (SRS) settings for the loading for students with disability. The Board considered State and Territory funding allocations to their member schools to inform its assessment of the SRS settings.

To be clear, this is not a review of how funding provided through the loading for students with disability is used, nor is it an assessment of how students are categorised in the Nationally Consistent Collection of Data on School Students with Disability (NCCD). Any support provided under the National Disability Insurance Scheme (NDIS) or the provision of personal care in schools is also out of scope for this review.

Similarly, the Board has not considered the appropriateness of the NCCD as the means of identifying students with disability to attract additional Australian Government school funding.

The full terms of reference are at Appendix A.

The review process

The Board established a Sub-committee to lead the review, comprising Professors Ken Smith (Chair), Greg Craven AO and Stephen Lamb. The Sub-committee sought nominations from State and Territory governments and the non-government sector for a panel of experts to support its work. The Expert Panel comprised:

• Professor Christine (Chris) Forlin, international inclusive education consultant • Professor Matthew Gray, Director, Centre for Social Research and Methods, Research School of Social Sciences, Australian National University (ANU) • Ms Kate Griffiths, Program Manager, Assessment and Reporting, Australian Curriculum,

Assessment and Reporting Authority (ACARA) • Mr David Pattie, Group Manager, Improving Student Outcomes, Australian Government Department of Education • Mr Mark Tainsh, education consultant • Ms Nicola Taylor, Senior Data and Policy Analyst, National Catholic Education Commission (NCEC) • Ms Robyn Yates OAM, Associate Chief Executive, Association of Independent Schools of New

South Wales.

The Sub-committee also sought independent advice from Mr Brian Smyth-King, education consultant.

2

The Board commissioned a range of work from the Expert Panel, including the following reports:

• Review of additional resourcing analysis: Report prepared for the National School Resourcing Board; M. Gray • International approaches to costing adjustments: Report prepared for the National School Resourcing Board; M. Gray • Best-practice adjustments for students with disability: Report prepared for the National School

Resourcing Board; C. Forlin • A review of current government Approved System Authorities’ arrangements for funding of students with disabilities and common reform directions: Report prepared for the National School Resourcing Board; M. Tainsh • Review of the Commonwealth’s assurance processes for payment of the students with disability

loading: Report prepared for the National School Resourcing Board; C. Murphy.

Extensive consultations were conducted over the course of the review. The Board:

• released a consultation paper inviting public submissions and received 33 submissions from individuals, representative peak bodies, independent, Catholic and government school organisations, associations and Approved System Authorities • held two policy roundtables with representatives from State and Territory education departments

and non-government school peak bodies • held a practitioner workshop bringing together allied health and medical practitioners as well as, teachers, principal practitioners and policy makers nominated by State and Territory education departments and non-government school peak bodies • held targeted face-to-face consultations, including with the Independent Schools Council of

Australia, NCEC, Victorian Department of Education and Training, Tasmanian Department of Education, Australian Capital Territory (ACT) Education Directorate, Catholic Education Archdiocese of Canberra and Goulburn, Association of Independent Schools of the ACT and selected national peak disability bodies.

The Board also consulted with Education Council’s Joint Working Group to Provide Advice on Reform for Students with Disability (JWG), the Australian Education Senior Officials Committee (AESOC) and senior officials from the Australian Government Department of Social Services and the Australian Government Department of Education. A full list of stakeholders consulted are at Appendices C, D and E.

3

Review context This section sets out key background information and wider context for the review. Since 2018, the Australian Government’s recurrent funding to schools for students with disability has been based on teachers’ assessments of the adjustments required for students, collected through the NCCD.

Schools are obliged to make reasonable adjustments for students with disability to enable them to access and participate in education on the same basis as other students

The Disability Standards outline the obligations of schools under the Disability Discrimination Act (1992) to enable students with disability to access and participate in education on the same basis as other students. The Disability Standards require schools to ensure that a student with disability has opportunities and choices that are comparable with those offered to students without disability— including making reasonable adjustments for admission and enrolment, participation, curriculum development, and the use of facilities and services.1

An adjustment is a measure or action taken to assist a student with a disability to participate in education and training on the same basis as other students. Adjustments are considered reasonable where they take into account a student’s learning needs and balance the interests of all parties affected, including those of the student with disability, the school, staff and other students.2

The introduction of the NDIS does not change the obligations of schools under the Disability Standards to provide reasonable adjustments to all students with disability

The introduction of the NDIS has created uncertainty about the intersection of responsibilities in school settings. Currently, education providers are responsible for delivering personal care in schools for students with disability. This responsibility is unchanged by the NDIS. The NDIS funds supports for daily living that a student would require in any setting, that is, whether or not the student is at school. While the NDIS provides individualised packages of funding to eligible people with disability who require additional supports not provided by existing government services, these packages exclude activities that are reasonable adjustments, which are already the obligation of mainstream service systems, including schools.

In its response to the 2015 review of the Disability Standards, the Australian Government agreed further work could be done to clarify the intersection of education providers’ responsibilities for the provision of reasonable adjustments and supports under the Disability Standards and the NDIS.3 This work is expected to be finalised in 2023. In the meantime, the Council of Australian Governments (COAG) Disability Reform Council has agreed that personal care in schools can be considered in-kind contribution to the NDIS by States and Territories.

A number of stakeholders raised the intersection between the NDIS—most notably personal care in schools and transportation to and from school—and the support provided for educational

1 Australian Government Department of Education and Training, Disability Standards for Education 2005 fact sheet, viewed on 2 April 2019, https://docs.education.gov.au/system/files/doc/other/dse-fact-sheet-2-dse_0.pdf.

2 Australian Government Department of Education and Training, Disability Standards for Education 2005 fact sheet, viewed on 2 April 2019, https://docs.education.gov.au/system/files/doc/other/dse-fact-sheet-2-dse_0.pdf.

3 Australian Government Department of Education and Training (2015) Australian Government Initial Response to the 2015 Review of the Disability Standards for Education 2005, Australian Government Department of Education and Training: Canberra, p. 6.

4

adjustments in schools as an issue requiring further clarity. The Board expects that the national policy work underway will resolve these issues.

All Australian governments have embraced an inclusive education policy

Inclusive education refers to the philosophy of embracing human diversity and valuing and supporting the full participation of all students as equal members of an educational community.4 This means that education environments and teaching strategies should be designed to include and benefit all students.

In the last 30 years, there has been a period of reform and change to the way Australian society and schools view, respond to and support students with disabilities to contribute to the nation’s broader economic and social development.

Schools have undergone a significant shift away from the industrial model of schooling with little regard to individual circumstances, including the impact of socioeconomic, physiological and cultural differences on a student’s ability to participate.5

Schools have moved away from a focus on ensuring a known and small group of students with severe disabilities could access buildings and playgrounds, toward the expectation of participation and achievement for all children with disability on the same basis as their peers, through schooling systems that have inclusion at the heart of their culture, curriculum, pedagogy and practices.6

Supporting this cultural change has been the growth of more equitable funding approaches that take account of cohorts within school populations, as well as a steady and considerable increase in funding to support students with disability. These changes are also reflected in the Disability Discrimination Act and Disability Standards.7

While individual approaches vary, most national, State and Territory policies and initiatives in Australia include the following principles:

• a focus on the individual child and their learning and support needs • the need to build systemic capacity through developing the knowledge, ability and skills of the schools’ workforce • effective pedagogy for students with disability and inclusive schooling systems which benefit all

students • all sectors sharing a commitment to ensure students with disability receive the support they need • schools and their communities being best placed to make decisions, in consultation with parents and students, about the aspirations and needs of their children and young people with disability. 8

4 Cologon, K. (2013) Inclusion in education: towards equality for students with disability, Children with Disability Australia: Victoria, p. 6.

5 Tainsh, M. (to be published) A review of current government Approved System Authorities’ (ASA) arrangements for funding of students with disabilities and common reform directions: Report prepared for the National School Resourcing Board.

6 Tainsh, M. (to be published) A review of current government Approved System Authorities’ (ASA) arrangements for funding of students with disabilities and common reform directions: Report prepared for the National School Resourcing Board.

7 Tainsh, M. (to be published) A review of current government Approved System Authorities’ (ASA) arrangements for funding of students with disabilities and common reform directions: Report prepared for the National School Resourcing Board.

8 Tainsh, M. (to be published) A review of current government Approved System Authorities’ (ASA) arrangements for funding of students with disabilities and common reform directions: Report prepared for the National School Resourcing Board.

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In keeping with these principles, all governments have worked to deliver key national reforms and initiatives, including:

• the NCCD • the NCCD Portal, which provides resources for school leaders, teachers, education assistants, early childhood educators and school communities • a national curriculum that encompasses the needs of students with disability • identifying priority actions arising from the 2015 review of the Disability Standards. 9

Education and learning for students with disability is also a key area of inquiry for the Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability

On 5 April 2019, the Prime Minister, the Hon Scott Morrison MP, and the Hon Paul Fletcher MP, Minister for Families and Social Services, announced the establishment of a Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability (the Royal Commission). The Commissioners appointed to oversee the Royal Commission have been directed to inquire into violence, abuse, neglect and exploitation of people with disability in all settings and contexts, including schools.

In October 2019, the Royal Commission released the Education and Learning issues paper, which notes it will consider the systemic and structural factors that cut across the key issues and barriers experienced by students with disability, such as policy frameworks, funding and data collection. It will also consider the link between inclusive education and an inclusive society, which supports the independence of people with disability and their right to live free from violence, abuse, neglect and exploitation.10

The Royal Commission is required to provide an interim report no later than 30 October 2020, and a final report no later than 29 April 2022.

It will be important for the Board’s recommendations to be considered in the broader context of the findings of the Royal Commission and the next review of Disability Standards scheduled for 2020.

Australian Government recurrent funding for schools is needs-based and provides additional funding for students with disability

Australian Government recurrent funding for schools is calculated based on the SRS. The SRS is an estimate of how much total public funding a school requires to meet the educational needs of its students. It is made up of a base amount for every primary and secondary student and six loadings to provide extra funding for disadvantaged students and schools.

The SRS loadings are intended to represent the additional efficient cost, funded from all sources, to give schools with a particular characteristic or with particular types of students the same opportunity to achieve nationally agreed educational outcomes as schools that do not attract loadings.11

The SRS has loadings for socio-educational disadvantage, students with disability, low English language proficiency, Aboriginal and Torres Strait Islander students, school location and school size.

9 Tainsh, M. (to be published) A review of current government Approved System Authorities’ (ASA) arrangements for funding of students with disabilities and common reform directions: Report prepared for the National School Resourcing Board.

10 Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability, Education and Learning Issues Paper, viewed on 27 November 2019.

11 Gonski, D., Boston, K., Greiner, K., Lawrence, C., Scales, B. & Tannock, P. (2011) Review of Funding for Schooling—Final Report, Australian Government Department of Education, Employment and Workplace Relations: Canberra, p. 166.

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Apart from school size (which is based on a sliding scale of set amounts based on student numbers), these loadings are calculated as a percentage of the SRS base.

The Schooling Resource Standard (SRS)

Source: Developed by the National School Resourcing Board based on the Australian Education Act 2013.

As the SRS is an estimate of how much total public funding a school needs, both the Australian Government and State and Territory governments contribute to the total funding amount. In line with States and Territories having full constitutional responsibility for schools, the Australian Government will fund at least 20 per cent of the total SRS for government Systems by 2023— reflecting the Australian Government's role as the minority public funder of government schools. The Australian Government will fund at least 80 per cent of the total SRS for non-government schools and Systems by 2023, reflecting its role as the majority public funder of non-government schools.12

Likewise, State and Territory governments provide a contribution to both sectors, making a higher contribution to the government sector. These contribution amounts—to both government and non-government sectors—vary between jurisdictions. Minimum State and Territory funding contributions are set out in the Act, or in individual bilateral agreements between the Australian Government and State or Territory governments. As a result of these shared contribution arrangements, changes to the settings for the SRS loadings have flow-on effects for State and Territory governments as well as the Australian Government.

The Australian Government provides funding to Systems based on the SRS. Systems have more detailed knowledge of their students and schools and the Australian Government provides the flexibility for Systems to apply that knowledge to address needs as they see them, according to the principle of subsidiarity.

12 Australian Government Department of Education and Training, What is the Schooling Resource Standard and how does it work? Fact sheet, viewed on 2 April 2019, https://www.education.gov.au/what-schooling-resource-standard-and-how-does-it-work.

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The Australian Government’s funding for students with disability is allocated based on a national data set that identifies the reasonable adjustments schools are making

In 2008, COAG committed to working toward a nationally consistent approach to identifying school students with disability, including measuring the level of educational adjustment. The NCCD model was developed collaboratively with government and non-government sectors, trialled in 2011 and 2012, and endorsed by Education Ministers in 2013. It was then progressively implemented from 2013 to 2015, with 2015 being the first year in which all Australian schools participated.

Under the NCCD, teachers use their professional judgement based on evidence to determine the level of adjustment provided to students with disability and the broad category of disability under which the student best fits (physical, cognitive, sensory, social/emotional). This approach is based on the principle that teachers and school teams, in consultation with students, clinical experts and families, are best placed to judge what reasonable educational adjustments a student needs, in line with the Disability Standards.

The NCCD records all the reasonable educational adjustments provided to school students by schools throughout the country across four levels of adjustment: support provided within quality differentiated teaching practice (QDTP), supplementary, substantial and extensive.

The move to using NCCD as a national instrument to count students with disability was a recommendation of the 2011 Review of Funding for Schooling Final Report, which:

• found significant variation in funding for students with disability between States and Territories, and that students with disability in non-government schools received substantially less funding than those in government schools, particularly those with high support costs • noted that, while students with disability often require additional assistance to access and

participate in schooling, there are significant differences in the educational needs of students within this cohort, and a funding range for the students with disability entitlement should be established.13

The loading for students with disability is the only SRS loading that requires assessment at the school level, based on a range of variables identified according to teacher judgement. The other SRS loadings are based on statistical analysis or have fixed definitions for eligibility (for example, the school size loading is based on full-time equivalent student numbers). As students are included in the NCCD based on teachers’ professional judgements about the level of adjustments they require, there is an element of subjectivity involved. Additionally, as the NCCD is context specific, the same student could be categorised differently depending on the existing resources of the school they attend.

13 Gonski, D., Boston, K., Greiner, K., Lawrence, C., Scales, B. & Tannock, P. (2011) Review of Funding for Schooling—Final Report, Australian Government Department of Education, Employment and Workplace Relations: Canberra, p. 119, 184.

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Box 1: Nationally Consistent Collection of Data on School Students with Disability (NCCD)

NCCD gives us a national definition of a student with disability.

The NCCD reports school students with disability by the level of support they receive to access and participate in learning, rather than on category or medical diagnosis of a specific disability.

The NCCD has four levels of adjustment: support provided within QDTP, supplementary, substantial and extensive. The frequency and intensity of the adjustments increases through the levels of adjustment.

Further information is available at www.nccd.edu.au.

Schools that are providing reasonable adjustments to students in one of the top three levels of adjustment (supplementary, substantial and extensive) attract increasing levels of funding through the loading to reflect the increasing average costs of adjustments for those levels. There is no additional funding provided for QDTP under the loading for students with disability.

It is important to note that the funding a student attracts is based on the adjustments schools are providing rather than the previous Australian Government arrangements, which used state-specific definitions of disability (mainly based on medical/clinical diagnoses).

To enable instalments to be paid earlier in the year based on an anticipated entitlement, the anticipated loading for students with disability for any given year is calculated and allocated based on the previous year’s NCCD data. Following the reporting of the current year’s NCCD data to the Australian Government Department of Education in August, Australian Government funding allocations are then adjusted later in the year to reflect these changes and the final entitlement.

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There has been a long and continuing evolution of Australian Government funding arrangements for students with disability

Prior to 2018, for Australian Government funding to support students with disability was provided through targeted programs, National Partnership funding or a flat rate loading based on medical diagnosis.

Evolution of Australian Government funding for students with disability

Source: Developed by the National School Resourcing Board.

Notes: Prior to 2009, the Australian Government recurrent funding for both government and non-government schools did not separately target funding to students with disability. The Nationally Consistent Collection of Data on School Students with Disability was implemented progressively between 2013 and 2015, with 2015 being the first year in which all Australian schools participated. It has been used to inform funding since 2018.

The current settings for the loading for students with disability have been made possible with the introduction of the NCCD. In 2018, using NCCD data, the Australian Government moved from flat rate loadings for mainstream and special schools to allocating funding based on the level of adjustments being delivered by schools. The three loading amounts for students with disability were based on per-student spending identified for selected students in a national sample of schools. The same loading amounts now apply to both mainstream and special schools.

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Moving to adjustments as the basis for funding significantly increased the number of students with disability attracting Australian Government funding

As the NCCD matures as a collection and teacher judgements about adjustments for students with disability and how they are categorised are refined, the number of students identified in the collection has been increasing. Exhibit 3 shows the student numbers in the NCCD from 2015 to 2018. It includes students in the three funded and one unfunded (QDTP) NCCD levels of adjustment.

The growth in NCCD student numbers shown in Exhibit 3 represents a 12 per cent increase over the period 2015–2018. This outpaced the growth in total student enrolments, which was 3.8 per cent over the same period (Exhibit 4).

It should be noted that Australian Government funding for students with disability during 2015–17 was based on the previous flat loading. Any trends in NCCD student numbers will need to be considered from 2018 onwards as the NCCD data did not inform funding allocations before then.

Number of students in the NCCD has been increasing since 2015

Source: Derived from student numbers and school students with disability on ACARA’s National Report on Schooling data portal.

Note: The number of students includes students across all four NCCD levels of adjustment.

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Total student enrolments have also increased since 2015

Source: Derived from student numbers and school students with disability on ACARA’s National Report on Schooling data portal.

In 2018, each sector had approximately the same proportion of their students included in the NCCD (Exhibit 5). That is, students in the NCCD made up approximately 20 per cent of students in the government sector, 18 per cent of students in the Catholic sector and 19 per cent of students in the independent sector.

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Students included in the NCCD as a proportion of the total number of students in each sector in 2018

Source: Derived from student numbers and school students with disability on ACARA’s National Report on Schooling data portal.

In terms of absolute student numbers, however, the majority of students included in the NCCD in 2018 were in the government sector, as illustrated in Exhibit 6. Based on these figures, approximately 67 per cent of students in the NCCD were in the government sector, 18 per cent of students were in the Catholic sector and 15 per cent of students were in the independent sector.

This is a reflection of each sector’s share of overall student enrolments. In 2018, the government sector accounted for 66 per cent of enrolled students, while the Catholic and independent sectors accounted for 20 per cent and 15 percent respectively.

Number of students included in the NCCD by sector in 2018

Source: Derived from student numbers and school students with disability on ACARA’s National Report on Schooling data portal.

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In 2018, the government sector supported the majority of students at each NCCD level of adjustment (Exhibit 7).

Proportion of students in each NCCD level of adjustment by sector in 2018

Source: Derived from student numbers and school students with disability on ACARA’s National Report on Schooling data portal.

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The quantum of funding provided for the loading for students with disability is growing

The Australian Government’s funding allocation through the loading for students with disability is significant. It accounted for 9.3 per cent ($1.85 billion) of the total $19.9 billion Australian Government recurrent funding for schools in 2019. Funding for the loading is estimated to grow, on average, by 5.1 per cent per year from 2018 to 2029.14

As shown in Exhibit 8, in 2018 the students with disability loading was the second largest loading after socio-educational disadvantage (but with a higher per-student average funding amount).

The loading for students with disability was the second largest SRS loading in 2018

Source: Derived from Australian Government Quality Schools Fact Sheets and data provided by the Australian Government Department of Education (unpublished).

Note: the figures in Exhibit 7 have been rounded to the nearest dollar.

14 Australian Government Department of Education, What is the Schooling Resource Standard and how does it work?, viewed on 31 October, 2019, https://docs.education.gov.au/node/44541.

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Current settings for the loading for students with disability were informed by school spending on students with disability in 2015

The settings of the loading for each of the three funded NCCD levels of adjustment—supplementary, substantial and extensive—were informed by research into school spending on students with disability at each level of adjustment. The Australian Government used a 2015 survey of school spending on students in the NCCD to determine the combined average costs for additional resourcing provided at each level of adjustment across mainstream and special schools. These costs were applied to the number of students represented in the 2017 NCCD and then increased to ensure that the move to the new arrangements provided additional total Australian Government funding for students with disability.

The loading and base per student (primary and secondary) amounts are set out in Exhibit 9.

The loading for students with disability increases according to the level of adjustment (2019 figures)

Source: Developed by the National School Resourcing Board based on the Quality Schools fact sheet: What is the Government doing to support students with disability?

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Part 1: Current settings of the loading An early critical task for the review was to determine a method for assessing the validity of the current settings of the loading. In validating the settings, the Board felt it was important to consider not only the dollar value of the loading for each funded level of adjustment but also the relative difference between the dollar amounts at each level. That is, the Board’s assessment should attempt to answer the following questions:

• Is the dollar value of the loading adequate to meet the average cost of adjustment at each level? • Is the relative difference in dollar values across the three funded levels of adjustment appropriate (based on differences in the types of adjustments required at each level)?

To inform its work, the Board identified a number of methods for costing adjustments to provide a comparison with current arrangements.

1.1 Approaches to quantify the cost of schooling can be used to cost adjustments to support students with disability There are four approaches commonly used to quantify the cost of schooling, including the cost of educating students with particular characteristics and needs. These are:

• Professional judgement: draws together experienced educators and subject matter experts to identify what should be in place (programs, practices, staff) for a student to receive an adequate or agreed standard of education. • Evidence-based: uses a set of evaluated and effective educational interventions from education

literature and research, rather than from a panel of experts, to identify what should be in place (programs, practices, staff) for a student to receive an agreed standard of education. • Successful schools: determines the minimum level of funding required to reach an agreed standard by using the program-level costs of schools that have successfully reached that standard. • Regression-based: uses historical data on student characteristics and needs, outcomes and actual

expenditure in order to estimate the relationship between spending and student outcomes.15

While much of the research in this area has occurred in the context of school funding more broadly, these approaches can also be applied more narrowly to estimate the cost of educating students with disability—noting there are challenges in doing so, as outlined in Section 1.2.

1.2 Each approach has limitations and will produce different results While these four approaches are the most commonly used for estimating the costs of schooling and for assessing costs based on the best available research, they all have strengths and weaknesses. A 2006 United States review of their application found that not all approaches are able to accurately define the costs of adjustment.16

15 Gray, M. (to be published) Review of approaches to costing educational adjustments: Report prepared for the National School Resourcing Board.

16 Harr, J., Parrish, T., Chambers, J., Levin, J. & Segarra, M. (2006) Considering Special Education Adequacy in California, American Institutes for Research: Washington.

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This is supported by the findings of a review of the approaches by Professor Matthew Gray at the ANU Centre for Social Research and Methods, which found that:

• Professional judgement approaches are now widely used. This is due, in part, to reliance on expert knowledge to determine the adjustments that will best meet the needs of students with disability and ensure they are best placed to get the most from school.17 They also produce easy-to-understand results and provide confidence that costings reflect best practice. When applied to individual students, rather than schools or Systems, this approach can result in costs that are higher than the actual adjustments made by schools. • The criteria used to select successful schools is open to debate. It can also be difficult to know

whether success can be generalised across schools, or whether it is a function of other factors such as effective school leadership. • Judgements about measuring educational quality, outcomes or participation can be sensitive to the statistical model used under a regression-based approach. This approach also reflects choices

made within existing school budgets, which may not necessarily reflect the resources required to achieve a pre-determined education standard.18

It should be noted that these approaches are used to provide average costs. While appropriate for funding purposes, averages can conceal a considerable spread of costs. Averages may be higher or lower than the costs for an individual student.

In addition, all four approaches are impacted by differences in expected standards of education, a lack of clarity about the causal relationship between costs and outcomes, and poor-quality data.

This creates challenges from a policy perspective, as the approach used can produce very different estimates of the relative costs of educating students with different characteristics. This challenge is particularly acute when estimating the educational adjustment required to allow students with disability to participate in education on an equal basis as other students. This is due to the limited data on outcomes for students with disability and difficulties with defining measurable participation for students with disability on an equal basis.19

1.3 Drawing on these approaches, the Board commissioned three research projects to validate the loading settings The Board commissioned three research projects to test the validity of the current settings:

1. Review of original additional resourcing analysis that informed the current settings. 2. Cost estimates of best-practice reasonable adjustments based on professional judgement. 3. Comparison with arrangements used by State and Territory Systems through targeted programs for government schools.

As described previously, the research projects examined both the dollar values and funding relativities at each funded level of adjustment. Relativities provide a useful perspective when analysing funding distributions within a defined budget, particularly in areas of social policy, such as

17 OECD (2017) The Funding of School Education: Connecting Resources and Learning, OECD Reviews of School Resources, OECD Publishing: Paris, http://dx.doi.org/10.1787/9789264276147-en.

18 Gray, M. (to be published) Review of approaches to costing educational adjustments: Report prepared for the National School Resourcing Board.

19 Gray, M. (to be published) Review of approaches to costing educational adjustments: Report prepared for the National School Resourcing Board.

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education, where there will always be tension between funding requirements and budgetary constraints.

Relativities were calculated by setting the supplementary per-student funding value at 1.0. Substantial and extensive funding values were then divided by the supplementary value in order to convert each value into a multiple of 1.0.

Overall, the three research projects show significant variation in both cost estimates and relativities and do not provide a consensus view. The Board cannot, therefore, reliably draw on the results of these projects to recommend specific changes to the current loading values.

While the Board is not prepared to draw premature conclusions unsupported by evidence, valuable insights into the loading settings can be drawn from the projects:

• There are some limitations to the original study on which current estimates are based (Project 1). • Professional judgement using a panel of experts can help estimate costs but needs to cover a wide range of adjustments (Project 2). • Targeted programs provide a useful point of comparison with the current loading settings but do

not account for all System spending on students with disability (Project 3).

The lack of a consensus view is also reflected in stakeholder feedback on the loading settings.

1.4 Project 1: There are some limitations to the original study on which current estimates are based Project 1 reviewed the methodology and findings of the original study underpinning the current loading settings in order to test the validity of the original estimates in terms of both dollar values and funding relativities.

The Board notes that the findings of the original study were based on early NCCD data and there have been significant improvements in data consistency and reliability since that time.

Box 2: Review of original additional resourcing analysis that informed the current settings

In 2015, Education Council commissioned a study to identify the additional resourcing provided for all levels of adjustment for students with disability counted in the 2015 NCCD. The original study analysed data from a survey of 200 schools (182 mainstream schools and 18 special schools).

To inform the review, AESOC provided the Board with reports from the study and access to the original unit record data file.

The review of the original additional resourcing analysis was undertaken for the Board by Professor Matthew Gray from the ANU Centre for Social Research and Methods.

Project 1 cost estimates are broadly consistent with current settings

This project revealed cost estimates largely in keeping with current settings. While the estimates do not match exactly, in part because of the data transformation methods used at the time of the original work, the estimates were broadly consistent.

Analysis of the original methodology and data raised a number of issues, some of which were identified at the time of the earlier survey work:

• The sample of special schools, from which most students requiring extensive adjustments were drawn, was quite small (18 out of the original 200 schools).

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• The sample of schools in regional and rural areas was too small to understand the effects of location on cost of adjustment. • Some schools, often those with large numbers of students receiving adjustments, appear to have provided average costs for students at each funded level of adjustment (rather than individual

costs). The use of average rather than individual per-student costs produced noticeable ‘spikes’ or clustering in costs within adjustment levels. This was more prevalent in special schools, with average costs provided for almost half (48.7 per cent) of special school students and 24.6 per cent of mainstream school students.

− For example, one special school in the survey appears to have reported a single adjustment cost of $19,325 for all 373 students.

• The inclusion of averages in the survey data compromised the ability to model student-level costs in order to identify factors associated with differences in costs. This means it is not possible to use the existing data to understand the variation in adjustment costs for students, particularly those requiring substantial and extensive adjustment.

The data also revealed overlap between the costs of adjustments at all three funded levels of adjustment, as well as significant variation in costs within each level. While this variation was present at all funded levels of adjustment, it was most pronounced for students requiring substantial and extensive adjustments:

• Supplementary cost estimate range: $54 to $84,008. • Substantial cost estimate range: $126 to $133,240. • Extensive cost estimate range: $1,360 to $158,391.

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Exhibit 10 shows the distribution of per-student funding costs by adjustment level within the ranges listed above.

Distribution of per-student adjustment costs for Project 1: Review of original additional resourcing analysis that informed the current settings

Source: Review of original additional resourcing analysis.

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Despite the limitations of the original study, it is the Board’s view that the cost estimates produced by its review are broadly consistent with the current loading values. Additional data would, however, be needed to provide more complete confidence in the existing settings.

Project 1 funding relativities are broadly consistent with those of the current loading

As shown in Exhibit 11, funding under the current loading at the substantial level is 3.5 times the supplementary amount (for both primary and secondary students). Funding at the extensive level is 7.4 times the supplementary amount (for primary students) and 7.5 times the supplementary amount (for secondary students).

Relativities of SRS loading for students with disability in 2019

Source: Developed by the National School Resourcing Board based on Quality Schools fact sheet: What is the Government doing to support students with disability?

There is a high degree of alignment between current loading relativities and those generated by the review of original additional resourcing analysis, which is to be expected given the current loadings were informed by the original study (see Exhibit 12). Relativities between the three funded levels of adjustment are slightly flatter in the figures from the review, reflecting slightly higher cost estimates for supplementary adjustments and slightly lower cost estimates for substantial adjustments.

While noting that separate primary and secondary relativities were not provided in the review of original additional resourcing analysis, the analysis suggests using a modified additional resourcing model (based on the original data collection) would have only a minor impact on current loading values.

2019 SRS loading relativities compared to the review of original additional resourcing analysis that informed the current settings

Source: Developed by the National School Resourcing Board based on Quality Schools fact sheet: What is the Government doing to support students with disability? and the review of original additional resourcing analysis.

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1.5 Project 2: Professional judgement using a panel of experts can help estimate costs but needs to cover a wide range of adjustments This project estimated the cost of best-practice reasonable adjustments (identified by experienced practitioners) for 24 case studies in order to compare with the current loading settings in terms of both dollar values and relativities. In doing so, it looked at:

• The range of cost estimates for reasonable best-practice adjustments at each funded level of adjustment. That is, the spread between the lowest and highest cost estimates at each funded level of adjustment. • The average cost estimates at each funded level of adjustment. That is, the sum of all cost

estimates within a level of adjustment divided by the number of case studies (eight) at each level.

Box 3: Cost estimates of best-practice reasonable adjustments based on professional judgement

The project involved:

− Developing 24 case studies (student profiles) drawn equally from the supplementary, substantial and extensive levels of adjustment and from the four broad categories of disability within each level; namely, physical, cognitive, sensory and social/emotional (Exhibit 13).

− Consulting with 39 practitioners working in schools, Systems and a range of allied health areas to agree a set of best-practice reasonable adjustments for the 24 case studies that would allow students to access and participate in education on the same basis as other students.

− Costing the adjustments by applying a set of assumptions to reflect that adjustments occur in a school and classroom setting where students participate with other students, and not in isolation. It was also necessary to recognise that teachers and other staff operate within a school timetable, sets of broader duties, and industrial awards which shape the number of available hours for classroom delivery and preparation.

A key focus of the project was identifying quality practice without reference to available resources. Whereas adjustments collected under the NCCD are actual adjustments made by schools for students with disability, the adjustments collected for this project are those that experienced practitioners and clinical experts believe should be in place.

Professor Christine (Chris) Forlin, in consultation with Mr Brian Smyth-King, led the work with practitioners to identify best-practice reasonable adjustments for the 24 case studies. Professor Matthew Gray undertook the costing of adjustments.

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Case studies used to inform Project 2: Cost estimates of best-practice reasonable adjustments based on professional judgement

Source: Developed by the National School Resourcing Board based on student profiles curated by the Australian Government Department of Education.

Project 2 cost estimates are higher than the current loading settings and reveal significant overlap between the three funded levels of adjustment

Analysis of the project data shows that adjustment activities fall broadly into four categories— planning, preparation, delivery and review. The highest cost estimates are associated with delivery as the majority of adjustments occur within the classroom environment and are delivered predominantly by a human resource, such as a teacher or education assistant.

Examination of the range of cost estimates reveals significant overlap between the three funded levels of adjustment. This reflects differences in the types of adjustments required by students and the category of disability identified as the main driver for the adjustments provided. Adjustments for cognitive disability were the most expensive, followed by physical disability, sensory disability and social/emotional disability. This is a function of the higher cost of delivering adjustments for students in these categories (that is, adjustments for cognitive and physical disability tend to involve more human resources).

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As shown in Exhibit 14, the overlap is most pronounced between the substantial and extensive levels. The degree of overlap is not dissimilar to that found in Project 1: Review of original additional resourcing analysis that informed the current settings.

Range of professional judgement cost estimates by funded adjustment level

Source: Developed by the National School Resourcing Board based on analysis of Project 2 professional judgement cost estimates data.

Examination of the average cost estimates revealed average costs greater than the current loading values (Exhibit 15). This is not surprising. While the professional judgement model is a common method for cost estimation, it can generate higher estimates because experts are encouraged to focus on designing or identifying the most effective services or adjustments rather than worry about what they cost.20

Professional judgement average cost estimates compared to the SRS loading

Source: Developed by the National School Resourcing Board based on analysis of Project 2 professional judgement cost estimates data.

It should be noted that this project was not designed as a costing model. Rather, it was a validation project to test the concept of a professional judgement approach. The project was necessarily limited by the time available to the Board and the number and diversity of case studies in the sample size. While the 24 student profiles were drawn in a representative way from across the three funded

20 Hoff, D. (2004) ‘The Bottom Line’, Education Week, Vol. 24, Issue 17, pp. 29–30, 32, 35–36.

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NCCD levels of adjustment and disability categories, they may not fully reflect the wide range of adjustments and associated costs that exist at each level.

The cost estimates arising from this project, therefore, are not rigorous enough to inform a recommendation to retain or change the current loading values for students with disability.

Project 2 funding relativities are flatter than those of the current loading

As shown in Exhibit 16, relativities generated using the professional judgement approach are flatter than the current loading relativities. This is particularly pronounced at the secondary level and is a result of higher cost estimates for supplementary adjustments relative to the cost estimates for extensive adjustments.

The higher cost estimates for supplementary adjustments may reflect the particular case studies selected for this project, noting the wide range of students included at the supplementary level of adjustment. Without a more diverse sample of case studies on which to assess costs (including greater representation across year levels and disability categories), it is difficult to be certain about the accuracy of estimated costs.

It is also unclear whether the flatter relativities are linked to the higher costs associated with cognitive and physical categories of disability, which were evenly represented across the three funded levels of adjustment within the 24 case studies.

While noting the limitations of this research project, this analysis suggests that applying the relativities generated by a professional judgement approach would have a significant impact on current loading settings, with less difference between the loading values for the three funded levels of adjustment.

2019 SRS loading relativities compared to professional judgement

Source: Developed by the National School Resourcing Board based on analysis of Project 2 professional judgement cost estimates data.

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1.6 Project 3: Targeted programs provide a useful point of comparison with the current loading settings but do not account for all System spending on students with disability.

This project examined the alignment between the per-student funding provided under State and Territory targeted programs for government schools and the current loading settings in terms of both dollar values and funding relativities.

Box 4: Comparison with arrangements used by State and Territory Systems through targeted programs for government schools Targeted programs, along with equity-based programs, are the two main programmatic approaches used by government Systems for distributing students with disability funding to government schools. Generally, targeted programs provide resources to support a subset of students with a specific form of disability and moderate to high needs, while equity-based programs use a formula to distribute funding for students with lower levels of need.21

For consistency, all State and Territory government school Systems were invited to contribute 2018 data to this project. Six responses were received:

• Four provided data on their targeted program expenditure by level and the number of students supported by those programs (by NCCD level). • One provided information on targeted program full-time equivalent (FTE) staffing allocations to support students with disability, as well as the number of students supported (by NCCD level).

The FTE information was converted into dollar figures for the purposes of this project. • One provided high-level information on targeted program expenditure but was not able to provide the numbers of students supported by NCCD level.

Publicly available information on targeted program expenditure was available for one additional System. Information on the numbers of students supported (by NCCD level) was not available.

Following consultation with the NCEC, Catholic Systems were not included in this project as they do not use targeted programs to distribute funding to their member schools.

This project was undertaken for the Board by Mr Mark Tainsh.

In contrast to the three funded NCCD levels of adjustment, State and Territory targeted programs are more graduated, containing multiple levels of funding. Among the States and Territories that provided data for this project, the number of funding levels within targeted programs ranged from six to 12. Across all programs, the amount of funding attached to each level ranged from $1,998 to $60,237.

It should be noted that the level of funding a student with disability attracts under a State or Territory targeted program does not necessarily relate to their assessed NCCD level. For example, students assessed as supplementary under the NCCD can attract the highest level of targeted program funding, while students assessed as extensive can attract lower levels of funding. In a small number of cases, students assessed as QDTP―an unfunded level of adjustment under the NCCD―attract funding under targeted programs.

The purpose and criteria for State and Territory targeted programs reflect each individual State and Territory circumstances and are designed to meet the needs of the students in their program. The

21 Tainsh, M. (to be published) A review of current government Approved System Authorities’ (ASA) arrangements for funding of students with disabilities and common reform directions: Report prepared for the National School Resourcing Board.

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focus of targeted programs is generally students with higher needs. Targeted programs are supplemented by other funding to support all students with disability.

While targeted programs do not represent a System’s entire spend on students with disability, they do provide a useful point of comparison with the current loading settings. Analysis of targeted program information also provides insight into the consistency between Australian Government funding allocations based on the NCCD and the distribution of funding under State and Territory targeted programs.

In order to compare targeted program funding with the current loading settings, the Board calculated an average per-student expenditure amount for targeted programs. Averages were calculated using two methods:

• Average per-student expenditure aligned to System distribution. That is, using State and Territory targeted program funding levels to create a per-student average at a low, mid and high funding point. These figures reflect a program’s lowest funding level, a mid funding level, and its highest funding level. • Average per-student expenditure aligned to NCCD levels of adjustment. That is, a weighted

average created by calculating the sum of program expenditure on students at each NCCD level of adjustment (regardless of their targeted program level) and dividing this by the number of students in each level of adjustment.

The alignment of targeted program expenditure with current loading settings varies depending on the method used to calculate per-student averages

Comparing these two per-student averages with the loading settings revealed that:

• targeted program expenditure aligned to System distribution is slightly higher than current loading settings, though not markedly so (Exhibit 17) • targeted program expenditure aligned to NCCD levels of adjustment is similar to current loading settings at the substantial level, but higher at the supplementary level and lower at the extensive

level (Exhibit 18).

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Average per-student expenditure aligned to System distribution

Source: Developed by the National School Resourcing Board based on analysis of data provided for Project 3: Comparison with arrangements used by State and Territory Systems through targeted programs for government schools.

Notes: Based on 2018 data from the six Systems that provided information, as well as publicly available information.

Average per-student expenditure aligned to NCCD levels of adjustment

Source: Developed by the National School Resourcing Board based on analysis of data provided for Project 3: Comparison with arrangements used by State and Territory Systems through targeted programs for government schools.

Notes: Based on 2018 data from the five Systems that provided information on the numbers of students supported by targeted programs, by NCCD level.

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Project 3 funding relativities vary depending on the method used to calculate per-student averages

As shown in Exhibit 19, when converted to relativities, the average per student expenditure aligned to System distribution (that is, the low, mid and high funding points within targeted programs) are similar to SRS loading relativities for the supplementary, substantial and extensive levels of adjustment. This is not surprising given the degree of consistency between targeted program expenditure and current loading settings.

2019 SRS loading relativities compared to average per-student expenditure relativities (aligned to System distribution)

Source: Developed by the National School Resourcing Board based on Quality Schools fact sheet: What is the Government doing to support students with disability? and analysis of data provided for Project 3: Comparison with arrangements used by State and Territory Systems through targeted programs for government schools.

When aligned to funded NCCD levels of adjustment, however, the average per-student expenditure relativities are considerably flatter than the SRS loading relativities (Exhibit 20). This is a result of higher funding at the supplementary level and significantly lower funding at the extensive level.

2019 SRS loading relativities compared to average per-student expenditure relativities (aligned to NCCD)

Source: Developed by the National School Resourcing Board based on Quality Schools fact sheet: What is the Government doing to support students with disability? and analysis of data provided for Project 3: Comparison with arrangements used by State and Territory Systems through targeted programs for government schools.

Project 3 also showed a weak alignment between the number of students included in the NCCD and the number of students funded under State and Territory targeted programs

In addition to comparing average per-student expenditure, Project 3 also identified significant differences between the way the Australian Government allocates funding for students with disability and the way Systems distribute funding through targeted programs. A comparison of students funded under targeted programs and those identified as requiring adjustment under the NCCD reveals that, on average, targeted programs fund far fewer students than those included in the NCCD (Exhibit 21).

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Proportion of the NCCD population funded under targeted programs for government schools

Source: Developed by the National School Resourcing Board based on analysis of data provided for Project 3: Comparison with arrangements used by State and Territory Systems through targeted programs for government schools.

Note Based on data from the five Systems that provided information on the numbers of students supported by targeted programs, by NCCD level.

Exhibit 21 shows that for students identified in the NCCD as requiring supplementary, substantial and extensive adjustments, an average of 10, 36 and 54 per cent respectively are funded under State and Territory targeted programs. These averages fall within a much wider range (for example, 2–35 per cent at the supplementary level, 14–71 per cent at the substantial level and 12–90 per cent at the extensive level). Notably, an average of 5 per cent of QDTP students also received funding under targeted programs (within a range of 0.5–14 per cent).

It should be noted that the lower end of these ranges is affected disproportionally by data from one System, as its targeted program does not cater for the majority of its students with higher needs. If you remove this System from the data set, the average proportion of NCCD students funded under targeted programs increases to 7 per cent for QDTP, 19 per cent for supplementary, 50 per cent for substantial and 78 per cent for extensive.

This suggests potentially stark differences between the numbers of students reported in the NCCD and those funded under State and Territory targeted programs. It also suggests significant variation in the funding provided to students at the same levels of adjustment. For example, in one System, over 200 students at the extensive level of adjustment received the lowest level of targeted program funding, while a similar number received the highest level. Additionally, one student at the QDTP level of adjustment also received the highest level of program funding.

High: 14%

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The Board is unable to determine the extent of the inconsistency, as targeted programs do not represent Systems’ total spend on students with disability. This point was emphasised in System responses to the Board’s data request, with many noting they also provide support for students with disability through:

• population-based funding • funding for special schools, classes and units • payments to schools on an application basis • regional and state-wide resources, such as coaches and advisory teachers, allied health

professionals, vision impairment services, deaf and hard of hearing services, autism hubs and assistive technology services.

The Board recognises, too, that States and Territories provide funding for students with disability in non-government schools and have generally been the majority funders of special schools, including for those in the non-government sector.

In addition, the data examined by the Board did not reflect the changes some Systems have made since 2018 to align their arrangements with the NCCD. As indicated by one System, these changes will impact significantly on the numbers of students funded and the amount of funding that a student may receive into the future.

1.7 There is insufficient evidence to determine the adequacy of current loading values for students with disability Overall, the variation in both cost estimates and relativities produced by the three research projects means the Board cannot use these projects to recommend specific changes to the current loading settings at this time.

While Project 1 and Project 3 show a degree of consistency with current loading settings in terms of dollar values, both projects have limitations which mean more complete information would be needed to provide absolute confidence in the existing settings.

Similarly, feedback received through public submissions was mixed, noting that there is some consensus that funding at the substantial and extensive levels is too low:

The current and projected funding (until 2029) for supplementary to extensive students is … sufficient to provide reasonable adjustments, in general creating more parity between students with additional needs and mainstream students. (Northern Territory Catholic Education submission, p. 1)

The current loading model does not guarantee the capacity for schools to educate students with substantial and extensive adjustments. The general response from principals is that there are inadequate levels of funding to support the personnel and physical resources required to meet the needs of students requiring higher levels of adjustment. (Australian Primary Principals Association submission, p. 1)

Some stakeholders also noted the limitations inherent in a funding allocation model based on three broad funded levels of adjustment:

… the NCCD categories are limited in accurately capturing the actual resourcing required for individual students with disability. Instead resources are allocated according to set funding amounts for each of the three categories. This is a very rigid, unresponsive method. This stepped approach to funding (with significant differences in funding between categories) may result in the allocated funding being significantly under or over

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the actual cost of adjustment needed. (New South Wales Department of Education submission, p. 4)

Others have suggested that the NCCD could be revised to include additional levels:

My recommendations to the panel are to … add additional levels ... There is a huge jump financially between each level, having greater levels and a higher top end, as well as specific required documentation for each of the levels will enable schools to effectively categorise students and link this to the reality of the support required … (Anonymous 2 submission, p. 2)

Increasing the number of funded levels within the NCCD would result in a loading that more closely mirrors the multiple levels found in government Systems’ targeted programs. While this approach is appropriate at a System level and reflects the principle of subsidiarity, it would be difficult to implement at a national level, given the granularity of data required to underpin the approach.

Finding 1.

Cost estimates vary across the research projects and there is insufficient evidence to determine whether the current loading settings are the most appropriate inputs for the Schooling Resource Standard.

In addition, all research projects a degree of overlap between the costs of adjustments at all three funded levels of adjustment, as well as significant variation in costs within each level. While this variation was present at all funded levels of adjustment, Projects 1 and 2 found it was most pronounced for students requiring substantial and extensive adjustments.

Further work is required to understand the extent of the overlap, as well as the reasons for it, in order to better differentiate between the NCCD levels of adjustment.

Finding 2.

The degree of overlap in cost estimates at all three levels, particularly the substantial and extensive levels, suggests a need for better differentiation.

While the Board’s analysis of relative funding levels across all three projects suggests the current relativities may be appropriate, conclusive evidence is not yet available. It is clear that different methods of calculating the cost of adjustments produce significantly different results.

As shown in Exhibit 22, when looking across all three projects, it shows that relativities generated using the professional judgement approach are flatter than both the current loading relativities and those produced by the review of the original additional resourcing analysis. The flattest relativities are produced by average per-student expenditure under targeted programs when aligned to the NCCD levels of adjustment.

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2019 SRS loading relativities compared to all project relativities

Source: Developed by the National School Resourcing Board based on Quality Schools fact sheet: What is the Government doing to support students with disability? and analysis of findings across all three research projects

Given these differences, further work is required to understand:

• higher supplementary cost estimates (compared to extensive) suggested by the flatter relativities produced by the professional judgement approach and targeted program expenditure • flatter relativities between substantial and extensive levels of adjustment.

The New South Wales Department of Education submission notes the potential for perverse incentives to arise from the current steep relativities that allocate funding that may be significantly less or greater than the actual cost of adjustment required:

The funding model may also lead to incentives for adjustment levels to be under or overestimated at the school level. As such, NSW would like the [Board] to consider how the NCCD categories can better align with need, and consider options to reduce the funding gaps between categories. (New South Wales Department of Education submission, p. 4)

Finding 3.

Funding relativities differ according to the method used to cost adjustments and there is insufficient evidence to determine whether the current relativities are appropriate or not.

The Board also believes the divergence between the numbers of students reported in the NCCD and those funded under targeted programs warrants further exploration, particularly given its potential to create funding anomalies. A better understanding of Systems’ funding allocations for students with disability is needed to understand the variation in funding provided to students within the same level of adjustment.

Finding 4.

Approved System Authorities’ funding allocations for students with disability from targeted programs show:

− variation in funding provided to students within the same Nationally Consistent Collection of Data on School Students with Disability levels of adjustment − divergence between the numbers of students reported in the Nationally Consistent Collection of Data on School Students with Disability and those funded under targeted

programs.

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1.8 The cost of adjustments is affected by the context in which they are made It is important to note that none of the Board’s research projects examined the effectiveness of funding for students with disability (that is, there is no link to student outcomes), or the impact of school context on the cost of providing adjustments for students with disability. Instead, the Board sought stakeholder insights on the impact of school context via its consultation processes. The majority of submissions to the review stated that the cost of adjustments is affected by the context in which they are made. Key contextual factors include:

• school location • whether a school is part of a System • the number of students with disability within a school • the stage of schooling, including key transition points.

The cost of adjustments varies by school location

Through its public submission process, the Board heard that school location has an impact on the cost of delivering adjustments. For example, schools in regional or remote locations may have limited access to the specialist support required to deliver adjustments. Accessing support from other locations increases the cost of delivery:

Regional and rural schools that are located significant distances from a regional or major city will not usually have access to the facilities and services that are often essential to support students with additional needs being able to access and participate in learning in school. Thus, costs to provide for the necessary recommendations to support complex students are incurred at local school level, and often need to incorporate travel time and associated additional expenses. (Catholic School Parents Australia submission, p. 3)

This is not unexpected. The variability of specialist support available to schools for identifying and supporting the needs of students with disability was also noted by the New South Wales Legislative Council Inquiry into education of students with disability or special needs in New South Wales.22

The cost of adjustments varies between systemic and non-systemic schools

The cost of adjustments can also be affected by whether a school is part of a System or not. Systems are able to achieve economies of scale by purchasing services centrally. For example, the Tasmanian Department of Education has centrally funded programs that provide assistance for students with disability in areas such as:

• transport assistance • minor access works and building modifications • assistive technology • provision of specialist equipment • therapy services • mediation and liaison services.23

22 New South Wales Parliament Legislative Council, Portfolio Committee No. 3 – Education, Report no. 37 (2017) Education of students with a disability or special needs in New South Wales, New South Wales Parliament Legislative Council: Sydney, p. 128.

23 Tasmanian Government Department of Education, Resourcing to Schools, viewed on 26 November 2019, https://www.education.tas.gov.au/supporting-student-need/support-students-disability/resourcing-to-schools/.

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As noted by the Independent Schools Council of Australia, this type of support is not available to non-systemic schools:

It is important to note that the situation for stand-alone schools is very different to systemic schools and may have cost implications. For example, systems benefit from economies of scale and can purchase services and manage administration on behalf of large numbers of schools. These efficiencies are not necessarily applicable to stand-alone Independent schools. (Independent Schools Council of Australia submission, p. 8)

System support can also help small schools:

… smaller schools have less capacity to reallocate other funds than larger schools. For example, a small school is more sensitive to increasing enrolment of students with disability and/or movement of existing students to a higher level of educational support. This highlights the importance of school system support and analysis of the most effective distribution of available resources. (Queensland Catholic Education Commission submission, p. 3)

The cost of adjustments varies according to the number of students with disability within a school

The number of students with disability within a school can affect the cost of adjustments, as schools with higher numbers of students with disability can meet student needs at a lower cost than schools with fewer students:

These cost differences arise because of efficiencies in staff training, in learning materials, in the use of specialised support staff and, increasingly, in the cost of systems and processes in relation to administration. (Catholic Education Commission of Victoria submission, p. 4)

Funding for students with disability should be subject to a school density factor, which recognises that the per-student cost of meeting the needs of students with disability is inversely correlated to the number of students with disability enrolled in a school. (Catholic Education Commission of Victoria submission, p. 5)

The Catholic Education Commission of Victoria also noted that schools where students have similar disabilities are also able to meet student needs at a lower cost.

While the concentration of students with disability at special schools would suggest they are able to meet student needs at a lower cost than mainstream schools, some submissions reported high costs associated with educating students in special schools.

… the cost of educating students in special schools is similar to the cost of educating students with extensive adjustments in mainstream schools, regardless of the level of adjustment provided to the students in special schools. (Independent Schools Victoria submission, p. 3)

The Australian Government Department of Education indicated the current NCCD model may not be meeting the needs of special schools or special assistance schools.

The administrative burden on staff at special and special assistance schools is greater than in mainstream schools. Related is the comparative difficulty in quantifying adjustments made for students in an environment that caters specifically to high need students. Research indicates that special schools tend to under-report students in the NCCD, despite provision of adjustments for the vast majority of their students. Meeting

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the NCCD evidentiary requirements and assurance processes can be challenging for these schools. (Australian Government Department of Education submission, p. 5)

The cost of adjustments varies by stage of schooling

Feedback varied on whether the cost of adjustments was higher in primary or secondary school settings. Some stakeholders argued that younger students are less independent and require more support. Others argued that the need for support is more intense in secondary years, where students undertake a wider range of subjects across multiple classrooms and with multiple teachers.

The current loading settings do not differentiate materially between costs in primary and secondary settings:

In the early years the ratio of adjustments and supports for the children is far higher than in the senior primary years … children are not as independent and require more support, supervision and guidance … a considerable amount of resourcing is provided in the early years, ranging from: Speech Pathologists, Psychologists and Occupational Therapists being employed in our schools to meet the ever growing needs of our children. (Independent Education Union of Australia submission, p. 5)

The cost of supporting a student in a secondary setting can be much greater than in a primary setting depending on the type of disability and the nature of the adjustments required ... For example, a student with a vision impairment will require significantly higher resourcing in their secondary years due to accessing different subject areas and teachers, where curriculum content needs to be translated into Braille. In addition, secondary students who require transfer and positioning, mobility or support for personal care may also require a higher level of adjustment due to both their physical size or as a result of increased internalising/externalising behaviours … associated with their disability. (South Australia Department for Education submission, p. 2)

A number of submissions mentioned the need for additional support at points of transition within the school journey. These include the transition from early childhood education to primary school, from primary to secondary school, from secondary to senior secondary, and from senior secondary into further education, training or work:

Transitioning to a new year level or educational juncture (i.e. to prep or secondary) can be challenging and extensive resources are required to make the transition a success. However, transitioning into secondary has specific circumstances that requires substantial planning and support, e.g. increased student movement to classrooms and managing a more complex learning environment. Consideration should be given to additional funding for students at the two key transition periods of entry to primary school and entry to secondary school. (Queensland Catholic Education Commission submission, p. 4)

Our school has noticed much more need for adjustment for students at the transitioning from primary to secondary school. There is also a greater need for adjustment as they move into senior secondary education. The supports provided by the College at these levels are far greater at these points, although not effectively changing the level of adjustment. (Anonymous 1 submission, p. 1)

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Finding 5.

Stakeholders have reported that the cost of adjustments varies according to school context and stage of schooling.

1.9 Further evidence is required to determine refinements to the loading settings The analysis and consultations undertaken by the Board suggest the current loading settings could be refined to provide a more nuanced estimate of the costs of adjustments for students with disability. In the absence of conclusive research findings, however, the Board has insufficient evidence to determine the precise nature or extent of potential changes to the settings at this time.

The Board recognises that any immediate change to the loading settings would be premature given:

• the recent changes to the funding model for students with disability • the need to develop a more robust evidence base to underpin any changes.

The Board recognises that future changes to the loading settings are likely to occur against the backdrop of broader changes arising from the findings of the Royal Commission and the review of the Disability Standards.

It will be important for any potential changes to be considered in this broader context to ensure consistency in policy aims and priorities.

Changes to the funding model for students with disability were introduced in 2018

The current funding model for students with disability has only been in place since 2018. As described in the review context, the change represents a positive evolution from previous arrangements:

The introduction of the NCCD and linking it to government funding has improved the outcomes for students. By expanding the group of students eligible for government funding, the NCCD recognises the additional needs of all students with disability, rather than just a narrow sub-set … and helps to ensure no students fall through the cracks, either through a lack of funding, or a lack of identification of their needs. Its more inclusive nature has resulted in a greater focus on curriculum differentiation and catering for the needs of individuals, while also helping to reduce stigma associated with word ‘disability’. (Independent Schools Victoria submission, p. 2)

Given the relatively early stage of implementation, the Board believes the current loading settings should remain in place while an evidence base for future change is developed. This recognises that changes arising from the new funding model are still flowing through the system. For example, since the introduction of the NCCD in 2018, some government Systems have moved to align their targeted programs with the NCCD. South Australia’s Inclusive Education Support Program has introduced nine categories of adjustments aligned to the three funded NCCD adjustment levels (essentially a low, medium and high category within each funded NCCD adjustment level). From 2020, Tasmania will also implement a new funding model aligned to the NCCD.

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Box 2: Tasmanian Educational Adjustments Disability Funding model

From 2020, the new Tasmanian Educational Adjustments Disability Funding model will deliver funding to support students with disability in Tasmanian government schools.

The model will deliver a base allocation to every school for every student eligible under NCCD categories, from supplementary to extensive. It will also provide targeted funding for graduated levels within the NCCD—three levels within extensive and two levels within substantial.

In 2019, the Educational Adjustment Descriptor Tool24 was used during the moderation process to identify the level of adjustment being provided to each student. This tool has helped school staff to define the levels between high and low in both extensive and substantial, has guided the types of educational adjustments that could be delivered and has informed goals in individual student learning plans.

The Board also recognises that potential changes will need to be assessed in terms of their impact on sectors, Systems and individual schools. This includes the interaction of the loading for students with disability with other elements of the SRS, as well as implications for the school funding transition arrangements that continue until 2029.

Finding 6.

There is insufficient evidence to determine changes to the current loading settings without further research to build the evidence base for change.

A strong evidentiary base is required to underpin future changes

Future changes to the loading settings need to be informed by a strong evidentiary base. The Board’s review suggests that the work program to develop the evidence base will need to include the following components:

• better understanding the context in which the loading operates • establishing parameters to underpin a refined costing model • refining the costing model using a mix of approaches to quantify costs (regression-based modelling, professional judgement, successful schools).

The work program should also have reference to international approaches to funding students with disability, including those in other federated states such as the United States and Canada.

In addition to the discussion below, a set of key research questions is provided at Exhibit 23 to guide the future work program.

24 Tasmanian Government Department of Education, Tasmanian Educational Adjustment Descriptor Tool, viewed on 25 November 2019, https://documentcentre.education.tas.gov.au/Documents/Education%20Adjustment%20Descriptor%20Tool%20-%20v11.pdf.

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Better understanding the context in which the loading operates

As foreshadowed in the preceding sections, the Board has identified a number of areas where further work is required to better understand the context in which the loading operates, including:

• better differentiation between all NCCD levels of adjustment, particularly the substantial and extensive levels • understanding Systems’ funding allocations for students with disability, with a particular focus on:

− the divergence between the numbers of students reported in the NCCD and those funded under targeted programs − the variation in funding provided to students within the same NCCD levels of adjustment − exploring opportunities to enhance consistency and accountability for allocation and

distribution of funding for students with disability to ensure better outcomes for students irrespective of school system.

While the Board was not asked to review the NCCD itself, the work program may also wish to consider whether the NCCD is the right mechanism for counting students with disability and whether three levels is appropriate.

Consideration could also be given to the proportion of students that should be funded under the loading, including consideration of what proportion of students should receive targeted funding versus mainstream funding to cover a range of needs.

Establishing parameters to inform a refined costing model

Evidence is also required to establish some of the parameters that will inform a refined costing model. This part of the work program should:

• define the factors affecting the cost of adjustments that should be considered in any refined costing model (building on those identified in Section 1.7) • define consistent criteria for identifying successful schools or programs (to inform a successful schools approach) • define consistent student outcome measures for students with disability (to inform

regression analysis).

The Board acknowledges the challenges inherent in a focus on student outcomes. There is currently no single agreed method for measuring outcomes for students with disability in Australia, although the Board notes that some Systems have either developed, or are working toward developing, such measures. For example, Queensland’s Every student with disability succeeding plan refers to the following measures of success:

• improving the A–E performance for students with disability • increasing the proportion of students with disability receiving a Queensland Certificate of Education • decreasing the proportion of students with disability receiving a school disciplinary absence • reducing the number of students with disability not attending a full-time program.25

The New South Wales Department of Education submission indicates it has committed to development of consistent evidence-based approaches.

25 Queensland Government Department of Education, Every student with disability succeeding, viewed on 27 November 2019, https://education.qld.gov.au/students/students-with-disability/succeeding-with-disability.

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Current areas of focus include: addressing and understanding learning growth for students with severe intellectual disability; and increasing the accessibility and inclusiveness of survey instruments that measure student wellbeing. Our future focus will include increasing the accessibility and inclusiveness of our measures of student independence. (New South Wales Department of Education submission, p. 8)

Refining the costing model using a mix of approaches to quantify costs

At a minimum, the Board believes this should include repeating the original 2015 additional resourcing analysis using an updated methodology and sample frame to address the limitations of the original study and ensure the resulting cost estimates reflect, as accurately as possible, the cost of educating students with disability. This would involve:

• increasing the number of schools surveyed (particularly special schools and those in regional and rural areas) • capping the number of responses required from individual schools to reduce incentives for schools to provide average costs • oversampling students at the extensive level of adjustment to understand the cost drivers

at that level • looking beyond in-school funding to account for centrally-funded activities and services.

The data collection and analysis should also reference the contextual factors affecting the cost of adjustments discussed in Section 1.7. The increased maturity of NCCD data would also aid a project of this type if it were to be conducted again.

The variation in dollar values and relativities produced by the Board’s research projects suggests that relying on a single method for costing adjustments may not produce the best estimate of costs.

Instead, a mix of approaches incorporating a professional judgement element, as well as a focus on student outcomes via successful schools and programs, may offer a more nuanced method for determining the cost of adjustments and the relativities between them.

The New South Wales Department of Education submission highlighted the importance of professional expertise and an outcomes focus in informing the funding model.

New South Wales believes that contemporary expertise must inform any funding approach. Specialists and experts should be engaged to bolster an evidence base of a good practice. This will provide a shared understanding of which approaches best support improved learning outcomes for students with different needs. (New South Wales Department of Education submission, p. 4)

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Key research questions

Source: Developed by the National School Resourcing Board

Finding 7.

Any further research should be undertaken using a range of approaches to quantifying the cost of schooling in order to inform an updated estimate of the cost of reasonable adjustments.

The Australian Government should retain the settings for the loading in the short term while further work is undertaken to evaluate the validity of the settings.

1.10 The work program should be implemented over a two-year period as an Education Council priority Development of the evidence base should occur over 2020 and 2021, to allow the results to be considered ahead of making changes to the loading from 2023. This would align with other changes to the SRS settings following capacity to contribute changes flowing from the new school reform agreement.

Implementing the work program will require the cooperation of State and Territory governments, as well as the non-government sector. As such, it should be an Education Council priority and included in the AESOC work plan.

It is anticipated that the Royal Commission and the progressive rollout of the NDIS will increase community expectations about the transparency of funding allocations for students with disability.

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This is likely to extend to transparency about the evidence on which government policy in this area is based. Consideration should be given to publishing the agreed work plan and, as a minimum, a summary of the research outputs. This would help stakeholders, particularly parents and school communities, to better understand the intended inputs and outcomes of funding for students with disability.

While the Board recognises the cost of implementing a rigorous work program, the quantum of funding involved and projected growth in the number of students with disability attracting the loading warrants investment in this area. Given the shared funding contribution arrangements, any changes to the settings for the students with disability loading have implications for all Australian governments. As a result, the Board considers that funding according to Education Council cost-share arrangements would be appropriate.

Consideration should also be given to governance arrangements that will best support efficient delivery of the work program. For example, it could be supported by a reference panel comprising representatives from all States and Territories, as well as the Catholic and independent sectors.

The Australian Government, in collaboration with State and Territory governments, should invest in the development of a strong evidence base (over two years) to inform a refined costing model for the students with disability loading.

This costing model should inform the settings for the loading from 2023.

The work program to develop an evidence base to inform a refined costing model should be an Education Council priority; supported by a reference panel comprising representatives from all States and Territories, and the Catholic and independent sectors.

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Part 2: Assurance of Australian Government funding for students with disability

This section examines assurance activities undertaken by the Australian Government to support the accuracy of NCCD data provided to calculate a school’s Australian Government funding allocation relating to students with disability. The Board examined the Australian Government Department of Education’s assurance processes, focusing on improving the quality and accuracy of reported NCCD data, as well as the accountability of Approved Authorities for accurate reporting. The Board focused on assurance processes targeting:

• capacity-building to support schools to improve the quality of NCCD assessment and documentation • assurance activity to verify reported NCCD documentation and monitoring of trends to identify outliers • management of non-compliance, including the use of transparency as a lever for driving

improvement. This report does not comment on Systems’ arrangements for distribution of Australian Government funding for students with disability or Systems’ arrangements to monitor the impact of Australian Government school funding.

2.1 The Australian Government has an ongoing and essential role in ensuring public confidence in schools funding arrangements The Australian Government estimated that it would contribute $1.85 billion in 2019 to the students with disability loading (as at Budget 2019–20). The size of the Australian Government investment, the increase in community expectations about how funding is used, and the nature of the funding input have determined the assurance activities conducted by the Australian Government Department of Education.

Assurance activities provide confidence to the public that Australian Government funding for schools is being spent in accordance with legislative requirements. Misappropriation of Australian Government funding is a serious issue and non-compliant behaviour and defrauding the Government of school funding damages the public’s perception of the sector, increases costs to the Australian Government and taxpayers, and has the potential to adversely impact on student outcomes26, which is contrary to its policy objectives.

It should be noted that the results of the Australian Government Department of Education’s assurance and compliance activities show that, in the main, Approved Authorities try to get it right, and where they do not, the errors are unintentional and due to lack of understanding of what is required or simple mistakes.27

26 Australian Government Department of Education, Schools Funding Assurance Framework, viewed on 29 October 2019, https://docs.education.gov.au/documents/schools-funding-assurance-framework.

27 Australian Government Department of Education, Schools Funding Assurance Framework, p. 14, viewed on 12 December 2019 October 2019, https://docs.education.gov.au/documents/schools-funding-assurance-framework.

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The Board expects that interest in how public funding to support school students with disability is calculated and distributed, and how its impact is evaluated, will increase as the Royal Commission progresses. In this context, the Board considers the interests of the Australian Government, and the Australian education system more broadly, are best served by providing the public with clarity on how Australian Government and System funding is calculated including the inputs used for these purposes.

2.2 The Australian Government Department of Education’s assurance framework for school funding is risk-based The Australian Government Department of Education is responsible for verifying the accuracy of the data it receives from schools to calculate a school’s Australian Government funding allocation and preventing the misappropriation of Australian Government funding for schools.

The Australian Government Department of Education’s assurance framework establishes a risk profile and targets activities accordingly

In September 2019, the Australian Government Department of Education published the Schools Funding Assurance Framework (the framework). The framework describes the Australian Government Department of Education’s approach to managing risk of error, non-compliance and fraud in respect of Australian Government funding for school education under the Act28, including the Australian Government’s funding allocation for students with disability. It sets out how assurance activities are practically undertaken by the Australian Government Department of Education by targeting prevention, assisting the regulated population to comply and taking action for non-compliance when required.

To target prevention, the Australian Government Department of Education undertakes a range of capability building activities, including the delivery of training, and the development and dissemination of support materials. Assurance and compliance activities include post enumeration activities that verify the accuracy of data provided through the annual school census. The Australian Government Department of Education’s capability building and compliance activities aim to move regulated entities towards making a conscious decision to comply with their obligations in respect of the funding provided to them.29

The framework sets out the risk-based approach the Australian Government Department of Education uses to carry out assurance activities. This recognises that it is not feasible to expend unlimited funds and resources to undertake assurance activities. Instead, it is more realistic to direct activities to areas where there is the potential for the greatest risk of non-compliance. The adoption of a risk-based approach addresses a key recommendation made in the 2017 Australian National Audit Office report on Monitoring the Impact of Australian Government School Funding (that the Australian Government Department of Education establish a risk-based approach to monitoring compliance).30

28 Australian Government Department of Education, Schools Funding Assurance Framework, viewed on 29 October 2019, https://docs.education.gov.au/documents/schools-funding-assurance-framework.

29 Australian Government Department of Education, Schools Funding Assurance Framework, viewed on 29 October 2019, https://docs.education.gov.au/documents/schools-funding-assurance-framework.

30 Australian National Audit Office (2017) Monitoring the Impact of Australian Government School Funding, ANAO Report No. 18 2017–18, ANAO: Canberra.

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2.3 Context and circumstance are important factors in defining potential risks There is no single right, correct or best way to conduct assurance activities in any given circumstance.31 However, in order to be effective, assurance activities need to consider the context and the circumstances in which they are operating. This allows for identification of areas of high priority and areas of high risk of non-compliance so that activities can be targeted. 32 Key contextual factors for the Australian Government Department of Education are:

• that reported NCCD data is based on teacher professional judgement • that there are differences in data governance and reporting requirements for government and non-government schools.

NCCD data is based on teacher professional judgement

The data inputs used to calculate funding allocations other than the funding allocation for students with disability are binary and are subject to reliable verification. The use of NCCD data to calculate the Australian Government’s funding allocation for students with disability is more complex.

Under the NCCD, teachers use their professional judgement based on evidence to determine the level of adjustment provided to students with disability and the broad category of disability under which the student best fits. This approach is based on the principle that teachers and school teams, in consultation with students, clinical experts and families, are best placed to judge what reasonable educational adjustments a student needs.

The management of the self-reporting nature of the NCCD data is the key risk for accurately calculating the Australian Government’s funding allocation for a school for students with disability.

NCCD data is reported to the Australian Government in different ways leading to different risk profiles

The process for collecting and reporting NCCD data is outlined in the NCCD Guidelines, which specify:

• which students Approved Authorities must include in the NCCD • the information that Approved Authorities must provide to the Australian Government Department of Education • the day by which that information must be provided.

The Board heard that the majority of schools and sectors demonstrated a significant effort to comply with NCCD reporting requirements. However, the reliance on self-reported NCCD data introduces the potential for manipulation and perverse outcomes.

Differences in data governance and NCCD reporting requirements for the government and non-government schools sectors influence the risk profile of different Systems. NCCD data is reported to the Australian Government in different ways:

• For government schools, data is collated by State and Territory governments through the Government Schools Data Submission.

31 Murphy, C. (to be published) Review of the Commonwealth Assurance Processes for Payment of the Student with Disability Loading: Report prepared for the National School Resourcing Board.

32 Murphy, C. (to be published) Review of the Commonwealth Assurance Processes for Payment of the Students with Disability Loading: Report prepared for the National School Resourcing Board.

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• For non-government schools, data is provided through the Non-Government Schools Census.33

This small difference alters risk profiles in a fundamental way. The risks associated with Australian Government funding to government schools are reduced by the nature of Australian Government and State and Territory school funding arrangements. As noted previously, State and Territory governments provide the majority of public funding to schools, which significantly reduces or removes the risk of individuals seeking personal benefit through fraud and misappropriation of the Australian Government component. State and Territory governments also undertake their own assurance and compliance procedures and have systems and controls in place.34

In contrast, reported NCCD data from the non-government sector can be provided at the level of a single school or collated by a small or large System. Depending on context, some non-government schools could have limited capacity or resourcing to overlay controls and undertake their own data assurance activities. As the Australian Government is the majority funder for non-government

schools, this presents a greater risk for the Australian Government Department of Education.

2.4 Capability building is an important component of assurance The quality of the NCCD data provided by schools has taken on a new level of significance now that it forms part of the data set used to calculate a school’s Australian Government funding allocation for students with disability. The following sections of the report will examine the assurance activities that build capacity and understanding of the NCCD process and activities that validate the accuracy of the NCCD data provided to the Australian Government Department of Education.

Improving the quality of NCCD data has been a collaborative effort by Australian governments and the non-government school sector

In undertaking this review, the Board was asked to consider the work of the JWG. Membership of the JWG comprises the Australian Government, State and Territory governments, non-government representatives (Independent Schools Council of Australia and NCEC), ACARA and the Education Council Secretariat.

The JWG provided advice and recommendations to the Education Council on the ongoing implementation of the NCCD to support the development of a high quality, reliable and robust national data collection on school students with disability. The JWG also drove and directed national activity aimed at the continual improvement of the accuracy of the NCCD and the development of processes and resources to support the identification of need, potential adjustments to meet those needs, consultation and monitoring.

Overall, the Board found that JWG facilitation of sector collaboration has contributed positively to the NCCD, with schools recognising the value of NCCD processes aiming to meet their statutory obligations and supporting students with disability.35 As a result, schools and Systems are adjusting their processes and internal systems to better align with NCCD requirements. In turn, improvements in NCCD data quality and a greater sense of collective ownership of the NCCD.

33 Collection and reporting of NCCD data is described in the NCCD Guidelines for that year and based on the Australian Education Regulation 2013.

34 Murphy, C. (to be published) Review of the Commonwealth Assurance Processes for Payment of the Student with Disability Loading: Report prepared for the National School Resourcing Board.

35 Murphy, C. (to be published) Review of the Commonwealth Assurance Processes for Payment of the Student with Disability Loading: Report prepared for the National School Resourcing Board.

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The JWG will not continue from 2020 but its role has been identified as important to future assurance activities, particularly implementation of the Australian Government Department of Education’s assurance framework.36 For this reason, regardless of the governance arrangements in place, the Board considers that further multilateral activities to improve NCCD data quality, involving all school sectors, are necessary.

Finding 8

A cross-sectoral approach has contributed positively to building Approved System Authorities and schools capacity to implement the Nationally Consistent Collection of Data on School Students with Disability.

The Australian Government Department of Education and the JWG engaged PricewaterhouseCoopers Australia (PwC) to undertake the 2015 NCCD Continuous Quality Improvement Project (2015 NCCD CQIP) and the 2016 NCCD Continuous Quality Improvement Project (2016 NCCD CQIP). Both projects involved PwC working directly with teachers and leaders to understand schools’ application of the NCCD and the processes in place to support students with disability to review the quality and consistency of data collected through the NCCD for 2015 and 2016.

The 2015 report made recommendations about the distribution of national resources to support the collection, including information about how the data will be used, development of additional case studies, feedback to schools about application of the NCCD model, and several recommendations

about staff training, particularly for the QDTP level of adjustment.

Similar to the 2015 report, the 2016 report also made recommendations about staff training (frequency and barriers to accessing training), case studies and guidance materials. It also recommended guidance for school moderation and cross school/sector moderation, increasing comparability of data between schools, re-designing NCCD professional learning website, and changes to new teacher preparation and teacher registration to meet the Australian Professional Standards for Teachers that relate to students with disability.

Capacity-building activities to improve the quality of NCCD data are ongoing

The Australian Government has allocated $20 million over four years (2017–18 to 2020–21) to strengthen and quality-assure the NCCD across all sectors.37 The funding supports activities that will improve the quality and consistency of the NCCD and ensure that teachers and schools have the knowledge and evidence required to make accurate assessments under the NCCD.

The Australian Government has been working with the JWG to develop and implement projects to achieve these objectives including:

• the development of the national online NCCD Portal, as a single authoritative source of information on the NCCD for school leaders, teachers, support staff and parents/carers • a gap analysis project to identify knowledge and training gaps in the NCCD • a Teacher Judgement project that identified factors influencing the consistency and accuracy of

teacher judgements about the level of adjustment and disability categories in the NCCD.

36 Murphy, C. (to be published) Review of the Commonwealth Assurance Processes for Payment of the Student with Disability Loading: Report prepared for the National School Resourcing Board.

37 Australian Government Department of Education, What is the Government doing to support students with disability?, viewed on 27 November 2019, https://www.education.gov.au/what-government-doing-support-students-disability.

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The Board understands that there is work ongoing to develop a set of resources to guide school staff in collecting evidence to support decisions to include students in the NCCD count. These resources will include templates to help schools document and store evidence. The Board is aware that these resources have been piloted with a number of independent and Catholic schools and will be made available on the NCCD Portal.

It is clear that while the Australian Government has provided funding to support activities that improve the quality of NCCD data, their success has been largely due to the cooperation of all sectors.

Stakeholders reported that capability building activities targeting NCCD quality are valued

The Board heard positive feedback from schools and sectors about the quality and usefulness of the training and materials developed for the NCCD.38 In particular, the online NCCD Portal was viewed extremely favourably for providing schools with access to consistent training, support and messaging, unconstrained by diversity and geographic spread:

The NCCD website is a fantastic resource to help develop and maintain consistency with identifying level of adjustment and category of disability. The training modules are also a great form of professional development, and we have mandated that each staff member at school has to complete the module that is relevant to them. (Ms Melanie Franciscus, submission, p. 1)

This sentiment was echoed by the Association of Independent Schools of South Australia:

…the NCCD portal is also now considered comprehensive and provides robust processes and materials suitable for informing decision-making at the school level. (Association of Independent Schools of South Australia submission, p. 3)

As well as the New South Wales Department of Education:

… the NCCD Portal … provides teachers and schools with consistent information on best practice, moderation and extensive case studies to improve their identification of disability adjustments. (New South Wales Department of Education submission, p. 8)

2.5 There is a need for ongoing capacity building While feedback has been positive about the work undertaken to date, stakeholders have identified areas of the NCCD data collection where further refinement is required. This includes guidance to help teachers to determine the appropriate NCCD level of adjustment and meet evidentiary requirements.

Determining the appropriate NCCD level is an ongoing challenge for some teachers

Determining the appropriate NCCD level of adjustment for students with disability was highlighted by stakeholders as an ongoing challenge for some teachers and schools. A number of submissions by schools reported difficulties in accurately assessing criteria between the three funded levels of adjustments and the wide variation in student-need represented at each level of adjustment:

…there is confusion over criteria within the definitions of the top three levels. (St John’s Regional College submission, p. 1)

38 Murphy, C. (to be published) Review of the Commonwealth Assurance Processes for Payment of the Student with Disability Loading: Report prepared for the National School Resourcing Board.

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This confusion may lead to a scenario where more students are being included in the NCCD count, and some assessed at higher levels of adjustment than is warranted. This could be compounded by the fact that evidentiary requirements are the same for students regardless of level of adjustment. For example, the fact that students assessed in the QDTP and supplementary levels have the same evidence but only supplementary-level students attract funding. This may influence decision-making.

As raised earlier, this could create perverse incentives to assess students at higher levels of adjustment to increase funding allocations under the loading. Some stakeholders noted the link to funding may encourage some schools to report students at higher levels of adjustment and not work at reducing adjustments over time.

This could have an impact on a school’s Australian Government funding allocation for students with disability and the adjustments that a student receives.

This issue was highlighted in the Australian Government Department of Education’s submission to the Board:

… research commissioned by the department shows that in cases where students present on the cusp of the levels, for example between QDTP and supplementary, there is a tendency for school staff to err towards counting a student at the higher level. On the other hand, there is no incentive for schools to accurately report scaling down adjustments when this is appropriate, with the accompanying reduction in financial support.' (Australian Government Department of Education submission, p. 5)

The Board heard about the value of more case studies developed to help teachers make difficult decisions about the NCCD level of adjustment at which a student should be reported. It also notes that there is ongoing work being undertaken by the Australian Government Department of Education to develop and publish additional case studies on the NCCD portal:

… there is an opportunity to use the NCCD platform … to develop and share 'good practice’ ... Currently, NCCD case studies focus on illustrating situations in which a student falls within a defined NCCD category of adjustment. Consideration could be given to including the outcomes of the adjustments in case studies. This would enable … a shared understanding of factors that support successful adjustments that promote optimal educational and future employment (or wellbeing outcomes). … a strengthened focus on outcomes [also] promotes accountability for Commonwealth and system investment. (New South Wales Department of Education submission, p. 8)

Imputing disability is a challenge for some stakeholders

The reporting of NCCD relies on teacher/school judgement. This is a shift from the previous arrangements based on medical diagnosis. As a result, the Board noted a reluctance among stakeholders to impute or attribute a disability to a student:

Teachers hesitancy to “Impute” a disability and lack of official diagnosis impacts on schools ability to place students on NCCD. (St John’s Regional College submission, p. 1)

This could be due to teachers not wishing to raise the issue with parents, a lack of understanding of the broader definition of disability used in NCCD (which allows disability to be imputed) and/or lack of experience or expertise in conducting such assessments. There could also be some uncertainty stemming from guidance material on the NCCD Portal related to support provided to students in the unfunded level of the NCCD, namely, QDTP. The issue of students who have experienced trauma being excluded from the NCCD, which was raised by a number of stakeholders, may be an example of the latter.

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While the review did not consider teacher judgement in the assessment of a student’s NCCD level of adjustment, teachers’ confidence when making an assessment could be affected by the training they receive prior to entering the profession. Improvements in this area could assist the quality of NCCD data.

Approaches to in-school and in-System moderation vary appropriately but further work is needed to ensure consistency across schools, sectors and states

The 2019 NCCD Guidelines strongly encourage all schools to undertake internal moderation of NCCD data well in advance of when the official data is required. The processes by which sectors undertake moderation and provide NCCD data to the Australian Government Department of Education vary. Government schools provide NCCD data to State and Territory education departments to quality-assure prior to submission to the collection. Non-government schools and Systems submit NCCD data directly to the Australian Government Department of Education, which undertakes additional quality assurance of the data.

The Board heard about the various moderation processes that operate in individual jurisdictions and Systems and the value these processes add to the NCCD data collection process.

Moderation of teacher assessments and data collection is integral to ensuring data quality. It should be an ongoing process which ensures an improvement in data and informs future practice. (New South Wales Department of Education, p. 9)

These activities vary appropriately and provide a useful means through which to understand requirements and offer a level of assurance over the quality of the data. The Board is of the view that moderation processes, both at the individual and System level, could be improved through the introduction of a national approach to moderation that allows for consistent application across sectors and jurisdictions. This would bolster efforts to ensure consistency of judgements. In this context, moderation is not a deterministic exercise, but rather refers to capability building.

Finding 9.

The Australian Government’s contribution to building capacity to administer the Nationally Consistent Collection of Data on School Students with Disability at the national and Approved System Authority level has been well received and stakeholders have called for it to continue alongside assurance and compliance efforts.

The Australian Government should continue its current level of investment in comprehensive training and development to support consistency in the collection and moderation of data under the Nationally Consistent Collection of Data on School Students with Disability until at least 2023. This should include the Australian Government taking a leadership role in a national cross-sectoral approach to moderation.

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Stakeholders have reported challenges meeting NCCD evidentiary requirements

The Board heard from a number of stakeholders that the administration of the NCCD is cumbersome, resource intensive and puts significant pressure on schools. As noted in the Australian Government Department of Education’s submission to the Board, however, there has been little change to NCCD requirements for schools in moving to the new arrangements:

… schools are not required to create new or additional evidence for the purposes of the NCCD. Evidence to support the NCCD should be drawn from classroom practice in place to meet the obligations set out in the DDA [Disability Discrimination Act (1992)]and DSE [Disability Standards for Education 2005]. (Australian Government Department of Education submission, p. 7).

Stakeholders reported that the capacity of schools to meet NCCD evidence requirements varies. For example, the Board heard that the cost of administering the NCCD could be greater for non-systemic schools, particularly independent schools and small schools in remote locations without access to system-wide support services that exist in larger jurisdictions. The Australian Government Department of Education’s submission identified the difficulty for special schools or special assistance schools in meeting the NCCD evidentiary requirements and challenges with assurance processes for these schools.

This issue, and its potential impact on funding allocations, was also raised by stakeholders in public submissions:

The government should research the extent school resources may be impacting the NCCD. Detailed student-level comparisons should be made of the NCCD submitted by highly resourced (mainstream) schools and lower-resourced schools, to establish whether, due to the NCCD methodology, students that have similar needs receive more adjustments (and therefore more SWD funding) in highly resourced schools. (Catholic Education Commission of Victoria submission, p. 5)

The Australian Government, through the Non-Government Reform Support Fund (NGRSF), is providing funding to non-government representative bodies to support the implementation of existing and new policy initiatives, including the NCCD. Non-government representative bodies are undertaking a range of capacity-building activities in schools in their sectors. For example, in 2019, approximately $50 million NGRSF funding was used to implement the NCCD, including to provide schools with professional learning in NCCD, as well as teacher release time for NCCD assessments.

It was evident to the Board through consultations and submissions that there are specific challenges for non-systemic schools in administering the NCCD. Many Systems have centralised support services to help schools implement the NCCD. This allows them to leverage efficiencies and achieve economies of scale, which is not available to non-systemic schools. It will be important to ensure that these schools are supported in their implementation of the NCCD.

The Board acknowledges that Australian Government funding for the NGRSF is due to conclude in 2022. The Australian Government has also announced the $1.2 billion Choice and Affordability Fund that aims to support non-government schools as a flexible means of driving government priorities.

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The Australian Government should ensure, in its provision of support funding through the Choice and Affordability Fund and the Non-Government Reform Support Fund, that there is ongoing support and resources to build the capacity of non-systemic schools to implement the Nationally Consistent Collection of Data on School Students with Disability.

2.6 Post enumeration is the main assurance activity undertaken by the Australian Government Department of Education Within the Australian Government Department of Education’s framework, a number of activities are undertaken to verify the accuracy of the data received from schools and prevent the misappropriation of Australian Government funding. These activities include financial auditing and checking and post enumeration activities.

Post enumeration verifies a sample of schools’ data reported through the Non-Government School Census

The Non-Government Schools Census is the method by which NCCD data is reported by non-government schools and Systems to the Australian Government. Each year, the Australian Government Department of Education undertakes a post enumeration exercise to verify the accuracy, completeness and reliability of information provided through the Non-Government Schools Census. Approximately 200 non-government schools participate in the post enumeration process each year. These schools are selected via a random sample from the population of schools. A small number of schools are targeted based on intelligence held by the Australian Government Department of Education.

It should be noted that the post enumeration exercise for non-government schools verify a range of information provided to the Australian Government within the Non-Government Schools Census. In this report, the Board has only examined post enumeration activities that relate to the NCCD information.

For the NCCD, the post enumeration exercise verifies the number of NCCD students reported by the school at the supplementary, substantial and extensive adjustment levels and a 10 per cent random sample of students reported at the QDTP level. It does this by ensuring that the school has kept the evidence required under the NCCD Guidelines. The post enumeration process does not assess the school’s decision to report a student in the NCCD, or its decision about the level of adjustment or category of disability within which students have been reported.

Box 3: Evidentiary requirements for the post enumeration process for the Non-Government Schools Census

At a minimum, records must be kept for each student reported in the NCCD demonstrating the student has been provided with an adjustment/s for a minimum period of 10 weeks of school education (excluding school holiday periods) over the 12 months preceding Census Day, to address the functional impact of a disability.

If schools are selected to be part of the post enumeration exercise, they are required to produce evidence for each student in each of the following categories:

• The student’s needs for adjustment have been identified and arise from a disability (as defined under the Disability Discrimination Act).

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• Adjustments for a minimum period of 10 weeks of school education were provided to address the student’s individual needs based on their disability. • Adjustments provided to the student were being monitored and reviewed, and consultation and collaboration with the student and/or parents and carers or associates occurred.

2.7 Stakeholders have identified areas for further refinement of the post enumeration processes for the NCCD 2018 was the first year in which NCCD data was collected as part of the Non-Government School Census. The 2019 post enumeration process (on the 2018 data) was the first time the validation of NCCD data was incorporated in the Australian Government Department of Education’s post enumeration process. Throughout the Board’s consultation, stakeholders raised a number of issues relating to the NCCD component of the post enumeration process undertaken in 2019

There is inconsistency in the application of the post enumeration processes for the NCCD

The Board heard that there is a need to continue to strengthen the post enumeration process for verifying NCCD data, including ensuring that the process is consistently applied across schools. Independent Schools Queensland reported:

In some schools, contractors reviewed available evidence for all students in the funded levels and a selection of students at the non-funded level. In other cases, evidence from only a selection of students was reviewed. In some instances, a particular type of evidence was expected even though the NCCD Guidelines do not specify that particular documents must be used and available at a post-enumeration visit. (Independent Schools Queensland submission, p. 4)

While the NCCD Guidelines specify the types of evidentiary requirement that a school must keep when reporting a student with disability, the Board heard that schools and Systems would welcome clarity on the post enumeration process and the types of information that will be requested. The National Catholic Education Commission suggested:

… QA processes could be improved by transparent and timely notification of what each process will be assessing compliance against and consistency of approach across all schools, rather than variable requests for evidence in particular formats. (National Catholic Education Commission submission, p. 4)

This view was supported by Independent Schools Queensland:

… member schools would welcome increased clarity on the type/s and extent of evidence that should be gathered and retained including how that evidence should differ according to the level of adjustment a school assigns for a student. (Independent Schools Queensland submission, p. 4)

The Australian Government Department of Education’s submission indicated that work is underway to develop guidance and templates to help schools document and store evidence for the NCCD:

… templates have been piloted with a number of independent schools to test if they are fit for purpose and useful. (Australian Government Department of Education submission, p. 6)

The Board is aware that in November 2019, the Australian Government Department of Education began notifying Approved Authorities about the post enumeration process for 2019 Non-Government Schools Census. This notification included the expected timing of post enumeration

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visits in 2020 and specific guidance about the validation of evidentiary requirements for reported students with disability.

The post enumeration process does not account for school context

The Board heard that the 2018 post enumeration process did not account for school context and that some individuals (contracted by the Australian Government Department of Education) undertaking the post enumeration did not understand the environment they were assessing. The Independent Schools Council of Australia highlighted the challenge in applying the post enumeration process to different schools:

Another concern of the sector is that while the approach to compliance taken by auditors in the post-enumeration exercise is broadly acceptable for the majority of mainstream schools, it does not take into account the particular and often challenging circumstances of schools serving highly disadvantaged communities, including special schools, special assistance schools and majority Indigenous schools. (Independent Schools Council of Australia submission, p. 12)

The Queensland Catholic Education Commission offered a suggestion for how this could be addressed. It suggested that educators could be included in the post enumeration exercise conducted by contractors who may not have received specific training in the area of inclusive education/special education. This could help the contractors understand the connections between disability, functional impact and reasonable adjustments. It could improve awareness of what is possible or reasonable in different contexts.

The Board acknowledges that improvements are underway for the 2019 post enumeration process as noted in the Australian Government Department of Education’s submission:

Future assurance activities will be cognisant of the school context and may require differentiated approaches to suit different circumstances. (Australian Government Department of Education p. 7).

The Board is also aware that the Australian Government Department of Education is undertaking work to actively improve its assurance processes for NCCD data. To inform this work, the Australian Government Department of Education commissioned PwC to undertake a project that examined the validity of 2018 NCCD data reported by selected schools and the processes within schools and Systems to support decision-making processes and assure data. The Board acknowledges that this work is important but heard that schools were sometimes confused about the intersection between the PwC project and post enumeration activities.

This was noted in the NCEC submission:

The NCEC is informed that differing approaches adopted to aid the assurance process is confusing for schools. Catholic education has noted significant differences in the post enumeration audits undertaken by contractors engaged by data and census branch and the quality assurance validation undertaken by PwC. (National Catholic Education Commission, p. 3)

The Board is of the view that if activities such as those undertaken by PwC occur in the future, the Australian Government Department of Education should consider carefully how it communicates the purpose of the activity to all schools and Systems and not just those involved in the audits.

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Finding 10.

Stakeholders have reported that the Australian Government’s post enumeration process for the Nationally Consistent Collection of Data on School Students with Disability was applied inconsistently and did not take school context into account in 2018.

Australian Government investment in post enumeration has been valuable but ongoing refinement is required

Board research has identified the importance of post enumeration and ancillary processes as continuing components of the assurance framework.39 By devoting effort to capability building activities at the front-end collection process, the post enumeration process will provide intelligence about the success of these efforts to improve data quality. Further, the existence of follow-up reviews is critical as a deterrent to fraud in this subjective, self-reporting environment. Board research also identified the need to ensure the post enumeration exercise seeks the right information. Schools need to be aware that submitted data that varies significantly from past years or comparable schools/sectors will be queried and can be checked at any time.40

The Australian Government should refine the design and delivery of the post enumeration process for assurance of the Nationally Consistent Collection of Data on School Students with Disability to ensure it is consistent and responsive to school context.

2.8 Assessing and reporting compliance outcomes NCCD data should be compared across years as the dataset matures

As the NCCD data set grows and matures it provides the Australian Government Department of Education with the opportunity to gain valuable insights and intelligence about compliance and where to direct investments to improve data through input controls. The Board supports the comparison of NCCD data from the current year to previous years to confirm data quality and/or identify variations between years or jurisdictions. This analysis and information could be used to ensure a risk-based approach to the post enumeration process. It could also inform the development of training and support materials to improve the quality of data collected.

As part of its assurance processes, the Australian Government should use data analytics to identify variations in the Nationally Consistent Collection of Data on School Students with Disability data from past years and between jurisdictions, sectors and schools.

Regulatory functions should have consequences for non-compliance

Any regulatory function should have consequences for non-compliance. The Board heard that the overwhelming majority of schools correctly report the NCCD data used to calculate a school’s funding allocation for students with disability. However, given the size and diversity of the population of

39 Murphy, C. (to be published) Review of the Commonwealth Assurance Processes for Payment of the Student with Disability Loading: Report prepared for the National School Resourcing Board.

40 Murphy, C. (to be published) Review of the Commonwealth Assurance Processes for Payment of the Student with Disability Loading: Report prepared for the National School Resourcing Board.

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schools, the Australian Government Department of Education’s assurance framework needs to cater for all outcomes.

The Act includes provisions that allow the Australian Government Education Minister to take actions if an Approved Authority, non-government representative body or State or Territory fails to comply with particular requirements. These actions can extend to the withdrawal of funding, revoking the status of the Approved Authority and, in the most serious cases, pursuing criminal changes and prosecution. These formal sanctions are a strong deterrent and should be used when warranted. The Australian Government has demonstrated that it will take serious action, when needed, to address serious breaches by schools or Systems.

That said, the Board’s considers the Australian Government Department of Education’s investment for improving NCCD data quality at the time of collection, which acts as a preventative measure for non-compliance, is in line with its commitment to a risk-based assurance framework. A continued investment in controls for input of NCCD data will help ensure students who require additional support will continue to receive it and not be penalised by the actions of those charged with the responsibility for meeting and complying with the requirements of the Act.

2.9 The Australian Government Department of Education’s process for assessing the quality and accuracy of NCCD data is sound As discussed in earlier sections, the Australian Government Department of Education’s assurance activities identify areas of risk, target activities and promote improvement. Activities of this type that consider both the context and circumstances in which they are operating, make up a better practice approach to assurance 41

The Board supports the collaborative approach that the Australian Government Department of Education and the JWG have undertaken to develop and deliver assurance activities that improve schools capabilities to administer the NCCD. These activities have been well received by stakeholders but there are calls to continue capability building and refine post enumeration. The Board considers future capability building and assurance activities should aim at improving the quality and accuracy of NCCD data.

Based on the level of investment to date and actions the Australian Government Department of Education has taken to address stakeholder feedback (including the development of additional case-studies and early communication with Approved Authorities about 2019 post enumeration), the Board is of the view that assurance processes for the NCCD are commensurate with the Australian Government’s investment in this areas of school education.

That said, the Australian Government Department of Education should continue to monitor the appropriateness and the level of investment in assurance activities to ensure continuation of this targeted approach.

41 Murphy, C. (to be published) Review of the Commonwealth Assurance Processes for Payment of the Students with Disability Loading: Report prepared for the National School Resourcing Board.

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Finding 11.

Australian Government assurance processes for determining the accuracy of data reported under the Nationally Consistent Collection of Data on School Students with Disability compare favourably with what is considered best practice.

Finding 12.

The Australian Government assurance processes are commensurate with the Australian Government’s funding contribution for students with disability.

2.10 Transparency can improve the quality of NCCD data over time In December 2012, Education Ministers agreed that NCCD reported data would be made available on My School from 2016, subject to confirmation of data quality. Currently, NCCD data is reported at the individual school level to the Australian Government. Aggregated NCCD data at the national, State and Territory, and sector level is made publicly available through the Report on Government Services and the annual National Report on Schooling in Australia.

The Board considers it is timely to enhance transparency by publishing NCCD data at the school level and making it publicly available on My School. Transparency measures drive compliance behaviour and ongoing improvement through public scrutiny. Broader Systems’ arrangements for distributing needs-based funding are not considered in this review.

In considering its position on transparency of NCCD data, the Board has been mindful of the specific conditions set out in the Privacy Act 1988 and the Australian Education Regulation 2013 about identifying people with disability and nationally agreed protocols for the publication of data on My School. It has also been mindful of views expressed by stakeholders in 2016 when the Australian Curriculum, Assessment and Reporting Authority consulted on a proposal to present data about students with disability on My School. Concerns expressed at that time went to the quality of the NCCD data. The Board believes that NCCD data quality has improved sufficiently to be used to calculate funding and is, therefore, suitable for publication.

Greater transparency would provide two clear advantages. The first is from a compliance perspective. Transparency would provide additional incentives and a control over the accuracy of information through more eyes reviewing the information42, without an additional reporting burden being introduced. It would also offer a deterrent for providing information that is inaccurate or wrong at the same time as recognising those who are doing the right thing.

Transparency could also lead to improved quality of data over time. During the review, the Board heard that concerns about accuracy and consistency in NCCD data are exacerbated by limited transparency and accountability for adjustments. It also heard that some sectors shared information on student classifications at the individual school level and used this information to compare data across schools. Those practising this approach viewed sharing as favourable as it prompted questions about outliers and changes over time.

42 Murphy, C. (to be published) Review of the Commonwealth Assurance Processes for Payment of the Student with Disability Loading: Report prepared for the National School Resourcing Board.

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The proposal to publish NCCD data at school level may attract opposition, but privacy concerns can be addressed and the benefits that would flow from transparency are significant.

The Education Council should pursue publishing school-level Nationally Consistent Collection of Data on School Students with Disability student numbers (by adjustment level) on the My School website, in line with the other Schooling Resource Standard inputs, having due regard for privacy issues.

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Appendix A—Terms of reference The Australian Government through its Quality Schools reforms is committed to Commonwealth schools funding that is needs-based, transparent and equitable so students with the same need in the same sector will attract the same level of support from the Commonwealth.

School funding under the Australian Education Act 2013 (the Act) is calculated using the Schooling Resource Standard (SRS), which is an estimate of the total public funding required by each school to meet the educational needs of its students. The SRS provides a base amount for every primary and secondary student, along with six loadings that provide extra funding for students and schools with educational disadvantage. This includes a loading to support students with disability.

Under the new arrangements, including transitional arrangements, in place from 2018, the loading for students with disability is based on the categories of educational adjustments under the Nationally Consistent Collection of Data on School Students with Disability (NCCD).

Through the loading, additional resourcing is provided for students receiving supplementary, substantial or extensive levels of educational adjustment. The amount of the loading is expressed as a percentage of the base per student amount, as set out in the table below. The Australian Government does not fund the fourth category (i.e. quality differentiated teaching practice) of adjustment under the NCCD.

Table 1: Loadings for students with disability as a percentage of the base per student amount Base (2018) Supplementary Substantial Extensive

Primary students $10,953 42% 146% 312%

Secondary students $13,764 33% 116% 248%

This targeted funding is possible with the introduction of the NCCD, which was a recommendation of the 2011 Review of Funding for Schooling, led by Mr David Gonski AC. The NCCD is based on a broad definition of disability consistent with the Disability Discrimination Act 1992 and the Disability Standards for Education 2005 (the Standards), and was initiated by Education Council in 2008.

2017 was the third year in which all schools were required to report under the national collection. To ensure the collection continues to improve, the Australian Government is investing an additional $20 million over four years to 2020-21 to support quality assurance and moderation of the NCCD across all sectors.

The loadings provided under the Act are, together with state and territory contributions, intended to give schools the resources they need to address the functional impact on student learning due to disability and deliver an inclusive education in accordance with the Standards. Together with base funding, all the loadings are provided as a single payment for the purposes of education. Approved authorities and schools are expected to use their total resources in flexible ways to meet the educational needs of all their students.

The COAG Education Council’s Joint Working Group to Provide Advice on Reform for Students with Disability (JWG) is responsible for continual improvement of the NCCD. This includes providing advice to support high quality, reliable and robust collection of data, assisting approved authorities and school teams to understand and participate in the NCCD by maintaining the NCCD Guidelines and assisting schools and systems to undertake moderation and assurance processes through the development of support resources.

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Membership of the JWG comprises the Australian Government, State and Territory governments; non-government representatives (Independent Schools Council of Australia and the National Catholic Education Commission); the Australian Curriculum assessment and Reporting Authority; and Education Council Secretariat.

The Australian Government has commissioned the National School Resourcing Board (the Board) to conduct a review of the settings of the loadings for students with disability.

Scope

The Board will consider, provide findings and make recommendations relating to the current settings for the loadings for the top three NCCD levels of adjustment, taking into consideration:

• previous research on funding for students with disability, including work commissioned for the JWG • the level of resources used to support students with disability at each level of adjustment under the NCCD • the level of funding for educational adjustment provided by approved system authorities to

member schools for students with disability under each system’s needs-based funding arrangements • any significant variations related to school setting or context. The focus of the review is primarily on the Commonwealth SRS settings for the student with disability loading. State and territory allocations will only be used to inform the assessment of Commonwealth settings for the purpose of the review.

The Board will also consider, and where appropriate provide recommendations on, Commonwealth assurance processes (having regard to the work of the JWG) undertaken to support the accuracy of information provided to calculate a school’s Commonwealth funding entitlement relating to students with disability, including the accountability of approved authorities for accurate reporting.

Any support provided under the National Disability Insurance Scheme or the provision of personal care in schools will not be examined in this review.

In providing recommendations to Government, the Board will consider the financial impact on governments of its collective recommendations and provide at least one budget neutral option for any changes to the settings for the loadings for students with disability. The Board will consider the impact of any change on schools and education authorities.

Consultation

In undertaking its review, the Board will consult with stakeholders from both the government and non-government sector, including the JWG, and invite submissions from relevant parties.

Timing

The Board will provide its final report to the Australian Government Minister for Education by December 2019.

The Minister will invite the Chair of the Board to present the final report to Education Council.

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Appendix B—Review process On 15 November 2018, the Hon Dan Tehan, Australian Government Minister for Education commissioned the terms of reference for a review of the loading for students with disability.

The Board considered the full range of experiences, ideas and insights put forward by stakeholders through the submissions and consultations. The Board released a consultation paper inviting public submissions to inform its consideration of the review from 9 July to 20 August 2019.

The Board undertook targeted face-to-face meetings with a range of students with disability stakeholders in Melbourne on 17 September 2019 and Sydney on 19 September 2019. It also met with a number of other stakeholders throughout the review, including a practitioner workshop on

30 May 2019 and two policy roundtables on 31 May 2019 and 11 November 2019.

National School Resourcing Board members

Mr Michael Chaney AO (Chair)

Emeritus Professor Denise Bradley AC (Deputy Chair)

Professor Natalie Brown

Professor Greg Craven AO

Mr William (Bill) Daniels AM

Professor Stephen Lamb

Professor Ken Smith

Dr Alison Taylor

Review Sub-committee

The Board established a Sub-committee to oversee a program of work for the review on its behalf, chaired by Professor Smith and supported by Professor Lamb and Professor Craven.

Expert Panel

The Sub-committee was supported by an Expert Panel that comprised members who possess expertise in the areas of education and students with disability policy, economic and financial modelling and students with disability system administration. The Expert Panel members were:

Professor Christine (Chris) Forlin

Professor Matthew Gray

Ms Kate Griffiths

Mr David Pattie

Mr Mark Tainsh

Ms Nicola Taylor

Ms Robyn Yates OAM

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Review Secretariat

A Secretariat from the Australian Government Department of Education supported the Board in the conduct of its business and the review process. The Secretariat operated independently of the department and reported directly to the Chair. The members of the Secretariat were:

Ms Quyen Tran, Branch Manager

Mr Liam Smyth, Director

Ms Sandra Chamberlain, Assistant Director

Ms Aysha Osborne, Assistant Director

Ms Anne Perusco, Assistant Director

Mr Damian Prendergast, Assistant Director

Ms Leah McCourt, Policy Officer

Ms Fiona Ngai, Policy Officer

Ms Paige Eriksson, Policy Officer

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Appendix C—Policy roundtables In recognition of the highly technical nature of the terms of reference of the review, the Board sought participant nominations from jurisdictions and held two policy roundtables, comprising system administrators with funding experience and principals of special schools and mainstream schools with high proportions of students with disability.

Nominated by Name Position

Government sector

Australian Government Department of Education

Ms Tanya Blight Branch Manager, School Assurance

Australian Government Department of Education

Ms Judy Bungbrakearti Director, NCCD and Census Assurance

Department of Education–New South Wales

Mr Luke Clarke Director, National Funding

Department of Education–New South Wales

Ms Louise Farrell Director, Disability, Learning and Support

Department of Education–New South Wales

Ms Lucy Lu Director, Statistics and Analysis

Department of Education–New South Wales

Mr Greg Noonan Leader, Specialist Support Services

Department of Education and Training—Victoria

Ms Sharon Barry Director, Inclusive Education

Department of Education and Training—Victoria

Mr Alan Wilson Manager, Disability and Additional Needs

Queensland Department of Education

Mr Craig Blair Director, Queensland State School

Resourcing

Queensland Department of Education

Ms Deborah Dunstone Assistant Director-General, State Schools—Disability and Inclusion

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Nominated by Name Position

Queensland Department of Education

Mr Boyd Paties Executive Director, Queensland State School Resourcing

Queensland Department of Education

Ms Carmel Ybarlucea Executive Director, State Schools— Disability and Inclusion

Department of Education—Western Australia

Ms Dene Cranwell Director, Student Support Services

Department of Education—Western Australia

Ms Alison Ramm Executive Director, Strategy, Policy and Governance

Department of Education—Western Australia

Ms Catherine Shepherd A/Assistant Executive Director, Statewide Services

Department for Education—South Australia

Mr Ian May Director, Disability Policy and Programs

Department for Education—South Australia

Ms Lynley Page Manager, Resourcing and Policy

Department for Education—South Australia

Dr Mark Witham Director, Funding

Department of Education—Tasmania Ms Lynne McDougall Director, Inclusion and Diversity Services

Department of Education—Tasmania Ms Jacqui Wilson Deputy Director, Finance and Budget Services

ACT Education Directorate

Ms Deb Efthymiades Deputy Director-General, System Policy and Reform

ACT Education Directorate

Ms Coralie McAlister Executive Branch Manager, Strategic Policy

ACT Education Directorate

Ms Kate McMahon Executive Branch Manager, Learning and Wellbeing Policy and Design

Northern Territory Department of Education

Ms Lorraine Hodgson Principal, Nemarluk School

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Nominated by Name Position

Northern Territory Department of Education

Ms Heather van Munster Director, Budget and Resource Analysis

Independent sector

Independent Schools Council of Australia Mr Nigel Bartlett Manager, Funding and Accountability, Independent Schools Victoria

Independent Schools Council of Australia Ms Colette Colman Special Adviser, Independent Schools Council of Australia

Independent Schools Council of Australia Mr Jeeves Jayatilleke Analyst, Funding and Accountability, Independent Schools Victoria

Independent Schools Council of Australia Mr David Robertson Executive Director, Independent Schools Queensland

Catholic sector

National Catholic Education Commission Ms Mary Carmody Senior Education Adviser, Inclusion and Learning Team, Catholic Education South

Australia

National Catholic Education Commission Ms Judy Connell Manager, Learning Diversity, Catholic Education Services, Melbourne

National Catholic Education Commission Ms Patrice Daly Policy Adviser

National Catholic Education Commission Ms Paula Power Coordinator, Students with Disability Team, Catholic Education Western

Australia

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Appendix D—Practitioner workshop The Board brought together 38 teacher and principal practitioners, allied health and medical practitioners and policy makers, nominated by State and Territory education departments and non-government schools peak bodies.

Name Position

Ms Wendy Attwood Principal, Cooma Public School, Department of Education—New South Wales

Ms Jo Belchamber Head of Learning Enrichment, Pacific Lutheran College, Queensland, Independent Schools Council of Australia

Ms Lina Bertolini Principal, St Helena’s Catholic Primary School, Ellenbrook, Catholic Education Western Australia

Mr Mike Bettenay West Byford Primary, Department of Education—Western Australia

Ms Marion Blaze Manager, State-wide Vision Resource Centre, Department of Education and Training–Victoria

Mr Brendon Bleakley Associate Principal, Atwell College, Department of Education—Western Australia

Mr Geoff Brind Head of Special Education Services, Albany Hills State School—Special Education Program, Queensland Department of Education

Ms Mary Carmody Senior Education Adviser, Inclusion and Learning Team, Catholic Education South Australia

Professor Suzanne Carrington

Program 2 Director: Enhancing Learning and Teaching, Autism Cooperative Research Centre, Queensland University of Technology

Mr Luke Clarke Director, National Funding, Department of Education—New South Wales

Ms Jacky Dawson Manager, School Support, Student Needs, Independent Schools Council of Australia

Ms Kyrie Douch Deputy Principal, Cranleigh School, ACT Education Directorate

Mr Steve Edmonds Principal, The Crescent School, Department of Education—New South Wales

Ms Kathryn Ferguson School Services Wellbeing Coordinator, Queanbeyan, Department of Education—New South Wales

Dr Tina Fersterer Psychologist, Ferntree Gully Paediatric Clinic, Australian Psychological Society

Ms Samantha Giles State Manager, Policy and Programs, Catholic Schools New South Wales

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Name Position

Ms Lorraine Hodgson Principal, Nemarluk School, Northern Territory Department of Education

Mr Mark Hohnke Director Statewide Services, State Schools—Disability and Inclusion, Queensland Department of Education

Ms Sharon Jackson Principal, Transition Centres, Disability Policy and Programs, Department for Education—South Australia

Ms Linda Lane Durham Road School, Department of Education—Western Australia

Ms Elizabeth Levesque Manager, Victorian Deaf Education Institute, Department of Education and Training—Victoria

Ms Sheryl MacDonald Senior Adviser NCCD, Disability Policy and Programs, Department for Education—South Australia

Dr Elizabeth (Libby) Maher Senior Education Consultant, Student Services, Independent Schools Council of Australia

Mr Ian May Director, Disability Policy and Programs, Department for Education—South Australia

Ms Lynne McDougall Director, Inclusion and Diversity Services, Department of Education— Tasmania

Ms Cathrine Montgomery Manager, Student Support, Tasmanian Catholic Education Office

Ms Lyn O’Shannessy Education Adviser Inclusion Support Services, Catholic Education Northern Territory

Ms Paula Power Coordinator, Students with Disability Team, Catholic Education Western Australia

Ms Joy Ready Catholic Education Melbourne, Senior Education Officer, Learning Diversity—Sandhurst Diocese

A/Professor Gehan Roberts Associate Director (Clinical Services), Centre for Community Child Health Royal Children’s Hospital

Mr Greg Rochford Chief Executive Officer, Neurodevelopmental and Behavioural Paediatric Society of Australasia

Ms Jean Walker ACT Education Directorate, Assistant Director/Deputy Principal, Inclusion and Engagement, Student Engagement, Service Design and Delivery

Ms Jenny Wallace Principal, Waratah Special Development School, Department of Education and Training—Victoria

Dr Kerri-Lyn Webb Medical Lead Evaluation, Health Systems and Services Research and Centre for Children’s Health Research, Queensland Health

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Name Position

Professor Katrina Williams Professor of Paediatrics, Monash University

Ms Jacqui Wilson Deputy Director, Finance and Budget Services, Department of Education— Tasmania

Ms Tina Wilson School leadership team, Kingsford Smith School, ACT Education Directorate

Ms Laura Wrigglesworth Head of Learning Support, Aitken College, Victoria, Independent Schools Council of Australia

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Appendix E—Targeted consultations The Board undertook targeted consultations with key stakeholders, largely identified through the public submission process.

List of stakeholders consulted

Australian Association of Special Education

Association of Independent Schools of the Australian Capital Territory

Australian Capital Territory Education Directorate

Australian Council of State School Organisations

Australian Government Department of Education

Australian Parents Council

Australian Special Education Principals’ Association

Catholic Education, Archdiocese of Canberra and Goulburn

Catholic School Parents Australia

Centre for Community Child Health, The Royal Children’s Hospital Melbourne

Children and Young People with Disability Australia

Department of Education–Tasmania

Department of Education and Training–Victoria

Department of Social Services

Independent Schools Council of Australia

Monash University, Faculty of Education

National Catholic Education Commission

National Independent Special Schools’ Association

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Appendix F—Public submissions The Board received 33 submissions to the discussion paper. Authors who specifically requested that their submission remain confidential are not included on this list.

Public submissions to the review

Anonymous 1

Anonymous 2

Association of Independent Schools of South Australia

Australian Council of State School Organisations

Australian Government Department of Education

Australian Primary Principals Association

Australian Special Education Principals’ Association

Catholic Education, Archdiocese of Canberra and Goulburn

Catholic Education Commission of Victoria

Catholic Education Northern Territory

Catholic School Parents Australia

Centre for Independent Studies

Christina Holly

Department for Education—South Australia

Department of Education—New South Wales

Emmaus College (Victoria)

Gina Trimble

Independent Education Union of Australia

Independent Schools Council of Australia

Independent Schools Queensland

Independent Schools Victoria

John Gardiner

Melanie Franciscus

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National Catholic Education Commission

Queensland Catholic Education Commission

St John's Regional College Dandenong (Victoria)

St Bernard's College Essendon (Victoria)

Victorian Ecumenical System of Schools

Youth Off The Streets

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Appendix G—References References

Australian Education Act 2013 (Cth) No. 67 (Austl.)

Australian Education Regulation 2013 (Cth) Select Legislative Instrument No. 195 (Austl.)

Australian Government Department of Education, 2019 NCCD guidelines, viewed on 27 November 2019, https://www.nccd.edu.au/tools/nccd-guidelines-0.

Australian Government Department of Education, Schools Funding Assurance Framework, viewed on 29 October 2019, https://docs.education.gov.au/documents/schools-funding-assurance-framework.

Australian Government Department of Education, What is the Government doing to support students with disability?, viewed on 27 November 2019, https://www.education.gov.au/what-government-doing-support-students-disability.

Australian Government Department of Education, What is the Schooling Resource Standard and how does it work?, viewed on 31 October, 2019, https://docs.education.gov.au/node/44541.

Australian Government Department of Education and Training (2015) Australian Government Initial Response to the 2015 Review of the Disability Standards for Education 2005, Australian Government Department of Education and Training: Canberra.

Australian Government Department of Education and Training, Disability Standards for Education 2005 fact sheet, viewed on 2 April 2019, https://docs.education.gov.au/system/files/doc/other/dse-fact-sheet-2-dse_0.pdf.

Australian Government Department of Education and Training, What is the Schooling Resource Standard and how does it work? Fact sheet, viewed on 2 April 2019, https://www.education.gov.au/what-schooling-resource-standard-and-how-does-it-work.

Australian National Audit Office (2017) Monitoring the Impact of Australian Government School Funding, ANAO Report No. 18 2017–18, ANAO: Canberra.

Cologon, K. (2013) Inclusion in education: towards equality for students with disability, Children with Disability Australia: Victoria.

Gonski, D., Boston, K., Greiner, K., Lawrence, C., Scales, B. & Tannock, P. (2011) Review of Funding for Schooling—Final Report, Australian Government Department of Education Employment and Workplace Relations: Canberra.

Gray, M. (to be published) Review of approaches to costing educational adjustments: Report prepared for the National School Resourcing Board.

Harr, J., Parrish, T., Chambers, J., Levin, J. & Segarra, M. (2006) Considering Special Education Adequacy in California, American Institutes for Research: Washington.

Hoff, D. (2004) ‘The Bottom Line’, Education Week, Vol. 24, Issue 17.

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References

Murphy, C. (to be published) Review of the Commonwealth Assurance Processes for Payment of the Students with Disability Loading: Report prepared for the National School Resourcing Board.

New South Wales Parliament Legislative Council, Portfolio Committee No. 3—Education, Report no. 37 (2017) Education of students with a disability or special needs in New South Wales, New South Wales Parliament Legislative Council: Sydney.

OECD (2017) The Funding of School Education: Connecting Resources and Learning, OECD Reviews of School Resources, OECD Publishing: Paris, http://dx.doi.org/10.1787/9789264276147-en.

Queensland Government Department of Education, Every student with disability succeeding, viewed on 27 November 2019, https://education.qld.gov.au/students/students-with-disability/succeeding-with-disability.

Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability, Education and Learning: Issues paper, viewed on 27 November 2019, https://disability.royalcommission.gov.au/about/Pages/Questions-and-answers.aspx.

Tainsh, M. (to be published) A review of current government Approved System Authorities’ (ASA) arrangements for funding of students with disabilities and common reform directions: Report prepared for the National School Resourcing Board.

Tasmanian Government Department of Education, Resourcing to Schools, viewed on 26 November 2019, https://www.education.tas.gov.au/supporting-student-need/support-students-disability/resourcing-to-schools/.

Tasmanian Government Department of Education, Tasmanian Educational Adjustment Descriptor Tool, viewed on 25 November 2019, https://documentcentre.education.tas.gov.au/Documents/Education%20Adjustment%20Descriptor%20Tool %20-%20v11.pdf.