The Nationally Consistent Collection of Data for Students with Disability

Managing workloads

Almost two years on, the introduction of a new system to calculate students with disability loading has had a significant impact on how schools receive funding – and on the expectations, judgement and workload of teachers and principals.

In effect since 1 January 2018, the Nationally Consistent Collection of Data for Students with Disability (NCCD) model should, in theory, provide for heightened effectiveness in targeting funding required to implement adjustments in educational provision for students with disability. However, part of this heightened effectiveness must be the appropriate support and resourcing of staff involved in all aspects:

  • the identification of adjustments
  • the implementation of adjustments, including planning of PLPs and other curriculum adjustments, teaching and LSO support work, recording, assessment and reporting, and preparation and participation in Program Support Groups (PSG)
  • the undertaking of internal NCCD moderation processes to ensure consistency of decision making
  • the collection and entry of NCCD data required, including recording of evidence of adjustments, and
  • any NCCD audit process the school may be required to go through.

The NCCD model requires schools to:

Step 1:Determine which students are receiving adjustments to access education because of disability, consistent with definitions and obligations under the Disability Discrimination Act 1992 (DDA) and Disability Standards for Education 2005 (the Standards).

Step 2: Determine which of the four levels of adjustment is being provided to each of these students (QDTP – within ordinary range of differentiation, Supplementary, Substantial, Extensive) and identify and collate evidence to support the decisions made.

Step 3:Determine the broad category of disability under which each student best fits and identify and collate evidence to support the decisions.

Step 4: Record and submit the data.

Audit requirements

The processes and procedures used to identify and document the level of adjustment provided for each student with a disability can be audited by the Federal Government. For a student to be included in the NCCD, the school must have evidence of adjustments provided to meet ongoing, long term specific needs associated with disability that have a functional impact on the student’s schooling. Evidence and any associated records for the NCCD must be kept for a minimum of seven years. Schools will need to develop processes to record, store and maintain evidence and allocate sufficient time and staffing to this.

Managing workload checklist

Opposite is a checklist that may be useful for individual IEU members and IEU subbranches/chapters to use in identifying the key workload drivers associated with the NCCD and the measures needed to manage the workload of individuals and ensure reasonable and equitable workloads across staff.

In many Catholic system and independent school industrial agreements, there are clauses relating to various aspects of workloads, including clauses on consultation on workload matters.

In some agreements consultative committees are established and have a role in recommending workload management processes. Even with these agreement clauses, the key is to make them work effectively in managing workloads and reducing stress.

It is important that workload management is a central resourcing consideration of systems and schools, not only when new and additional directives and initiatives are being implemented, but in an ongoing basis in respect to teachers’ overall workloads, as well as in specific times of high workload activity. Time is the chief answer. Time to do one’s job! Adequate staffing levels are key, as is adequate additional resourcing in high need periods.

NCCD Workload Checklist Tool

This tool can be used for both individual teacher workload analysis and overall picture of a school’s NCCD teacher workload.

NCCD Individual Teacher Workload Activity/DriverNumbers/ HoursWorkload Management– additional release time, reduced class size, LSO (TA)hours, other admin support etcNumber of students identified for NCCDNumber of students at the four Levels of Adjustment:– QDTP – Supplementary– Substantial– ExtensiveNumber of students with PLPsNumber of other students requiring specific intervention strategiesNumber of meetings associated with NCCD identification and moderation (planning/ attendance)Number of program support group (PSG) meetings (planning/attendance)Targeted assessment and recording/reporting activityData/evidence entryLeadership/co-ordination activity (including if holding POL)Other

What are our teachers saying?

Jane Wenlock – levels of adjustment

I believe that the NCCD is a very positive funding program for Catholic and independent schools. Under this funding model, students who require adjustments to their program and meet the definition of a disability under the Disability Discrimination Act 1992, are attracting funding for the adjustments that are being provided to them.

In practice though, there have been a number of issues surrounding the NCCD. Two significant concerns are the level of adjustment schools are identifying students at, and the imputing of a disability - an ‘imputed’ disability is something that someone, (the teacher) believes the student has.

The interpretation of the appropriate level of adjustment is inevitably school specific. Teachers generally pitch their initial starting point of their lesson to the middle band of their classes. Yet as educators we know that the middle band is not identical between schools.

Teachers in school A may start their lessons already with a greater level of adjustment than a teacher in school B. Teachers from the first school may only provide evidence for the NCCD for those students who need the extra adjustments, rather than the adjustments that are provided to all students who fit the criteria.

Due to this, schools may be missing out on counting some students for the NCCD, as their starting point for the norm is lower than that of other schools.

Another issue is in respect to teachers imputing a disability. Within the NCCD guidelines, teachers are able to impute that a child has a disability using their own analysis of data. When using the word ‘disability’, teachers need to have a clear understanding of what this is and how this is measured. This is a change for teachers who have relied, in the past, on other health or specialist education professionals to diagnose a disability. Teachers need to have considerable professional development to advance their understanding within this area, as do preservice teachers within their university courses.

For teachers, the impact of the NCCD is the significant time that is required to administer the extra recording, noting and inputting of various forms of additional data to justify the stated needs of these students. Ensuring there is accountability documentation requires time and effort from teachers, which adds to an ever-increasing workload.

Teachers need to be trusted, as professionals who develop strong knowledge of a students’ learning and ability. We know when to adjust our teaching to meet the needs of the individual student/s in front of us. This is what needs to be championed through the NCCD. Procedures need to be developed that meet the needs of the school’s community, so that teachers and parents work collectively to the benefit of the child, without increasing the teachers’ workload and taking valuable time away from what is our core business – teaching.

Jane Wenlock teaches at Kolbe Catholic College Melbourne

Angela McDonald – evidence gathering, reporting and data entry

Each school, system and diocese has been in the process of developing protocols around the identification and collection of evidence for NCCD. Teachers have been required to document a minimum of 10 weeks of evidence to support the level of adjustment given to the student.

Evidence needs to be collected to support the assessed needs, the adjustments made, the monitoring and consultation.

Evidence includes but is not limited to adjustments or supports required in assessment settings, documented adjustments to learning materials, adjustments to teaching (program, weekly or term planning), record of social emotional interventions, documentation of environmental adjustments, specific resources developed to support individualised learning, transition visit records, personalised organisational devices, Personal Care/Health Plans, Positive Behaviour Support Plan, Risk Assessment Plans, additional supervision requirements, adjusted timetables (student/ teacher), therapy or disability specific programs, records of meetings to plan for adjustments with specialist staff, records of advice sought, and conversations with the student or parent, guardian or carer, specialist training for students/staff.

This collection of evidence requires a substantial amount of work from the classroom support assistants, classroom teachers, learning support teachers, leadership teams and includes liaison with other specialist staff. Ultimately though, the burden of evidence is placed upon the classroom teacher.

It is an extensive administrative load. The leadership teams and learning support teachers are required to finalise the levels of adjustments and ensure there is adequate evidence to substantiate the level of adjustment given. This requires many additional collaborative meetings. All teachers, but especially early career teachers, need support and time to manage and navigate the NCCD processes.

Schools are grappling with issues such as:

  • Where to store the evidence?
  • What can be done to streamline evidence collection?
  • Who can collect the evidence?
  • How much is enough evidence?
  • What level of detail is required?
  • How can schools manage the increased workloads?
  • What training and ongoing support is needed?

Differences of opinions over the level of adjustments occur, despite guidelines. Schools need to crosscheck the information from Personalised Plans and across other documentation to ensure it is aligned and validates the level of adjustment given.

The complexities of navigating NCCD are compounded by the uniqueness of the students involved and the nuances that each school and system bring to the process.

Angela McDonald teaches at St Thomas Aquinas Primary School in ACT.

...surely one of the most exciting initiatives to further the cause for diversity and inclusion within Australian schools..

Annette Campbell – time, time, time!

The NCCD is surely one of the most exciting initiatives to further the cause for diversity and inclusion within Australian schools.

The collection is having a positive impact on support for students with disability in myriad ways.

Disability is now high on the agenda, and schools are working hard to embed their obligations under the Disability Standards for Education into practice.

Education providers everywhere are evaluating their learning and support systems and processes to ensure quality teaching for all students is their main priority.

Indeed, the NCCD may, perhaps, be considered the long overdue catalyst for reform in Australian schools, breaking the industrialised mould of the ‘one size fits all’ model of curriculum delivery and instead propelling teachers to meet students where they are at in their learning, to cater for individual needs through bespoke differentiation and the design of respectful learning tasks.

So, at long last, the landscape for inclusion of students with disability seems brighter.

The government has seen fit to fund students with disability in a logical and needs based way rather than through the highly restrictive diagnostic eligibility criteria of disability seen in the past.

These changes bode well for the many (approximately 18%) of students with disability in our schools who require some form of adjustments to access learning.

Who, though, is not faring so well in this new paradigm of educational modernisation? You guessed it – the classroom teacher.

The NCCD brings with it high accountability and increased transparency.

The NCCD is not optional; it is a mandatory, ongoing exercise whereby the general classroom teacher has an essential role in collating and recording the adjustments they are providing for individual students as part of their teaching practice.

In essence, the NCCD obliges teachers to document their own teaching practice in an evidentiary way.

Teachers must make visible the work that they undertake with students with disability.

Each school has its own NCCD record keeping format with which teachers are expected to comply and the school day now sees teachers not simply planning, preparing and delivering their lessons, and correcting and marking student work – as has been the norm for teachers for time immortal – but also gathering multiple examples of adjustments, provided to multiple students (around 18% of the class), and uploading such evidence for compliance purposes.

Work samples, unit or weekly planning, behaviour information, testing data, adjusted worksheets, alternative format tasks, modified homework, scaffolds, visual supports, file notes, checklists, observations, emails, meeting notes, phone call notes – the collection and upload of these masses of evidence now forms part of a teacher’s expected daily practice.

And, while best practice sees the evidence collection as being embedded in normal school routines, the increase in the administrative demands that the NCCD brings to the role of a teacher cannot be refuted.

There is growing feeling among many teachers that the additional workload that the NCCD brings, on top of all that teachers already do within their roles, now makes the job unmanageable.

While maintaining an evidence base is a requirement of the NCCD, teachers simply ask for one thing to assist them to carry out their duties professionally and proficiently: time.

Annette Campbell is Head of Faculty, Exceptional Learners, St Patrick’s College Shorncliffe Queensland.

Compiled by Cathy Hickey, Assistant Secretary, IEU Victoria Tasmania Branch.