Part 2 of a three-part series on NCCD funding, educational support, and school governance.

A ‘typical’ neuro-divergent/mentally disabled student (possibly an oxymoron) gets through a single school day because well-trained staff know when to intervene, when and how to adapt the lesson, and when to stay close.

Much of this work becomes so familiar that documenting and explaining it can feel trite, but we live in a compliance-driven world where schools are regularly asked to justify their NCCD classification.

For the student, this has a seemingly limited benefit on their daily support. But for the schools trying to assist them, it can be make-or-break from a financial perspective.

How do schools make NCCD funding judgments?

In the first article of this series, I explored the growing scrutiny of NCCD funding and its consequences for schools and students. This week, I want to examine the decisions behind the claims: how schools interpret the guidance, document their practice, and build confidence in their assessments.

When the support works, the need becomes harder to see

One of the most difficult situations I’ve seen is a student struggling in mainstream education, then moving to a specialist setting and, perhaps for the first time in their school journey, finally getting the support they need to thrive.

Staff tailor learning, create predictable routines, respond supportively when the student is distressed, and provide supervision to help them participate.

The family is rapt. They experience a happier child because their attendance improves and learning becomes possible again.

Understandably, parents start to believe their child might be able to return to mainstream schooling. I can appreciate that hope, but I have also seen improvement interpreted as evidence that the student is now “fixed”.

And once they’re “fixed”, there’s no longer a need to attend the setting that provides those regular, daily adjustments.

What concerns me is whether the improvement has been understood in context.

Why do we continue to hold onto the idea that students with intellectual disabilities can be “fixed”? We wouldn’t expect the same of their peers with physical disabilities. After all, no one expects a child to give up their wheelchair simply because they can get to and from school independently.

Sure, we want our children to be ‘normal’ – whatever that may be – but for many, their disabilities will track with them for their lifetime.

And without the appropriate adjustments to achieve equity in their school environments, these students will be further frustrated and may give up on their opportunity to learn. 

This is an important point for Boards and regulators to understand. A settled classroom does not show how much adaptation, supervision, and individual assistance went into making it settled.

And I wonder how clearly that work is visible within funding assessments. Can the evidence explain why a student is participating successfully, including the adjustments that continue to make that participation possible?

Progress should be recognised and support reviewed as needs change. But success alone cannot tell us which adjustments are no longer needed.

Who defines the NCCD levels of adjustment?

The authoritative starting point is the NCCD Guidelines: Effective 2026 Onward, including the descriptors in Appendix 2.

The official portal also provides clarification and supporting resources. These deserve attention alongside the Guidelines themselves, particularly where schools are considering timing, attendance, and evidence.

I’m mindful that adding further clarity to these guidelines could land me in the proverbial. For now, I’ll continue to point you to the existing government framework for determining NCCD adjustment levels. Schools should apply the framework to each individual situation, with appropriate advice to support them.

Making educational support visible

Some adjustments are easy to recognise. Others become apparent only through understanding what staff do throughout the day.

I have observed support that involves helping students regulate, adapting instruction, managing transitions, and providing close supervision across learning activities and breaks.

For example, a quiet space might be one visible part of a much wider approach. What matters is the support surrounding its use: why the student needs it, how staff assist, and how that assistance enables participation in education.

For Boards, this creates an important gap between knowing that a school supports students and understanding how that support informs its census decisions.

A staffing budget alone can’t explain that, and neither can a diagnosis or a general description of the cohort.

It’s important that leadership can explain the connection between the student’s educational barriers, the adjustments delivered, the evidence retained, and the judgment ultimately recorded.

And finding a system to achieve that, without robbing your staff of the time that should be dedicated to supporting the student, is critical.

If only regulators understood that!

Does the evidence explain the decision?

Let me provide some clarity. There is a significant difference between planning an adjustment and demonstrating what occurred.

An individual learning plan (ILP) may outline the intended support while other planning records may help explain how that support was delivered, reviewed, or changed. The question is whether the school’s evidence, considered together, supports its decision.

The Department’s official clarification on evidentiary requirements states that no additional evidentiary obligations have been introduced for the 2026 NCCD. Schools must continue to retain appropriate and sufficient records aligned with the support reported.

But what is that evidentiary requirement?

The guidelines state, “…schools must continue to keep appropriate and sufficient records that meet NCCD requirements. This includes evidence of supports delivered, aligned with both the frequency and intensity of the level of adjustment reported.”

Governors need assurance that their processes work. That does not require an examination of individual students’ sensitive records, but it does require an understanding of how leadership checks that its census decisions are supported.

The assumptions worth challenging

I would encourage school leaders to examine these assumptions:

• Diagnosis determines the level. The assessment should clearly reflect the educational adjustments provided to the individual student.
• Last year’s classification still fits. Classifications need to be reviewed against current evidence, including any changes in the support provided.
• A whole-school approach explains individual support. Records should make each student’s experience of that support visible. The brush-stroke approach, while certainly simpler, cannot be applied to every student.
• Attendance difficulties establish the adjustment level. The assessment should distinguish attendance concerns from the disability-related adjustments provided. This is an important point, as students with disabilities may have additional reasons for absences that should be considered.
• Small classes or staffing ratios tell the story. Schools should be able to explain how those arrangements translate into assistance for each student. Schools should not expect classroom teacher-student ratios of 1:20 to fall within the Extensive band.
• Support is consistent throughout the day. Variations in its frequency and intensity, and the reasons for them, should be understood and recorded.
• Greater independence means less support is needed. Improved independence may reflect the effectiveness of ongoing adjustments, so progress needs to be considered alongside the support enabling it. Students heading off to the local shops during the lunch break, unsupervised, do not support the argument for ongoing adjustments.

These prompts should take schools back to the official guidance, professional moderation, and authoritative advice where uncertainty remains.

Government must provide goalposts schools can trust

Rightly, there’s an expectation schools need to defend their funding decisions, but society also expects the government to provide criteria clear enough to make those decisions with confidence.

Schools commit to staff, programs, and student places well before a government auditor arrives. And this is one of the significant pain points for school leaders. How do you plan when an audit is unlikely to take place until 6 months after the census submission?

They need to understand the requirements when they make those commitments—and know that the same interpretation will apply when their evidence is assessed.

Broad criteria leave room for subjective judgment by regulators, so they must also allow schools to defend that judgment. If an assessor reaches a different conclusion, the school deserves a clear explanation grounded in guidance available at the time.

Calling an explanation a “clarification” does not settle whether it changes what schools were reasonably expected to understand or demonstrate. Government should be able to identify what was clarified, when it was communicated, and how it affects earlier decisions.

The sector’s concerns are substantive. In its July 2026 update, Independent Schools NSW identified issues involving attendance, communication, consistency between audit decisions, review processes, and significant repayments.

I find it difficult to reconcile demands for certainty in schools’ evidence with uncertainty about how that evidence will be interpreted.

Government needs to publish clear, dated guidance, explain material changes before schools make budget and recruitment decisions, and demonstrate consistency across assessments. Schools also need a meaningful review process through which defensible professional judgment receives fair consideration.

Where an interpretation is contested, a lower funding outcome should not become the default simply because it reduces public expenditure. The purpose of scrutiny must remain accurate assessment and appropriate educational support.

Confidence requires a process

Anecdotally, I have heard accounts of schools becoming more cautious about classifications because they fear scrutiny. Such accounts do not establish what the correct classifications should have been.

Yet they do raise a question: are decisions being driven by evidence, or by anxiety about what an assessor might accept? Neither anticipated revenue nor fear of reputational damage provides a sound basis for classification.

I’d like schools to build confidence through review, moderation, and clear documentation of their reasoning. If any uncertainty remains, leaders can seek guidance from the responsible authority or sector body and keep a record of the response that informs their decision.

The official NCCD FAQ confirms that further School Funding Integrity changes remain under development for future years. Schools therefore need a reliable way to monitor guidance as it evolves.

For me, the immediate challenge is ensuring that the school’s evidence clearly supports the judgment exercised by its leadership.

Next week, I will take that question into the Boardroom and examine how governors can understand the financial exposure beneath those decisions.

Before then, I would encourage one conversation between your Board and leadership team:

What gives us confidence that our census decisions accurately reflect the educational support we provide - and that we can demonstrate it?