The first in a three-part series on NCCD funding, educational support, and school governance.

Government funding underpins the operation of independent schools. Debates over its allocation can become heated, but the stakes rise further when that funding supports students with complex, intensive educational needs.

That is what concerns me about the growing scrutiny of NCCD funding. Behind the arguments about classifications and repayment demands sit schools making employment commitments, families seeking suitable education, and students whose participation depends on sustained support.

From the outset, I support accountability for public funding.

Schools should be able to explain and defend their claims. But I also believe the government must provide sufficient clarity for those decisions to be made with confidence.

Over the next three weeks, I will explore the tension heating up between schools and a government hell-bent on reducing their burden in this space. This first article considers the funding scrutiny and its consequences. Next week, I will examine the distinction between Extensive, Substantial, and Supplementary adjustments. The final article will turn to the boardroom: what governors should understand about the funding judgements supporting their school’s financial model.

The question connecting all three is straightforward. How do we correct unsupported claims while protecting the educational support students genuinely need?

Why NCCD funding is under scrutiny

Recent reporting in The Age has brought that question into sharp focus.

On 1 September, Alex Crowe reported that Hester Hornbrook Academy faced a $22.9 million disability funding repayment demand. The school announced staffing and program cuts while disputing the department’s assessment. Melbourne City Mission, which operates the academy, maintained that it had acted in good faith and rejected what it described as a draft determination.

The scale of the reported funding dispute deserves scrutiny. Hester Hornbrook’s most recent public financial data show that approximately 95.5% of its gross income is Commonwealth and state recurrent funding. For me, that level of public investment demands rigorous oversight of the evidence and judgements supporting funding claims.

The school disputes the department’s assessment, and that dispute must be resolved through the proper process. However, reliance on government funding alone cannot justify retaining a classification or establish the validity of a claim.

My broader concern is the effect that high-profile disputes can have on confidence in special assistance and special schools. Schools providing intensive, well-evidenced educational adjustments should be assessed on their own practices and evidence.

Boards should understand how their funding classifications are determined, how those decisions are checked, and whether expenditure commitments rest on defensible assumptions.

Public funding brings a responsibility to demonstrate that claims are justified.

What NCCD funding is intended to support

The Nationally Consistent Collection of Data on School Students with Disability records the educational adjustments schools provide because of disability. Its three funded levels inform the student-with-disability loading in school funding calculations.

The purpose is to help students participate in education on the same basis as their peers.

It’s a matter of equity, not equality. A diagnosis alone does not explain the support a student receives throughout the school day.

In my experience, intensive support can involve adapted lessons, individual assistance, regulation support, and close supervision across classrooms, transitions, and breaks. Some adjustments are readily visible. Others become apparent through the frequency and continuity of staff involvement.

The challenge is translating that daily reality into a classification that another professional can examine and understand.

There are substantial financial consequences attached to that judgment. The Department’s 2026 Schooling Resource Standard figures show full secondary disability loadings of approximately $45,086 for Extensive adjustments, $21,089 for Substantial adjustments, and $5,999 for Supplementary adjustments.

These are full SRS calculation amounts; the Commonwealth payment depends on its applicable funding share and the school’s circumstances.

The difference between $45k and $6k helps explain why classification scrutiny can quickly become an operating-model problem.

When a classification becomes a financial dependency

If a school commits expenditure on the assumption that a large proportion of students will continue to attract Extensive funding, reclassification can expose a serious gap. It doesn’t take much to realise that a repayment demand imposes a burden that schools can ill afford.

Still, the financial impact alone doesn’t tell us whether the original claim was justified. It helps to distinguish between deliberate inflation, a reasonable interpretation that was later disputed, and support that was genuinely provided but not documented clearly enough.

Those characteristics should influence how we discuss accountability.

Concerns about implementation are already public. In its July 2026 NCCD update, Independent Schools NSW identified issues being raised nationally, including interpretation of the continuous 10-week requirement, attendance arrangements, communication of changes, consistency between audit decisions, review processes, and significant repayments.

That does not establish that disputed assessments are wrong. But it does establish that questions about clarity and fairness warrant examination.

I have also heard an anecdotal account of a school recording its students at Substantial because of concern about defending Extensive classifications. I can’t independently determine whether those students met the Extensive descriptor, but their past reputations help me assess their validity.

The example nevertheless raises a question worth investigating: could fear of scrutiny encourage schools to understate support they can legitimately demonstrate?

Mainstream independent schools face this pressure too

This discussion isn’t just limited to special assistance schools (SAS) or special schools. It also affects mainstream independents.

A school supporting a small number of students with intensive needs may face staffing costs that exceed the additional funding attributable to those students. Consider an illustrative teacher’s aide position costing roughly $65,000 annually. Even the full Extensive loading would cover only part of that cost, before other adjustments are considered.

That comparison does not establish a universal funding shortfall. Base funding, other resources, and staffing arrangements also matter. Nor should we assume every Extensive student requires a dedicated full-time aide.

But it does show why a high classification is insufficient evidence that a school is making a financial gain.

Specialist settings may be able to share expertise and infrastructure across a concentrated cohort. Mainstream schools may have fewer opportunities to do so. So, both need a realistic understanding of their costs.

Accountability must reach the boardroom

For me, this brings the issue back to governance.

Boards should understand which classifications underpin their revenue, how those judgements are supported, and what happens if they change. Approving staffing or expansion without examining those assumptions may leave the school in a very delicate position.

Government has a corresponding responsibility. Guidance needs to arrive early enough to inform budgets and recruitment. Schools need consistent assessment and a meaningful opportunity to explain contested judgements.

Where intensive support becomes financially unsustainable, students may face reduced staffing and fewer available places, potentially threatening their school’s viability. Correcting claims therefore requires attention to what happens after the funding decision.

Next week, I will examine the descriptors more closely, particularly their application to mental health and social-emotional disability.

For now, I would encourage every principal and board to consider one question:

How much of our school’s financial sustainability depends on funding decisions we haven’t yet had the chance to fully examine?