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Include parent and student feedback in NCCD accountability measures

Recent accountability changes are good, but our input as recipients is critical information

For many neurodivergent learners, their needs are considered significant enough to receive what the system calls Disability Funding. This is provided by the Federal Government and delivered to state education bodies — public, Catholic and Independent schools.

The NSW Department of Education defines disability under the broad, functional umbrella of whether a condition requires reasonable adjustments for the student to access and participate in education on the same basis as their peers. A formal medical diagnosis is not always required; a student's needs can be "imputed" by the school based on observations and functional impact.

The Nationally Consistent Collection of Data on School Students with Disability (NCCD) determines how disability support funding is allocated to Australian schools. Schools self-report the level of adjustment they are providing to students with disability — and the funding they receive is based on that self-reporting.

The NCCD framework already requires schools to hold evidence that supports are needed and have been provided — including evidence of consultation with parents and carers — and the Australian Government has begun recovering funding from schools that cannot substantiate their claims. We believe this focus on accountability is positive — but it does not go far enough. Auditors assess a school's own documentation; nothing requires independent evidence from parents or students. We call for systems that enable parents and students to confirm or refute the following:

• meaningful consultation has occurred
• that supports have been consultatively reviewed and adjusted in a meaningful and consistent way

We believe both parent and student voice must be included in any audit review.

“National data does not reflect rates of enrolment refusal, shortened school days, modified timetables, withdrawal from activities, or informal exclusions – even though this is commonly reported by families and highlighted in CYDA and Disability Royal Commission evidence.”

When All Else Fails, Funding Follows the Child — to Home-School or Distance Education

What happens to disability funding when the system has failed a child and they can no longer attend?

A parent choosing to home-school or enrol their child in distance education is, in almost every case, a last resort — not a lifestyle choice. It happens when the school environment has proved unable to meet their child's needs: through ongoing inability to provide supports, through a student being unable to cope psychologically in the school environment, or sometimes through a system that has effectively pushed them out.

Their child still has a right to an education. The need has not gone away. But at the moment, when a family makes this call, the disability funding stops — and all responsibility transfers to the parents, with no resources to meet it. Parents are left to pick up the pieces the system dropped, entirely at their own expense.

We believe that when a student moves to distance education or home schooling as a direct result of the school system's inability to meet their needs, the disability funding should follow them to the parent. Eligibility criteria are entirely workable — both parents and schools will have documentation that could support an application.

“There is strong evidence that students with disabilities, additional learning needs or specific learning disabilities are more likely to be absent than those without.”

Increase in Both Knowledge and Capability of Teachers & Principals About Supporting Neurodivergent Learners

Supporting neurodivergent learners is not the responsibility of one person. It requires shared knowledge, accountability, and a commitment to continuous improvement at every level.

Schools are environments, not just classrooms. Neurodivergent learners need whole-of-school support — across the physical environment, the social environment, where executive functioning skills are needed, through transitions, in learning and assessment activities, in sport, assemblies, carnivals and more. It takes a whole-of-school approach to providing this.

“Parents overwhelmingly (95%) thought teachers and key staff needed professional development and training to better understand and support students with ADHD.”

“Only around one in three families believed teachers and support staff had adequate training to support their child (35%).”

Part 1

Substantive Neurodivergence Learning in Teacher Training

Most Australian teachers enter classrooms with little to no formal training in neurodivergence. What exists is often optional, surface-level, or focused on a single condition rather than the spectrum of neurodivergent learning profiles a teacher will encounter across their career. A child's experience of school should not depend on whether they happen to be assigned to a teacher who sought out this knowledge on their own initiative. We are calling for a substantive, mandatory increase in neurodivergence learning within initial teacher education programs.

Part 2

Mandatory, Annual Professional Development — Individual and Whole of School

Initial training is not enough. Knowledge about neurodivergence is evolving, and the needs within any school community change year to year. We are calling for mandatory annual professional development on supporting neurodivergent learners — required at the individual teacher level and at the whole-of-school level. And it has to be substantial: not a one-off box to tick, and not a policy that merely makes training available, but robust, sustained learning that actually changes classroom practice.

Part 3

Whole of School Continuous Improvement Reporting

Individual effort is not the same as systemic improvement. We are calling for whole-of-school continuous improvement reporting requirements that make each school accountable for how it is progressing in its ability to support neurodivergent learners — not just whether policies exist, but whether outcomes are improving.

An Independent Complaints Body

Create a complaints pathway with real investigatory power and real consequences

In NSW, a parent can currently turn to the Human Rights Commission, Anti-Discrimination NSW, or the NSW Ombudsman — the last of which covers public schools only, and only in relation to how a complaint is managed, not the substance of the complaint itself. There are also dedicated offices for children and young people — the NSW Advocate for Children and Young People and, nationally, the Children's Commissioner — but by design these are systemic advocates. Their statutory role is to speak up on children's issues in general; they are directed to focus on systemic matters and refer individual concerns elsewhere, not to take, investigate or resolve one family's dispute with a school.

None of these bodies combine what a family in dispute actually needs: expertise in neurodivergence and education, the authority to investigate the substance of the decision, and the power to compel a school to change. The children's commissioners are limited to systemic advocacy; the discrimination bodies can only conciliate a complaint that can be framed as discrimination; and the Ombudsman can look at process, not the appropriateness of the support. We believe the situation is similar across all Australian jurisdictions.

This is not only our view. When the NSW Auditor-General examined the Department of Education's complaint handling in 2024, it found that students with disability and their families “may be reluctant to make complaints about their school, to their principal, perceiving a conflict of interest and risk of negative consequences,” and that the Department “does not have oversight of the number, type or trends in complaints arising at the school level.” The same audit pointed to the Disability Royal Commission's call for complaints handling that operates “at arm's length from schools” — a recommendation all governments accepted in principle in July 2024. The audit also directed the Department to enhance its support to families to resolve conflicting views “in a timely manner,” and set January 2026 as the date for delivery; six months past that deadline, families still have no independent avenue. (NSW Auditor-General, Supporting students with disability, 2024)

The consequence is that families who have the persistence, the knowledge, and the resources to navigate a complex and discouraging system might eventually get somewhere. Families who don't — and they are the majority — absorb it quietly, because there is nowhere else to go. What would change this is an independent complaints function with genuine independence, investigatory authority, and the power to mandate outcomes. Whether that is a brand-new body or an existing office given the mandate and powers matters far less than the powers themselves — expertise in neurodivergence and education can be built or brought in; the authority to investigate and to compel change is the part that has to be legislated.

“Complaints are useless as education department does not follow them up. There is no accountability by schools or teachers who are breaking disability discrimination law.”