The National consistent collection of data (NCCD) relates to school students with disabilities who need adjustments to receive the same learning and opportunities as their peers. Schools are eligible for this type of assistance in the form of funds if they are eligible. Eligibility is strict and comes in the form of evidence. School leaders, teachers and guardians all have the responsibility in collating relevant evidence and data to show that a student needs substantial adjustments to their learning and a possible demonstration of that. However, when school’s fail to compile adequate evidence they will experience major drawbacks.
Whilst NCCD is an assistance scheme to help students, it also shifts a huge focus on compliance and best practice. If schools do not integrate compliance practices daily, they may be faced with extreme consequences and can even be asked to pay back the already received and spent funds.
Therefore, it takes a huge team and amount of effort and consideration to go through the NCCD process, funding and evaluation. Hence why many schools struggle and may be unmotivated in applying for NCCD funds which can push back any learning opportunities to those students in need, creating a barrier in their education.
Compliance responsibilities of school leaders
Each year schools must follow an NCCD process.
- Identify which students are receiving adjustments under the DDA.
- Determine whether adjustments are quality differentiated teaching practice, supplementary, substantial or extensive.
- Record the category of disability whether its cognitive, sensory, physical, social or emotional.
- Document and verify the evidence and submit.
Every student included in the NCCD must be backed by contemporaneous evidence. This means it must include records showing the time adjustments were made and demonstrations of this adjustment. Data must be collected, centralised and stored and accessed securely for a minimum of 7 years.
School leaders are prompted to take accountability and responsibility of the strength of evidence provided and ensure that everything submitted is valid and follows the standards of NCCD.
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Consequences of audit failure
Audit failures are more common than schools think. At the end of the day NCCD audits are to measure compliance processes and not educational reviews. A common misconception is that there is leniency in enforcement; however, this is not the case, and many schools face serious consequences.
First and foremost are the financial consequences. If a school fails to substantiate its NCCD claims, the government will have the authority to require a repayment of that funding, even if it was received and spent already. This isn’t just a temporary financial drawback, this can impact staff positions being cut, programs and services relied on parents being cancelled and funds may need to be diverted from other areas of operations.
As well schools will face reputational damage. Questions may arise from school councils, parents and carers, staff and system sector authorities who may have lost confidence in the leadership process or may place school under closer scrutiny. Schools should not neglect the legal consequences. Failure to adhere to legislation may result in further investigation. Additionally, the school may be flagged as having lacked effective risk control and compliance processes which is not good image for stakeholders.
To add to the pile of consequences, school’s often overlook the workload burden and stress, and burnout associated with collating NCCD data and evidence.
What should you do?
Leaders need to start prioritising compliance practices as well as provide adequate systems, training and support to alleviate the burden pushed on already overworked staff.
The first step to change is to acknowledge the faults within their systems and teams. Without this exposure, institutions fail to see what needs to be amended and will not be prepared for an NCCD audit. Every leadership team should ask themselves a range of evidence, financial, staff and governance-based questions to test whether they are truly ready and capable for receiving funding. Questions include, could you produce contemporaneous evidence from 3-5 years ago for every student under the NCCD, do we know the exact dollar value of disability funding linked to our NCCD submission and are our staff confident in their own records or anxious about potential scrutiny. These are just a few questions that will help set your school on to the right path.
Simultaneously, leaders will need to prepare their team and themselves to ensure that everyone is on the same page. This includes leadership ownership, compliance training, centralised evidence systems, internal audits and governance reporting. By taking these steps, institutions are building audit resilience to prevent the devastating consequences.
Conclusion
The real risk of the NCCD process is lack of documentation. Verbal assurances and random notes are equivalent to weak evidence and do not withstand scrutiny. This is what leads schools to major drawbacks and risks. The stresses and risks of these audits can place a burden on current staff leading to overwork, unnecessary stress and reputational damage.
It’s time to make a change now and start preparing before the audit notice arrives. To stay ahead schools must embed audit readiness into everyday practice, treat evidence seriously, invest in training and systems, conduct regular internal audits and take responsibility.
Step up as a leader, embrace the challenges and achieve audit readiness.
