Reasonable Adjustments Under the Disability Standards for Education 2005

What the Disability Standards for Education 2005 actually require

The Disability Standards for Education 2005 (the Standards) sit underneath the Disability Discrimination Act 1992 (DDA) and translate that anti-discrimination law into concrete obligations for schools. They cover enrolment, participation, curriculum, student support services, and the elimination of harassment and victimisation. Across all of these, two ideas do most of the work: reasonable adjustments and the same basis as peers test.

For Disability Inclusion Coordinators and Learning Support Coordinators, the Standards are not abstract compliance. They are the legal backbone of everything your student-support team does day to day — and they are the same obligation the Nationally Consistent Collection of Data on School Students with Disability (NCCD) asks you to record. The NCCD does not create new duties; it asks you to evidence the ones the DDA and Standards already impose.

What is a "reasonable adjustment"?

A reasonable adjustment is a measure or action — or a group of measures — taken to help a student with disability participate in education on the same basis as a student without disability. That phrase, *on the same basis as peers*, is the heart of it. The goal is not to lower expectations or give an advantage; it is to remove the barrier that the student's disability creates so they can show what they know and take part in school life like everyone else.

Adjustments can be small or significant, and they live in the everyday business of teaching as much as in formal plans. The NCCD frames them across five areas of personalised learning and support:

• Curriculum, teaching and learning — modified tasks, scaffolds, extra time, alternative formats.
• Communication — visual supports, communication devices, simplified instructions.
• Participation — building social competence and ensuring safety in group and unstructured settings.
• Health and personal care — toileting support, medication management, care plans.
• Movement and mobility — physical access, equipment, assisted movement around the school.

What makes an adjustment "reasonable" is a balancing exercise: it weighs the student's interests, the effect on the student and on others, the costs and benefits, and the impact on the school. There is no fixed list — reasonableness is judged in context.

A critical clarification reinforced in current guidance: an adjustment must address the functional impact of the student's disability — not academic gaps on their own, not behaviour as such, not attendance, and not difficult home circumstances. If you cannot trace the adjustment back to how the disability affects functioning, it is not a reasonable adjustment under the Standards, and it should not be recorded as one in the NCCD.

The consult-then-adjust obligation

The Standards do not just require adjustments — they require consultation about adjustments, and the sequence matters. You consult, *then* you adjust.

Consultation means genuine discussion with the student's parents or carers (and with the student themselves where appropriate and possible) about the impact of disability and the adjustments that will help. It is a conversation, not a notification. It should happen before an adjustment is put in place, and it should continue as part of an ongoing review.

Two practical points trip teams up:

1. Consultation is required; parental consent is not. You do not need a parent's permission to count a student in the NCCD. You *do* need to have consulted. These are different things, and conflating them either over-collects consent forms or under-documents consultation.
2. If consultation did not precede an adjustment, record why. Current NCCD guidance has tightened the documentation expectation here. If circumstances meant you adjusted first — an urgent safety need, an unreachable family — note the reason and the steps you took to consult as soon as practicable. A documented reason is defensible; a silent gap is not.

Consultation is also one of the four NCCD evidence areas (alongside assessed individual need, the adjustments provided, and monitoring and review). So every consultation conversation you document is doing double duty: meeting the Standards' legal obligation and building one quarter of your NCCD evidence base. For the mechanics of capturing it, our NCCD evidence collection and documentation guide walks through each evidence area in turn.

"On the same basis as peers" in practice

This test is easy to state and easy to misapply. It does not mean treating every student identically — identical treatment is often exactly what disadvantages a student with disability. It means making the changes that put the student in a comparable position to access the same opportunities: enrolment, the curriculum, assessment, excursions, the playground, and student services.

A useful self-check when you design an adjustment: *Does this give the student access to the same opportunity their peers already have — no more, no less?* Extra reading time in an exam restores access to a student whose disability slows decoding; it does not give an advantage, because the assessment is testing comprehension, not speed. That framing keeps adjustments proportionate and keeps them tied to functional impact rather than to general academic catch-up.

How this underpins your NCCD evidence

Because the NCCD is built directly on the DDA and the Standards, doing reasonable adjustments well *is* doing the NCCD well. The NCCD model is four steps:

1. Is an adjustment being provided?
2. What level is provided most of the time — Quality Differentiated Teaching Practice (QDTP), Supplementary, Substantial, or Extensive?
3. What category of disability is the adjustment responding to — Physical, Cognitive, Sensory, or Social/Emotional (these are imputed by the school team from available evidence, not diagnosed)?
4. Record it with evidence.

Note that category is imputed by your team. Where adjustments are genuinely being made in response to the functional impact of disability, you can impute a disability based on available evidence without a formal diagnosis. The adjustment drives the data — not a label. To pin down the level decision, see our companion guide to NCCD adjustment levels, which works through QDTP, Supplementary, Substantial and Extensive with documentation examples.

A few anchors worth keeping front of mind:

• The 10-week rule. To count a student, you need evidence that reasonable adjustments were provided for at least 10 weeks within the 12 months before the census. Extensive adjustments must be in place at all times.
• The census reference date is the first Friday in August, and the year runs Planning (Term 1) → Implementation (Term 2) → Validation and submission (Term 3) → Reflection (Term 4), with moderation building consistent judgements across the team.
• The principal attests that there is evidence for every student's inclusion, category and level. Your documentation is what makes that attestation honest.

What to document

You do not need bespoke new paperwork. The NCCD is designed so schools reuse existing records — and reasonable adjustments generate those records naturally. For each student, aim to have evidence across the four evidence areas:

• Assessed individual need. Observations, screeners, specialist reports, work samples, or a record of the team's professional judgement showing the functional impact of the disability.
• Adjustments provided. The actual measures in place, mapped to the five areas of support, captured in your plan (whatever it is called in your state — IEP, ILP, PLSP, ICP, NEP or PLP; these are just containers for the same content) and in everyday teaching artefacts.
• Consultation and collaboration. Dated notes of conversations with parents/carers and the student, including a recorded reason on the rare occasions consultation did not precede an adjustment.
• Monitoring and review. Evidence the adjustment is being checked and changed over time — review dates, updated goals, changes to the level provided.

If you organise thinking by the eight domains of functioning (an organising layer over category × area — for example, Curriculum Access & Learning, Attention/Executive Function & Self-Regulation, and Communication under Cognitive; Social/Emotional & Behavioural Wellbeing and Safety & Risk Management under Social/Emotional; Sensory Function under Sensory; Mobility & Movement and Health & Personal Care under Physical), the link between the barrier, the adjustment and the evidence becomes much easier to articulate at moderation.

A short worked example

A Year 4 student is missing instructions in whole-class teaching. The team observes and assesses the functional impact (auditory processing difficulty), consults the family before changing anything, and puts in place visual instruction cards and pre-printed task steps — a Communication adjustment, in the Cognitive category. They review at the end of the term and find it is working most of the time at a Supplementary level. Four evidence areas, one ordinary teaching change — and a defensible NCCD record, all from work the teacher was doing anyway.

Bringing it together

Reasonable adjustments are not a compliance afterthought; they are the legal duty at the centre of inclusive practice. Consult first, adjust to restore access on the same basis as peers, tie every adjustment to functional impact, and capture the four evidence areas as you go. Do that, and the NCCD stops being a separate August scramble and becomes the natural by-product of good support.

This article is general guidance, not legal or funding advice, and it never promises a funding outcome — your task is sound evidence, well documented.

If your team is spending more time writing up consultations and reviews than having them, Grounded Scribe can help. Our Australian-hosted, AI-assisted documentation tools turn the conversations you already have into NCCD-ready evidence — aligned with the national data standards, with as much processing as possible done in Australia under the Australian Privacy Principles. Explore how we support Disability Inclusion Coordinators, then dig into the practical detail in our NCCD evidence collection guide and NCCD adjustment levels guide.