NCCD Guidelines Part 2:
Who's Actually Responsible?

A Whole-School Roles and Responsibilities Framework

Ask five staff members at your school who's responsible for NCCD moderation, and you'll probably get five different answers. The classroom teacher assumes it's the learning support team's job. The learning support team assumes the diverse learning or inclusion team is driving it. The executive assumes the principal will provide clear directions, while the principal signs off on data that they were never actually part of moderating.

This isn't a hypothetical. It's the most common failure point in NCCD practice — and it has nothing to do with staff not caring. It happens because "everyone's responsible" so easily becomes "no one's accountable," when responsibility is never explicitly stated, communicated, or embedded into the school year.

In Part 1 of this series, we covered the legal and financial architecture sitting above the NCCD — the Disability Discrimination Act 1992, the Disability Standards for Education 2005, and the $5.1 billion Student with Disability Loading that depends on accurate data. This post takes that legal obligation and brings it down to ground level: who does what, in which role, at which point in the year.

Why role clarity isn't optional

The Disability Standards for Education (DSE) require schools to make reasonable adjustments and to be able to demonstrate that those adjustments are meeting student need. That's not a job description for one person — it spans everyday teaching practice, specialist support, whole-school oversight, and formal sign-off. When those layers aren't clearly defined, the gaps show up exactly where they matter most: incomplete evidence, inconsistent Levels of Adjustment (LOA) decisions, and moderation sessions that consist of one overworked inclusion leader trying to single-handedly validate an entire school's data in the last week of Term 3.

A genuine whole-school NCCD process needs five layers of responsibility working together, each with a distinct role. Here's what that looks like.

The five roles in a whole-school NCCD system

1. Classroom Teacher — the evidence generator

Classroom teachers are where NCCD evidence actually starts. This role is about identifying need through everyday observation and assessment, and then doing the less glamorous but essential work of writing it down.

In practice, this means:

• Identifying students who may require adjustments through ongoing observation and assessment

• Planning and implementing curriculum-aligned, reasonable adjustments — not just intentions, but actual documented practice

• Collecting evidence of student need, the adjustments provided, and the impact of those adjustments

• Actively participating in NCCD discussions and moderation, not just supplying evidence on request

If evidence collection is treated as something that happens to classroom teachers rather than by them, the data will always be thin. This is the role most schools under-resource in terms of time, and it's the one the whole system depends on.

2. Inclusion Support Teacher — the consistency coach

This role goes by different titles depending on your state or sector — Learning Support Teacher, Diverse Learning Teacher, SEN Teacher — but the function is the same: supporting classroom teachers to get adjustments and evidence right, rather than doing the work for them.

Core responsibilities include:

• Guiding teachers in selecting and implementing adjustments that are actually appropriate to the student's need

• Supporting the development and review of IEPs, behaviour support plans, and health care plans

• Helping teachers understand what does and doesn't count as usable NCCD evidence

• Ensuring adjustments are correctly aligned to Levels of Adjustment

• Contributing directly to moderation discussions, bringing a cross-classroom view

3. Inclusion Leader — the whole-school driver

This is the role that holds the process together — often titled Learning Support Coordinator, Head of Special Education Services (HOSES), or Diverse Learning Leader. Where the previous two roles operate at the individual student and classroom level, this role operates at the whole-school level.

Responsibilities include:

• Overseeing NCCD data collection processes across the entire school

• Ensuring all staff understand their obligations under the DDA and Disability Standards for Education, not just the mechanics of data entry

• Leading professional learning on reasonable adjustments, evidence collection, and Levels of Adjustment

• Monitoring the quality and consistency of plans, evidence and LOA decisions across classes and stages

• Leading or coordinating formal moderation sessions

• Maintaining secure, organised documentation systems staff can actually use

If your school doesn't have staff able to fill this role with real authority and time allocation, this is usually where NCCD data quality quietly breaks down.

4. Executive / Middle Leader — the accountability bridge

Assistant principals, head teachers, year coordinators and curriculum leads sit between classroom practice and whole-school oversight — and that positioning matters. This role exists to close the gap between what's meant to happen and what's actually happening in classrooms.

In practice, this means:

• Checking that teachers in their team or faculty are actually implementing adjustments, not just planning them

• Monitoring documentation quality within their area of responsibility

• Participating directly in moderation and LOA decision-making

• Naming and addressing gaps in practice early, rather than letting them surface at final moderation

5. Principal — the compliance owner

Under the Australian Education Regulations 2023, this responsibility legally cannot be delegated away — a principal can distribute tasks, but ultimate accountability for the accuracy and integrity of a school's NCCD submission sits with them.

That means:

• Ensuring the school meets its legal obligations under the DDA and Disability Standards for Education

• Endorsing the NCCD data the school submits — which should mean genuine review, not a rubber stamp

• Ensuring systems exist for accurate data collection, evidence-based decision-making, and real moderation

• Allocating the resourcing (time, staffing, professional learning) that makes the other four roles actually achievable

• Building and sustaining a whole-school culture where inclusion is standard practice, not a compliance add-on

The trap: writing this down once and never returning to it

Here's the uncomfortable truth: most schools have thought about roles at some point — usually in an induction slide or a one-off staff meeting. The problem is that role clarity isn't a one-off communication. It needs to be visible and revisited across the year, because NCCD isn't a Term 3 event — it's a cycle with different responsibilities activated at different points, from early identification in Term 1 through to final review in Term 4.

That's exactly why role clarity and a term-by-term moderation timeline need to sit in the same document — and why it's worth having a single, adaptable reference your whole staff can see, rather than reconstructing "who does what" from memory every August.

This is the exact gap our NCCD Roles & Responsibilities Framework is built to close — a whole-school, editable reference that maps these five roles against a term-by-term moderation timeline, so nothing depends on institutional memory or a single overstretched inclusion leader. It's designed to be adapted to your own role titles and used across any Australian state or territory system.

Where this leads

Role clarity solves who does the work. It doesn't yet solve how moderation itself should run, what counts as strong evidence, or where school moderation processes most commonly go wrong. That's where Part 3 of this series goes next — a practical walkthrough of the moderation process itself, from evidence quality through to the moderation conversation.

References

• Australian Government Department of Education. NCCD Guidelines: Effective 2026 Onward. nccd.edu.au

• Disability Discrimination Act 1992 (Cth); Disability Standards for Education 2005 (Cth); Australian Education Regulations 2023 (Cth)