Submission to Senate Inquiry into the 
Education of Students with Disabilities
TAFE Directors Australia
TAFE Directors Australia (TDA) is the peak representative body for TAFE Institutes Australia-wide, with its members being the CEOs/Directors of the institutes.  As such, the association represents Australia’s public providers of vocational education and training (VET).

Current Situation
TDA notes the sound initiatives and good progress made in improving the access of students with disabilities to vocational education and training.  In particular, we note the positive contribution of the Commonwealth Disability Discrimination Act 1992 and Australia’s National Strategy for Vocational Education and Training 1998-2003 in making achieving equitable outcomes one of the five core areas of the business of vocational education and training.

The Australian National Training Authority’s Bridging Pathways – National Strategy and Blueprint for Implementation are also positive steps to empower people with disabilities to achieve their goals, open doors to vocational education and training, result in higher employment rates, and create a more accountable system.  The ultimate objective of providing people with disabilities with the same opportunities as other students is strongly supported by TDA’s members.  

Similarly, actions taken by individual State and Territory governments to improve accessibility to vocational education and training, and greater access to learning supports are also welcomed.

The challenges faced in meeting the Bridging Pathways – National Strategy goals need to be considered in the context of the funding situation facing vocational education and training providers in general and the TAFE system in particular.

TAFE Institutes account for nearly 75% of vocational education and training students and about 84% of VET in terms of curriculum hours delivered.  One in ten working age Australians are enrolled in TAFE.  National Centre for Vocational Education Research (NCVER) data shows that TAFE graduates come from a range of socio-economic backgrounds, 5% have reported disabilities, 31% are from non-English speaking backgrounds, 2% are indigenous Australians, 26% are over 40 years of age, and 39% are from regional and remote areas.  The figures for module completers are often notably higher.  Thus, TAFE Institutes play a particularly important role in meeting the needs of Australians from recognised equity groups or who find it difficult to access vocational education and training.  

Meeting the needs of these people has been made more difficult due to funding cuts and the loss of growth funding in recent years.  Funding per curriculum hour dropped 10% in real terms over the two years 1997-1999.  With a substantial and ongoing increase in TAFE student enrolments (currently in excess of 7% per annum), the decline in funding per student has been even greater.  Against this background of constrained funding, meeting the needs of people with disabilities is therefore made more difficult.

While statistics differ on the percentage of people with disabilities in the community and their participation in vocational education and training, it is clear that:
•	people with disabilities deserve equitable opportunities to participate in education
•	education leads to better employment opportunities
•	employment leads to better lifestyles and reduced need for public support.
People with disabilities have a strong expectation that they should be able to access the full range of community services and activities and they are increasingly doing so.  It is therefore reasonable to expect that there will be a growth in demand by students with disabilities for access to vocational education and training, and that this will thereby further increase the need for appropriate and adequate public funding.

Adequacy of Current Policies and Programs
The criteria used to define disability and to differentiate between levels of handicap
Terminology and Definitions
There is presently significant variation in the terminology and definitions used to define disability and to differentiate between levels of handicap.  The variations exist across the States and Territories, and bodies such as the Australian Bureau of Statistics (ABS), the National Centre for Vocational Education and Research (NCVER), and the Ministerial Council on Education, Employment, Training and Youth Affairs (MCEETYA).

These inconsistencies result in differing assessments of students’ needs, and therefore entitlements.  For example, schools in NSW have a much narrower definition of disability than does the TAFE sector.  This particularly relates to students with learning difficulties.  

Such inconsistencies are reflected in collected data and published statistics, and make meaningful comparisons very difficult.  Data and statistics are also affected through the method of assessment.  Problems exist where individuals are asked to self assess (eg the ABS Census), especially when terms such as “disability” are not adequately defined.  Data thus gathered results in widely different statistics to data based on status assessed professionally.

If initiatives are to be effective and equitable, it would be desirable to map and evaluate current practices, with a view to:
•	establishing a nationally applicable approach to defining disability, and 
•	providing guides to the assessment of educational implications which can be used across all sectors of education.  
This would encourage a streamlined, equitable and consistent approach nationally.

Assessment Models
TDA notes that a medical assessment model for disability is often insufficient for educational purposes because it does not capture how the disability impacts on lifelong learning considerations such as accessing the curriculum, learning, and achieving personal outcomes.  Other professionals such as educationalists, sociologists, audiologists often have more appropriate tools for identifying the needs of individuals for life long learning.  A key consideration is the extent to which the curriculum and delivery need to be adapted to meet the learning outcome.  In practice this means that the definition and level of disability needs to be determined by an assessment of individual need, agreed between a Disability Consultant and the student, with input from their carers and other supporting agencies.  

Eligibility for the Disabled Apprentice Wage Subsidy (DAWS) is based solely on a medical certificate, which can be inappropriate for students with learning, intellectual or hearing disabilities/impairments.  Eligibility would be more appropriately based on a variety of evidence, such as medical evidence, psychologist reports or audiograms, thereby removing the need for the students to undergo the additional medical process and incurring its costs.

The accuracy with which students’ disability related needs are being assessed
In accord with the current direction in VET to focus on learner needs, it is essential that an individual’s learning support needs are able to be determined.  Groups of students should not be stereotyped as requiring, or not requiring, particular learning support.  The needs of individual students with disabilities, like their able-bodied counterparts, will vary and educational organisations should be able to respond to those differences in need.

One useful measure for the accuracy with which disability related needs are being assessed is the rate of successful vocational outcomes (eg module/course completion, moved onto further study or gained employment).  It may be misleading to measure outcomes at the time of transition – rather, measurement some six to 12 months later through systemic longitudinal research provides a more robust picture of a sustained, and therefore more beneficial outcome.

There is a need to develop a nationally consistent checklist for assessing a student’s functionality.  It would ideally be completed by teachers and disability coordinators, with doctors’ reports, psychological assessments, audiograms and the like, attached for supporting evidence.  This assessment checklist should form part of the young person’s transition from school to the VET sector/other support agency to employment. 

Factors to be considered in the assessing disability related needs should include:
•	the type and degree of disability
•	reasonable adjustment provisions taking into account the student’s cognitive, expressive, receptive, adaptive abilities, and literacy and numeracy skills
•	course content
•	family support
•	advocacy and support networks
•	resources available and management support, and
•	attitudes.

Reasonable Adjustment
People with disabilities require reasonable adjustment to meet competency standards.  Reasonable adjustment provisions for content delivery may include extra technical support, theory tutorials, co-teaching by special education and subject specialists, special resources tailored to individual needs, and adaptive technology.  While current competency assessment procedures for students with disabilities are the same as for mainstream students, reasonable adjustment can include additional time, visual/graphic or verbal demonstrations rather than paper/pen written exams.

The critical issue relating to reasonable adjustment is that flexible and adequate funding is required to meet the specific individual needs of students.

Existing Training Issues
In addition to the technical skills required for particular jobs, like other students people with disabilities require other work related skills to ensure successful vocational outcomes:
•	a functional level of literacy and numeracy linked to the vocational goal
•	working in teams may need to be taught as it is not an incidentally acquired skill
•	understanding of workplace culture and informal communications skills and socialisation
•	relationships with colleagues/supervisors.
Access courses are designed to meet these needs by teaching skills as a stepping-stone to further study, traineeships and apprenticeships, and it is important that they be retained.

The particular needs of students with disabilities from low socio-economic, non-English speaking and Indigenous backgrounds and from rural and remote areas
Recent research has shown that students who belong to more than one target group will be exponentially disadvantaged.  Therefore, support for these individuals will frequently need to be higher if equitable access is to be provided.

The major barriers to education for people with disabilities despite legislation, reasonable adjustment, government policies and practices that promote participation, still continue to be:
•	physical access
•	teaching practices, and
•	staff attitudes.

Students with multiple disadvantage have decreased opportunities for successful completion of courses.
•	An isolated student with a disability (eg vision impairment) finds it very difficult to attend a campus, especially at night, when reliant on public transport, which is more expensive than in metropolitan areas.  Students with disabilities often find it not viable in terms of cost and timetables to travel to the appropriate campus.
•	In some areas, a high proportion of TAFE students with disabilities come from other language and cultural backgrounds.  In some cultures, people with disabilities have no rights and responsibilities.  Therefore their required level of support when accessing TAFE is significantly greater.  To ensure successful outcomes for the student, it may be necessary to educate and support family members to overcome cultural barriers to information about available services.
•	Many refugees and migrants experience various forms of trauma, including the division and separation of families.  From some areas, the incidence of disabilities is greater, and some disabilities, such as psychological disability, have a severe impact.  Extended instructional time and other learning supports are required to ensure equality of opportunity and equality of outcomes.  In many cases a student’s residency status prevents them from accessing benefits.
•	Other problems that are often faced by students with disabilities, and that can be exacerbated when other factors such as low socio-economic status, remoteness, language and cultural differences are also involved, include:
•	gaps in education
•	lack of self esteem
•	problems in locating and connecting with other appropriate disability support services
•	delays in intervention for economic or isolation reasons
•	cost of installing and maintaining adaptive technology, and difficulties in accessing staff expertise in their use
•	isolation from support networks
•	Digital Divide issues, and
•	need for extended instructional time.

The effectiveness and availability of early intervention programs
Any program or preparation that assists in a more positive transition to vocational education and training can be considered as “early intervention”.  TDA notes that the effectiveness of early intervention is dependent on the student identifying a need on enrolment.  This is particularly an issue for students with psychiatric disabilities who are hesitant to have it known.  Overall, the effectiveness of these courses can be measured by the number of students moving from discrete to mainstream classes as they gain increased skill and confidence.

Examples of discrete access courses include the Certificate I in Work Skills, and the Statement in Employment Skills, which provide preparatory vocational and job skills, thereby maximising learning and the likelihood of success when students move into mainstream courses with support.  The courses are offered according to funding availability, demand, suitable accommodation, skilling of teachers, and the availability of appropriate adaptive technology.

A good example of an early intervention program in NSW operates under the TAFE/Vocational Education and Training (T/VET), where students undertake a TAFE course as part of their Higher School Certificate (HSC) during Years 11 and 12.  T/VET provides initial vocational training and preparation to undertake and complete the course at a later date.  Teachers/consultants attend the schools for individual education planning as part of T/VET planning, and also as students are leaving school to establish links with appropriate TAFE services.  TDA notes that this avenue requires a student to be undertaking the HSC, which until recent years was not possible in NSW for students with disabilities, especially for those with intellectual disabilities.  Participation in TAFE could be more effective if enrolment in T/VET was extended to Year 10 to give students more time to complete their courses using TAFE resources.

TDA notes that there appears to be a lack of consistency in early intervention programs.  The learning needs of students with disabilities are often not identified early due to inadequate funding, especially in regional and remote areas.  Children from lower socio-economic backgrounds are also disadvantaged when parents cannot either identify or afford assessment of learning difficulties.  Moreover, there are not enough programs to bridge the gap between the school and adult learning environments.

In some States/Territories, it would appear that the method of funding for early intervention and disability support services requires attention and improvement.  
•	Existing funding guidelines do not promote the development and implementation of formal inter-agency agreements that define roles, responsibilities, service delivery components and funding sources for transition planning and case management services.  In practice, this can mean that agencies may receive funding to provide job placement and training for people with disabilities, but these funds may not flow through to TAFE when students are placed in TAFE courses and utilise the learning supports available at institutes.  
•	It appears that some support agencies are under pressure to provide programs for students, and include TAFE even when it is not appropriate.  
•	There appears to be a trend by smaller providers to bid for ad hoc short programs, creating a lack of consistency and no long-term depth of expertise being developed or retained.
•	Retained “ownership” of a student can also become an issue.  Many students with disabilities currently enter the education system with the assistance of a an externally funded agency and are likely to stay with that provider over extended periods, notwithstanding that their needs may be better met elsewhere or may have changed.  This can happen due to limited knowledge of, or links with other support services, and may also arise from the basis of funding.

Access to and adequacy of funding and support in both the public and private sectors
If the TAFE sector is to significantly improve the services and support it provides to students with disabilities, it is critical that:
•	TAFE Institutes be adequately funded to accommodate students with disabilities, including those from multiple equity groups;
•	TAFE Institutes have suitably trained and supported staff who understand students’ needs, and are knowledgeable about available learning supports; and
•	there is access to learning supports.

To increase the participation rate of students with disabilities in VET, significant Commonwealth and State/Territory funding will be required.  Bridging Pathways – Blueprint for Implementation identifies a series of focus areas and actions required.  While a number of actions identified for ANTA are already within the scope of existing projects, Bridging Pathways identifies other actions that require a further $2.5 million dollars to undertake research or complete initiatives.  Further actions by individual Commonwealth and State/Territory agencies, and actions through Cross-Government Collaboration have been identified but resource requirements have not been calculated.

TDA stresses that funding for additional places in TAFE Institutes is a very high priority, especially for students with disabilities.  While in many cases infrastructure needs and students support services are already in place, additional capital and operating funding will be required to support higher numbers of students with disabilities.  The installation, maintenance and updating of adaptive technologies is also essential.

A key factor in the movement of people with a disability into employment is extensive planning, support and ongoing monitoring to ensure that access to the most appropriate educational pathway is achieved.  This aspect of the service provision is vital and is not reflected in the outcome measures prescribed by ANTA.  They are hidden costs that institutes are currently forced to bear from within existing budgets.  The importance of these services must be recognised and funded.

Additional flexible funding is also required to develop and implement vocational programs for people with disabilities.  These programs can provide significant benefits to students but require valuable staff time to seek funding, thereby impacting adversely on timeliness.  Currently, such funding is often short-term, preventing continuity and the development and retention of staff expertise.   This situation is not helped when bidding for programs is on an ad hoc basis.

TDA suggests that it would be useful to establish a central repository of information relating to national funding resources and related criteria.

Further research is also needed to:
•	investigate the effectiveness of self-paced learning and flexible delivery strategies for people with disabilities
•	explore the implementation of inclusive practice across all facets of TAFE delivery to maximise outcomes, and
•	explore the concept of separate or customised curricula to accommodate people with disabilities and other disadvantaged groups, and the effect of modified curricula on the credential.

The nature, extent and funding of programs that provide for full or partial learning opportunities with mainstream students
Bridging Pathways – National Strategy says that “for the vocational education and training systems to be truly client centred, it needs to ensure those policy reforms such as user choice and flexible delivery are inclusive of people with a disability”.  It adds that to succeed in providing client focused training, the VET system needs to “incorporate disability considerations into the delivery of training to clients in rural/remote areas, those with cultural needs, women and students of all ages”.  TDA strongly supports a client-focused approach that addresses the needs of students with disabilities in both policy development and training delivery.

TDA notes that on-line delivery is one option for meeting many students’ needs.  On-line learning should not, however, be seen as the panacea to all problems, especially for providing accessibility to students with disabilities.  In many disciplines, there is no substitute for face-to-face teaching and learning, and for the exchange of ideas and experience with fellow students and colleagues.  This is particularly so when students are experiencing language, cultural or contextual difficulties.  We stress the importance of retaining at least some initial face-to-face delivery as the primary mode of teaching and on-line delivery to be considered, in the main, as a useful adjunct or natural educational progression with an appropriately prepared student.

Many vocational education and training courses now fall under the Australian Qualifications Framework (AQF) and the competency principles inherent in the Training Package approach.  TDA is concerned that Training Packages do not necessarily meet the needs of students with disabilities in a number of ways.

•	Being derived with industries’ needs in mind, many Training Packages are centred on work place delivery, and do not cater well for those students who are not currently employed or not employed in areas related to their studies.  As students with disabilities are less likely to be employed than mainstream students they are, as a group, disadvantaged to a greater extent.

•	Generic skills and underpinning knowledge are essential elements in vocational learning and are highly valued by employers.  They provide the foundation necessary for dealing with the range of contingencies that can arise in the workplace.  They are also the essential skills for responding to change, achieving job mobility and enabling life long learning.  Many Training Packages need to be considerably improved to ensure that generic skills and underpinning knowledge are adequately addressed.  Given that “people with a disability more often enrol in preparatory, basic education and basic employment skills programs than do other students”, students with disabilities are potentially further disadvantaged and would find it difficult to undertake or complete many Training Packages.

•	TAFE Institutes have found that there are substantial costs involved in implementing Training Packages associated with flexible delivery, customisation, resource development, professional development, assessment, travelling and record keeping.  However, the necessary funding has not been provided and this is imposing real constraints on implementation.  Increasing accessibility to Training Packages for students with disabilities’ needs to be addressed, but will incur additional costs for which the Institutes are not adequately funded.

The Commonwealth Government focus on apprenticeships in policy development and funding also disadvantages students with disabilities.  The National Centre for Vocational Education Research (NCVER) statistics show that people with a disability comprise only 2% of people undertaking New Apprenticeships.  Clearly, to meet their needs and aspirations, both mainstream students and people with disabilities need the Government to recognise that other viable options, such as full and part-time TAFE study, do exist and that more attention needs to be paid to these areas in policy development and funding.

Teacher training and professional development
Students with disabilities need quality teachers and support staff to ensure positive outcomes including module completion, course completion and achievement of vocational goals.  To ensure maximum outcomes and to conform to government policies, the ongoing training of staff at all levels is essential.  These costs are mainly borne by institutes.

To provide necessary educational and support services, the following is required:
•	highly qualified and experienced teacher/consultants to oversee the provision of service delivery
•	disability teachers (possibly employed on a casual basis by the teacher/consultant) to work with subject teachers to implement reasonable adjustments or to deliver specific access courses for specific disability groups or individuals
•	educational assistants and specialists such as Sign Language Interpreters to work with teachers to ensure that the high quality of service required by students with disabilities is not compromised, and
•	all TAFE staff  to be trained in disability issues.

TDA notes that disability training is not currently an integral part of the training for full-time teachers, nor is it a condition of their employment.  Further, part-time teachers employed for their subject and/or industry experience may have no teacher training at all.  This makes the implementation of reasonable adjustment a considerable challenge.

Bridging Pathways – Blueprint for Implementation has identified an ANTA action for staff development to increase skills in inclusive teaching practices to be completed by end-2002 with a budget of $1 million.  Further Blueprint actions for professional development components in Training Package Support Materials and inclusive workplace practices in relevant training programs are welcomed.  The adequacy of such programs and their funding will need to be monitored throughout the course of implementation.

The legal implications and resource demands of current Commonwealth and state and territory legislation
The Disability Discrimination Act is significant ground-breaking legislation.  Its application within the education sector should not be diminished by policies and practices driven by shrinking resources.  

Training providers are obliged to provide the necessary supports and adaptations required for a person with a disability to access education in the same way as mainstream students.  Because TAFE, the public provider, cannot claim “unjustifiable hardship”, institutes are forced to either risk discrimination complaints or fund the support of students with disabilities from other resources, thereby potentially putting mainstream student completions and employability at risk.

Adequate funding is essential, as is the identification and dissemination of appropriate approaches for quality systems and programs in order that funding can be used in the most effective and efficient ways.

Centrelink Support Benefits
The majority of students with a disability are in receipt of income support from the Commonwealth Government.  The need to constantly provide Centrelink with information regarding students’ study program variations and patterns of attendance consumes a significant part of Teacher/Consultant time.  This situation is exacerbated due to staff turnover at Centrelink  and other Commonwealth agencies, requiring the provision of regular updates on issues relating to students with disabilities accessing vocational education and training.  TAFE staff also often act as advocates for students when they have benefits withdrawn incorrectly.  These are essential and time-consuming services that TAFE staff provide, with the institutes bearing the costs.

Youth Allowance
Eligibility for Youth Allowance requires participation in full-time education and training.  For some students with a disability, part time training may be more suitable.  But eligibility for the benefit is then jeopardised.  Given that there is often no other income support, students may be forced to undertake training in areas in which they have little or no interest or commitment.

Disability Support Pension and Pensioner Education Supplement
Access to these supplements is based on attending a minimum of eight hours per week.  For some students, the appropriate pathway based on the disability may be less than the eight hours per week required to qualify for these benefits.

Mobility Allowance
Due to their disability, some students require travel training to ensure that they are able to successfully travel to and from an institute, work placement or place of employment.  This service is often provided by TAFE staff at the institutes’ cost.

Specialist Employment Services
While people with disabilities can register with multiple employment agencies like other unemployed people, intensive assistance funding is only available to one agency at a time for each person.  There are few jobs available for people with disabilities, so jobs may be with one agency whilst the clients are with another.  As existing funding arrangements do not promote formal inter-agency agreements, jobs and clients go unmatched.  New approaches that focus on the client are required.

Rather than specialising, employment agencies are now often trying to cater to all disability groups.  Many agencies do not however have the resources or expertise to adequately address needs as varied as psychiatric, hearing impaired, vision impaired and acquired brain injury.  Further, while assisting to find employment, some agencies are unable to offer the level of support necessary for a person with a disability to successfully maintain employment.

To access a specialist employment agency, the person with a disability has to be prepared to prematurely make the decision to relinquish their disability support pension and to move onto a much more insecure unemployment benefit type of income support.  With this also comes a more onerous reporting system back to Centrelink.  This acts as a disincentive to the person with a disability who has accessed training, as they may not feel confident that they are able to sustain full-time employment in an unpredictable labour market.

Proper Role of Governments
What the proper role of the Commonwealth and states and territories should be in supporting the education of students with disabilities.
Services accessed by people with a disability are spread across a number of Commonwealth, State/Territory and local government agencies.  While some rationalisation might be warranted, there needs to be clear information on regulations and responsibilities, in particular it is essential to provide:
•	clear guidelines about funding
•	improved and flexible school to adult education and/or work programs

Additional Material
Additional facts, opinions, arguments or recommendations that our outside the Inquiry’s Terms of Reference
Quality initiatives should be identified for purposes of best practice recognition.  Benchmarking should be encouraged.  

A national Centre for Education of Students with Disabilities should be established, and/or Centres of Excellence should be identified for benchmarking and mentoring purposes.