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Response to Proposed New Guidelines for the Inclusion Support Program

12 Nov 2019

Supporting inclusion at school

About Noah’s Ark

Noah’s Ark Inc. is a non-government organisation that was founded in 1971. Noah’s Ark’s primary role is in early childhood intervention (ECI) services for children with disabilities or developmental delay and their families and carers. We operate from 20 locations across metropolitan and regional Victoria, as well as in the ACT and Albury NSW. Last year these programs reached over 2,200 families. Since the introduction of the National Disability Insurance Scheme (NDIS), Noah's Ark has been able to continue supporting children and families as they move into their primary school years.

In addition to receiving federal funding via the NDIS, Noah’s Ark currently receives funding from the Victorian Government (Department of Education and Training) for the delivery of some ECI services and for the Kindergarten Inclusion Support, Pre-School Field Officer and Parent to Parent Programs. Noah’s Ark also provides training and resources nationally and internationally on early childhood intervention and inclusion. Noah’s Ark has been active nationally in the development of services for young children with a disability and has strong links to the early childhood intervention field internationally.

Noah’s Ark managed multiple Inclusion Support Agencies in Victoria from 2006 to 2016 under the Inclusion and Professional Support Program (IPSP). We have been involved in the inclusion of children with disabilities in ECEC since the early 1990s and continue our involvement through our role in ECI and training.

Noah’s Ark welcomes the opportunity to comment on the proposed changes to the Inclusion Support Program (ISP) Guidelines.

John Forster, CEO


The vision of Noah’s Ark is that “every child develops meaningful relationships, participates and learns with the encouragement and understanding of their families, carers, educators and communities”. Inclusive early childhood education plays a very significant role in the realisation of that vision, so we recognise the important role played by the Inclusion Support Program (ISP).

Early Childhood Intervention (ECI) aims to enhance the development, wellbeing and participation of children with a disability or developmental delay aged from birth to seven years old. As children learn throughout the day from all their activities and interactions, ECI supports the important people in children’s lives, including their families and educators. As formal early childhood education and care (ECEC) plays a significant role in children’s ongoing learning and development, any barriers to accessing ECEC need to be identified and addressed if children with disabilities are to have the best opportunities to achieve their potential.

While there is overwhelming evidence of the benefits of early childhood education for all children (Centre for Education Statistics and Evaluation, 2014; Warren, Vialle, & Dixon, 2013), access and full participation are not always available to all children (Australian Government Productivity Commission, 2014). The children that most commonly miss out are those with a disability or developmental delay and those from low socioeconomic circumstances at risk of abuse, neglect and developmental disadvantage (Gilley, Tayler, Niklas, & Cloney, 2015). Children from Culturally and Linguistically Diverse (CALD) backgrounds also access ECEC at lower rates (Baxter & Hand, 2013).

The Australian Government has recognised the need to support the inclusion of children with disabilities since the early 1990s and has funded a number of programs to support inclusion since this time.

Programs that support inclusion

The current guidelines for the ISP continue the Australian Government’s commitment to supporting the inclusion of children with disabilities and other additional needs. The ‘Introduction and program overview’ set out in the guidelines for the ISP represent a positive and contemporary view of the aspirations for inclusion. These include that all children are recognised and valued, experience a curriculum that is relevant to them and are regarded as learners. It also acknowledges that inclusion is supported by research and that Australia has obligations to provide children with disabilities with inclusive opportunities, particularly through initiatives of the United Nations.

Various national programs, including the Supplementary Services program, Inclusion and Professional Support Program and Inclusion Support Program, have funded services to support inclusion. These have evolved as research and experience in supporting children’s inclusion has developed. In this context it is important to note that the last major review of the evidence supporting inclusion by the Australian Government was prior to the introduction of the Inclusion and Professional Support Program in 2006. As this was nearly 15 years ago it would be timely for the Department of Education to undertake a major review of developments in this area, including what is regarded as best practice nationally and internationally.

Australian Government programs have funded two core types of resources, ‘capacity building’ resources such as planning, training, mentoring and coaching, and practical resources, such as subsidies for additional staff and equipment. While these approaches have become a fixture in Australia, there has been ongoing research and evolution elsewhere, particularly in how they are applied. In addition, there has been a development in how the ‘quality’ of inclusion is understood. In the ISP Guidelines the terms access and participation are used interchangeably because there is no framework for understanding what participation or the ‘quality inclusion’ involves beyond attending a service. There have been significant developments in both the ‘what’ and ‘how’ in the literature on inclusion since 2006.

The literature on inclusion

The Australian literature on early childhood inclusion (with a focus on disability) provides some insights into strategies that have been identified as positively supporting inclusion. These include:

  1. The importance of training to better prepare undergraduate educators (Cologon, 2011; Cologon & Mevawalla, 2018; Kishida & Kemp, 2009; Kraska & Boyle, 2014; Petriwskyj, Thorpe, & Tayler, 2014; Warren et al., 2013); and high quality ongoing professional development (Cologon & Mevawalla, 2018; Kishida & Kemp, 2010; Mohay & Reid, 2006; Warren et al., 2013; Williamson, Davis, Priest, & Harrison, 2011)
  2. The importance of the leadership in services and educators who positively support inclusion and the impact of sufficient support, training and resources to support this positivity (Mackenzie, Cologon, & Fenech, 2016; Petriwskyj et al., 2014; Warren et al., 2013)
  3. The importance of high quality pedagogy/ programming and the impact on the outcomes for all children (Centre for Education Statistics and Evaluation, 2014; Cologon & Mevawalla, 2018; Driscoll & Carter, 2009, 2010, 2018; Kemp, Kishida, Carter, & Sweller, 2013; Kishida & Kemp, 2009; Mackenzie et al., 2016; Petriwskyj et al., 2014; Scott, 2016; Trembath, Balandin, Togher, & Stancliffe, 2009; Warren et al., 2013)
  4. The importance of positive relationships between educators, parents, consultants and children (Mackenzie et al., 2016; Warren et al., 2013)
  5. The importance of collaboration between professionals to support a holistic understanding of the child and support the implementation of intervention strategies in multiple environments, thus maximising a child’s learning opportunities (Warren et al., 2013; Wong & Press, 2017)

There is little Australian research on the contribution of additional educators in early childhood services. However there is a lot of research regarding the use of funding for educational support staff in primary schools, which is overwhelmingly negative (Boyle, Scriven, Durning, & Downes, 2011; Butt, 2016; Jackson, 2008; O’Connor et al., 2015; Punch, 2015).

One of the significant international developments has been in defining the quality of inclusion. Of particular interest is the Inclusive Classroom Profile (Soukakou, 2012; Soukakou, Winton, West, Sideris & Rucker, 2014). The Inclusive Classroom Profile, which is designed for children two to five years has identified a series of practice for which there is an evidence base that they improve inclusion.There are 12 elements which include:

  1. Adaptations of space and materials/equipment - assesses the extent to which adults adapt the space, furniture and materials to promote children’s learning and social experience in the classroom
  2. Adult involvement in peer interactions - assesses quality of adult engagement in supporting reciprocal, sustained peer interactions
  3. Adults’ guidance of children’s play - evaluates adults’ engagement and scaffolding of children’s play
  4. Conflict resolution - evaluates adults’ involvement in supporting conflict resolution
  5. Membership - assesses the extent to which children have equal opportunities to assume social roles and responsibilities in the classroom
  6. Relationships between adults and children - evaluates the reciprocity, sustainability and content of adult–child verbal and non-verbal social interactions
  7. Support for communication - assesses the extent to which adults promote and facilitate functional, social communication skills among children with and without difficulties
  8. Adaptation of group activities - assesses the extent to which adults adapt group activities to promote active engagement and meet individualized needs
  9. Transitions between activities - assesses the extent to which transitions are organized and adapted to prepare children for activities
  10. Feedback - evaluates the frequency and nature of feedback provided to individual and groups of children
  11. Family-professional partnerships - evaluates the promotion of daily communication and exchange of information on children’s learning
  12. Planning and Monitoring of Children’s Individual Needs and Goals - assesses the extent to which IEP goals are being planned, implemented in daily activities, and how children’s progress is being monitored

While these strategies are identifiable from the Early Years Learning Framework for ECEC, the ICP identifies the level of engagement of children in the strategies, that is the level of participation. It provides descriptors of the various levels in which these strategies can be implemented. Several States in the USA are currently introducing the ICP to measure the quality of inclusion in their ECEC services. It is one way of reporting to the State that it is getting value for money from its investment.

A second international development has been in becoming much more intentional in how the notion of ‘capacity building’ is implemented. This is based on research about the effectiveness of professional development. Recent research has identified coaching as a promising job-embedded professional development strategy to support implementation of quality teaching practices (Snyder, Hemmeter & Fox, 2015). The most effective professional development for supporting the inclusion of children with a disability involves coaching within a defined framework that includes: a) shared goals and action planning, b) reflection and feedback, and, c) focussed observation. Coaching for ECEC educators has been described as an important competency “driver” to ensure evidence-based practices are implemented as intended and lead to positive outcomes for children (Fox, Hemmeter, Snyder, Binder, & Clarke, 2011).

Quality versus quantity and the ISP Guidelines

The ISP guidelines are proposing a major increase in the number of children supported through the ISP. Our understanding is that this is to be done with no additional funding. If a large number of additional children are to be accommodated, then it is reasonable to assume that all children will get less support than currently. The question of quality versus quantity is therefore important.

A number of children identified as having ‘additional needs’ in the new guidelines were eligible for support under the IPSP, including children from Aboriginal and Torres Strait Islander backgrounds, children from Cultural and Linguistically Diverse (CALD) backgrounds, children from refugee and humanitarian backgrounds and potentially children with challenging behaviours and trauma related behaviours, depending on how those behaviours were understood. Children with medical or health issues have also been supported at times. There is no question from our perspective that these children should remain eligible for inclusion support.

There are two categories of children which are new and require further consideration. The support of children presenting with learning, language and speech delays is core to the early childhood curriculum and the focus of both ECEC services and schools. As these criteria is written, it is very open and the number of children who would be eligible would be extensive. It is not clear why this is being transferred from a general curriculum issue to an ‘inclusion issue’. The same argument applies to children who do not meet developmental targets under the Australian Early Development Census (AEDC). Reaching these targets should be the focus of the ECEC curriculum and should not require an ‘inclusion’ focus.

The current measures of success for the proposed ISP Guidelines (Section 1.6) are quantitative. They refer to the number of children accessing services, being aware of the services available and hours in attendance at the ECEC service. While the term ‘participation’ is used, the lack of any definition, as noted above, means that it effectively has the same meaning as ‘access’.

The other measures of success refer to services and include: the number of services with a Strategic Inclusion Plan; increased, knowledge, skills and confidence of educators; awareness of services available through the ISP and an increased number of services funded by the ISP. The lack of any framework in which staff can demonstrate increased knowledge, skills and confidence means any reporting against this cannot be objective. The basic premise of the revised guidelines is a broadening of the eligibility criteria of children who can receive services. It would therefore be very surprising if the number of children and services being supported did not increase.

It is our view that from 2020 the Inclusion Support Programs needs to measure the quality of inclusion for children with additional needs, in addition to measures of the number of children receiving support. The intention to broaden the eligibility criteria without a measure of quality means that unintended consequences such as poorer experiences for children with a disability will not be monitored. While we can support the broadening philosophically, we do not believe that there is a strong enough framework to ensure that its application does not disadvantage children with a disability.


It is our understanding that the proposed new guidelines for the ISP, and the broadening of the eligibility criteria to include more children, is being done in the context of no additional funding.

We are concerned that children with developmental concerns that have been historically addressed as part of the ECEC curriculum, as identified above, are now being included in an ‘inclusion’ program. Without further rationale we do not understand this change and therefore cannot support it.

We are also concerned that the proposal to broaden the criteria to include additional children is being considered in the context of program guidelines that do not have clear descriptors of what the quality of inclusion should be. Without a clear understanding of quality, it is likely that increasing demands on the ISP from a broader population will lead to a poorer experience for children with a disability.

We urge the Department of Education to review the literature on inclusion to ensure that Australian children are able to receive the highest quality support that ensures their access and meaningful participation in ECEC services.


  1. That the Department of Education undertake a major review of the literature on, and practice developments in, the inclusion of children with disabilities, developmental delays and additional needs and adopt a measure/s of the quality of inclusion to be provided through its programs such as the Inclusion Support Program.
  2. That the Department of Education undertake a study to establish the cost of providing high quality inclusion support to children with a disability.
  3. That the Department of Education undertake a costing of its proposed expansion of the criteria for the Inclusion Support Program on the basis that it maintains high quality inclusion for children with a disability.
  4. That the Department of Education provide additional funding if required to ensure all children funded by the ISP receive high quality inclusion supports.


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