Introduction
The Reasonable Adjustment Policy has been formulated cognisant of the Standards for Registered Training Organisations (RTOs) 2025, the Disability Discrimination Act 1992 (DDA), and the Disability Standards for Education (Education Standards) 2005.
Scope and Application
The policy is applicable to all employees of the National College of Australia (NCOA), learners, and/or prospective learners. It applies to adjustments that NCOA may make to its training and assessment services to meet the needs of individual learners with a disability.
This policy does not apply to other variations that NCOA may make to its training and assessment services, such as course extensions and deferrals.
The Australian Blockchain Association (ABA) partners with NCOA, the Registered Training Organisation (RTO) regulated by the Australian Skills Quality Authority (ASQA), to market and promote accredited courses in emerging technologies, including the Course in Cryptocurrency and Blockchain Technologies, 11304NAT Certificate III in Crypto Asset and Blockchain Technologies, Diploma of Crypto Assets and Blockchain Technologies, and 11381NAT Certificate III in Artificial Intelligence (AI) Engineering.
Overview
NCOA’s primary purpose is the provision of quality vocational education and training programmes to learners, with a focus on practical applications in blockchain, cryptocurrency, and artificial intelligence (AI), such as neobanking services or hybrid centralised/decentralised exchange (CEX/DEX) services to facilitate on-chain activities without full asset custody.
To specify the conditions under which NCOA will apply its Reasonable Adjustment Policy to implement adjustments that enable a learner with a disability to access NCOA’s training and assessment services on the same basis as every other learner, in line with Standard 2.4 of the Standards for RTOs 2025, which requires reasonable adjustments to support VET students with disability to access and participate in training and assessment on an equal basis.
NCOA will apply this policy consistently and fairly across all programmes and any learner enrolled into a programme at NCOA, ensuring that adjustments do not compromise the integrity of the qualification or create unjustifiable hardship, as per ASQA guidance and practice notes.
Given the fully online nature of NCOA’s courses, which are delivered through digital platforms without physical premises or face-to-face interactions, the scope for certain reasonable adjustments is inherently limited. For example, modifications to physical environments or in-person support are not feasible. Learners must fully disclose any additional needs or disabilities at the time of enrolment to allow NCOA to assess whether it can meet those needs without compromising course integrity or incurring unjustifiable hardship. Failure to disclose at enrolment may result in NCOA being unable to provide adjustments retrospectively, potentially leading to enrolment refusal or suspension if needs cannot be accommodated in the online format. This aligns with the 2025 RTO Standards’ emphasis on early identification of learner needs (as outlined in practice guides for training support) to ensure accessible learning environments and student-centred outcomes.
Policy
The Disability Discrimination Act (DDA) makes it unlawful to discriminate against a person on the grounds of disability. Section 22 of the DDA sets out requirements for educational authorities and providers.
The definition of disability under the Act includes:
- Physical disabilities.
- Intellectual disabilities.
- Psychiatric disabilities.
- Sensory disabilities.
- Neurological disabilities.
- Learning disabilities.
- Physical disfigurement.
- The presence in the body of disease-causing organisms.
The Disability Standards for Education (Education Standards) under section 31 of the DDA outline NCOA’s legal obligations in relation to meeting the needs of learners with a disability.
NCOA meets its obligations by providing reasonable adjustments to learners with a disability to ensure they have the same opportunities as other learners to participate in the course and use all relevant services and facilities. NCOA invites disclosure by learners with a disability if they require adjustments to support their learning and takes measures to prevent harassment or victimisation of all learners by any other person.
NCOA also applies the Education Standards at course completion by ensuring that all learners with a disability who have met the course requirements through reasonable adjustment receive the same recognition as learners without a disability.
NCOA applies reasonable adjustments to its assessment system to accommodate the individual needs of learners with a disability, taking into account the Principles of Assessment, specifically fairness and flexibility under the 2025 RTO Standards.
At all times, NCOA considers the learner’s needs in the assessment process and makes reasonable adjustments to accommodate the learner (e.g., by providing oral rather than written assessment where feasible online) without compromising the rigour of the assessment process (e.g., if there is a requirement to complete documentation in a unit of competency, oral assessment is not appropriate). However, due to the online delivery mode, adjustments are constrained to digital adaptations, such as screen reader compatibility or extended time for submissions, and may not extend to physical or in-person accommodations.
All adjustments to training and assessment must be approved by the Quality and Compliance Manager and are recorded and tracked through the learner management system to monitor the effectiveness of the adjustment, in compliance with ASQA’s practice guides on training support.
Negotiating Adjustments
NCOA recognises that reasonable adjustments should be negotiated individually. It ensures that all staff are aware of their responsibilities and that appropriate professional development is provided to help staff feel comfortable in negotiating and implementing adjustments.
Usually, the person with disability is the best person to explain the impact of their disability on their study and identify the adjustments that may help them or they have found useful in the past. NCOA may ask learners to provide documentation from a medical or other health professional to help guide this process. Given the online nature, negotiations will focus on digital solutions, and NCOA will assess early (at enrolment) if the requested adjustments are feasible within the course structure. If not, NCOA may advise that the course is unsuitable, aligning with the 2025 Standards’ requirements to avoid enrolment where needs cannot be met without unjustifiable hardship.
Reasonable adjustment activities can involve:
- Modifying or providing equipment (e.g., compatible software).
- Changing assessment procedures (e.g., extended deadlines).
- Changing course delivery (e.g., alternative formats for online materials).
- Modifying premises (not applicable due to online delivery).
Determining Reasonableness
The determination of ‘reasonableness’ takes into consideration the suitability of the adjustment to the learner with a disability as well as the likely impact on the organisation. Any adjustment must not create unjustifiable hardship, including unreasonable costs, for NCOA and/or any other parties, including other learners. Similarly, NCOA must ensure that the integrity of the unit/s of competency is maintained. Where completion of the qualification is specifically related to an ‘occupational’ outcome, any adjustment to the assessment process may only be accommodated if the workplace can be similarly ‘adjusted’ to accommodate the needs of the learner.
Due to the fully online format, certain adjustments (e.g., physical aids or on-site support) may be deemed unreasonable or impossible, potentially leading to non-enrolment if disclosed needs cannot be met. This is assessed on a case-by-case basis, with full disclosure required at enrolment to enable this evaluation, as per ASQA guidance on creating accessible learning environments.
Engaging in reasonable adjustment activities, such as assisting learners to identify their learning needs or offering a variety of training and assessment options within the online constraints, exemplifies good practice by NCOA and its employees.
Possible Reasonable Adjustments
Various adjustments can be made to meet the needs of learners and will be negotiated on a case-by-case basis, limited by the online delivery mode. Examples of adjustments used by NCOA include:
- Verbal assessment as a direct replacement for written assessment (via online calls where feasible).
- Technology options for vision-impaired learners to assist them with reading and interacting with learning resources (e.g., screen reader-compatible materials).
- Liaison with external organisations for additional digital support.
- Hard copy resources where there is a learner need (posted if necessary).
- Additional individual tutorials to work through learning materials with the trainer/assessor (via online platforms).
Advice for trainer/assessors about reasonable adjustments for individual learners should be sought from the lead trainer. All adjustments to training and assessment must then be approved by the Quality and Compliance Manager and are recorded and tracked through the learner management system to monitor the effectiveness of the adjustment.
In line with the 2025 RTO Standards’ focus on inclusive practices, NCOA incorporates AI-enhanced tools for adaptive learning paths to support accessibility in our blockchain, cryptocurrency, and AI education offerings. For enquiries, contact the ABA team today.