Reasonable Adjustment Procedure - Adjustment Framework
Purpose
This procedure establishes how the Australian Shiatsu College identifies, assesses, documents, and implements reasonable adjustments for students with disability, health conditions, or unique learning needs. It operationalises the commitment made in the Access, Equity, Inclusion, and Diversity Policy and ensures ASC meets its obligations under the Disability Discrimination Act 1992 (Cth), Disability Standards for Education 2005 (Cth), Equal Opportunity Act 2010 (Vic), the Standards for Registered Training Organisations 2025 and the DEWR Guidance for Supporting Students with Disability in VET.
Scope
Applies to all current and prospective ASC students across all programs (Diploma, short course, CPD, online), and to all staff involved in teaching, assessment, clinical supervision, and student administration.
Guiding Principles
ASC’s approach to reasonable adjustment is grounded in the following commitments:
- Genuine inclusion: Every student deserves a genuine opportunity to participate and succeed. ASC does not look for reasons to refuse adjustments — it looks for ways to make participation possible.
- Individual assessment: No two students have the same needs. Adjustments are considered on a case-by-case basis, not applied as blanket rules.
- Proactive identification: ASC does not wait for students to ask for help. Trainers and staff are expected to notice and respond to signs that a student may need support.
- Confidentiality: Disclosure of a need is treated with strict confidentiality and does not affect a student’s standing, assessment, or relationships within the College.
- Honest boundaries: Some requirements of this qualification cannot be adjusted without compromising its integrity or client safety. ASC is committed to being honest about these boundaries while exhausting all genuine adjustment options first.
- Balance: Adjustments must not materially disadvantage other students or impose unjustifiable hardship on the College.
What Is a Reasonable Adjustment?
A reasonable adjustment is a modification to the way training is delivered or assessed that enables a student with a disability, health condition, or unique learning need to participate on the same basis as other students — without compromising the integrity of the qualification or the inherent requirements of professional Shiatsu practice.
Adjustments may relate to:
- How training content is delivered (format, pacing, modality, environment)
- How assessments are submitted or conducted
- The timing or scheduling of learning activities
- The physical or environmental conditions of learning
- The level of support available during learning and assessment
When Is an Adjustment Not Reasonable?
An adjustment is not reasonable where it would:
1. Compromise an inherent requirement of the qualification Some competencies cannot be modified without fundamentally altering what the qualification certifies. These are addressed in the companion document: Reasonable Adjustment Guide — ASC-Specific Adjustments and Inherent Requirements.
2. Create unjustifiable hardship for the College Factors considered include:
- Financial cost relative to ASC’s resources as a small, specialist institution
- Operational disruption to course delivery
- Availability of infrastructure (for example, ASC does not have private treatment rooms — all learning and clinical activity occurs in communal spaces)
- Impact on the sustainability of the adjustment over the full duration of the program
3. Materially reduce the quality of training for other students ASC operates with small cohorts by design. This is a deliberate educational choice that benefits all students through close trainer attention and community-based learning. However, it also means that trainer time and resources are finite. Where implementing an adjustment would require a disproportionate and sustained redirection of trainer attention away from the cohort as a whole, this is a legitimate consideration in assessing reasonableness.
This does not mean ASC will refuse adjustments because they require additional effort. It means ASC will honestly assess whether an adjustment can be sustained across a full semester or year without systematically disadvantaging other students.
4. Compromise health and safety For the student, other students, clients, or staff. Client safety is a non-negotiable threshold in all clinical settings.
Confidentiality
Disclosure of a disability, health condition, mental health condition, or learning need is handled with strict confidentiality throughout.
- Information is shared with trainers and relevant staff only to the extent necessary to implement agreed adjustments
- Information is shared only with the student’s consent, except where a safety risk requires disclosure
- Disclosure does not appear on academic transcripts or external records
- Disclosure does not affect how a student’s work is assessed or how they are treated within the College community
- All adjustment records are stored securely and accessible only to the Director — Student Wellbeing & Progress and authorised administrative staff
Students are encouraged to disclose needs early — the earlier ASC is aware, the more effectively support can be planned. However, there is no deadline for disclosure. A student may raise a need at any point during their studies.
Proactive Identification of Needs
ASC does not rely solely on students identifying and disclosing their own needs. Trainers and staff play an active role in noticing when a student may be experiencing difficulty and responding proactively.
At Enrolment
All students are invited — but not required — to disclose any disability, health condition, or learning need that may affect their studies. This invitation is made through the enrolment process and is framed as an opportunity to plan support, not a gatekeeping mechanism.
During the Program
Trainers are expected to:
- Notice signs that a student may be struggling beyond what would be expected for their stage of training
- Raise observations sensitively and privately with the student before escalating to a formal referral
- Complete a Trainer Identification referral (via the Adjustment Request Form) where they believe a student may benefit from a formal adjustment
Signs that may prompt a trainer referral include (but are not limited to):
- Consistent difficulty with written assessments disproportionate to verbal ability
- Significant anxiety responses in clinical settings
- Difficulty reading or responding to client non-verbal cues across multiple sessions
- Repeated disorientation or difficulty navigating the floor environment
- Patterns of absence or disengagement that may indicate an underlying health or wellbeing issue
Important Note on Trainer Referrals
A trainer referral is not a diagnosis and must not be framed as one. Trainers identify observed behaviours and patterns — the Director — Student Wellbeing & Progress determines whether a formal adjustment process is warranted. Students are always consulted before any adjustment is actioned.
The Adjustment Request Process
Who Receives Requests
All adjustment requests — whether student-initiated or trainer-identified — are directed to the Director — Student Wellbeing & Progress.
Contact:
- Email: info@australianshiatsu.college.edu.au
- Phone: 03 9387 1161
- Online form: via the Adjustment Request Form
Step-by-Step Process
Step 1: Submission
- Student submits a self-referral via the Adjustment Request Form, or
- Trainer/college administrator submits an identification referral via the same form
- An automatic acknowledgement is sent to the submitter
- A reference number is generated and the request is logged in the Adjustment Register
Step 2: Initial Contact
- The Director — Student Wellbeing & Progress contacts the student within 5 business days of submission
- The purpose of this contact is to discuss the student’s needs, clarify any information, and begin identifying possible adjustments
- The student is not required to provide a formal diagnosis, though supporting documentation (e.g., medical certificate, specialist report, NDIS plan) may assist in identifying more targeted adjustments
- Where a student has been referred by a trainer, the student is contacted before any further action is taken — consent is obtained before the trainer is informed of any adjustment decision
Step 3: Assessment of Reasonableness The Director — Student Wellbeing & Progress assesses whether the proposed adjustment(s) are reasonable, having regard to:
- The nature and extent of the student’s need
- The adjustments available in an ASC context (see Part 2)
- Whether the adjustment compromises any inherent requirement
- The impact on other students and College resources
- Any evidence or documentation provided
Where the matter is complex or involves clinical safety considerations, the Director may consult with the relevant Course Coordinator or trainer (with the student’s consent).
The Director – Student Wellbeing & Progress Director consults with the Director – Education of Curriculum and Educational Content for all adjustments that affect the design, delivery, or marking of an assessment instrument. For adjustments limited to support services (e.g. note-taking, assistive technology, additional rest breaks outside assessment) consultation is at the coordinator’s discretion. This consultation is documented in the record.
Step 4: Decision and Documentation
- A decision is reached within 10 business days of the initial contact (Step 2)
- The decision is documented in the student’s file and the Adjustment Register is updated
- The student receives written confirmation of:
- Adjustments approved and how they will be implemented
- Any adjustments that were not approved and the reason
- Their right to appeal the decision
- The written decision is issued as a bilateral agreement. The student is asked to digitally sign and return the agreement. A copy of the signed or acknowledged agreement is retained in the student’s file and a copy is provided to the student. Where the student declines to acknowledge the agreement, this is recorded in the RA case notes with the date and manner of attempted contact.
Step 5: Implementation
- Agreed adjustments are communicated to relevant trainers and staff (with the student’s consent and limited to what is necessary)
- Adjustments are implemented as soon as practicable — typically before the next significant assessment or activity
- The student is invited to provide feedback on whether the adjustments are working
- Assessment instrument annotation (mandatory)
- Where a reasonable adjustment has been applied during an assessment event, the assessor must record a notation directly on the assessment instrument (whether paper-based or digital). The notation must include:
- the type of adjustment applied (e.g. extended time, oral response, quiet room)
- the date and time of the assessment event
- the assessor’s full name
- a brief statement of how the adjustment was implemented
- a brief statement of whether the adjustment was effective in enabling the student to demonstrate competency without compromising the integrity of the assessment
- This annotation becomes part of the assessment record and is retained with the student’s assessment evidence. Where a digital assessment platform is used, the notation is entered in the designated feedback field.
- Where a reasonable adjustment has been applied during an assessment event, the assessor must record a notation directly on the assessment instrument (whether paper-based or digital). The notation must include:
Step 6: Review
- Adjustments are reviewed at the end of each semester, or earlier if:
- The student’s circumstances change
- The adjustments are not working as intended
- A trainer raises a concern about implementation
- The student may request a review at any time
Timeframes Summary
| Stage | Timeframe |
|---|---|
| Acknowledgement of request | Automatic upon submission |
| Initial contact with student | Within 5 business days |
| Decision reached | Within 10 business days of initial contact |
| Implementation | As soon as practicable; before next significant assessment |
| Scheduled review | End of each semester |
If a Request Is Declined
Where an adjustment is not approved — either in full or in part — the student will receive:
- A written explanation of why the adjustment was not considered reasonable
- Information about alternative options where they exist (e.g., deferral, modified study load, alternative pathways)
- Information about the Complaints and Appeals process if they wish to challenge the decision
ASC will not decline an adjustment without first genuinely exploring whether any form of the adjustment is possible. A decline is a last resort, not a default.
Register and Record-Keeping
Adjustment Register
All requests are logged in the Adjustment Register (accessible to Director — Student Wellbeing & Progress and authorised administrative staff only).
The register records:
- Reference number
- Date of submission
- Student ID (not name — privacy protection at register level)
- Type of referral (student self-referral or trainer identification)
- Current status (pending / approved / partially approved / declined / under review)
- Review due date
The register does not contain the nature of the student’s need, diagnosis, or details of adjustments — this information is held in the student’s individual file.
Student File
The full adjustment record is held in the student’s file and includes:
- Completed Adjustment Request Form (Parts A or B, and Part C — decision)
- Any supporting documentation provided by the student
- Written decision and rationale
- Records of implementation and review
- Any correspondence related to the adjustment
All adjustment records are retained for a minimum of 7 years in accordance with the Records Retention and Archiving Policy.
Quality Assurance
Adjustment Register data is reviewed by the Director — Student Wellbeing & Progress at the end of each semester to identify:
- Patterns in adjustment types (which may indicate curriculum or delivery design issues)
- Whether adjustments are being implemented consistently
- Whether any systemic barriers to participation exist that could be addressed proactively
Findings are reported to the Directors’ meeting as part of the continuous improvement cycle.
Responsibilities
| Role | Responsibilities |
|---|---|
| Director — Student Wellbeing & Progress | Receives all requests; conducts reasonableness assessment; makes adjustment decisions; maintains student file records; oversees register; conducts semester review |
| Course Coordinators | Support implementation of approved adjustments; consult with Director on complex cases; ensure trainers are briefed appropriately |
| Trainers/Assessors | Implement agreed adjustments in delivery and assessment; observe and identify students who may need support; complete trainer identification referrals where appropriate; maintain confidentiality |
| Students | Disclose needs as early as possible; engage honestly with the adjustment process; provide relevant information or documentation; communicate if adjustments are not working |
| Executive Management | Policy oversight; resource allocation to support reasonable adjustments; final decision-making authority on unjustifiable hardship determinations |