SEN0167

Written evidence submitted by Tracy Jubb

I work for a borough council as a SEND Improvement Officer. I visit mainstream nurseries and schools in my role and have observed good and not so good practices in terms of SEND provision. I am also part of the LA’s SEND strategic team and understand the pressures on the LA as well as the pressures educational settings face. I have submitted the evidence below because I am passionate about improving outcomes for children with SEND. It still feels like families have to battle to receive appropriate support and provision for children with SEND. The current system is broken and the demands/expectations on services is resulting in quality practitioners feeling overworked, disillusioned and seeking employment in other sectors with fewer challenges.

1. Support for children and young people with SEND

• The quality of SEN support in mainstream schools and EYFS settings is not consistent. Not all MATs prioritise SEND. Challenges for some settings is capacity and funding.
• There are many training modules and resources on inclusive practices but not all settings engage. SEND/Inclusion training needs to be mandatory for all staff just as safeguarding training is.
• Before requesting an EHC needs assessment settings must evidence a graduated response and parents/carers should have a legal means of address if this has not happened. Create an education ombudsman similar to the LGSCO whereby schools and settings are fined and/or reprimanded if SEN Support has not been provided when there is a clear need.
• It is difficult to recruit TAs when pay and conditions are not as good as jobs in industry. We are expecting poorly paid TAs to work with some of the most complex and vulnerable children in our schools and expecting good outcomes.
• There are inconsistencies in time SENCos are given for the role. Many have teaching commitments and other areas of responsibility which can impact on timely identification and intervention.
• Substantive training is readily available for settings but the time and cost of training can make it difficult for staff to be released to access this. Make SEND training mandatory similar to the safeguarding training staff are expected to complete.
• Special schools and PRUs are oversubscribed. It makes it difficult for any outreach and pro-active work to be offered to mainstream settings. Specialist staff are highly skilled and experienced and could provide effective advice and support to mainstream settings but they do not have the capacity.
• The threshold to agree an EHC needs assessment is too low. Due to the inconsistencies in SEN Support parents and carers are wanting an EHCP to secure specialist provision. Agencies are being swamped with requests for statutory written advice which is impacting on early intervention work resulting in more children with unmet needs.

2. Current and future model of SEND provision

• With pressures on budgets there need to be more shared services across a region or sub-region. For example, low incidence regional teams such as those for MSI, Down’s syndrome, communication aids.
• Independent special schools are able to dictate cost of placements and often price increases have been above rates of inflation. Prices should be capped especially for those places already commissioned. It is difficult to move a child from a school they have attended for a few years simply based on costs.
• Promote use of inclusion hubs within mainstream schools. Many of our schools do this well with clear assessment criteria, rationale, curriculum offer and staffed by a skilled teacher whereas others do not. DfE to provide guidance on how these types of inhouse provisions should work and make sure Ofsted inspectors understand that for those pupils with more complex needs inclusion is not always about being present in a mainstream class for the majority of the time.
• There needs to be more emphasis on life skills and vocational curriculums for those who will be unable to get GCSEs in the wider curriculum.
• The SENDAP has resulted in better quality assurance of AP. Schools need to continue to consider if AP is in the best interests of the pupil and have clear intended outcomes for placements.
• There needs to be more timely responses when pupils are at risk of persistent school absence or exclusion e.g. access to emergency top-up funding until an EHCP review can be completed. The 8+ weeks required to complete a review and agree future provision can result in a small number of pupils missing education. During this time many of these pupils experience increasing mental health issues and no longer wish to return to education.
• LAs need to have greater powers to over-rule decisions on permanent exclusion if found to be discriminatory. Direct schools to fund AP rather than permanently exclude. Complete assessments similar to EHCNA to identify if more specialist/alternative provision is required.
• Some early years and school placements for children with medical needs should be joint funded by health and LA (HNB). Funding to link to the provision stated in the health care plan.
• Post 16 education, training and employment offers need to be wider. YP that are neurodiverse without a learning disability struggle to find FE providers able to meet needs. Settings are either too big or too specialist. Those on a supported internship struggle to get placements. All public sector organisations should offer a minimum number of internship placements.

3. Finance, funding and capacity of SEND provision

• There needs to be a more equitable SEN funding formula. More inclusive mainstream settings. Independent and NMSS schools to be capped on placement prices.
• The cost of additional adult support has increased significantly – pay rises, minimum wage increases, NI increases etc. Element 2 and Element 3 funding has not kept pace with this which has reduced the amount of additional support that can be provided. EHCPs may state full-time one-to-one support but in reality, many schools cannot afford this with the SEN funding provided.

4. Accountability and Inspection of SEND provision

• Inspection of inclusion should be based on the Whole School SEND Framework. Many schools use this when completing SEND peer reviews and it could be adapted.
• LAs should be able to direct academies to admit children with EHCPs rather than having to appeal to the Secretary of State.

January 2025