SEN0444
Written evidence submitted by National Association of Head Teachers (NAHT)
- NAHT welcomes the opportunity to submit evidence in response to the Education Committee’s inquiry - assessing the current system of children’s social care in England.
- NAHT is the UK’s largest professional association for school leaders. We represent more than 38,000 head teachers, executive heads, CEOs, deputy and assistant heads, vice principals and school business leaders. Our members work across: the early years; in primary, special and secondary schools; independent schools; sixth form and FE colleges; outdoor education centres; pupil referral units; social services establishments and other educational settings, across England, Wales and Northern Ireland.
- In addition to the representation, advice and training that we provide for existing school leaders, we also support, develop and represent the school leaders of the future, through the middle leadership section of our association. We use our voice at the highest levels of government to influence policy for the benefit of leaders and learners everywhere. This puts us in an excellent position to provide evidence to this inquiry.
SEN support in mainstream schools and early years settings
Defining inclusion
- Schools seek to support every pupil to make progress, experience achievement and thrive. However, several factors, many beyond their control, have over the last decade or more made this particularly challenging when supporting pupils with SEND.
- One challenge in addressing SEND system shortcomings, remains the availability of high-quality data which contains sufficient granular detail. NAHT called on the previous government to publish the available provision against the known levels and types of pupil need. To establish baseline of need and find improved solutions for sufficiency in the future, such granular detail is essential.
- The current government commitment to develop a more inclusive education system is welcome. An articulated vision of ‘inclusion’ is needed to illustrate what this will mean in practice across the whole system, not just for early years or mainstream settings - specialist settings must be part of an inclusive offer to pupils.
- Different pupils need different environments – both in size (numbers on roll) and school type. Inclusion is as much about pedagogy, as it is about the type of setting.
- Inclusion cannot be realised by simply expecting mainstream settings to support more pupils with SEND (previously placed in specialist settings) without the essential extra funding, trained expertise and support (including from external services, such health and social care).
- Historical insufficiencies in mainstream core budgets resulted in erosion of staffing capacity. This resulted in a reduction in schools’ ability to intervene early and provide timely support for pupils with SEND. Therefore, some pupils don’t receive early support and subsequently require intensive intervention (or even formal assessment) once challenges have escalated over time. This is an ineffective use of precious resources. Core budgets need to be bolstered to enable schools to once again respond swiftly with SEN support.
- Strong evidence must direct the most effective support for pupils with SEND, and this understanding needs to be knitted throughout the professional development of leaders, teachers, and support staff. From initial training to ongoing career development, each professional requires high-quality, fully funded, SEND and inclusion training. Existing school budgets cannot support this.
- The opportunity to include aspects of inclusive practice beyond just SEND should also be explored.
- Inclusion cannot be realised by just establishing new SEN Units or Resourced Provision in mainstream schools. The risk in only focusing on this provision is that it may reduce the numbers of pupils in special schools, but they could still remain largely separate from most of the mainstream pupil population, which is not inclusion.
- The inclusion vision is not just for mainstream settings, it must be truly ambitious and far reaching and must describe a whole inclusive educational landscape and be focused on ensuring every pupil is supported in the most appropriate setting that best meets their needs. This means there will remain key roles for mainstream, special schools, alternative provision (AP) and all other types of settings.
- inclusion must encompass the entire spectrum of education, including AP. AP plays a critical role in supporting pupils with complex needs, particularly those who may face challenges in maintaining placements in mainstream settings due to unmet needs, social-emotional challenges, or other barriers to engagement. A truly inclusive system must articulate the distinct contributions of AP in ensuring every pupil is supported in the most appropriate setting to thrive academically and personally.
- NAHT remains concerned about the placement of pupils in mainstream, Pupil Referral Units (PRUs), or other forms of AP without sufficient regard to their specific needs. Often, these settings are underfunded or lack the specialist resources and training required to meet the increasingly complex needs of the pupils they support. Any overhaul of the SEND system must address this imbalance, ensuring AP settings are equipped to provide high-quality, needs-led support.
- Challenging behaviour that can lead to exclusion is often a manifestation of unmet or unsupported SEND. Properly resourced AP, integrated into the broader education system, can provide a vital pathway for pupils needing tailored, focused interventions. Schools and AP settings must work collaboratively, with adequate multi-agency support, to facilitate early identification of needs and smooth transitions between settings, avoiding unnecessary exclusion.
- Funding and facilitating a role for special schools that includes continuing a core educational role alongside outreach and training should also extend to AP. Like special schools, AP settings hold significant expertise in managing complex and challenging behaviours, which could be leveraged to support mainstream and other settings through outreach, professional development, and shared resources.
- Some pupils benefit from flexible arrangements that include time spent in AP alongside mainstream or special schools. For example, AP can be a temporary intervention that enables pupils to address challenges, develop coping strategies, and reintegrate into their primary educational setting. For others, longer-term placements in AP may be necessary and appropriate to ensure they receive the personalised support they require.
- The government must recognise AP as an essential component of a fully inclusive system – it cannot be seen solely as a last-resort option for excluded pupils. Instead, AP should be positioned as a proactive and preventative resource that contributes to the early intervention agenda. Investment in AP should include workforce training, funding, and cross-agency collaboration to ensure it can deliver its full potential in supporting pupils with SEND.
- Special schools should not become a one-size-fits-all provision due to funding pressures, and the government should fully support specialist SEND provision, including resourced mainstream schools and specialist support services.
- NAHT remain concerned about the current process of identification, allocation and placement of pupils with additional needs and our members want an overhaul of the dysfunctional system that perpetuates the unsuitable placement of pupils in mainstream, PRUs or AP which may be unable to properly meet their needs.
- NAHT recognises the work of schools in managing pupils with complex needs. Clear pathways and proper support networks must be established to support those pupils who can compromise the safety and academic focus of others.
- In a truly inclusive system, parental choice must remain. Parents of pupils with SEND should have an equal right to demand places in special schools or mainstream schools, as they judge appropriate for their children. Local authorities (LAs) should be equipped to be accountable for ensuring there is sufficient specialist provision in their area, including for children under 5.
- Government must consider the full range of essential components in the education system - funding, workforce expertise and capacity (both education and other specialist staff), curriculum & assessment, school performance measures and other school accountability systems.
- Each needs to be reviewed and improved through the lens of inclusion - especially how the whole system incentivises supporting the progress and celebrating the achievement of all pupils, including those with SEND.
- An effective system should mean that funding for SEND provision is provided wherever the pupil is educated. When pupils move between settings, receiving schools should not face delays in accessing the SEND funding / provision required.
- NAHT’s funding survey of members in 2024 produced findings in relation to SEN:
- 99 per cent reported that funding for pupils requiring SEN support (with no EHCP) is insufficient.
- 99 per cent reported that the funding they receive to fully meet the needs of all pupils with EHC plans is insufficient
- Vast majority reported that they were diverting funding from core budget to address insufficient funding required for health (85 per cent) and social care provision (88 per cent).
- Government must provide increased and protected new funding for children with SEND for a minimum of three years, to maximise meaningful support and enable schools to build capacity.
- National formula for high needs sought to allocate funding to LAs on the basis of strong proxies of need, however, real terms impact on school budgets since 2015, increasing numbers of pupils with SEND, and growing complexity of additional needs, means government must review the quantum and distribution of high needs funding to ensure it is sufficient, and targeted effectively.
- One challenge in developing greater inclusivity is the burden of high-needs underinvestment by the previous government and subsequent overspend in LAs. NAHT believe the government should cancel all LA high-needs deficits to stop the current level of debt consuming any new funding set aside for pupils with SEND.
- Early years and mainstream schools also require fully funded SEND training for staff, but current CPD budgets are insufficient.
- The schools’ core and high-needs funding crisis, and unrelenting pressures on health and social care services, threatens the ability of mainstream schools to be inclusive.
- A consistent, uniform level of per pupil resource provided to mainstream schools is essential, alongside a pooled procurement system for purchasing SEND resources to be used to provide support to children with SEND.
Improving inclusive practice and workforce implications
- Schools fill health and social care funding and provision gaps. Wider accountability requires strong levers to ensure health, social care and other support services are held to account if they do not fulfil their respective duties.
- Specialist support staff – e.g. speech and language therapists – see themselves as part of the solution in providing a more inclusive mainstream education system.
- With sufficient specialist staff capacity, earlier intervention becomes easier, as does implementing ambitious, realistic timescales for formal assessment. When working collaboratively around the child, a resourced multi-agency approach can make a significant difference.
- The SENCo role has become a huge, varied and significant role and has grown in responsibility. Government should establish a unified definition of the SENCo role, that encapsulates core expectations and describes other potential aspects of the role for training purposes. A definition agreed and accepted by the whole profession and not simply a chosen ‘expert’ group, including SENCo practitioners, will secure far greater buy-in.
- When seeking to improve the effectiveness of multi-agency and joined up working cross education, health and social care, the implementation of health provision needs to be legal and safe.
- For children who require health provision whilst at school, system-level change is needed. Current DfE statutory guidance on supporting children with medical conditions does not describe clear parameters specifying the health care that schools can directly provide and fails to recognise the concept of legal delegation of NHS care at an individual or organisation level.
- The Children and Families Act 2014 Section 100 duty on schools is for them to ‘make arrangements’ to support pupils with medical conditions; however often through under the umbrella of reasonable adjustments, the accepted narrative has become that ‘schools must provide what is needed’. This narrative sidesteps the legal obligations of the NHS and positions schools as a substitute NHS service. This does not align with the legal framework and creates acute local issues between schools, NHS practitioners/commissioners and LAs, as well as for school support staff who are in some cases expected to deliver NHS care with minimal or no NHS-commissioned clinical support – sometimes outside of the appropriate legal, governance or regulatory frameworks.
- This practice jeopardises the safety of both staff and children. A compliant solution must be found, which puts the right people in the right place to provide care. This should include an NHS-commissioned, needs-led clinical school nursing service for schools, alongside the LA-commissioned public health nursing service. Ensuring safe care for pupils with medical needs must be a top priority.
Education, Health and Care Plans
- For EHC plans to retain genuine value, they need to be supported by the administrative capacity to keep them current and therefore regularly updated. This means appropriately funding LAs. The current number of EHC plans and increasing requests for assessment risks completely overwhelming LAs.
- Health bodies frequently fail to feed in information to annual reviews. When specialist workforce is sufficiently resourced, capacity is created for all consultees to be included for proposals that require agreement to an EHC plan, including where a change of school / setting is proposed.
- Inclusion means appropriate school placement. NAHT believe change of school placement consultation should only occur when schools are fully available to provide evidence i.e., not during summer recess. Only extremely rare, unavoidable circumstances should result in LAs requesting such information during school recess periods.
- National consistency is key. We welcome the development of a digital EHC plan template, that retains enough flexibility to meet pupil needs.
- Each LA has a slightly different Annual Review format which creates huge, unnecessary complexities for special schools who can often support pupils from across multiple LAs. For EHC plans to maximise their impact, Annual Reviews also need to be standardised.
Current and future SEND needs
- Pupils with SEND deserve qualification routes that recognise their specific needs, and values them as learners equal to their mainstream peers. The way schools are measured as ‘successful’ doesn’t sufficiently recognise the progress and achievement of all pupils.
- NAHT adopted the social model of disability - we would urge policy makers to follow suit to develop greater inclusivity.
- The model helps develop solutions that focus on removing obstacles - systemic, attitudinal, communication and environmental barriers. It can be applied to the current system through the lens of pupils with SEND (and other groups) – removing barriers so every pupil can thrive.
- School leaders believe in inclusion, but are hampered by existing obstacles, e.g. schools funding mechanism – which is insufficient, provides only short-term certainty and inhibits strategic planning and capacity building.
- The most recent school capacity data showed that special schools are at least 4000 pupils over capacity.
- Numbers of pupils with SEND are supported in mainstream settings who, following formal assessment, require a special school / specialist place. However, there is no space available.
- To provide urgently needed stability, mainstream schools must be provided with equitable funding as would be received by special schools when the child has to attend a mainstream setting instead, due to lack of specialist capacity.
- An overarching workforce strategy is required so that for assessment, identification of needs, provision of support, there are appropriate numbers of sufficiently trained specialist staff, e.g. Educational Psychologists.
- Government must work with representative bodies of the specialist professions to develop a clear understanding of the current capacity compared to the current workload / level of pupil need.
- Understanding and compelling whichever sector is responsible for each aspect of support to deliver it is essential. The aspiration for all in the system must be beyond a set of minimum standards.
- As part of a truly inclusive system, behaviour expectations within a school need to be fully accessible and achievable for all pupils, including those with SEND.
- There are examples of excellent SEND practice and expertise within the school system, especially in the special school and AP sectors. NAHT were disappointed that the SEND Green Paper did not appear to explore this opportunity sufficiently, and describe how the wider system, and especially early years and mainstream settings, should benefit from the expertise within the specialist sector.
- Funding and facilitating a role for special schools that includes continuing a core role of education for pupils with the most complex needs alongside an outreach training and support role, in similar way that was described for alternative provision in the Green Paper, must be explored.
- Pupils with SEND are supported in all types of educational setting. Dependent upon the type and complexity of need, and the resource, provision and expertise available, the appropriate setting for a particular pupil’s education can and will vary. Some pupils with SEND can flourish and be well supported in early years and mainstream classes (with the requisite resource and staffing), as well as the right health and social care support in place, where necessary.
- Others are better supported in a mainstream SEN Unit – with the same consideration of additional resource / support. Some pupils with SEND will always require full-time provision most appropriately delivered in specialist settings.
- A few may require a flexible approach between settings – for a number this may be required on a temporary basis, for others, the flexible mix may be required longer-term. The focus should always be on what is in the best interest of the pupil and ensuring whatever the setting, each is furnished with the required resources and support to provide an excellent educational experience.
- To improve the quality of SEN support in mainstream schools and early years settings, it is too simplistic to just look at numbers of children and young people with SEND – SEND is too broad a term. More specific types of needs must be looked at alongside the numbers of special schools, and mainstream SEN Units and resourced provision.
- It remains unclear to NAHT how the Department for Education are able to accurately coordinate the SCAP and Net Capacity Assessment process, alongside the pupil census data in order to calculate the required capacity in SEND provision across early years, mainstream, and SEN Units / resourced provision, special schools, without more granular data on pupil needs.
- NAHT understand that the type of SEND supported by each special school / SEN Unit / Resourced provision is not understood well enough at a national level at present and neither is SEND capacity in early years settings.
- This appears to be a particular issue as the type of need does impact upon the type of provision required and the SEND capacity available. For example, some pupils with sensory and/or physical needs, especially if they require mobility aids, may require far more space and a higher staff to pupil ratio, whether in a specialist setting or mainstream setting. This data impacts on budget, staffing and training.
- Understanding if we have the right type and mix of settings to meet the range of specific needs of pupils is essential for sustainable long-term planning. It will also prove essential for the government to fully commit to their inclusive education plans.
January 2025