SEN0486

Written evidence submitted by London Southeast Academies Trust

Background Context

London South East Academies Trust (LSEAT) is a mixed Trust, and was established in 2013, by Bromley College (now London South East Colleges). With our college sponsor already providing high quality pathways into vocational training, apprenticeships, higher education and careers, we had the capacity and expertise to help improve the life chances of all children and young people, no matter their interest, ability, special educational need or background. Giving these young people the opportunity to progress into further education and beyond to employment, independent living and adulthood was, and remains a priority for both our Trust and our College. Being able to support children and young people at an earlier stage is fundamental to improving their life chances and outcomes and so the strategic alignment between our Multi Academy Trust and the College has enabled us to systematically influence and develop the SEND system right across the region in which we operate.

Our Trust is committed to raising attainment, encouraging aspiration and supporting social mobility for every single child and young person. LSEAT’s projected turnover for 2024/25 is £55.6m, with 3000 pupils spread over five mainstream primary schools, two alternative provisions, four schools for pupils with Social, Emotional and Mental Health needs and two specialist schools, one for Autism and the second for pupils with Profound Multiple Learning Disabilities/Severe Learning Difficulties. Bexley Music is also part of our Trust, which is based at Belmont Academy (one of our primary schools) and is the lead music provider in the Borough. It works with schools, community groups and individuals, offering high quality musical education and opportunities to people of all ages across the region.

Many pupils and their families across our Trust’s schools face significant economic challenges as well as special needs and learning difficulties – with eligibility for free school meals (FSM) that is 2-3 times the London average. 26.8% of our children live in the top 30% most deprived areas by IDACI. Even in our relatively well-off areas such as Bromley and Surrey, we support the most disadvantaged learners. For example, 88% of students at our specialist school in Bromley are eligible for free school meals meaning we cater for ‘islands of disadvantage.’ These learners are also more likely to be affected by multiple layers of disadvantage, reporting special needs and a greater likelihood of being in care in addition to their financial disadvantage. For example, 13.7% of one of our Bexley specialist secondary’s pupils were Children Looked After (CLA). At the same time, a high proportion of these pupils are eligible for FSMs and have EHCPs. This means several of our pupils are at high risk of becoming NEET post-16, meaning we have adopted curriculums that are destination-led for the best possible outcomes.

Support for children and young people with SEND

Defining what inclusivity in mainstream schools and early years settings should mean and look like in practice

For us, inclusivity means that all students are given the support they need to access a curriculum that enables them to fulfil their potential and thrive. This includes both internal and external support, from a range of specialist therapists. This support should not only enable pupils to progress academically but also foster their sense of belonging. We are convinced that belonging needs to be key to children’s experience in education, in a way that encourages their sense of acceptance and wellbeing. Maslow’s hierarchy of needs[1] places belonging in the middle layer of needs and in terms of importance. A sense of belonging can only emerge after physiological, security and safety needs are met and is key to support the higher layers such as achievement and self-actualisation which are the focus of education. When serving children with the levels of deprivation we have described earlier, one can see the additional challenges SEND children and young people may face in feeling that they belong.

Furthermore, in the wider inclusion context, we see real synergy between intersectionality in Equity, Diversity, and Inclusion (EDI) and the concept of belonging in the SEND (Special Educational Needs and Disabilities) system. Both share some common principles, though applied to different contexts. 

Intersectionality in EDI

Intersectionality is a framework that examines how various social identities (such as race, gender, class, and disability) intersect and create overlapping systems of discrimination or disadvantage. It recognises that individuals can experience multiple forms of oppression simultaneously, and these experiences are interconnected rather than isolated.

Belonging in the SEND System

In the SEND system, the concept of belonging goes beyond mere inclusion. It emphasises creating an environment where all students, regardless of their abilities or needs, feel valued, accepted, and integral to the community. This approach ensures that students with SEND are not just present in mainstream settings but are actively supported to thrive and participate fully. Common principles across EDI and the SEND system include recognition of diversity, a focus on equity, a holistic approach and empowerment and advocacy. We think there is merit in considering system reform from this perspective and building on what has worked in this space.

Curriculum Design

Any attempt to generate a common understanding of inclusivity in mainstream, needs to be in line with the review of the national curriculum. Children with SEND face many barriers when accessing the curriculum, such as struggling with constantly changing topics due to the amount of content expected to be covered in a short period of time. The current assessment system favours standardised tests and written exams which are less accessible for SEND pupils. This is why young people with SEND are over-represented in the cohort of learners who have to resit their GCSEs at post-16 education. As the Education Policy Institute has shown, students with SEN support are around 40% less likely to pass English and maths whilst students with EHCPs are 40% and 28% less likely to pass English and maths, respectively[2].

Additionally Resourced Provisions in mainstream schools

A new model of mainstream inclusion should not be pursued at the expense of the specialist sector. The rapid growth of Additionally Resourced Provisions (ARPs) raises concerns that cost-driven motives are overshadowing the need to maintain specialist expertise and skills in the SEND sector. Effective inclusion requires clarity, collaboration and transparency, not competition between mainstream and specialist provision. Both must co-exist to meet the diverse needs of children, but we are seeing worrying trends where mainstream schools with tight budgets are competing with specialist settings for the same funding opportunities. These practices risk deskilling SEND professionals and undermining the quality of support for children with complex needs, which must remain a priority. We firmly believe that inclusivity can be achieved in mainstream education while a proportion of pupils have their needs met in specialist settings.

Outcomes for children and young people with SEND and how these can be improved

At the same time that we urge the government to provide a common definition of inclusivity in the education system, we would like a review of what is understood by ‘outcomes.’ Currently these are mainly focused on academic outcomes, such as achievement and progression rates. While transition into employment is often included as an outcome for older learners, we believe that this definition should be broadened to include a holistic approach that considers other areas of student’s personal success. This applies both for children with and without SEND.

Current attainment measures do not promote inclusion as we have defined it in the answer above, because they do not support children with SEND. Measures of attainment need to be redefined in order to capture the success of every child who is able to achieve to the best of their ability from their starting point. This demands a rethink of the assessment system and what education is ultimately for.

A new outcome framework could look at best practice from the Preparing for Adulthood programme created by National Development Team for Inclusion (NDTi), commissioned by the DfE to support the SEND reforms[3]. This framework includes outcomes in employment, independent living, community inclusion and health, from early years to post-19 education. This would broaden the focus from academic success to a more holistic approach that supports children with SEND.

There is currently little confidence among parents in the SEND system, as evidenced by the number of successful appeals against SEND tribunal decisions.  This means the SEND system is characterised by confrontation rather than collaboration. Parents know their children best individually, mostly in the home environment, and therefore have a key role in ensuring their child can meet the outcomes set out in their EHCP, particularly being prepared for transitions into further education. Thus, stakeholders such as Local authorities and MATs should focus on collaborating with parents, starting with strong engagement so the system can start to function in a collaborative way, prioritising children’s interests rather than creating counter-productive division, affecting the joined-up support they need.

Workforce issues for teachers, SENCOs, specialists, early years practitioners and all those who work with children with SEND

Recruitment challenges prevent schools from generating truly inclusive learning environments. The government has focused so far on the recruitment of 6,500 new teachers, which is part of the solution. However, an additional programme is needed to support the recruitment of support roles, including teaching assistants and specialist therapists, particularly educational psychologists, occupational therapists, and speech and language therapists. These roles, along with SENCOs, are fundamental for enabling teachers to fulfil their role in the classroom. Teachers need input from the diagnoses produced by different specialist therapist to know how best to personalise learning to individual pupils.

A comprehensive strategy to recruit for specialist therapist roles needs to consider the pipeline of skills entering the healthcare sector, supported by the NHS Long Term Workforce plan[4]. Local authorities and schools currently struggle to find the required services due to a lack of workforce available with the level of expertise that is required. Regional and local partnerships with higher and further education providers have to be at the centre of a strategy to train this workforce and could be connected into future iterations of Local Skills Improvement Plan developments, informing priorities and investment interventions in the skills systems. Incentives on the supply side need to include higher salaries for roles such as educational psychologists who are employed in local authorities to review EHCPs.

Teachers also rely on the day-to-day support of teaching assistants during class. However, this is one of the hardest to recruit vacancies in the sector due to historical low salaries and high demands that made them competitive compared to jobs in other sectors. These support roles are also the one most in risk of redundancy when schools need to make efficiencies amidst tight funding. One way here at LSEAT that we have tried to address this is by successfully partnering with our Trust’s founding sponsor, London South East Colleges and the local DWP provider to run Sector Based Work Academy Programmes (SWAPS) addressing entry level role into education and health.

Other support roles, such as SENCOs, are under great workloads due to administrative tasks that reduce their capacity to impact the quality of teaching and support that pupils receive directly. The Workload Reduction Taskforce[5] has not yet produced specific recommendations on how to reduce the administrative burden on SENCOs for which further review, and guidance is needed.

Finally, early years needs to be a priority in terms of recruiting experienced staff that can deal with the level and complexity of needs coming through the system from this stage. Investment in early identification of needs is critical, particularly in the early years, where timely intervention can make a significant difference in a child’s development and long-term outcomes. However, the current lack of professionals means many children’s needs go undiagnosed until much later, making support less effective and more costly. For instance, around 60% of children in SEMH schools have speech and language difficulties. Addressing these early on would prevent the frustrations and communication barriers that often lead to exacerbated SEMH issues, improving long-term outcomes for children. Improving recruitment, pay, and working conditions across all SEND professions must be a priority to ensure children receive the right support as early as possible.

What substantive training is needed for teachers, teaching assistants and all those who work with children with SEND to improve knowledge of SEND and pedagogical approaches to teaching SEND Children to increase their inclusion in schools?

Although the Initial Teacher Training (ITT) Framework has been developed and improved, it still does not incentivise trainees to join specialist schools and alternative provision (AP) settings. SEND training is still seen as an additional, rather than being integral to the ITT. This is no longer sustainable with a rising number of pupils with SEND, including among those in mainstream schools. A truly inclusive education would require every mainstream and early years teacher to be a SEND teacher. We believe that the way to achieve this would be to make completing a SEND placement mandatory in the ITT.

This would not only improve training in the teaching workforce but would also make recruitment easier if some weeks of practice in specialist schools and AP settings was made compulsory as part of the training. Trainees often know little about how these settings differ from mainstream schools and early career teachers may have many misconceptions about them such as the pupil-teacher ratio or the level of support available in classroom.

Additional to changes in the ITT Framework, there needs to be a focus on continuous professional development. We support initiatives such as Whole School SEND which have provide the mainstream sector with relevant online resources[6]. The DfE needs to be complement this with a stronger in-person offer that can be personalised to make it relevant to each setting.

The role of and capacity of specialist schools, independent schools and AP

Specialist schools and AP settings play a vital role in the education system, enabling mainstream schools to continue supporting the majority of pupils. However, despite the increasing number of pupils being suspended or permanently excluded, AP settings have not received the necessary attention and support. These settings provide nurturing environments for pupils who may have undiagnosed needs and struggle with the larger class sizes in mainstream schools.

Our AP teams assess each pupil’s needs, which may involve supporting the process of requesting an Education, Health and Care Needs Assessment (EHCNA), and identifying specialist or mainstream settings that can better meet their needs within a 12-week period. For pupils excluded at Key Stage 4, we ensure they receive both academic and pastoral support, enabling them to sit their assessments, including GCSEs.

AP settings also play a key role in promoting inclusivity in mainstream schools through their outreach services. Our highly experienced outreach team at LSEAT works within pupils' school settings to support children at risk of exclusion. Their primary aim is to prevent exclusion by providing direct support to both the school and the pupil. Our multidisciplinary team of experienced professionals conducts on-site needs assessments and collaborates with school staff to develop strategies for re-engaging individual pupils in learning. While their main focus is on social, emotional, and mental health (SEMH) needs, they also identify overlapping challenges and tailor support to help pupils remain in mainstream education.

This is a costly service due to the high level of professional expertise required. Currently, it is funded by the local authorities of Bexley, Bromley, and East Sussex. However, it has proven to be a highly cost-effective solution, as 75% of the pupils we support successfully remain in mainstream settings – significantly reducing the costs associated with exclusion and placement in AP or specialist settings.

With the increasing number of pupils at risk of exclusion and a government push for greater inclusivity in mainstream schools, AP settings must receive the necessary support to strengthen and expand their outreach services. Securing funding to recruit the right team of experts will be key to achieving this. As a multi-academy trust working across various local authorities, we have been able to pool resources to sustain this effective team. Similar economies of scale could be incentivised in other regions relocating the LSEAT model which has been so successful.

Finally, independent schools fill gaps where local authority provision is insufficient. While we recognise the demand for these schools, particularly for children with profound and multiple learning disabilities (PMLD), we believe the DfE should conduct a cost-benefit analysis of this provision. Understanding the impact of independent settings compared to local provision is crucial. Sufficient capital and revenue investment should be allocated to strengthen local authority provision, reducing long-term reliance on independent and out of borough providers. A good example of where this type of approach is emerging is in our Heron Academy provision in Lambeth which is a feeder school to the High Needs provision of London South East Colleges, Nido Volans Lambeth. Both were previously failing provisions but through a strategic partnership between the Local Authority, us as a Trust and our Sponsor College LSEC, we have a blueprint for sustainable local high needs offer and a significant step forward in system alignment for longer term SEND planning.

What can be done to support parents, carers and children or young people before, during and after the EHC Plan process?

To support parents, carers, and young people throughout the EHC Plan process, clear and consistent communication is essential. Awareness campaigns should ensure that all families understand their rights and the support available. There is an imbalance in how schools and local authorities approach the process – while some schools have a key role in signposting and providing good guidance, some local authorities are incentivised to generate barriers, making it harder for families to access the support they need.

The process can be costly, putting some parents at a disadvantage. Funding and support should be made available to support those who may struggle to navigate the system, building on the approach of SEND Navigators (like Health Navigators), in Cornwall Local Authority. Additionally, the annual review should be a key moment to assess whether the EHCP remains necessary, ensuring it continues to meet the child’s needs effectively. Strengthening these areas will create a fairer, more accessible system that genuinely supports children and young people.

Current and future model of SEND provision

How does SEND provision vary between local areas and what can be done to promote consistency of approach?

Despite having a standard place funding £10,000, SEND provision varies significantly between local areas due to disparities in banding systems, creating a postcode lottery that affects the level of support children receive. In areas with lower top-up funding, there is greater strain on the system, leading to fewer assessments, reduced support, and more children being placed in costly independent settings. To promote consistency, top-up funding should be formalised through a national banding system that ensures all children have equitable access to the support they need regardless of where they live. Funding per pupil across our schools ranges from £13k to £26k which means that we cannot provide the consistency that we would like for pupils in our Trust where the costs of living and recruitment pressures can escalate so close to London and more affluent areas like Surrey.

A key difference between local authorities is how therapy services are funded and delivered. For example, in Surrey, therapies are provided centrally, whereas in Bromley and Bexley, funding is given to schools to commission their own services. This leaves gaps in assessment and intervention where no systemised provision is available and places the burden of commissioning healthcare services on schools. Without sufficient in-house professionals, some local authorities fail to meet statutory requirements. A more consistent national approach to funding and delivering specialist services is fundamental to solving issues in the SEND system and would equally help the new Integrated Care Service structures which have been implemented in longer term planning.

What can be done to improve the effectiveness of multi-agency and joined up working cross education, health and social care?

Multi-agency working across education, health, and social care is often inconsistent, with EHCPs primarily focused on education and limited input from health and care services. These sectors should be held accountable in the same way as schools to ensure a truly joined-up approach. There are major inconsistencies in access to external therapists and reviews to EHCPs. A national model for multi-agency collaboration would help standardise support. Embedding the principles of operating as Anchor or Public Institutions in this approach would support the delivery of better outcomes and greater public and social value.

High staff turnover in social care and multi-agency teams further disrupts continuity, making it difficult to build effective working relationships. This relates to challenges in recruitment and retention of workforce in the sector, as highlighted above. Reducing reliance on agency staff and improving retention through better pay and working conditions would enhance stability, ensuring that children receive consistent, high-quality support across all sectors.

How can specialist provision, especially support for conditions which occur infrequently but give rise to the need to a high level of support and which may be beyond the capacity of individual local authorities, best be provided and commissioned?

Many schools provide excellent support for children with profound and multiple learning disabilities (PMLD), but some needs are so complex that even the best-equipped settings struggle to meet them. In these exceptional cases, the specialist independent sector plays a valuable role. It should be reserved for the most complex needs rather than more common conditions like SEMH.

Regional commissioning could ensure access to highly specialised provision while reducing reliance on independent placements over time. Investment in training and workforce development is also crucial, as the level of expertise required to support these children is immense. Strengthening local authority provision where possible, while recognising the need for a niche independent sector, would create a more sustainable and effective system.

How can innovation be encouraged across the system to address the current pressures and challenges?

Innovation is often limited by funding constraints, staffing shortages, and the intense day-to-day pressures within the system. Many professionals are so focused on managing immediate challenges that they have little time or capacity for strategic thinking and innovation. Addressing recruitment and retention issues in education is crucial to innovation; without a stable workforce, it is difficult to step beyond operational demands. The government could replicate the highly successful Cabinet Office delivered Leadership Programme for Leading Collaborative Organisations[7] with a focus on the requirements of cross system planning and collaboration for SEND reform.

What can be done to reduce the disproportionately high exclusion rates for students with SEND?

There is a clear need for mainstream schools to become more inclusive and reduce the suspension and permanent exclusion rates, which almost doubled between the autumn terms of 2022/23 and 2023/24[8]. This will require additional resources for early identification of needs and support both in and outside the classroom, as well as a cultural shift that promotes a sense of belonging. Continuous professional development for staff is essential to ensure that teachers and support staff have a deep understanding of SEND and how to meet individual needs effectively. Exclusion should not continue to be normalised as a means of managing behaviour -persistent disruptive is the most common reason for both suspensions and permanent exclusions nationally. Additionally, the curriculum and assessment systems must be reformed to accommodate diverse learning needs, reducing the pressure on schools to exclude pupils based on forecast achievement.

Finance, funding and capacity of SEND provision

Is reform needed for funding of SEN support provision in schools, where currently the school is responsible for funding the first £6,000 of provision?

The current notional £6,000 funding should remain flexible, allowing schools to use it in the way that best suits their needs. This is key for the funding of a range of SEN professionals, including SENCOs. However, additional funding should be allocated directly to the pupil to ensure that the support required for their needs is fully met.

Accountability and inspection of SEND provision

What should Ofsted's new 'inclusion' criterion for the inspection of mainstream schools look like?

Ofsted’s new 'inclusion' criterion should focus on how schools support their most vulnerable students, including those with SEND and those from disadvantaged backgrounds. It should assess the leadership and strategic approach to inclusion, evaluating how this influences teaching, learning, behaviour, and attendance across the school. True inclusivity means providing the necessary internal and external support, such as specialist therapy services, so that all pupils can access an appropriate curriculum. Importantly, schools must also create an environment where pupils feel a strong sense of belonging and wellbeing, ensuring inclusivity is not just about academic progress but about fostering acceptance and personal development.

Inclusion should be embedded across all areas of judgement, not treated as a separate issue. Leaders must demonstrate how they provide equal or greater support for children with SEND and those eligible for pupil premium, ensuring they are integrated into the school community alongside their peers.

How best to hold all schools, irrespective of how they are constituted or their governance arrangements, to account for their SEND provision?

Accountability for SEND provision should consider the unique context of each school. A flexible framework is necessary, tailored to the type of school and the specific needs of its students. Mainstream schools, AP settings, and specialist provisions face different challenges and should not be assessed by the same standards. Each school’s approach to supporting SEND students must be understood in relation to its specific circumstances.

January 2025

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