SEN0881

Written evidence submitted by National Association of Principal Educational Psychologists (NAPEP)

This submission endeavours to support the work of the select committee from the perspective of the experiences of Educational Psychologists (EPs) and Local Authority Principal Educational Psychologists (PEPs) in England. PEPs have a unique perspective on the SEND system as LA EPs work across the full age range 0-25, and across SEN support and EHCP levels. LA EPs and PEPs work directly with a range of partners; schools; nurseries and PVIs; colleges; local authority and Health colleagues; and parents and carers. We also work at a range of levels, from the individual child level to more systemic and strategic levels.

Key messages

• We welcome a holistic review of the positioning of SEND within the wider education system. The curriculum and assessment review is welcomed, as is a focus on how inclusive schools with good outcomes for the whole of their student population, can be celebrated.
• The wider education system has not kept pace with the changes in our populations.
• Children are increasingly presenting in greater numbers with more complex special educational needs and disabilities (SEND).
• Schools are subsequently trying to meet these needs with local variation in supporting structures.
• Educational Policy development needs to follow the evidence; evidence about pedagogy and about how children and young people develop and learn, and with a vision in mind of the adults we are preparing for the future.
• LA PEPs, as leads of LA EP Services, are uniquely positioned to recognise the difficulties arising from a gap between identified need and access to services. All Local Authorities must have a PEP for strategic planning and operational implementation of the legislative requirements of SEND in local areas. They also ensure impartial, specialist professional advice and guidance, working within the professional codes of the HCPC and BPS.
• Educational Psychologists (EPs) are trained to doctoral level, their training enabling them to make a significant contribution to strategic planning and operational implementation of SEND in local communities. Their training positions EPs as experts in inclusion and supporting children and young people with a wide range of needs and vulnerabilities. They play a vital role in schools and the wider education system
• The scope of the contribution of LA EP workforce resource is currently not fully harnessed.
• The role of the EP has been narrowed by the rising demand for Educational Health and Care Needs Assessments (EHCNAs). EPs do have much to contribute for the most severe and complex SEND students. They are, however, also:

• very skilled at evidence-based early intervention work that prevents difficulties becoming entrenched and thus more difficult and expensive to address later,
• very skilled at methods of organisational change and systems work to support inclusion; and
• are trained in research methods and can support the development of the evidence base of what supports inclusion.

• There is currently a recruitment and retention crisis of EPs in LA Services and capacity across the EP workforce (i.e. including the private sector) is not keeping pace with the demand from schools and other partners for educational psychology time, which is required to support them to meet the need of children and young people.
• This lack of capacity is leading to many children and young people not having timely access to vital support. Moreover, there are regional disparities in access to EP services, which is resulting in unequal outcomes for children and young people.
• Action must be taken to address the current unequal access to EP services, such as through ringfenced funding for local authorities to provide the level of service required from the EP workforce. Furthermore, greater focus on measures to retain EPs working in local authority employment, alongside a fully funded and costed workforce plan to enable equitable delivery of EP services is critical.
• Henceforth, every maintained education setting must have a linked EP based in their local authority, that is free at the point of delivery and where they can have maximum impact working in partnership with colleagues in education, health and social care.

Support for Children and Young People with SEND

1.              SEN support in mainstream schools & settings

1.1               Assessing the current quality of SEN support in mainstream schools

              There is some great practice and interventions in place in schools across the country.               Each LA has a graduated response document and an ordinarily available provision               document that some schools and teachers deliver well. However, there is a lack of               consistency.

1.2               Defining what inclusive mainstream looks like

              Inclusive mainstream learning is: where the expertise required comes to the child in               their local school; the curriculum is sufficiently flexible to cover what children need to               know in their lives and is developmental considering what skills they are ready to learn               and in what ways; and  means we all learn together. This contrasts with the current               position of having to access support through ‘bolt on’ interventions, which then require               monitoring by external parties,  inadvertently creating ‘othering’ and additional               bureaucracy.

1.3                 How can inclusivity be improved

              Neurodiversity as the norm – we should expect individual difference not ‘one size               fits all’

              Ensure all individual strengths, achievements and needs are recognised and celebrated               (this happens in early years).

              Importance of pedagogy

• teach a curriculum about diversity and through having a diversity of teachers (Learning about Neurodiversity in Schools, University of Edinburgh Learning About Neurodiversity at School (LEANS) | Salvesen Mindroom Research Centre and unconscious bias, social history Home
• children need to have the opportunity to learn together and respect each other’s contributions. They could have group tasks in the same way adult education works e.g. action learning sets where groups work together to solve a problem. Children will be assessed on their ability to work with others and schools will be assessed on their ability to get the most out of these tasks.
• ensure expertise is developed in schools in a variety of ways e.g., through initial teacher training, increased access to services or through developing internal expertise. One example might be to have a lead specialist teacher for each of the areas of the code in every school. They would lead on monitoring the children identified with that area of need, arranging Continuous Professional Development (CPD) for staff, monitoring staff performance and depending on their cohorts each year maybe teaching in groups they could report to the SENCo.
• The DfE role is to set the standard for inclusivity, work on training and workforce development and gather evidence of what is working. The EP workforce could be galvanized to do this more directly, given their training in organisational psychology and research skills.

              Knowledge and skills for the future

• ensure the core curriculum reflects what our growing SEND population need e.g. independence/ preparation for adulthood/ communication skills/ understanding nutrition and health/ emotional regulation and relationships/social understanding including keeping safe online and assessing the quality of the information we are receiving.
• meta cognition must be explicitly taught. Executive functioning skills can be developed through developing meta cognition (thinking about thinking). Executive functions (memory, attention, flexible thinking, self-monitoring etc.) play a crucial role throughout childhood and underpins academic learning (Hwang, 2024; Zalazo and Carlson, 2020).
• Ensure curriculum content reflects the vision of the future adults we are preparing- Character education/citizenship

1.4               Should SEN support be put on a statutory footing?

• EPs understand the desire to make SEN support statutory; currently families feel statutory is the only way to have a right to challenge. 
• There does need to be an accountability framework for schools around the SEN support plan. This could happen in several different ways. LAs or Academy Trusts or LAs in partnerships with settings, could have a mechanism or an SEN Support Officer to support and resolve disputes. Alternatively, perhaps each school could have their own SEND Parent/Carer Forum where complaints could be reviewed by them under defined criteria. The powers of the mediation and or SEND tribunal process could be explored, for example, to consider, broadening their mandate that schools rather than just the LA can be challenged as schools need to be more accountable for the requests they make and the plans they need to deliver on.  Currently SEN Notional Funding is not ring-fenced in school budgets and there are no accountability measures to determine that money is being spent on children with additional needs.

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

2.1               The top-ranking skills that employers now look for in our modern world include being a               team player, being self-motivated, good verbal communication, joint problem-solving               skills and the ability to take initiative (McGunagle et al., 2020). Our curriculum needs to               reflect these skills, and an inclusive curriculum would deliver.

2.2               Workforce issues for Educational Psychologists

              PEPs are uniquely positioned to recognise the difficulties between need and access to               service. Children are increasingly presenting in greater numbers with more               complex special educational needs and disabilities (SEND). Educational               Psychologists (EPs) are experts in inclusion and supporting children and young people               with a wide range of needs and vulnerabilities and they play a vital role in schools and               the wider education system. 

              There is currently a recruitment and retention crisis of LA EPs and across the LA and               private sector combined, capacity is not keeping pace with demand. This is leading to               many children and young people not having timely access to vital               support. Moreover, there are regional disparities in access to EP services, which is               resulting in unequal outcomes for children and young people.

              Workforce issues for Educational Psychologists (EPs) could be directly improved by               enhancing the working arrangements (terms and conditions) for LA EPs and by               increasing the numbers of EPs being trained. It could also be addressed indirectly by a               set of robust measures that enhance parent/carer confidence in the mainstream system               to meet children’s needs (through a robust preventive offer alongside the other               measures to influence inclusion, and thereby better managing expectations, and reduce               the demand for statutory assessments, a demand for which has restricted the practice               of LA EPs).

              EPs are trained in research, training and intervention as well as identification of need. If               there was a clear commissioning route for research through Local Authority (LA)               services we would have greater understanding of what works for our SEND children and               be able to retain EPs in councils with a broad and impactful role that uses all the skills               they are trained to use. The British Psychological Society (BPS) are arguing to end the               post code lottery for our SEND children and schools by ensuring that there is a named               LA EP for all schools Thousands more children’s education at risk of reaching crisis               point due to workforce crisis, warns British Psychological Society | BPS . We could take               the opportunity to redefine the role of the EP so that they are expected to complete               school development work, training and case work in every school as well as high level               research ideally commissioned by DfE for the local authority. This would support               retention of EP’s in local authority employment. It is important that councils do not use               short terms contracts for this redefined role as research and school development work               requires work over time. The short-term culture in the EP and wider workforce is not               stabilising the system.

2.3               Workforce issues in schools

              Teachers and Teaching Assistants (TAs) require training in child development, history of               disability and disability/ SEND legislation, they need to understand the 4 areas of SEND.               Teachers and TAs need ongoing Continuous Professional Development (CPD) in this               area. They need access to quality supervision where they have a safe space to reflect               on their approaches and interactions with children and the wider workforce. I strongly               believe that access to quality supervision would support the retention of teachers as               well as address some of the inclusion and outcomes issues we face. The most inclusive               schools have a headteacher that has had experience of SEND.

2.4               Role of special schools, independent schools and AP

              A review of number, type, location, and availability of places at special schools is               needed.  For large counties children can be travelling miles to reach their schools and               for small local authorities there will naturally be movement across borders.  There is               valuable expertise in special schools and it would be beneficial for more outreach work               between special and mainstream schools to be seen where help is given to design,               develop, monitor and advise on curriculum, the environment, and pathways into               adulthood.  This would be especially beneficial for severe learning difficulties where               parental preference is for a mainstream setting.  We need to challenge the idea of ‘a               mainstream child’ or a ‘special school child’ and the idea that children sit neatly into               particular categories of need or types of special school.

              Independent special schools have a place for highly complex children and it is more               cost effective for a school to meet the needs of children from different local areas.                However, this could be looked at more closely with local areas joining up to create highly               specialist settings that are monitored by a region.

              Alternative provisions have been on the rise over recent years and reflect the ‘broken’               SEND system.  Schools and at times parents are seeking something smaller, bespoke               and nurturing for their children who are not managing in the mainstream.  There is               already work in place from the SEND and AP Improvement Plan and this work needs to               be described to the general public on what has been found to be helpful and good               practice.  There is a place for AP, but it needs to be regulated and part of the wider               educational offer with careful consideration of the curriculum pathways that children               have on offer to them and ways back into a mainstream if that is appropriate for that               child. 

2.5               The EHC needs assessment process works well for very complex children that need               specialist and personalised teaching and in these complex cases the process isn’t               adversarial because the level of significant needs has usually been known since birth.               Many requests for EHC needs assessments are a necessary process to access funding               to support differently and longer term in mainstream schools. A better and less               bureaucratic way to do this could be addressed through SEND budgets being distributed               differently but this would require SEND funding devolved to schools to be ring fenced               for SEND children. The SENCo needs to have oversite of the SEND budget (as they are               the ones making the decision to request an EHC needs assessment) and LAs must be               given the power to be able to monitor this spending before EHCPs are agreed.

              It would be helpful to have nationally agreed descriptions of what a mainstream school               can provide to support the decision to assess or not. This expected provision needs to               be monitored through school Ofsted inspections and/ or a new position such as a virtual               headteacher for SEND in each LA. Children who are Gillick competent and 12 years old               should have to consent to the assessment process and the legal framework needs to               follow.

3.               Current and Future SEND need

              Current and future SEND need is clearly rising. We have increased numbers of children               with neurodivergent presentations and poor mental health. There are more complex               non-verbal children that need special school places being identified. We need to build               mainstream capacity but alongside increasing the numbers of special school places for               children with complex developmental and medical needs. We have significantly more               knowledge about children’s needs and must accept that fitting children into traditional               education delivery models is no longer appropriate.  Any future changes to what are               taught and how children are educated should and must be based on best evidence.  We               must make much better use of evidence when making system wide changes to how our               children are taught and given the tools to learn as any statutory changes will have               implications for whole generations of children.

4.               Current and future models of SEND provision

4.1               Provision varies between LAs particularly in terms of PRU provision for excluded               children.  The duty to educate excluded children needs some careful consideration, for               example, should the duty become the responsibility of the academy chain? This could               ensure the child has been assessed holistically by their school prior to exclusion and               enable schools to have oversight of the outcomes for this vulnerable group.               Understanding a child in the system in which they live and learn must be central to               making significant decisions about children and young people that can have lifelong               impact on their futures.  Permanent SEMH placements need to occur through robust               assessment of need not by excluding them first and assessing them later. The               intersectionality between SEND, race, neurodiversity etc.  must be centrally discussed               by government, LAs, and Academy Trusts to tackle the disproportionality of some               children being disadvantaged by known biases, e.g., institutionalised racism.

4.2               Innovation can be encouraged across the system by making it genuinely child and young               person led. Children should decide what adjustments and assessments they want and               need.  Groups and forums need to be established at school level to challenge the               system. The current system services schools, organisations and to a lesser extent               parents but it doesn’t serve children. Children and young people know what they need               we need to listen more as too often this process is happening around them and not with               them.

5.               Finance, Funding and capacity of SEND provision

              Schools have a delegated budget for SEND which is not currently ring fenced. SENCos               can have mixed understanding of the budget and they sometimes give parents               misinformation about what they have funding for and make inappropriate requests for               EHC needs assessments as a result. This requires reform and more accountability. One               solution might be if schools only got this funding on the back of annual planning               regarding the types of needs coming into the school and the outcomes of the               interventions and support they have provided to date. This would be most appropriate if               the curriculum, assessment and mainstream offer were generally more inclusive so that               additional provision required is significantly reduced. In addition to this, schools are               required to provide reasonable adjustments under the Equality Act 2010, however, an               understanding of what this means is variable across the country and would benefit from               further case study exemplars to guide schools in what they think they can or cannot do.

6.               Accountability and inspection of SEND provision

              There are many inclusion frameworks and whole school approaches to mental health to               draw on. These tools are already active in our schools. School and local area inspection               frameworks need to align with changes made. It would be helpful if  Ofsted was curious               about how the school has assessed the needs of their population and planned for it.               Then they would be incentivised to embed inclusion topics into the curricula whether               it be neurodiversity, mental health or emotional barriers to attendance and therefore               demonstrate that SEND and Inclusion is an integral part of our culture and our               population.

January 2025

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