Written evidence submitted by the Children’s Services Development Group
Children’s Services Development Group (CSDG): Written evidence for the Education Committee’s inquiry into ‘The impact of COVID-19 on education and children’s services’, June 2020
- We are pleased to submit written evidence to the Education Committee’s inquiry into the impact of COVID-19 on education and children’s services. Our submission sets out how CSDG members responded to and resolved short-term concerns facing the children’s services sector, as well as issues that we continue to face in light of COVID-19 and the longer-term outlook for providers in this space.
- CSDG members have worked hard during this difficult time to ensure the continuation of high-quality education and care for the vulnerable children and young people we work with, across residential care, specialist education and foster care. This has required dealing with a number of challenges that government support was needed to address.
- These challenges ranged from confirmation of critical worker status, access to testing and PPE, lack of clarity around the support available for care leavers and the implications for carers and providers, alongside longer-term funding concerns. We would urge the government to address the outstanding issues as a priority and continue to engage with and consult the sector as we return to more normal circumstances.
CSDG members’ response to COVID-19
- CSDG members provide services across fostering, special educational needs and residential care. Our focus throughout this challenging period has been on ensuring the continued and safe provision of high-quality care and support for children and young people with some of the most complex needs.
- During this time our members’ frontline staff, including teachers and carers, have consistently gone above and beyond, ensuring that the children in our care continue to receive high-quality support during this period. Staff have been innovative in providing a wide variety of learning resources to support individual children across all services (from fostering to schools) to ensure their education may continue even if they are unable to attend school. Many have made personal sacrifices, including moving out of their family homes into nearby accommodation to help protect the vulnerable children they work with from the virus. We are incredibly grateful for their commitment and dedication. Where those children and young people in their care have been unable to attend school, members have invested in the provision of substantial online services, and trained hundreds of teachers to provide lessons through these digital platforms.
- From the earliest signs that COVID-19 would impact how our provision needed to operate, CSDG members began planning to ensure continuity of provision during this difficult period, including developing guides for staff in settings ahead of official guidance being published. We were aware that any removal of care and support would have had a hugely disruptive impact on the vulnerable children and young people we work with.
- Members quickly implemented plans to ensure that provision could continue safely, in line with advice and guidance from government. This planning was challenging because there was little or no information from the government on how to implement social distancing, isolation and shielding in special schools and children’s social care settings at this point. This was not made available until Saturday 21st March, by which point voluntary lockdown measures were already recommended and the announcement regarding school closures had already been made. This guidance was essential as the complexity of the needs of the children in our members’ care is such that continued staff contact is vital; often their care needs cannot be met without direct contact from multiple staff members.
- Our initial engagement with the Department for Education (DfE) sought to clarify the need for members’ provision to remain open to ensure we could continue supporting the highly vulnerable children and young people in our care, and to urgently request the publication of the guidance noted above. Access to PPE was also a great concern. Throughout this period, we have been concerned that children’s social care had been consistently overlooked in relation to PPE despite the highly complex needs of many of the young people members work with. The care required to meet these needs typically will include close contact and often elements of personal care. Should these young people be symptomatic, providing safe care becomes very challenging without PPE.
- We would like to emphasise that throughout this time we believe the officials at the DfE worked very hard to address issues we raised and to provide clarity as quickly and as comprehensively as possible. However, they have been working within the confines of wider government prioritisation which limited their ability to provide all the comprehensive answers we have needed on issues like PPE. CSDG fully appreciates that supplies must be distributed where they are most critically needed, particularly to the NHS. However, children’s social care providers also need access to a consistent PPE supply and, so far, the sector has not been prioritised to the extent we believe it should be. Despite the government’s assurance that allocations for children’s residential were identified, the Local Resilience Forums were inconsistent in their approach to the supply of PPE to the sector.
Implementation of the critical workers policy
- One of CSDG’s immediate concerns once school closures were likely to be announced was ensuring children’s services staff were designated as critical workers. This was crucial to enabling frontline and support staff to continue with their essential roles should any travel restrictions be imposed, and to enable their own children to attend school so they could attend work.
- The initial guidance published by the DfE on critical workers did not provide a sufficient level of detail to clarify to those not familiar with the sector that children’s services providers were designated as critical workers. While CSDG members were confident from the guidance that their employees were covered by it, and we were subsequently reassured by the DfE that this was the case, this was not the interpretation of those less familiar with the sector.
- This was particularly concerning given that the guidance was issued at midnight on Friday 20th March and schools had been ordered not to open except for the children of critical workers on Monday 23rd March. This left many children’s social care staff struggling to confirm over the weekend that their children would still be able to attend school on the Monday.
- A number of frontline staff found that schools were reluctant to accept that their children were eligible to attend. Some schools did not initially accept that children’s services employees met the definition of critical workers, while others insisted that both parents had to be critical workers in order for their children to be able to continue to attend school, contrary to the advice from the government. There was also confusion as to whether children in foster care could attend school, even though the guidance was clear that a looked after child or young person with a social worker was eligible to continue attending.
- We recognise that these are exceptional times. We are grateful that our workforce is considered critical workers, and that guidance was subsequently updated to address concerns, particularly in relation to the eligibility of children in foster care to continue attending school. However, this initial confusion and the limited time between publication of the critical works list and schools closing was very challenging.
Capacity of children’s services
Role of providers
- Throughout the crisis, our members’ services have continued to fully operate, despite the challenging circumstances. As the crisis has developed, demand for placements within our members’ services has remained consistently high, and our members have continued to accept new referrals where the young person’s needs can be safely met, and risk assessments are in place. Some of our members have even been able to support this ongoing demand by continuing with plans to open new settings. This highlights that even during the most serious of crises, children’s services remain essential. Independent providers have demonstrated commitment and compassion, playing a crucial role in helping local authorities to meet increases in their demand.
- We were pleased with the government’s decision to publish specific guidance relating to local authorities’ responsibilities towards care leavers. CSDG’s Destination Unknown report, published earlier this year, set out the often inconsistent and limited support for young people as they transition out of care when they turn 18. Our research highlighted the significant detrimental impact this can have on young people’s longer-term life outcomes. We encourage the Committee to consider the findings of our report both in the context of COVID-19 but also in the round.
- Whilst the guidance published by the government was welcome, it is important to recognise that young people leaving care are some of the most vulnerable in society. The DfE guidance encouraged local authorities to “prioritise the most vulnerable” care leavers. However, all care leavers are vulnerable and should, without exception, have maintained access to a comprehensive package of support to meet their individual requirements and fulfil their statutory entitlement. This is even more important during a time of national crisis.
- Under normal circumstances, care leavers face much greater challenges than their peers in securing employment, training and education, and finding safe and secure accommodation, and are more likely to suffer from poor mental health. The current crisis will only have exacerbated these challenges, meaning care leavers should be entitled to more support, not less.
- That is why we welcomed the government’s commitment to maintaining care placements during this challenging period for those due to leave care. It would not be expected for care leavers’ peers to be forced out of their home aged 18 in normal circumstances, let alone during this crisis, and we therefore should not expect it of some of the most vulnerable young people in society.
- Whilst this policy and the additional support for care leavers was welcomed, the decision does pose a number of important questions which still have yet to be fully addressed. On funding, it is still unclear how maintained placements will be funded, at what level and for how long. For example, one of the main challenges with Staying Put arrangements for young people in foster care in ordinary circumstances has been the associated reduction in carer fees, which has made it financially impossible for some carers to maintain a placement even if they wanted to. It is crucial foster carers are not unintentionally financially penalised for maintaining a placement after a young person’s 18th birthday during the crisis.
- Furthermore, no guidance has been made available regarding how settings should approach other placement referrals and safeguarding, especially in terms of younger children moving into a residential home or foster care household where a young person who was due to leave at age 18 has remained in placement due to the crisis.
- It is essential the government provides additional clarity on how long these extended arrangements will apply and publishes additional guidance relating to children’s social care and support for care leavers. It will be challenging to balance continuing to support foster care leavers in line with these arrangements and moving ahead with the placement of planned and commissioned foster care referrals. The sector needs to be able to plan effectively to ensure adequacy of placements and sufficiency across the system, and ensure the right support is in place for those due to leave care. As further details on the easing of lockdown measures are announced, we would encourage the DfE to consult extensively to ensure both care leavers and fostering capacity are not adversely impacted
- We welcomed the publication of government’s COVID-19 Action Plan for Social Care and are pleased with the recognition by government of the important role the care sector plays both during this crisis and in normal times.
- We welcome the inclusion of frontline children’s social care staff and foster carers, and their families, within the expanded testing regime introduced by government. However, given the complex needs of many of the children in our members’ care, we believe this was introduced too late. Fortunately, across all of our members’ residential care settings and special schools, we successfully managed to avoid a major outbreak. Where a very small number of minor outbreaks have occurred, these were all reported to relevant local authorities who worked with and supported us to manage these successfully. However, a lack of testing for the sector has created staffing pressures and meant that many staff members have had to self-isolate with symptoms when they may not have had the virus. Earlier access to testing would have enabled those staff members to come back to work, and allowed members to plan appropriately for those who tested positive to be unable to return to work for some time while they recovered, beyond the mandated quarantine period, and ensure they received the support they needed.
- In light of the potential for significant staff absences, we welcomed Ofsted’s decision to temporarily relax regulations on staffing ratios. While all efforts were taken to ensure that staffing ratios were maintained, this provided some necessary flexibility that enabled care to continue during this crucial time. Quality and safety were never compromised as a result and many of our members’ staff have gone above and beyond, isolating themselves from family to reduce the risk of being unable to support the children they work with.
Access to PPE
- As noted above, we have been frustrated by the government’s response to CSDG’s calls for additional PPE throughout the crisis. Our members care for some of the most vulnerable children, many of whom have highly complex needs. As such it was, and remains, imperative that our staff have access to PPE. Whilst we recognise there have been issues procuring PPE across the board, our members have faced significant stumbling blocks when accessing supplies even through recommended routes. We would add the DfE team were very helpful and responsive but were reliant on other government departments to achieve the required outcome.
- Our members have been liaising with all relevant bodies about PPE, including Local Resilience Forums and designated wholesalers. We have been able to secure some PPE, but this access has not been consistent, and deliveries often have not included the volume of items expected. It is fully appreciated that supplies must be distributed where they are most critically needed, however children’s social care providers also urgently need access to a consistent PPE supply. It is essential the sector is not pushed down the government’s priority list. We would urge the government to consider the needs of care services in the round and ensure that children’s services providers are also given priority access to PPE as and where it is required.
The effect of cancelling formal exams
- COVID-19 will have severely impacted the education of young people in care, especially those who were due to take exams. Many young people in care often come from highly disrupted educational backgrounds and children in care tend to experience higher rates of exclusion from school, and for the most part have lower levels of attendance, than their peers.
- Whilst relying on predicted grades may be a fair measure for some of their peers, for children in care these grades are unlikely to be a true representation of the young person’s ability – and those young people will have lost the chance to prove themselves. This becomes even more challenging when we consider that for those who were expecting to take their A-Levels or equivalent exams, any opportunity to sit them next year will be additionally challenging as it is unlikely they will still be in their current care setting and will instead be living independently at that point. Specific consideration needs to be given to supporting young people in care in relation to exams, and the additional support required to enable them to take exams next year instead.
Outlook for the sector
- CSDG’s members have successfully overcome the challenges posed by the pandemic to ensure we continue to provide vital, high-quality support to the children and young people in our care. The crisis will have an enduring impact on the whole children’s services sector, and it is crucial that government reflects upon its contribution and ensures that it continues to be appropriately supported and funded.
- It is clear that local authorities will have been placed under significant pressure during the crisis and will have had their already limited budgets stretched even further. Many additional burdens and responsibilities have fallen on local authorities during this period. Government should ensure that local authority children’s services budgets are sufficiently funded to ensure the best outcomes for children and young people in care, and for those requiring specialist education and support.
- The Secretary of State has been clear that standardised funding for mainstream placements should not be changed during the COVID-19 pandemic. Additional costs may be sought as needed from local authorities or the Regional Schools Commissioner. Likewise, in EHC plan commissioned placements, Commissioners should not seek to retrospectively “claw back” funding. It is essential this position is maintained.
- CSDG’s members implement robust placement-matching procedures which ensure a young person’s needs are always at the forefront of placement decisions. In normal circumstances, members have found that local authority funding pressures have led to commissioning decisions that do not primarily focus on improving a child’s outcomes, with commissioners choosing placements based on short-term affordability rather than what will best meet the child’s needs, often on an ‘in-house first’ basis.
- This invariably leads to multiple failed placements and further emotional upheaval for vulnerable children. CSDG has been campaigning for some time for the implementation of a commissioning approach that is needs not cost-based, via the development of a National Outcomes Framework that benchmarks all providers (local authority and independent) on value, quality, cost and outcomes to support effective outcomes-based commissioning. The continued financial pressures local authorities will be under means such an approach has never been more important, both financially and for the longer-term outcomes of vulnerable young people.
- The DfE’s upcoming reviews of the care system and SEND are an important opportunity to take stock of the sector. COVID has highlighted the incredibly important role that independent providers in this space play in meeting the needs of vulnerable young people. These reviews should recognise this, and the Department should work with providers to ensure adequate placement sufficiency is available across the country, so that every child has access to the care and support they need on a right-placement, first-time basis.
- The Children’s Services Development Group (CSDG) is a coalition of leading independent providers of care and specialist education services for children and young people with complex needs.
- We have worked and campaigned together since 2006, championing child-centred, outcomes-focused care for looked after children and young people and those with special educational needs that ensures their stable and successful transition into adulthood. Our members are: Core Assets Group, Compass Community, Outcomes First Group, SENAD Group and Witherslack Group.
 CSDG, Destination Unknown: Improving transitions for care leavers and young people with special educational needs and disabilities, February 2020 (available at: http://www.csdg.org.uk/2020/02/26/destination-unknown-improving-transitions-for-care-leavers-and-young-people-with-send/)