SCN0437
Written evidence from Parental Submission 146
Written evidence for the special educational needs and disabilities inquiry submitted by [name], [job title] and parent of young person with SEND. Evidence written on 12.06.18.
Executive summary
1.1. Quality of identifying and assessing SEND still remains an area of need for schools and settings
1.2. Quality assuring the providers of EHCPs, regulation of contracted out EHCP writers
1.3. Consistency of what the LA should provide by way of the decision making framework and local criteria for funding allocation for SEN provision
1.4. Community of schools funding allocation responsibility for SEN/ pump priming inclusion led projects which will impact on the growing local schools capacity to meet majority of pupil need ( high incidence) – inclusion funding
1.5. National framework of descriptors – learn from good practice
1.6. The effectiveness of Health and Social Care advice in an EHCP
1.7. Supporting parents of 19-25 year olds to raise expectations of independent living options
Main submission
2.1. The progress, which the ambition of the reforms originally promised has regrettably not delivered on in this regard. Our collective aspiration was to ensure a consistent and reliable approach to assessment of SEND both within schools and settings and via the statutory single assessment process. Sadly this has not happened consistently across all local areas with all sectors, especially in our schools. Life is still difficult for parents who in the main request open and authentic assessment of their child’s needs. However, we are still in the business of providing long and unwieldy experiences for many parent carers and children and young people of waiting, exclusive decision making processes, sidelined etc..
2.2. The key question here is “How are we ensuring we are identifying and addressing pupils’ needs / SEN as early as possible?” Where pupil-centred approaches are embedded within LA/school culture, good quality, whole approaches to identifying and meeting SEND are usually effective or are steadily improving in quality. This is often because the community view of the child’s needs is gathered, holding the child at the centre and parents often report that they are informed early on when concerns arise and that they are invited to contribute to ongoing assessment of their child’s needs.
2.3. There is much more we should be doing to improve our liaison with feeder schools/settings to prepare and deliver our best endeavours for pupils with additional needs as soon as they arrive with us/them? In many pupil cases the transition from early years to primary, primary to secondary and secondary to tertiary education does not start early enough. Effective transition for pupils with high needs require thoughtful, personalised planning arrangements to ensure smooth transition to the next stage of their education is successful. We should be tracking this group of pupils and monitoring the effectiveness of transition between phases and within the school itself as there is a suspiciously high correlation between this group of pupils and those who often find themselves receiving exclusion orders later in their schooling.
2.4. Have we available a range of tools and expertise to support identification and assessment of need and do class / subject teachers make enough effective use of these tools to identify pupils gaps in and barriers to learning, adapting their core teaching in the light of these findings? This is still a postcode lottery for some schools and families. Where effective assessment of need is taking place by class teachers, this is usually within a school environment where leadership for SEND is robust and ethically strong. This is not the case in all schools. Concerns understandably feature around teacher workload but where seamless assess-plan-do-review practice of the graduate approach to SEND works well in our schools, this is managed by empowering teachers with relevant information, support, advice and assessment tools. Outcomes of the school inspection process still reports some schools not serving pupils with SEN well enough and the quality of provision being variable and yet those very same schools are identified as outstanding – this lacks integrity in our community view of constitutes an inclusive and outstanding school – where is the consistency in this practice?
2.5. Do we need to refresh our procedures around identification and assessment of SEN? Every school should have done this as part of the reform programme for implementation of the revised SEND Code of Practice, however, this is not the case for a significant proportion of schools. There has generally been very little focus of this area of practice with schools and settings which in turn has lead to poorer outcomes for some groups of children who continue to be identified as having an SEN when in fact they may well be underachieving or a lw attaining pupil but not have an SEN which requires additional or different provision as stated in the CFA and SEND Code of Practice.
2.6. Are there any areas of SEN that our staff need training, to support their ability to identify pupil’s emerging difficulties as early as possible and know how to respond? Yes there are many but equally DfE has commissioned successfully an inordinate range of online training for staff covering the four broad areas of need. Yet many, many schools are still unaware of the extent of resource available to them for free in this regard. The SEND Gateway was designed, built and launched under my leadership during [redacted]. The ambition of the Gateway was that it would be accessed by all education professionals to promote the training and professional development of all staff. A quick win here is to ensure that every Local Offer and indeed every school website has published access to the SEND Gateway featured on their sites. We have to ensure that we use all means possible to support our staff in accessing development material and resource for free. However, we lead horses to water but cannot make them drink! We must tie up the loose end of school based CPD requirement to satisfy the school SEND Information report requirement of the provision of skilled staff in the graduated approach to SEND. There should be regular SEND audit outcomes of SEND CPD in each Local Area which should inform outcomes of the wider SEND strategy the local area is seeking to implement at any given time. Teaching schools, leading schools should be part of this engagement and monitoring responsibility.
3.1. In some LAs there has been a significant disproportion of attributing implementation funding for SEND to the statutory process. The target of completing transfers from statements/LDAs to EHCPs has been a huge burden for some local areas to cope with at a time where depleted central teams of well trained staff have often been lacking.
3.2. Where the transition process has worked well has been in areas where meeting the “target” of transfers hasn’t been the number one priority but developing the quality of the experience and enabling local parent/family leadership has been an authentic focus of reform e.g Rotherham Real Partnerships; Leicester Pupil Centred Review Training for al SENCos in all schools with two seconded SENCOs as PCP trainers who supported each and every SENCo through their first transfer review. This resulted in a much more coordinated and consistent transfer experience for all families and CYP resulting in better quality plans being designed with the voice of the YP at the heart of this.
3.3. In some LAs contracting out the writing of EHCPs is common practice at usually significant expense. This has often resulted in poor quality plans being produced by agents who were remote from the Local Area –why are we not commissioning and training local agents, parent/carers to provide this service which could be quality assured by the commissioning LA? Instead we have a huge range of unregulated organisations and individuals making financial gains at a time when a community response would be much more cost effective. Regulation of EHCP writing companies should be considered along with piloting approaches where local supporters of SEND are engaged in building capacity for LAs to respond to increasing levels of need.
4.1. Through my work with LAs during this interesting time of reform, I have noticed the following themes around funding for SEND; there will never be enough; a considerable amount of wastage of funding occurs when local arrangements for top up funding from high needs block is authorised without EHCPs but without appropriate robust accountability measures in place -this is happening in many areas and often arranged on a wing and prayer basis rather than a clear commissioning structure when schools are held to account properly. Where top up funding without the need for an EHCP can work well is through the formulation of community resource boards where schools are entrusted to manage and allocate high needs funding on behalf of the LA in partnership with them but by carefully coordinating a community of provision response – this can work really well for school and families, providing them with the flexibility of accessing additional resource when it is often needed quickly and efficiently. This approach is often a real test of the quality of relationship between local schools and their LA.
4.2. Many LAs specify a fixed cost on the provision required by a pupil with a high level of need –this is inconsistent and changes across all local areas. The problem with applying a formulaic approach to funding allocation decision making is that this process will not take account of local circumstances which then infers an increased level of difficulty for LAs in determining local funding arrangements for increasing levels of pupil need. Many local areas do not have a clear rationale which is locally understood and agreed by all stakeholders regarding funding allocations for high needs pupils. This is particularly difficult to manage in areas where prevalence of SEN is rising often at an increased rate of population growth locally. Support and Aspiration, the SEN Green paper (2011) referred to school funding frameworks, suggesting that more transparency was necessary for parents and others to understand how funding schemes might secure greater coherence. It also referred to the over-identification of children with SENs, and the need to focus on those pupils with the more severe and complex SEN.
4.2.1. “A national banded funding framework might set out high-level descriptions of the different types of provision for children with more severe and complex SEN or who are disabled, including, for example, additional curriculum support, therapy services, physical requirements, equipment, home-to-school transport, and family support (including short breaks).”
4.2.2. No such national framework of descriptors and bands has been developed and Local Authorities were expected to determine a local methodology for allocating high needs funding within the new national funding system. This is not consistent across all areas. It needs to be otherwise parents, families and children are subject to the postcode lottery effect of local funding for SEND determined on a flimsy basis. Good LAs where practice and funding SEN provision allocations are tighter but also transparent work well . Why are we not using this good practice to inform and support other LAs to do better in this regard?
4.2.3. Managing expectations in resource allocation decision making processes is an important aspect of funding arrangements for SEND locally. This is where we could and should be legitimately inspiring schools and providers to become more inclusive and providing start-up funding to enable highly inclusive schools to lead by example but develop others to adopt similar approaches. How can we enable LAs to develop a “project” funding stream to support the strategic ambitions of the local area in respect f developing inclusion – this funding does not need to come directly from HNB but could justifiably be released from schools reserves and pooled budgets with health and social care.
4.3. Implementing the reforms lacks urgency more generally in my experience. They have not been sufficiently prioritised by local areas and consequently impact of actions on outcomes has not been monitored rigorously enough. Review of Joint Area Inspection outcomes for SEND by Ofsted and CQC recognises that mechanisms for holding leaders to account for this are underdeveloped – poor strategic leadership and often in these particular areas the required transition plan was not fully in place and/or poorly implemented. This simply is not good enough. My concern overall here is that more LAs are receiving a written statement of action (WSOA )as an outcome of poor inspection - initially WSOA requirement for those LAs inspected early in the joint inspection process provided the necessary “shot in the arm” . However, since that time there is a worrying attitude percolating amongst the sector which could be suggestive that a WSOA just doesn’t cut it.
5.1. Four years down the line we still identify the all partner agencies are not working together effectively to implement the reforms –this is also a clear outcome of the many LA inspection for SEND jointly delivered by Ofsted and CQC. Families are still having to tell their story many times over despite our best intentions under the CFA to remove this practice at local level. Children’s commissioners should be ensuring that commissioning is informed by active engagement with children, young people and families using methods appropriate for them – this is not happening effectively in all areas. Consequently, the commissioning of some children’s services for SEND are being overlooked as many parents fee disenfranchised by the process. This is also linked to how well the Local offer is working as a local commissioning tool for families and commissioners. The local offer has the potential to be a powerful commissioning tool, allowing services to gather first-hand experience from families accessing their services on how they are (or are not) meeting individual needs. This individual level data when viewed collectively with feedback from a wide group of families should highlight where gaps in provision are and what could be commissioned going forward to fill these gaps. This really is a simple but effective tool which is not being used efficiently to inform commissioning and funding decisions intelligently. This is also an indication of well used and understood the effectiveness of the local offer is across services -how well is social care utilising the data provided by local offers to inform commissioning decisions etc. and similarly health.
5.2. Across all Local Areas there is a growing body of evidence through the EHCP process which indicates the level of disconnect in some areas between education, health and social care. LAs report the lengthy waiting times which inhibit the EHCP 20 week timeline from working efficiently. Often Assessment Officers are chasing up assessment reports from health and social care on a daily basis – this is not a waste of resource but indicates where SEND sits as priority in the working mindsets of those in health and social care. Capacity issues are in abundance and putting enormous pressure on our contributing colleagues in health and social care BUT there is more pressing issue around contribution and co-operation between Education, Health and Social care.
5.3. An EHCP is a joint plan although in reality as parent it reads much more as a an education only plan and herein lies a problem – we need the assessment contribution and cooperation of our health and social care colleagues to add value to the plan to improve outcomes for CYP with SEND. How well are we doing at this? Many parents would argue not well at all – this needs addressing otherwise the future of effective co-working across services will be affected, mindsets and attitudes will not progress to integrated models of working. Where integrated 0-25yrs services have been developed, the picture is mixed on the overall improvement of the quality of support and outcomes for CYP this offers.
6.1. I am the parent of a 17 year old apprentice who has SEND. As a family we supported our son to successfully achieve an apprenticeship at the age of 16 years. The local supported employment service could not provide any advice or guidance to prepare him for the world of work and training as his needs did not meet the thresholds. Despite the school offering good quality careers advice, expectations of our son starting college at entry level, (lower than GCSE courses he was taking at the time), were far too low. Careers guidance needs to develop a SEND focus to enable advisers to offer more personalised support at the point of access for YP. Discrete levels of support for employers is important for those YP who do not wish for their employers to label them in any way different to their colleagues – being seen as equals at this stage in a YP life is important – this takes skill and empathic approaches to work with YP in this way and their employers.
6.2. As a family we have received non information locally about securing independent living for our son in the future. When our son was 12 he expressed the desire to live with us, his parents, to the age of 37 – my heart sank! He clearly had a 25 year plan. But what our son at that time didn’t realise that his parents also had a 25 year plan and he did feature as highly in our plan as we did in his! As parents we need support and guidance to appropriately raise our expectations of YP and secure their aspiration to live independently of mum and dad. How many parents understand or are aware of the range of organisation who can assist YP and their families to plan for an independent supported living future? How many parent carers are aware of the maze of financial options available in how to fund and secure independent living for their YP? The 19-25 year old provision is a huge area of concern for us as parents and more generally across local areas. The Care Act requirement of continuing participation in education and learning along with the legal entitlement of an EHCP until your 25th birthday is largely an anathema to most families – this is are where I believe most LAs do not provide adequate information for YP and families and rely on adopting an ignorance is bliss approach to developing provision.
Recommendations
June 2018