This blog outlines our thoughts on the SEND and Alternative Provision Improvement Plan, including a summary of the changes from the 2022 Green Paper.
In March last year, the Government released its SEND and Alternative Provision Green Paper, setting out proposals to level up opportunities for children and young people with special educational needs and disabilities (SEND).
We considered this Green Paper and wrote a blog with our response. Now, a year later in March 2023, the Government has released the Special Educational Needs and Disabilities (SEND) and Alternative Provision (AP) Improvement Plan. This blog will take a look at what’s changed since the Green Paper and how our key areas of focus – data and technology – are addressed in the Improvement Plan.
The SEND and AP Improvement Plan details the Government’s plans to implement change across the SEND and AP systems in England from now until the end of 2025. Before rolling certain changes out across the country, the Government plans to establish up to nine Regional Expert Partnerships to “co-produce, test and refine key reforms”. Much of the country, therefore, will see limited change before 2025.
As this overview points out, a child with SEND who started secondary school at the same time as the SEND review, in September 2019, will currently be in Year 10. Once the Improvement Plan is fully implemented, they will be over compulsory school age. In other words, pupils could have gone through their entire secondary education before change is fully realised, missing out on the key benefits to their school experience.
Additionally, with a General Election between now and 2025 and no legislative changes on the horizon, it remains to be seen how completely these proposals are implemented.
1. Standardising performance measures
As in the Green Paper, the Improvement Plan aims to increase consistency across the country and standardise how performance of SEND provision is measured. The Government’s SEND review and countless other pieces of research have found access to SEND provision is patchy across England and whether a child is identified with SEND depends more on where a child attends school, as opposed to their needs.
Nationally consistent standards
A key focus of both the Green Paper and the Improvement Plan has been the implementation of national standards that deliver “consistent, clear and early support for children and young people with SEND”.
We welcomed this focus in the Green Paper, agreeing that standardising performance measures across all types of setting that support children with SEND would go some way to ensuring quality provision across the board. From our experience supporting local authorities to monitor pupil attendance, behaviour, outcomes and decisions, we know that this sort of monitoring is patchy and intelligence is often not shared between local authorities.
The SEND and AP Improvement Plan clarifies that these National Standards will “set clear and ambitious expectations for what good looks like in identifying and meeting needs, and clarify who is responsible for delivering provision and from which budgets, across the 0-25 system”. A partial timeline has been published, with a significant proportion of the National Standards due to be published at the end of 2025, after development with the Regional Expert Partnerships. There is concern that this roadmap is lengthy, with no clear deadline set for complete publication of these National Standards. In addition, with a General Election due between now and the end of 2025, any accompanying legislation is at risk. Without legislation or oversight, there is a clear possibility that any Standards will not be followed consistently across the country.
Contextual performance tables scrapped
In the Green Paper, the Government proposed to update Compare School and College Performance to provide contextual information alongside results data. This proposal aimed to “make it easier to recognise schools and colleges that are doing well for children with SEND”.
We previously highlighted how performance tables can provide a disincentive to schools taking on pupils with an EHCP if they believe this will have a negative impact on their progress scores – an issue our director Steve touched on in this Schools Week article. For this reason, we were supportive of contextual information being published.
However, this proposal appears to be missing from the Improvement Plan. Consultation responses to the Green Paper revealed that stakeholders were opposed to provider-level information being published. This was mainly due to it being available in other tools, such as performance tables. However, these other tools do not provide the contextual information that can be so important for pupils with SEND.
As we do in our Interactive SEND Dashboards, we believe there can be value in displaying this provider-level data in a way that contextualises performance in the unique landscape of each local authority and setting.
2. Benefitting from digital solutions
The Government relies heavily on digital technology in its proposals. This has the potential to facilitate dramatic improvements in the SEND system, improving both consistency and efficiency, and ultimately improving outcomes for children.
Digital EHCPs
The Green Paper had a strong focus on the implementation of digital EHCPs. This was reassuring, particularly as our review of EHCPs for five local authorities for the Mayor of London’s Post-16 SEND Review revealed the wide variety of approaches both between and within local authorities. This was backed up by an analysis of EHCPs by the Children’s Commissioner, which found considerable variability in 650 EHCPs across just two local authorities. Well-designed digital EHCPs will be crucial in ensuring consistent national provision.
This focus continues in the Improvement Plan, which states that “the case is clear for all SEND services to move to digital systems for EHCPs”.
However, as with other aspects of the Improvement Plan, timelines are a concern. The Government’s roadmap states that rollout of requirements across local authorities will take place in 2025. However, this is “dependent on digital solutions” and there is a serious risk of delay.
It is also unclear whether the Government will be providing the software and solutions for digital EHCPs, or if they will outline the requirements, with the development of software falling to third parties. Regardless of who is responsible for implementation, we re-iterate the importance of maintaining a national standard data structure for EHCPs. This means that, irrespective of what digital system is used, data from EHCPs can be passed seamlessly between local authorities when a child moves.
0-25 inclusion dashboard
The Green Paper set out proposals to introduce inclusion dashboards to provide “performance data and metrics across education, health and care”. There was limited detail provided on exactly what would be included in these dashboards and we emphasised the importance of including longer term outcomes that go all the way up to age 25.
In the Improvement Plan, the Government commits to publishing a local and national inclusion dashboard from autumn 2023. Due to reported tensions between the priorities of parents and local authorities, there is still no concrete detail on what will be included in these dashboards. Instead, a prototype is due by April 2023, which will be refined through user testing. It therefore remains to be seen what will be included and we remain concerned they will not cover data up to the age of 25.
As found in the consultation, there are many different ways to measure inclusion – some easier to capture than others. As a starting point, in order to raise the importance of inclusive behaviours in schools, in 2019 we developed our local authority inclusion index using DfE published data. You can see how your local authority measures up here.
3. Working towards more inclusive provision
The Government has acknowledged that a more inclusive education system is required to ensure that all children and young people with SEND have the opportunity to thrive.
Improving mainstream provision for pupils with SEND
There were a raft of proposals in the Green Paper to improve provision, including increasing investment, developing teacher training and sharing evidence-based practice.
This goal to improve mainstream provision continues in the Improvement Plan, with a particular focus on workforce. This includes reviewing Initial Teacher Training and Early Career Frameworks, introducing a new SENCo NPQ and upskilling teacher assistants. We have a history of supporting local authorities to improve inclusion, and endorse the idea of training and increasing staff resource to improve inclusion in mainstream settings. We talk about this more in detail in our recommendations on page 52 of our report for the Mayor of London.
However, the Government is also approving numerous applications from local authorities to open new special free schools in their area, in addition to the 49 which are already in the pipeline. There is a risk that this increase in special school places undermines the goal to educate more SEND pupils in mainstream settings. As a local authority colleague said to us, “if you build more special schools, you increase demand for special school places”. While there are many children and young people for whom special education represents the best setting, we are concerned that a large increase in the number of special schools may tip the balance in favour of placing children and young people into specialist placements, at the cost of improving mainstream settings. The below chart shows the proportion of EHCP pupils being educated in mainstream and special schools from 2017 to 2022. While the percentage in special schools has been falling since 2019, over a third of EHCP pupils are still placed in special schools.
Nevertheless, one benefit of new special schools may be to move pupils out of expensive independent settings. We worked with Birmingham City Council to review their funded school placements, identifying where more inclusive placement practices could allow reallocation of resources into better SEND provision in state-funded schools.
Post-16 provision
Following the Green Paper, there was concern about the limited focus on post-16 provision. For instance, the Association of Colleges highlighted how the Green Paper had little emphasis on colleges, despite claiming to provide for young people all the way into adulthood, up to age 25.
We had similar concerns. Our post-16 review found significant supply gaps in 19 to 25 provision, in particular, and we found the lack of emphasis on provision for adults troubling.
The Improvement Plan acknowledges this as a key area of feedback and there is greater inclusion of post-16 provision and its unique challenges in the Plan. It commits to supporting “effective transitions between all stages of education, and into employment and adult services”. This work to establish good practice in transitions will initially focus on transitions into and out of post-16 settings and there will be collaboration with the Association of Colleges and Natspec to develop guidance.
We noted that the one area of post-16 provision that received some focus in the Green Paper was the Supported Internship scheme. This is also an area of focus in the Improvement Plan, with the Government committing to invest £18 million between 2022 and 2025 to double the capacity of the Supported Internships programme. However, these have seen consistently low take-up, with just 1.9% of 16 to 25 year olds with an EHCP in England undertaking a supported internship in 2022. The below line chart shows the take-up of supported internships since 2017, which peaked at 2.1% of 16 to 25 year olds with an EHCP in 2020.
It remains to be seen how this investment will impact take-up, and whether the commitments to improving transitions will be effective, but the greater consideration of post-16 settings is an encouraging sign from the Improvement Plan.
Final thoughts
While the Improvement Plan is a positive step towards a SEND and AP system that works effectively, there are serious concerns about implementation. With a roadmap extending to 2025 and beyond, including a General Election due in the meantime, there are clear risks that it will not be implemented in full.
If you’d like to discuss changes to the SEND system or want to understand your local SEND picture, please get in touch.
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