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If the new systems are effective, tribunal cases will significantly reduce. It is too premature to remove tribunal powers and access before the new system has been shown to be successful. It is deeply concerning the education select committees advice wrt tribunal powers, legal rights and LGSCO having oversight of schools is being ignored

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A lack of accountability is one of the biggest issues in the current system, however the reforms proposed significantly reduce accountability further. One can only surmise therefore, that without increased accountability which is required, the systems just won't be effective and outcomes will deteriorate.

Another huge issue currently are the unrealistic expectationson children and the developmentally inappropriate curriculum which pushes children to become labelled with SEND. The proposed curriculum reforms however do nothing to improve these areas. So again will not reduce pressures on children, will escalate MH needs and"SEND" labels with demands on systems.

Finally the long term underfunding has contributed to current failings of the system. The funding allocated in the reforms however are wholly insufficient to bring the necessary improvements (see NEU analyses).

So whilst the principles in the reforms are laudable, the methods to achieve them will not succeed.

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Definition of specialist needed, there should be more than 1 specialist on a panel, the whole panel should surely be SEND specialists? Agree with comment for lived experience person too.

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Some children require long them use of APs when they cannot access other settings, (eg EOTAS) this must not be prevented.

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The child's needs. Something the LA has a poor track record with in our experience. What happens when the LA gives 3 unsuitable placements? And tribunal cannot longer instruct provision. Given the current track record of LAs naming suitable provision, the new system deals disastrous with rights to redress disappearing.

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Access to a full range of professionals as required by individual child & their needs

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Children of all ages need this route, not just under 5s. Delays in accessing right provision and meeting needs causes harms and increases needs & costs.

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ISPs must be appealable in the same way EHCPs are, with maintenance of current tribunal powers to instruct provision. They need to be considered together, so why not make them 1 document

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Accountability. Maintenance of tribunal powers to name and instruct provision. Routes to redress re ISPS, with independent oversight and scrutiny.

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I don't think SSPs will work. Children's needs don't fit neatly into boxes. Where is the evidence the SSP system will work? See earlier comment re: huge risks of implementing an untested system with no evidential support to Children's futures and outcomes.

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What is the definition of success here? I suspect the DfE's definition may be different to CYP's. Without fundamental curriculum reforms I am not sure success in mainstream inclusion based is realistic for many ND children.

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This is simply an unrealistic aim

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Legal protections to deliver the provision in the ISP are required to give confidence in ISPs

There has to be a route to redress for ISPs beyond school complaints. There has to be a route to independent oversight of ISPs where families are in disagreement with school. The Education Select Committee recommends LGSC Ombudsman is given powers to oversee school complaints. Tribunal rights for independent oversight would be even better and give confidence ISPs may be useful.

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Experts by experience should be used, eg dyslexic people, autistic trainers etc.

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Culture change at the top of school leadership, without culture change a few days of training will have little impact.

Environmental change is required to underpin inclusion. Teachers identified training as the least important factor in delivering inclusion in schools. Yet it is being sold as the cure-all for inclusion.

The NEU have identified the funding allocated for training will not lead to inclusion. It is wholly insufficient

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Inclusion is not going to be delivered by many areas of these reforms. There is a fundamental misunderstanding of inclusion, attending mainstream is not synonymous with inclusion. A clear and accurate understanding of inclusion has to be the top priority in order for any inclusion standard to be meaningful.

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Maintain the language of needs

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Look at Finland and use the Finnish model which centres mental health at the heart of education. This will require radical overhaul of teaching approaches and the curriculum. The curriculum needs to be developmentally appropriate, it is not currently so. The proposed curriculum forms (note no questions on those) will not help improve MH. Why are we expecting children to hit writing targets at 5 when their hands are not developmentally ready to write til age 7yrs? Discovery led learning must predominate in KS1 and cont into KS 2. If expectations are developmentally appropriate, far fewer will have "special needs " and need additional support. Oracy will be a significant difficulty for many neurodivergent children (along with others with significant communication difficulties and differences) and cause significant anxiety. Making all children take and resit GCSE maths will not help MH. Enable a curriculum that allows for agency and autonomy, that enables children to work to their strengths that gives them useful skills.

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Tribunal powers must be maintained until there is good evidence the new system is working. Removing the safety net of tribunal is appalling. There will be no independent oversight of provision, given the current state of the system in appropriatelyidentifying snd providing for needs, this feels absolutely disastrous. SEND children's outcomes will plummet.

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There needs to be evidence to show the new specialist packages work before implemented on national scale. It is bizarre that a completely new system without any evidence it can/will work abd deliver improved outcomes is being implemented. Children's futures should not be gambled on like this. Children just don't fit neat packages, the system should be based on individual needs not convenience to administrators. Harms are caused when children's needs are not fully met, there IS simple evidence of this.

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Legal requirement to deliver the provision in ISP, same as with current EHCP.

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Make more of the Year 6 healthy child review to support transition to secondary

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EOTAS: A standardised package approach will not work here

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I worry about schools being able to cope with a vast range of children's different SEND needs. At the moment my son's school copes with him by segregating him, that is not education it is management.

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that depends on the school, some haven't a clue about how to support SEND and are not best placed to decide, esp re: hidden disabilities

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I tend to agree - some will shut, they are businesses, profitability is the bottom line.

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I am worried that if you regulate the Independent sector too much, there will be a decrease of available places to the point where children in need of specialist places won't be able to get a place. I agree that costs are high but if these children could cope in a mainstream or LA run SEN school, then they would have been placed there. Maybe the government needs to invest in more LA run SEN schools if they want to reduce costs.

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there should be regulation and reasonable costs, our experience was of a racket. But whether regulation will lead to fair costs is debatable.

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registered health care professionals have professional codes of practice with regulatory bodies holding them accountable unlike education staff, registered HCPs therefore need to be involved in this

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remember that SEND doesn't equal learning disabilities - many young people with SEND are academically able but need other adjustments to achieve their potential

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Mentors that arent attached to a particular setting who can build a relationship with a YP to support the transition

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A lot of SENCO part time and overwhelmed

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valuing difference and diversity from day 1, every day of the year, not just once a year in "awareness" weeks

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There seems to be a confusion of learning difficulties and learning disabilities when there are distinct differences.

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Where is mental health? The need hasn’t gone away

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Mental Health in Schools Teams and the schools Pastoral, SEND and Inclusion teams all need to be joined up and understand that poor mental health is a SEND need

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Mental Health in Schools teams need to be additionally trained in supporting neurodivergent mental health, which can need a different approach to typical support approaches

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CAMHS waiting lists are woeful. Mental health tier 4 beds limited. Children need to be supported so the don't reach crisis and then for the few that so, quick and appropriate safety net needs to be there for them. Far too many children and young people end up in A&E in crisis. Far too many young people are medicated to manage behaviour rather than environmental adjustments. There is too low a take up of Oliver MCGowan training.

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We need to understand that children feel pressure of SAT testing

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If e h cp can't do this without parents fighting for it how will packages of support be different

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Will each school do it differently they do with e h c p .my child said 1 to 1 at all times this was denied by 1 head and given by another school without hesitation .

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WPCV facilitating the PINS engagement session meant that there was someone neutral to support the development of the involvement of parent carers - this really helped break down barriers to involvement

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The parent engagement sessions facilitated by the parent carer forums in schools as part of the PINS project was a good way to increase coproduction but this needs funding to be in all schools.

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There is no point asking schools to be more inclusive and to accept a wider range of needs whilst ofsted continues to penalise schools for less than perfect attendance figures and performance. The whole system needs to oversee and genuinely encourage genuinely inclusive practice.

I am also very concerned about the legal responsibilities shifting from the LAs onto schools (and presumably onto School Governors ). Schools cannot be responsible for deciding children’s needs, deciding what provision they need, providing provision and for evaluating the success of that provision. Especially whilst working to fixed budgets. It’s a recipe for failing more and more families. There needs to be independent oversight of the whole system.

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They are not monitored by l a to make sure e h c p is delivered so why would this be different

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We were told it was up to us to make sure our child got what was written on e h cp .We were new to this and wholly wording in places gave the school enough giggle room to leave my child waiting for class of year 4 student to settle then the teacher was expected to do 1 to 1 with irlens sat in a doorway opposite a window .How she learned anything we don't know

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1. Early identification and intervention so children receive support before needs escalate or attainment drops.

2. Sharing evidence-based inclusive practice that helps mainstream schools adapt teaching, communication and support effectively.

3. Stronger multi-agency working, with education, health, families and young people shaping consistent support and outcomes.

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There needs to be intellectual ability which is over and above cognitive flexibility. Where does challenging behaviour sit? Where does dyslexia fit? Learning difficulties like dyslexia should be separated from learning disabilities which affect IQ

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Children and young people will receive Specialist support through an EHCP in mainstream or special setting, if they require provision set out in one of the new nationally defined Specialist Provision Packages. Support may be delivered through a ‘Specialist Base’.

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Children and young people will get Targeted Plus support from their setting, with input from education and health professionals. School-aged children are also supported through their school group. Support may include access to a ‘Support Base’.

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Children and young people will get Targeted support from their setting, outlined in an Individual Support Plan that is developed with parents.

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The Universal offer will set a new baseline for mainstream education settings for children and young people aged 0-25

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How can they ensure children are best supported by the Universal Offer and in the Targeted, Targeted Plus and Specialist layers?

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How can they ensure children are best supported by the Universal Offer and in the Targeted, Targeted Plus and Specialist layers?

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Widen the range of experts that this includes. Barriers to learning included being in pain, tired, hungry, dysregulated. Children need help from continence teams, sensory OTs, dietitians, clinical psychologists, sleep teams, counselling, paediatricians, specialist nurses, etc etc to tackle constipation, ARFID, sleep issues, sensory processing issues, trauma etc as the foundation of being ready to learn. These are all huge unmet needs in the struggling systems

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To properly support such a range of children teachers and TAs need to be able to coregulate and to do that they themselves need to feel well supported and regulated. Teachers and TAs need proper breaks, relaxation spaces, ability to work flexibly and take leave as needed in term time. Encourage disabled staff into work by removing all these barriers to disabled teachers working and it will have a knock on effect of better environments for SEND kids

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Radical change is needed to ensure true inclusion: rethinking uniform and behaviour policies (get rid of uniform for the sake of the planet too!!), rethinking teachign spaces, and the curriculum etc etc

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Recognition that like for adults with disabilities and neurodivergence, full time attendance for SEND children is not something that is going to be acheivable for some without driving them into burnout. Flexible attendance for staff and student is true inclusion.

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Take care not to confuse RCT style evidence (what works in general) for inclusion - which needs an approach of different things working for different people in different circumstances. A realist approach to evidence synthesis may be most appropriate.

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important to involve children and parents most vulnerable to exclusion in coproduction - this is something that would need to be carefully thought out, be flexible, neuroaffirming etc etc. PDAers, families from the Gypsy Traveller Roma communities etc all need to be represented.

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SEND Reform Putting Children and Young People First Explaining the Consultation document for Warwickshire’s Parent Carers

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Register to join one of our online drop in sessions to give your feedback

Wednesday 29th April 1pm

https://www.eventbrite.com/e/national-send-consultation-

shaping-wpcvs-response-online-tickets-1985901069558

or

Thursday 7th May 7.30pm

https://www.eventbrite.com/e/national-send-consultation-

shaping-wpcvs-response-online-tickets-1985899954222

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Warwickshire Parent Carer Voice is an independent, parent carer led organisation for everyone with a child or children with special educational needs and/or disabilities aged 0 -25. By working with Education, Health and Social Care decision makers in Warwickshire we make sure parent carers are involved when designing services for our children/young people and their families.

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Show compassion that not all children can reach good level of development - that is what having a disability means. Constantly telling parents their children are failing / they have failed as a parent because their child is not developing typically is not supportive

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Family Hubs / Children's Centres need to be in all communities and families linked with consistent health visitors / early years support into the nursery / day care settings

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Children don't fit in boxes and focussing on areas of development only works if a child or young person can be in more than one category

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Making sure that every child has a plan that identifies their needs even if they don't need extra interventions through the targeted layer so that all school staff can be aware... many neurodivergent children are fine until they hit crisis or something goes wrong - if there is no information for supply teachers for example that this child/ young person is autistic or has ADHD it could quickly escalate in a classroom

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Clear guidance on which children should be included in this layer of support - currently there is lots of debate about whether a child should be on the SEND support register or not

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If a child needs a smaller mainstream class would they still get this? Many children in independent schools (not indepent specialist schools) are there for the small class sizes / adult to child ratio

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Where do the use of sign language interpreters in mainstream schools fit into these layers?

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Only if the trusts are all local otherwise it won't work

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Only if they are held accountable for exactly what they are spending it on

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There needs to be a statutory right to the provision in the ISP not just a right to a plan

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There needs to be a statutory right to the provision in the ISP not just a right to a plan

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Parent Carer Forums - both the one for the local authority footprint and ones for each school

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it feels like a ticking time bomb, I can see an increase in child stress and distress (plus parental stress) from the proposals here, pushing more children into standardised systems that they do not fit into, causing an increase in trauma and further lowering educational outcomes and opportunities for SEND children/future adults and increase in the associated costs eg MH harms and demands on health and social care systems.

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until the DfE actually engage with the evidence behind why CYP's MH is so poor, especially that of ND CYP and make fundamental changes to the curriculum, the proposals here are not going to help many. This is a sticking plaster approach that ignores the root causes. Upstream approaches are required, looking at and addressing root causes. They have been given the evidence of the changes needed to curricula and their delivery, but this has clearly not been engaged with. Make the curriculum more inclusive and neurodevelopmentally appropriate (e.g. children's hands are not designed to be writing at 4, bringing junior school level maths into infant school classes is a disaster, SATS suck the joy out of school and create harmful pressures for many), remove abstract notions of standard expectations and enable children to learn meaningful content, then numbers of children with SEND will naturally reduce. A look at the Finnish system would be very wise.

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I think it is wholly unrealistic to expect schools to be trained up and have provisions in place within 3 years. Has the training been identified yet? It will take 3 years to sort that. How many hours of training will be required for each member of staff? How will those teaching hours be covered or will staff be paid to undertake the training over and above their usual hours? There is huge cultural and attitudinal problems within many schools especially those running military style behavioural approaches, how will these settings' attitudes and policies be changed within 3 years?

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to ensure there is accurate understanding of the child's needs and how their care has been managed/not. They should be independent of the school to ensure impartiality.

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is "SEND specialist" defined anywhere?

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publish it

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that entirely depends on the needs of the child, there should be no standard time limits. It should be led by each individual's needs. It is not possible to put a time frame on this and should not be the approach used. It must be needs led not system/process led.

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there must be acknowledgement that some children are unable to access any setting (EOTAS), something ignored by the white paper

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there needs to be acknowledgement that some children are not able to access any setting, this cohort (EOTAS) have been left out of the white paper.

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parents need full assessment of their child's needs by the relevant professionals eg SLT, EP, OT to understand the needs and then compare these against those catered for by the various settings. Maybe a bullet point summary of needs so these can easily be identified from a 40+page EHCP.

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parents need clear, easily accessible information about the setting. Currently it is often v difficult to tease out what type of setting and cohorts are supported by different settings, requiring clicking on various webpages and policies to figure something as simple as the age of the CYP the setting supports. Some sort of standard easy read/tabulated system to be on each setting's website so parents can see at a glance the basics about the provision e.g. what age do they cater for (not unusual for consults to go to wrong age settings), is it a generic special school or specialist, for learning disability (what level) or learning difficulty (what types), is a mainstream curriculum delivered, what if any GCSEs or other qualifications are available for secondary provisions, is it a setting aimed to support those with challenging behaviour vs highly anxious high sensory needs who need a calm, predictable environment, medical needs supported or not. That sort of thing.

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effective accountability mechanisms, external to schools/LAs,

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assessment of the individual child's needs by registered health care professionals. That must be in place and the focus must be on the child's needs, to ensure a specialist placement is accessible

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sit together in an education team, not individual departments/professional siloes

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why is this an appropriate goal? Some children cannot succeed in mainstream settings due to environmental factors. That is fact and needs accepting. The thought that this can be achieved is a nonsense. Some children do not want to be in mainstream, they want to be with others like themselves, where they are not identified as different, less than, othered etc. We all need our tribe. A sense of belonging is essential. Belonging will not be there if a mainstream classroom/school environment is at odds with your needs

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I don't think it is realistic for every need to be catered for in this way. I believe the argument for this is flawed from the outset due to the diversity of need. Children who require EOTAS for example cannot be educated in a setting, they therefore cannot have their needs met in an inclusion base. Need to stop trying to standardise everything and keep the current focus on INDIVIDUAL NEEDS. Children are not standardised, we already know the harm from trying to fit square pegs into round holes.

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maintaining support across transition periods, which are extra tricky times for CYP

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write them clearly and concisely with SMART goals?! Does this really need asking?!

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involvement and contribution from appropriately qualified professionals where required e.g. specialist teacher, EP, OT, SLT

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there should be realistic minimum workload standards here given the significant increase in workload proposed for schools, e.g. x hours of SENCO per x number of children in a school

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understanding the role of the nervous system in "behaviour"/regulation and learning. Use Dr Ross Greene's children do well when they can and Dr Monica Delahooke's approaches that are underpinned by neuroscience, not out of date behaviourist approaches. And understand the harms that can arise from behaviourist approaches (e.g. see Alfie Kohn's punished by rewards).

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ask children and young people

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stop comparing children to a notional standard of development and labelling them as falling behind or below expectations when we know children develop at different rates and this is normal child development, not faulty. Monitor individual progress rather than rank and compare. Understand the mental health harms of labelling children from age 4 as "less than"

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understand the limitations and harms from using behaviourist approaches (punishment and reward) which can demotivate learners and cause increased anxiety - engage with the existing evidence!

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increase the autonomy of CYP in school, stop using fear to motivate and stop the military style policing and draconian, punitive behaviour systems

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stop SATS