TO:
Consultation on Options for the future of Specialist Education Provision
Views of the Suffolk Division of the National Union of Teachers
The views and suggestions which follow are have been collated from information and comments, mainly from members but also from some other key personnel in Educational Provision in all kinds of settings.
General: All those consulted welcome the avowed intention to consult on the best way to “re-design” specialist education provision in the County and we recognise the number of reports and observations from several quarters, including OFSTED, indicating that the current situation is unsatisfactory and has to be improved. The Authority is clearly falling short of its statutory duties in a number of ways.
The cabinet paper of 8th December stated that “the status quo is no longer sustainable or responsive to local need”. The Union would agree, and the first outcome of “re-design” must therefore be that there is a “sufficiency of provision” for pupils with SEND.
The work done by Paul Senior in 2014[1] on High Needs/EOTAS gathered some very useful data and put forward some 60+ action points but did not include all the costings and resource implications. Only a few of the recommendations have been actioned, and the principle suggestion, that of bringing all Alternative Provision under the management of three super-PRUs has apparently been dropped, wisely so in our view.
The current proposals (those set out in the Cabinet paper[2] of December 2015) are curiously disconnected from the data and earlier proposals – perhaps because of the perceived cost – and come across as representing hesitant management that appears to have lost its vision.
The overriding concern we share is the clearly documented lack of expert specialist provision to address identified needs of children and young people in the county. We can all point to different reasons for this lack of provision - including decisions taken to close EBD residential provision in 2001 (54 residential places) and the removal of the 51 Area Special Classes in 2004 which supported some 2,000 pupils spread across the county - providing a great deal of early intervention with geographical consistency.
Such decisions to remove what we had, without adequate replacement, has led to the current paucity of provision overall and geographical gaps. The arrival of Free Schools and Academies has complicated the coordination and control of provision, assessments and placements, where “independent” establishments can insist on their own criteria for admitting pupils. These changes, some the result of SCC decisions in the past, have led to the current situation of mis-match of child to provision and a large bill for out-county placements. This situation has been allowed to arise by the Council in the past by not effectively setting policy directions or scrutinising implementation.
It is now necessary to change tack radically, if the same problems and mistakes are not to be repeated.
The Options questionnaire is not helpful, in our view, because it is still looking at existing provision as it has become after some haphazard decisions and events, rather than stepping back to plan what is actually needed, as if designing provision from scratch. We suggest that “starting from scratch” is now required to plan a model structure for the future which will meet need, and implement that plan over time. But we should make the correct start now.
We believe that the Options Questionnaire relies too heavily on, perhaps wishful, thinking that provision can be improved by changing ownership or governance. Instead, the starting point should be the setting up of provision which meets the actual needs of the pupils requiring SEND support at the present time and in the foreseeable future. There is a desire to bring pupils back to in-County provision, which we all share, but it would be completely counter-productive, and morally indefensible, to move a child with complex needs from out-County to a PRU, without first ensuring that the curriculum, staffing and environment is at least as appropriate for that child as in the out-County provision. Placing a child in an unsuitable setting only causes further difficulties - this has been a recurring problem exacerbating the current unacceptable situation.
We note that the Cabinet paper referred to a two-phase “review of provision” in 2014-15 and 2015. Our reading of these reviews show a good amount of raw data, but we believe that, in order for consultees to make informed comments on the options, more interpretive detail is required, including identifying where gaps and insufficient provision have been identified. It is not possible from the existing raw data to be sure that pupils are placed in the most appropriate settings, or that any progress is being made by that child.
All too often, over the last few years, the “reviews” of provision have mainly been counting up the number of places in PRU, SSCs, etc., not evaluating or monitoring the quality or specialist provision that those places can genuinely support. The resulting action has tended to be “make do and mend” rather than any radical action to bring the service up to the required standards.
If the Authority is serious about meeting its statutory obligations in SEND provision, then it will have to find the resources to equip its own facilities as well as pay the appropriate rate to commission high quality provision from non-LA providers.
Many of our respondents expressed the view that “nothing would change” because the service had been so badly run down, and that there was not the funding to invest in the accommodation, staffing and quality control mechanisms required. The Union fears that this may be true, but we offer the following advice in the hope that the Authority will at last address the proven failings in this area of their statutory duties:
Recommendation 1: The first priority in re-designing Specialist Educational Services is to undertake another thorough, honest and complete audit of the current set of special and additional needs in the County. Much good work has been done on this (mainly by Paul Senior) but we believe that further collating and checking of data is required: this would involve examining the data for all pupils currently in non-mainstream provision, and for each one indicate the ideal provision identified for that child/young person. Some attempt should also be made at gauging the number of pupils in mainstream schools for whom the school feels unable to provide a fully appropriate education without outside support, and these details added to the overall findings. A report should be produced indicating the number of placements which are needed right now for each of the main categories of identified needs and in which locations. Categorisation of each child's needs should be undertaken by educational professionals, not administrative staff - the tendency to assume that a child is in the right placement already (accepted in the Paul Senior Action Plan) should be challenged.
Recommendation 2: The Council must, if it is to make the required improvement in outcomes for pupils, then map the number of places required in the County, with some geographical detail, for each category of SEND. In particular, where gaps in provision are identified, including where the only provision made so far is out-County, a report should be drawn up indicating what and where such provision is not currently available in-County. Ball-park funding consequences should also be attached, to indicate likely effect on budgets.
Recommendation 3: A long-term development plan should be produced to ensure that there is sufficient expert, specialist provision which can be commissioned to meet the needs identified by the audit. No pupil should be placed in any setting which is not specifically set up to meet those needs (trained, qualified and experienced specialist staffing, suitable physical and social environment, appropriate resourcing, etc). In most cases, some investment will be needed within the County budget if out-County placements are to be brought back “in-house”.
The current tendency, as reported to the Union and criticised by all recent reports including OFSTED, has been to simply place pupils into the nearest setting where there is a vacancy, or where there are deemed to be under-employed staff. This leads to pupils being allocated to unsuitable provision (unsuitable because it is not set up, equipped or appropriately staffed to meet that child's individual needs). It also leads to low staff morale and even work-related stress illness due to staff being expected to work with types of behaviour or learning difficulties outside their expertise, training and experience. Many current staff are working in settings for which they never applied, due to the many changes in EOTAS and PRU structures in recent years. Any mismatch of provision, including suitably qualified staff, with a child's honestly identified needs, is failing to secure a “sufficiency” of provision.
For example, some PRU staff may have been originally employed to tutor children out of school for medical reasons to access and obtain good results in a range of 5 or more GCSE subjects. That is in itself a specialist task, different from the skill set required of many secondary classroom teachers. It makes no sense to then re-direct these teachers to be teachers of classes of children with EBD - requiring a completely different skill set and background experience.
In 2012, the Authority made a mistake in issuing “generic” contracts to all EOTAS teaching staff, whatever their specialism. Teachers specialising in dyslexia, behavioural problems, autism, etc were treated as “generalists” and expected to be flexible - capable of being deployed to any case. and any EOTAS facility. When, in April 2014, management of most of these staff was transferred to specific PRUs, their previous specialisms were often not required in the PRU, but they were expected to become PRU class teachers, often teaching GCSE courses they had never done before. Such management decisions have had a serious deleterious effect.
To put more pupils, with even greater needs, into these PRUs with these staff would be a recipe for even greater disasters.
Recommendation 4: As part of the long-term redevelopment, each establishment or facility (PRU, school, Unit, tutor team) needs to have a clearly identified range of SEND for which the Authority may seek to commission places, in the knowledge that a child so placed will receive proper, appropriate provision. The establishments can then, over time, ensure that their staff are appropriately skilled and trained to specialise in the identified areas of provision.
Recommendation 5: Discussions need to take place with mainstream schools to establish the kind of SEND where all schools will be expected to make their own provision, identify the inclusion support that can be provided by the LA (or other providers), then establish clear thresholds for intervention from specialist services. This should not suddenly occur with an exclusion (essentially a decision taken by the school alone) forcing the issue and the Authority seeking a rapid (6-day) and, mostly likely, inappropriate solution.
Recommendation 6: The key to matching provision to the child is accurate assessment. Members comment that the class teacher/pupil tutor is seldom consulted in the assessment of a child's needs, while it is axiomatic that, after the parents/guardians, these staff know the child and his/her needs in great detail and have useful recommendations to make about what the child needs. There has in the past been a tendency to ignore such detailed existing knowledge and for placement decisions to be taken by Authority inclusion and administrative staff, not the professionals who best know the child.. Coordination of teachers' knowledge of the child with the professional input of Educational Psychologists and other agencies including CAMHS and Social Care, as appropriate, is essential to ensure an accurate assessment of holistic needs for each child. No decision to make a placement should be considered without such full background information. Up to now, too much emphasis has been given to costs and availability of places for child X, rather than what is the appropriate provision. This must change if the outcomes are going to change.
Recommendation 7: The child's assessed needs should be the sole criterion for deciding the best-fit setting for each individual. The Fair Access Panels do not, we are informed, follow this recommendation at present; they are reported to us as often pressurising schools to keep the pupils in mainstream (because there are no firm thresholds) or lead to negotiating who could take the child, rather than what provision would be most suitable. This sells the child short.
Recommendation 8: On occasion, there will be areas of uncertainty, with differences of opinion amongst the professional staff having input to a child's assessment. We suggest that the Authority could enhance the information and data to inform placement decisions, by having specific extra assessment facilities. These would preferably not be discrete units, but be one of the tasks specifically allocated to particular staff with appropriate expertise. Where 1:1 provision is required, the EOTAS tutor team could be developed to ensure that there are suitably qualified and experienced tutors to spend time teaching the pupil being assessed, and fully assessing how suitable the recommended provision for that child would be. The 1:1 team should be further professionalised to include expertise in assessment, SEN specialisms, behavioural difficulties, etc. Those expert staff did exist more informally in earlier structures and EOTAS Coordinators were generally good at matching tutors to pupils' needs.
Recommendation 9: Once a professional assessment has been completed, the best fit provision should be commissioned. If the required setting is not available in-County, then suitable out-County provision must be purchased. The best way of reducing such situations is to ensure that the greatest number of predictably required needs have already been provided for, developed, staffed and resourced. Sending one pupil with a particular set of needs out County for a year could pay for at least 4 full-time teachers to be employed in-County. So employing more specialist teachers in flexible/area roles could save considerable amounts - but the investment has to be made first before the budgetary benefit is felt, by avoiding out-County placements.
Omission: the overall planning “for the future” appears to have left out the 1:1 tutor team and the statutory requirements regarding children unable to attend school for medical reasons. Because this service is unpredictable re. numbers and range of additional needs, it can only efficiently be provided by a flexible pool, such as the Zero Hours team. Where such provision is made via a PRU with permanent staffing, this has proved inefficient and inflexible. We suggest that the team of tutors needs to be widened to include specialist tutors to respond from day one to medical cases, including those able to focus on supporting children's education in cases of particular medical conditions, especially in the area of mental health.
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The “Options” Questionnaire
1.3: SSCs. Prior to 2004, Area Support Classes spread equitably across the County in Primary and Middle Schools, provided effective and efficient support to pupils with a range of Special Needs in what proved to be a successful experience of early intervention. The Centres were staffed by teachers/TAs paid for by the Authority by way of an enhancement to the school budget and were a County resource - meaning that a child assessed by the Authority as benefitting from an ASC placement could be directed to the nearest available centre.
As the Options paper points out, the current “rump” of 7 SSCs, mostly in Ipswich, are not part of any such planned County resource, and are at the mercy of Governing Body decisions to stop that provision at a moment's notice - perhaps because SSC pupil outcomes are considered to be part and parcel of the school's overall OFSTED assessment. Having a class which invites children with SEN is likely to load the school's results towards the bottom range, inviting an “requires improvement” rating or worse, however well the children's special needs are being met. The new OFSTED framework for inspection (introducing value added data) may in time help remove that effect, but not in the immediate future.
Concerning option 1.2.2: We have seen the plans of at least one Special School which is offering to sell its expertise on an outreach basis to any Mainstream class that needs such support. In the absence of any LA-led initiative of this kind, such cooperation between Special and Mainstream schools may prove effective. It remains to be seen how financially efficient such cooperation could be (as all teacher time has to be paid for by somebody) while the Head and Governing Body of the Mainstream school will remain responsible to OFSTED for all outcomes, rather than the Special School. This may not be the best arrangement in all cases and will rely on an increase in staff at the Special school and confidence in the ability to sustain the arrangement. In any case, it would represent equitable provision in all parts of the County.