Community Impact Assessment Form For a summary of this Community Impact Assessment, click here Title of Community Impact Assessment (CIA): Inclusive Learning Service Directorate: Children’s Services Date of assessment: August / September 2012 Sue Woodgate / Lorraine Stephen Next steps: The Assistant Mayor for Children’s Services has agreed that a new Learning Support Service should be constructed from the budget currently available for the Inclusive Learning Service. The Assistant mayor has recommended that a full consultation exercise be undertaken against models 1 and 2 of the proposal. The consultation has been undertaken during the autumn term 2012-13. Section A – What are you impact assessing? (Indicate with an “x” which applies):A decision to review or change a service A strategy A policy or procedure A function, service or project X X Are you impact assessing something that is?:New Existing Being reviewed X 1 Being reviewed as a result of budget constraints Describe the area you are impact assessing and, where appropriate, the changes you are proposing? The current Inclusive learning service provides support at School Action Pus and Statutory levels to pupils who have Sensory Impairment. It also provides support at School Action Plus to pupils with Autism and Behavioural needs. It provides assessment against standardised tests for pupils with Specific learning Difficulties. There are currently 9.8 FTE teachers working with pupils with Sensory Impairment and 2 teachers and 2 consultants working with pupils with other needs. The service also employs a number of teaching assistants. The total budget for the service is just short of £1.5million. The service has no single reference point in terms of leadership and describes itself as rudderless. As well as the teams described above the service have recently been joined by the EMTAS team a team of a service leader, a teacher and Teaching assistants. . The proposal is to create from within the current budget a Learning Support Service which is designed to: - Meet the needs of the pupil population across the city in all four PLASC Categories. (Learning, Communication and Interaction and Sensory) - Support schools in meeting their duties through the National Curriculum statement which entitles all pupils to Quality First Teaching, - Support schools in meeting the needs of pupils at School Action and School Action Plus. - Focus on improving outcomes for children and young people. - Support settings and families where sensory / physical impairment is identified below statutory school age. The model/s suggested for the new service which will allow it to meet all the recommendations of the commission is/are: Model 1 Number of Staff 1 2 Group 1 1.5 1.5 Role Manager L13 Teachers TLR 2 + SEN 2 (1 Teacher QTVI / HI) Specialist Teachers of Communication and Autism Specialist Teachers of Speech Language and Communication 2 1 2 2.5 0.5 Group 2 4.5 or 5 Speech and Language Therapist Specialist Teachers of Pupil and School Support (Learning and Cognition) (SLA) Teaching Assistants Teaching Assistant 1 0.5 Teachers of the Deaf including Early Years (4.5 if TLR is QTHI) Audiologist (SLA) 2.0 or 2.5 1 / 0.5 0.8 6.5 0.5 1.5 Teachers of the Visually Impaired (2.5 if TLR is QTHI) Teacher / professional (OT)(SLA) for Physical Difficulties Mobility Officer Teaching Assistants TA 3 & SEN Teaching Assistant 1 Admin The total funding available is £1,200,000 this model requires £1,139,543 at the highest point on the scale for all staff. This would give for £70k to commission AHP support. Contact Hours available – 14.610 7,422 2,778 800 Teacher hours per annum. Teaching Assistant hours per annum AHP Hours Mobility Officer Hours Evaluation of the Model This model has minimal risk attached to it. There were 8 managers, 6 teachers and 2 consultant posts in the old model giving a total of 16 posts in the new model there are 3 managers and 12.5 teachers. There were 11.9 TA’s in the old structure there are 10 TA’s in the new structure. The level of mobility officer is maintained. In the old structure the only Associated Health Professional was a 0.5 Audiologist, the new structure has sufficient resource in it to 3 commission 2.0 full time equivalent AHP’s to cover, SALT, Audiology and Occupational Therapy. The model will be fit for the new proposed education, health and social care plan and a good basis on which to move forward into a way of working in partnership. This model is flexible and covers all the needs groups currently identified in both breadth and depth. This model responds to the comments which parents have made during the commission process. This model does allow for future flexibilities such as joint venturing, joint commissioning and trading. Model 2 Number of Staff 1 2 Group 1 1 1 1 2 7 1 Group 2 3.5 2.0 0.5 0.8 7 1 1.5 Role Manager L13 Teachers TLR 2 + SEN 2 (1 Teacher QTVI / HI) Specialist Teachers of Communication and Autism Specialist Teachers of Speech Language and Communication Speech and Language Therapist Specialist Teachers of Pupil and School Support (Learning and Cognition) Teaching Assistants Teaching Assistant 1 Teachers of the Deaf including Early Years Teachers of the Visually Impaired Teacher / professional for Physical Difficulties Mobility Officer Teaching Assistants TA 3 & SEN Teaching Assistant 1 Administration Contact Hours available – 10,183 14,168 1,235 800 Teacher hours per annum. Teaching Assistant hours per annum AHP Hours Mobility Officer Hours 4 The total funding available is £1,200,000 this model requires £1,098,987 at the highest point on the scale for all staff. This would give a small contingency of approximately £90k to commission AHP support. Evaluation of the Model This model has some risk attached to it. There were 8 managers, 6 teachers and 2 consultant posts in the old model giving a total of 16 posts in the new model there are 3 managers and 10 teachers. There were 11.9 TA’s in the old structure there are 16 TA’s in the new structure. The level of mobility officer is maintained. In the old structure the only Associated Health Professional was a 0.5 Audiologist, the new structure has sufficient resource in it to commission 1.0 full time equivalent AHP’s to cover, SALT, Audiology and Occupational Therapy. The model is moving towards being fit for the new proposed education, health and social care plan but would need further revisions to enable us to move forward into a way of working in partnership. This model covers all the needs groups currently identified but is very thinly spread and may lead to the need to review how we identify pupils with whom the service works. This model responds to the comments which parents have made during the commission process in that it increases the number of teaching assistants but at a cost to the number of qualified personnel either teachers or AHP’s . This model does not allow for future flexibilities such as joint venturing, joint commissioning and trading. New Service Final Specification Number of Staff Role 1 Manager L15 3 Teachers TLR 2 + SEN 2 (1 Teacher QTVI / HI 5-16 years, 1 Teacher QTVI / HI 0-5 years 1 Learning / Communication ) Group 1 1 or 1.5 Specialist Teachers of Communication and Autism MPG + SEN 1+1 1 or 1.5 Specialist Teachers of Speech Language and Communication MPG + SEN 1+1 1.5 or 2 Specialist Teachers of Pupil and School Support (Learning and Cognition) MPG + SEN 1+1 3 Teaching Assistants Group 2 5 4.5 or 5 Teachers of the Deaf including Early Years MPG + SEN 1+1 2.0 or 2.5 1 / 0.5 1 Teachers of the Visually Impaired MPG + SEN 1+1 Teacher MPG + SEN 1+1 / professional (OT)(SLA) for Physical Difficulties Mobility Officer 7.5 1 Teaching Assistants TA 3 & SEN Sensory Service Technician 1.5 Admin Commissioned Speech and Language Therapist Audiologist (SLA) Occupational Therapy Physiotherapy 6 Evaluation of the Model This model meets the recommendations of the Cabinet Commission and responds to some of the comments made through the consultation. There were 8 managers, 6 teachers and 2 consultant posts in the old model giving a total of 16 posts in the new model there are 4 managers and 12.5 teachers giving a total of 16.5 posts In the Group 1old model there were 3 teachers all with TLR’s or employed as consultants, in the new model there are 5.5 teachers and 1 manager (0.5) teaching commitment. In Group 2 for the old model there were 3 teachers all with TLR’s, in the new model this is reduced by 1 to 2. In the old model there were 4 teachers in the new model there is the equivalent of 5.5 FTE teachers. There is no Head of Sensory Services in the new structure, this role would be covered the Service Manager supported technically by the TLR’s. 7 The Teaching and Learning Responsibility posts will be offered for specific service roles working with pupils aged 0 to 5 and 5-16. There were 11.9 TA’s in the old structure there are 10.5 TA’s in the new structure. The level of mobility officer is raised to 1Full Time Equivalent. A new FTE role of Sensory Service Technician has been created in line with comments from members of the Sensory Teaching team and RNIB. In the old structure the only Associated Health Professional was a 0.5 Audiologist, the new structure has sufficient resource in it to commission 2.0 full time equivalent AHP’s to cover, SALT, Audiology and Occupational Therapy and Physiotherapy. Approx £85k is available to commission this support. Analysis of teaching / support time available. Actual teaching time available for Learning Support in the old model 3, Actual teaching time available for Learning Support in the new service 5.5, Actual teaching time available for Teachers of the Deaf in the old model 5.7, Actual teaching time for Teachers of the Deaf available in the new service 5.5. Actual teaching time for teachers of the Visually Impaired in the old model 2 FTE (Full Time Equivalent), Actual Teaching time in the new service 2.5 FTE (Full Time Equivalent),. Management time is reduced by 1.3 FTE to accommodate this. The model will be fit for the new proposed Education, Health and Care Plan (EHCP) and a good basis on which to move forward into a way of working in partnership. This model is flexible and covers all the needs groups currently identified in both breadth and depth. This model responds to the comments which parents have made during the commission process and to comments made by staff and parents during the consultation This model does allow for future flexibilities such as joint venturing, joint commissioning and trading. The recommendations of the Cabinet Commission are clear about the focus on pupil achievement and learning outcomes this model through a review of working practice will enable the new service to meet this recommendation. Section B – Is a Community Impact Assessment required (Screening)? Consider what you are impact assessing and mark “x” for all the statement(s) below which apply Service or policy that people use or which apply to people (this could include staff) Discretion is exercised or there is potential for people to experience different outcomes. For example, planning applications and whether applications are approved or not 8 X Concerns at local, regional or national level of discrimination/inequalities Major change, such as closure, reduction, removal or transfer Community, regeneration and planning strategies, organisational or directorate partnership strategies/plans Employment policy – where discretion is not exercised Employment policy – where discretion is exercised. For example, recruitment or disciplinary process X X X– If none of the areas above apply to your proposals, you will not be required to undertake a full CIA. Please summarise below why a full CIA is not required and send this form to your directorate equality link officer. If you have identified one or more of the above areas, you should conduct a full CIA and complete this form. Equality Areas Indicate with an “x” which equality areas are likely to be affected, positively or negatively, by the proposals Age X Religion and/or belief Disability X Sexual Identity Gender (including pregnancy and maternity) People on a low income (socio-economic inequality) Gender reassignment Other (please state below) (For example carers, ex offenders) X Race If any of the equality areas above have been identified as being likely to be affected by the proposals, you will be required to undertake a CIA. You will need only to consider those areas which you have indicated are likely to be affected by the proposals Section C – Monitoring information C1 Do you currently monitor by the following protected characteristics or equality areas? Age Yes (Y) or No (N) If no, please explain why and / or detail in the action plan at Section E how you will prioritise the gathering of this equality monitoring data. Y Details of pupils at all stages and phases of education will be used to inform the decision. This information will be taken from the Area Needs Assessment, the EMS database and the schools census returns. Other databases will 9 Disability Y Gender (including pregnancy and maternity) N Gender Reassignment N Race N Religion and/or belief N Sexual Identity N People on a low income (socio-economic inequality) N Other (please state) (For example carers, ex offenders) N support the understanding of the need base e.g. data submitted to CRIDE and RNIB. Details of pupils at all stages and phases of education will be used to inform the decision. This information will be taken from the Area Needs Assessment, the EMS database and the schools census returns. Other databases will support the understanding of the need base e.g. data submitted to CRIDE and RNIB. 10 Section C (continued) – Consultation C2 Are you intending to carry out consultation on your proposals? Yes If “no”, please explain your reason(s) why If “yes”, please give details of your consultation exercise and results below Staff consultation will take place Parent consultation will take place Presentation to Governors Presentation to Primary Heads on Stakeholder Group / Focus group Consultation responses - Creation of a Learning Support Service for Salford Range of responses via e-mail Responses were received from Health Colleagues National Associations Teachers SHAPAS LA officers Parents Local Association - SDCS The following are the responses to the statistical questions at the beginning of the questionnaire. 1. Are you a: Primary Teacher / TA 9 11 Secondary Teacher / TA Governor LA Officer Parents 8 0 3 0 2. The recommendations of the commission are to create a Learning Support Service covering sensory impairment, physical impairment, communication and cognition and learning difficulties. Do you think that the models created meet this recommendation? No Yes 5 16 3. Do you believe the professional staffing cohort of the new service should include: Teachers Yes No 22 Teaching Assistant Yes 20 No 2 AHP's (Allied Health Professionals – Speech and Language Therapists, Physiotherapist, Occupational Therapist, Audiologist) Yes 21 No 1 Mobility Officers Yes 15 No 1 12 4. Which of the associated health professionals do you think should have a role in the new service? SALT (Speech and Language Therapy) Yes 19 No 1 OT Yes No (Occupational Therapist) 16 4 PT (Physiotherapist) Yes 16 No 4 Audiology Yes No 19 1 None of them Yes 1 No 5. Do you think a service could be developed without a mobility officer being directly employed by that service i.e. the expertise in this area would be commissioned from an external provider? Yes No 12 10 13 6. The proposed teaching assistant structure in both models allows for the use of a teaching assistant level 1 to undertake resource creation as part of their job description. Do you consider this to be important in developing quality within the service? Yes No 13 7 7. Do you believe that model one can deliver the recommendations of the commission? Yes No 12 9 8. Do you believe that model two can deliver the recommendations of the commission? Yes No 5 10 9. Which model of delivery do you prefer? One Two Neither 3 1 8 14 Overall the preference was for a model similar to the one proposed at model one of the consultation document. Issues Response The responses below reflect all comments made during the consultation period and the themes cover all aspects raised. Where issues / comments have come from several respondents these have been combined to provide an overall response. 1. The rationale for the changes does not appear to have been fully explained. The rational for all the changes sits in the evidence which was presented in full to the Commission. Some of which is public is on the website, some of which is because of its sensitive nature is being used as management information. The commission members who have seen all the evidence are convinced of the need for change. Evidence presented to the commission which is in the public domain is on the Salford website. 2. The changes are being portrayed as a solution to efficiencies and funding reduction. This is not an efficiencies drive – all money stays in the system. 3. The need for a Visual Impairment (VI) Resources Assistant has been highlighted by a number of respondents. The model recognises that there is a need for a ‘Resources Assistant’, since the post became vacant the way in which Salford recruits to posts which are deemed ‘administration’ has changed. Therefore the way in which we approach this has to be changed. One respondent has suggested that we should view this post as being a technician post rather than resources assistant. This is supported by RNIB and is in the final service model. 4. If there is no Head of Sensory Service the person leading this strand will have no remit to take initiatives forward. All staff within the new structure will have the appropriate levels of responsibility to initiate and take forward change. It is not about status and label but about staff feeling empowered and supported to do the work. 15 5. There will be a significant reduction of teachers in the Sensory Team, especially The Hearing Impairment (HI) team. *TLR – Teaching and Learning Responsibility * TOD – Teacher of the Deaf * QTHI – Qualified Teacher of Hearing Impaired This has been the issue which has concerned respondents the most where they have felt the need to make additional comments. Lack of accurate data still makes it very difficult to assess. The issue has been given serious consideration, in doing that the current staffing model needs to be clarified. The model one proposal means. Current HI Staffing 3 x TLR 4 x Teachers = 5.5 TOD time Model 1 = 5 QTHI Actual reduction in model 1 0.5 Responses to the issue of the number of teachers of the deaf needs to be considered alongside comments on the role of early years teachers of the deaf and how we can meet the needs of pupils post 16. In the final model the actual reduction is 0.2 FTE There has been considerable discussion about the amount of time spent on TLR responsibilities by post holders and whether or not they had a responsibility across both Hearing and Visual Impairment. It is clear from the Job Descriptions of the TLR Holders in the Current Service that there is an expectation that they have a role across the Sensory Team. National Expectations would be that this was for 0.3 of a teaching week. Extracts from TLR Job Descriptions. 1. Teacher of the Hearing Impaired with responsibility for Early Years Delivery within the Sensory Team. 2. Teacher of the Hearing Impaired with responsibility for ensuring Sensory Team awareness of ICT initiatives in schools, the impact of these on children and young people with a sensory impairment and consequences for their access to the curriculum. 3. Teacher of the Hearing Impaired with responsibility for ensuring that the Sensory Team is aware 16 of initiatives in social and emotional aspects of learning as they affect children and young people with a sensory impairment. Analysis of the actual current caseload allocations of support to individual pupils by teachers in the Service shows that there will need to be no reductions in the amount of Teacher of the Deaf of Teacher of Visually Impaired pupil time allocated to individual pupils in the transition to the restructured service. The actual analysis based on sessions being 1.5 hrs shows that all sessions can be accommodated with capacity to ensure that the needs of pupils joining the caseload can be met. Parents will receive individual letters explaining their current allocations and projected allocations going forward. TA Session Sessions needed Total 5244 Actual Sessions Difference 6591 1347 Teacher Analysis from Caseload Data April 2013 Sessions Needed HI VI Supported 4135 1213 Monitored MI 484 Total 5832 125 Difference 5957 6. There is no evidence to show that pupils with Physical Difficulties require a service. Sessions available 6451.5 6451.5 Sessions available by need 4554 1897.5 494.5 6451.5 Equipment assessment has previously been done by SEN Consultants. They have provided information for schools in situations where a syndrome means that additional information is required to allow pupils to access education. This is not consistent with either enabling positive responses and provision or ensuring that we meet the needs of all pupils. What provision we have made 17 previously is no longer available therefore provision needs to be made elsewhere. It would also make us very vulnerable in terms of Equal Opportunities requirements. 7. Physical disabilities are not as much a barrier to learning as Hearing Impairment. This conflicts with current legislation and thinking on Equal Opportunities. 8. There has been no impact assessment on the changes which are being proposed. Impact assessments on caseload, diary commitment, travel, impact on schools etc has been looked at. Change in working practice should ensure continuation of service. The full CIA has been completed and will be presented with this paper. 9. It is not clear from the information given as to the relationship between pupil numbers and staffing. The service has already been restructured in 2007 and therefore there should be no change. Accurate data would have been very useful in further determining provision. However to argue that because there was a reduction in 2007- 2008 does not hold water. The world of SEN and Disability has changed in the last 5 years as has technological development. Analysis of data produced for the commission shows that there are simple practical changes which can be made which will improve working practice. 10. Staff need mandatory qualifications in sensory impairment. All staff employed to work primarily with pupils with HI/VI will either have the qualifications already or be offered the opportunity to become qualified - even though this is not mandatory. 11. There is a need for a strong preschool provision and this could be done There is a need for someone with the relevant skills knowledge and expertise to deliver the wide coverage required by stringent national requirements. 18 through the employment of a Teacher of Learning Responsibility (TLR) for Early Years. Recommendations are likely to suggest that we need the expertise at this level, whether it is a Teacher of Learning Responsibility (TLR) post is still to be determined. 12. One of the foci for the new service is increasing capacity of schools to meet SEND. The contention is that the Sensory Service already does this. Evidence provided for increasing capacity is very limited. This element has to be increased with the right people working and supporting at the right level. 13. Reduction in the number of teachers of the deaf will mean that they cannot Support pupils in college. College age pupils are funded differently. There are a number of ways in which this can be done and this will need to be worked out with post 16 providers and through a relevant plan with adults. 14. There is no money in school budgets to support the needs of pupils with Sensory Impairments. All schools have budgets to meet the needs of all pupils. All teachers are teachers of all pupils (NC statement Professional Standards for Teachers Care). Schools should be ensuring access to provision for all pupils from normally available resources – Support Services are there to ensure this happens. 15. Only pupils with a Statement will be guaranteed support. Support will be available at Early Years Action (EYA), Early Years Action Plus (EYAP), School Action (SA) and School Action Plus (SAP) levels. There are 19 mechanisms to ensure this can happen and schools that are able to demonstrate it are built into the proposals. The expectations of schools in this area in terms of meeting the needs of pupils with Sensory Impairments have been in available to schools for over a year. 16. The changes proposed will not facilitate the development of an Education Health and Care Plan (EHCP). The joint working envisaged with the Education Health and Care Plan (EHCP) is to support educational attainment achievement and goals. Having commissioned AHP time embedded in the service will support this as will working with health on their new referral pathway (Child Development Forums). Consistent, co-ordinated planning is key to success here. 17. Specialist Staff should be employed to meet the needs of Sensory Impaired Children. There is no expression of any intention in the proposal to stop using Specialist staff, quite the converse. 18. Mobility Officer Role. The inclusion of this role has been welcomed by all respondents. The query as to whether this role can/should be expanded is being considered. Royal National Institute of Blind People (RNIB) were keen to explore whether given the number of potential Braille users and meeting their needs there was flexibility in the role of mobility officers, which there is as we have 2 qualified mobility officers who are currently employed full time in a combined mobility officer / TA role. 19. That is proposed to have a salary capping at M2 for teachers and not pay SEN points. This is not suggested anywhere in the proposal or possible under Teachers terms and conditions. The proposal is very clear that all posts will be remunerated as required by the Teachers Terms and conditions document with appropriate arrangements for pay progression. SEN points will be awarded for future appointments on the basis of 1 20 SEN point mandatory, 2nd SEN point discretionary. 20. The union model and one respondent have suggested the Removal of the Service Manager Post. 21. A previous service user is concerned that teacher of the deaf (TOD’s) will not be available to replace batteries and clean Hearing aids. The Service Manager post is needed because they will manage not just the Sensory and Learning strands but Behaviour and EMTAS as well. They will also have a liaison role with the Principle Educational Psychologist. To expect the Head of Service Complex Needs SEN to take on another 4 direct line managements is untenable. This is a role that can be done in school, by teaching assistants (TA) and by pupils themselves. Teachers of the Deaf (TODs) need to be available to advise on effectiveness of aiding but basic maintenance can and should be provided from elsewhere. 22. RNIB were concerned that pupils and families had not been consulted during the process. A focus group of young people from a range of lead groups across the city was brought together by the Integrated Youth Support Service (IYSS). All lead groups were invited some were unable to provide representation, families have been involved in the commission and in the focus groups. Throughout the Commission Process and the consultation teachers in the service have been encouraged to engage with families and service users and to get comments / responses from them. Salford Deaf Children’s Society was offered a separate opportunity to contribute to the consultation and sit on the commission. Salford Family Forum also sits on the commission. There has also been a face to face discussion with an ex service user who wished to make their views known. 23. RNIB were concerned that the language and assumptions in the proposal did not meet the requirements of the proposed developments There are no clear directions as yet as to what these would look like therefore this is not possible. The current context for change including Education Health and Care Plan (ECHP’s) and School Funding Reform (SFR), are assumed within the document as a whole. The reason there are embedded Allied Health Professional (AHP’s) in the proposal is to ensure that the relevant professionals are there ready when guidance 21 nationally. 24. RNIB suggested it would have been helpful to have full data on numbers of pupils worked within the proposal. becomes clearer to support and develop the process going forward. We are also working closely with the development of the Child Development Forums and meet regularly with SRFT staff to ensure there is joint working. No data is included in the proposal because after numerous requests and deadlines accurate data on the number of pupils receiving/requesting the service was not made available until after the consultation had closed. This is a management issue which is being pursued separately. Data provided by service management on the 17th January has now been accepted as being accurate and has been used to draw conclusions about the number of pupils requiring the service this includes. Data produced by the teachers, PLASC, Local Disability Data, and national prevalence information. By triangulating these data sources we have confidence in the use of the data going forward. As the database strengthens and improves there will be ongoing review to ensure that pupil needs are met. January 17th 2013 Data provided by the Head of the Service. HI (Hearing Impairment) NATSIP A1 A2 A3 B1 B2 C1 Number 20 26 28 26 18 10 Total 128 C2/3 Total 180 308 VI (Visual Impairment) NATSIP Number 22 A1 A2 A3 B1 B2 C1 Total C2/3 12 11 5 13 5 8 54 54 Total 108 MI ( Multi Sensory Impairment) NATSIP A1 A2 A3 C1 Total Number 2 4 4 2 12 HI (Hearing Impairment) 25 Pupils are pre school 104 pupils are 5 – 16 years old Year Group -5 -4 -3 -2 -1 0 1 2 3 4 Number Total 64 2 2 5 2 3 11 10 10 16 3 Year Group 5 6 7 8 9 10 11 12 13 Number 5 8 6 12 12 5 5 5 2 60 23 141 VI (Visual Impairment) Year Groups Year Group -5 -4 -3 -2 -1 0 1 2 3 4 Number Total 30 1 1 6 3 2 3 3 4 3 4 Year Group 6 7 8 9 10 11 12 13 14 Number 7 2 6 3 1 2 1 1 1 24 MI Year Groups Year Group -3 -2 -1 3 4 5 10 16 Total Number 1 3 4 3 1 1 2 1 16 Pupils with Statements of SEN or at SAP from PLASC 24 Type ASD SLCN SPLD Hearing Imp. Visual Imp. Total Primary Secondary 123 571 158 38 21 911 69 219 43 12 10 353 25. RNIB commented that past staffing models were not within the document and that this made it difficult to compare with the proposed model. Both models are in the document which has been on the Salford website since October 16th 2012. RNIB have withdrawn this comment. Discussions about number of staff required and intensity of need is difficult to follow when accurate caseload info is not available. Validated CIPFA information tells us that 44% of pupils with VI with statements are in Special Schools which is above national average. What local information available indicates is there are 132 VI pupils, 18 of these are post 16, 40 have Statements, 28 of these are in Special Schools and 25 of them in local authority Special Schools. Assessment data has only been presented for 2 of the 132 pupils. It has now been established on the 17th January that 54 pupils were receiving direct support from the Service of which 2 are identified as Braille users. 26. RNIB commented that Early Years provision is specifically mentioned for Hearing Impairment (HI) but there is no specific mention of Early Years provision for Visual Impairment (VI). The consultation document specifically states that both the Education Psychology Team and the Sensory Team would work with Children and Families from point of diagnosis. Clearly as this is frequently in the early years they would be working in this area. It has been agreed that documents going forward will be specific in this area. There are currently 11 pupils under school age receiving support from the service. 25 27. RNIB were concerned that the referral process could become clogged by it having to come through a senior professional. Referrals will be able to be made by any appropriate agency. As at present there is an agreed/robust referral system for Sensory Support. It is important to establish the role of the manager as the accountable person in the system. A new referral process linked with health and other agencies has been developed with Salford Royal Foundation Trust (SRFT) Child Development Forum; the Head of Service / Teacher of Learning Responsibility (TLR) will sit on these panels and further develop working practice through this. 28. RNIB were concerned that the packages suggested would limit access to services. The packages within the proposal are designed to help schools understand the requirements of the notional SEN budget, enable access to central services and ensure that pupils with sensory impairment do not become disenfranchised because they are entitled to services from a centrally retained budget. Planning has been raised as an issue at all levels and needs to be addressed as an operational issue going forward. 29. Lack of planned approaches is leading to significant duplication / ignorance of work being undertaken. 30. Health professionals raised questions about how the Allied Health Professional (AHP’s) was to be funded and were they additional to those already there. We currently have Speech and Language Therapist (SALT) professionals and an Audiologist working in the service. These would continue and possibly with expansion for Speech and Language Therapist (SALT) and enhanced by further Allied Health Professional (AHP) support form Occupational Therapy and Physiotherapy. 31. Clarity needed about ways of working so that we have agreed interventions being used across the city to met need. The need for clarity of expectations from professionals is very clear. It is important that all partners are agreed on the working parameters and work together to ensure that recommendations are congruent. This is doubly important because only through planned working can we reduce duplication and make sure that we do it once – properly. It is very clear that this is important, however what has come through is that Teaching 32. Both Teachers and 26 Teaching Assistants have an important place in the service. 33. One model suggested the removal of Teacher of Learning Responsibility (TLR’s) from the structure. Assistant (TA3’s) need to be working at a significant level and empowered to take responsibility for their own work and develop a niche in terms of their unique contribution. This would remove strategic guidance on practice. As part of the consultation a further model was offered for consideration. This was submitted on behalf of some members by professional associations. 27 This model does not meet the recommendations of the Commission into Inclusive Learning Services as there is no provision for pupils with Physical Disabilities and the cost of this model would be approximately £200,000 over the available budget for the service with no funds to commission Health Services.. There is also less provision in this model for pupils with Autistic Spectrum Condition and Speech, Language and Communication Needs than in Model 1. This model does not fit the management structure agreed by the City Council and when considered alongside the other groups in the proposed service would increase the direct management posts for the Head of Service SEN by 6. There are also equal opportunities problems in this model because by reducing the management element in Group 1 it could be perceived that the needs of the pupils covered by this group were of lower status than those in Group 2. All issues raised have been considered carefully and have been used to review model one and produce a final model which will be recommended for implementation. Section C (continued) – Analysis 28 C3 What information has been analysed to inform the content of this CIA? What were the findings? Please include details of, for example, service or employee monitoring information, consultation findings, any national or local research, customer feedback, inspection reports, and any other information which will inform your CIA. Please specify whether this was existing information or was specifically in relation to this equality analysis and CIA process A Cabinet Commission was set up to inform the recommendations Membership of the Commission Cllr. Margaret Morris (Chair) – Assistant Mayor Cllr. Derek Antrobus / Cllr Paul Dennett - Assistant Mayor Cllr. Norbert Potter Cllr. Ray Mashiter Cllr. Lisa Stone - Assistant Mayor Cllr. Jillian Collinson National Deaf Childrens Society – Hazel Badjie Committee member for Salford Deaf Children’s Society and parent of 2 young people with different special educational needs – Lauren Walton Founder member of Salford Family Forum and parent of a pupil with a disability – Deanne Shaw Background and Scope of the Commission On the 10th of January 2012 a proposed new structure for their team was presented to the Inclusive Learning Service team members and the necessary consultation period began. The response to this from some officers and the receipt of a petition submitted by Lauren Walton and 5000 others led the Leader of the Council John Merry to agree to an extension of the consultation process related to the review of the provision of services to children and young people with hearing impairment within the wider review of Inclusive Learning Services. He also agreed to the establishment of a Cabinet Commission containing elected members and representative groups to support the process of consultation on, and future design of services. It was also agreed that full participation from related focus and other groups with the Commission be encouraged. Evidence was taken from all stakeholders. The Commission Process In order to carry out its role, the commission was required to determine the provision for all SEN groups by: o Establishing existing (as-is) practice of the specialist teaching arm of the Inclusive Learning Service o Establish statutory elements Benchmarking against local and national best practice standards, data and provision, e.g.: 29 o Ofsted 2012 framework for inspection of schools o Quality Standards for specialist teaching and support services for deaf people and young children o National Standards for school improvement professionals’ o Quality standards for special educational needs for support and outreach services o Other local authority data o Consider implications of green paper “Support and Aspiration” Determining models of provision based on the information gathered above. All models will include: o Community Impact Assessment o SEN Impact Assessment Consulting with partners and stakeholders Questions the Commission worked to answer The Commission set itself seven questions to answer by undertaking a variety of activities and using a number of methodologies. Activity undertaken on behalf of the Commission or by the Commission In order to ensure that all relevant evidence was collected the Commission has used a range of methodology. Data Collection In reviewing the data available to ascertain the number of pupils in Salford who may need an intervention from the Learning Support Service a wide range of data sets were used: a) The Area Needs Assessment: The Area Needs assessment is the single most comprehensive analysis of need of Children with Disabilities in Salford. All the data below except the CRIDE data and the caseload data have contributed to it. b) The PLASC data for 2011 and 2012. This is the data collected by the Department for Education in January every year. It is collected at pupil level and therefore reflects the schools view of the 5-16 population. c) The data produced from the Education Management System (EMS). This data is taken from the LA system which is maintained by the Special Needs Team and therefore accurately reflects the position with regard to pupils with statements of SEN. d) The CRIDE data for 2009 – 10, 2010-11 and 2011-12. This is a data set relating to pupils with Hearing Impairment and is internal data supplied by members of this team 30 to the National Deaf Children’s Society. e) The caseload data produced by the Sensory Service. This is internal data produced by the sensory service on the request of the commission. f) The Statistical First Release this is the annual DfE report based on the nationally available statistics on young people in England and Wales. It is a public domain document. Diary Logging Between the 16th of April and the 27th of April all members of the current Inclusive Learning Service undertook a comprehensive diary logging exercise against a series of predetermined codes. This was designed to establish both the range of activity they are currently performing and also where there are gaps in the offer which is currently made. The codes used were from 16th April to the 27th April inclusive and recognised as covering the range of activities which an Inclusive Learning Service should undertake. Web Trawl A web trawl was constructed and undertaken by a member of the commissioning team. The purpose of the Web Trawl was to collect high level information about LA provision which is made for pupils in mainstream schools as outlined on the public pages of the website of a sample of 40% of Local Authorities. From the information gained 12 LA’s were identified as needing further investigation, letters were written to the Directors of Children’s Services in those Local Authorities and a series of visits are underway. Visits have been undertaken to Lancashire, Staffordshire, Halton, Stockport, and Blackburn with Darwen, During the Open Session an additional Local Authority was identified as having good practice in the area of support for Children and Young People with visual impairment, this Local Authority was duly contacted. Open Session The open session met on the 9th May 2012. The following respondents gave evidence to the commission and their contributions can be accessed through the Salford website. http://www.salford.gov.uk/ilscommission.htm Ms S Cusick / Ms Grundy Dr J Muscutt – Principal Educational Psychologist Adele Ross – JSENSE Ms L Price EMTAS / ILS Ms L Armstrong / Mr R Cobb - RNIB Ms M Morris – SALT SRFT 31 Ms J Reeves - NDCS Ms P Dutton – Parent Dr A Pike – Consultant Community Paediatrician Ms J Heath – Head of Sensory Services Ms A Sharpe – Teacher of the Deaf Ms H Shenton – Teacher of the Deaf Ms A Bever-Warren – Head teacher New Park School Cllr Balkind – Supporter SDCS Ms S O’Neill – Parent Focus Groups Four Focus Groups have met three times, these focus groups were for National and Local Lobby groups, Education Representatives, Partners in Salford and Parents, a fifth Focus Group for young people has met twice. The focus groups were given structured tasks on each date they met and were supported to consider and answer the questions which the commission set itself. Questionnaires A series of questionnaires were developed for use with Schools and Settings and Parents and Carers. The questionnaires were available both online and in paper form. The response to the questionnaires was limited but those submitted were analysed and recurrent themes were translated into the overall recommendations. The Commission The commission itself has met five times including the Open Evidence Session. At each meeting, information collected since the previous session has been presented, and the commission has discussed in detail the implications of what it has been told and requested additional clarification / information. Section D – Potential impacts and how these will be addressed Could your proposals have a Yes (Y) No (N) Explain impact(s) and what evidence or data exists to support your analysis? 32 differential impact relating to age equality Will people within certain age ranges not be getting the outcome they need? Will people within certain age ranges be disadvantaged as a result of your proposals? If the impact is negative, how will it be reduced or eliminated? If you are unable to eliminate, reduce or mitigate negative impacts, are your proposals potentially discriminatory on the grounds of age? Will the proposals mean that people within certain age ranges will experience positive outcomes? Highlight any positive impacts N N N Y Pupils within the need groups, Physical Difficulties, Learning, Communication will get a service not currently available. In year 1 the provision for pupils with HI and Vi will be protected. Y Are the proposals likely to impact on community cohesion? Is there potential to enhance relationships between people who share a protected characteristic and those who do not? Identify areas where there is potential to foster good relations The proposals mean that more Salford Children will be educated in Salford in local mainstream schools. More Salford pupils who have problems with their learning will get support to achieve aspirational outcomes. All Secondary Head teachers and members of SHAPAs have signed upto the vision of the new service. Section D (continued) – Potential impacts and how these will be addressed 33 Could your proposals have a differential impact relating to disability equality Will people with a disability not be getting the outcome they need? Will people with a disability be disadvantaged as a result of your proposals? If the impact is negative, how will it be reduced or eliminated? If you are unable to eliminate, reduce or mitigate negative impacts, are your proposals potentially discriminatory on the grounds of disability? Will the proposals mean that people with disabilities will experience positive outcomes? Highlight any positive impacts Yes (Y) Are the proposals likely to impact on community cohesion? Is there potential to enhance relationships between people who share a protected characteristic and those who do not? Identify areas where there is potential to foster good relations No (N) Explain impact(s) and what evidence or data exists to support your analysis? N The proposals are not discriminatory on grounds of disability as the proposal is not to remove the service but to align it appropriately across all need groups. This means that the service will continue to be delivered but in a different way. There is a minimal reduction of teaching time for pupils with Hearing Impairment and this will be overcome by introducing more effective working practice. N N Evidence shows that robust alignment of Support Services against the national standards improves outcomes for clients in the focus groups. Y Clients who have needs in Physical Difficulties, Communication, Learning and BESD will receive an enhanced level of service, with equity being maintained across all need groups. Pupils with Visual Impairment will benefit from an additional teaching capacity of 0.5 and the services of a sensory technician. Y The proposals mean that more Salford Children will be educated in Salford in local mainstream schools. Therefore developing an increased understanding of people in the wider community and their needs. Section E – Action Plan and review 34 Detail in the plan below, actions that you have identified in your CIA, which will eliminate discrimination, advance equality of opportunity and/or foster good relations. If you are unable to eliminate or reduce negative impact on any of the equality areas, you should explain why Impact (positive or negative) identified Proposed action Person(s) responsible Required outcome Service Manager Where will action Target date be monitored? (e.g., Directorate Business Plan, Service Plan, Equality Action Plan) Business plan September 2013 Reduce the teaching capacity of the HI team by 0.2 Sensory Technician recruited Review working practice to ensure that pupils still receive a service in line with NATSIP requirements Undertake recruitment process HOS SEN Business plan September 2013 Effective working sustained. All staff moved into roles in the new service Undertake recruitment process HOS SEN Business plan September 2013 Effective working sustained. Service delivery design complete and communicated to schools Delivery design agreed and implemented across current teams ASAP AD and HOS SEN Business plan September 2013 Effective working sustained. Effective working sustained. Could making the changes in any of the above areas have a negative effect on other groups? Explain why and what you will do about this. No Review 35 Your CIA should be reviewed at least every three years, less if it has a significant impact on people. Please enter the date your CIA will be reviewed January 2016. You should review progress on your CIA action plan annually. 36 Section F – Summary of your CIA As your CIA will be published on the council’s website and accessible to the general public, a summary of your CIA is required. Please provide a summary of your CIA in the box below. Summary of Community Impact Assessment How did you approach the CIA and what did you find? The CIA was undertaken through the data collection and consultation for both the commission and the consultation on the structure of the new service. It was found that the perception of potential impact was more significant than the actual impact was going to be. It demonstrated new issues which will need to be considered in the service going forward and confirmed things which we knew needed to be dealt with. What are the main areas requiring further attention? Development of the New Service LSS Summary of recommendations for improvement Implement LSS from September 2013. 37 Section G – Next Steps Quality Assurance When you have completed your CIA, you should send it to your directorate Equality Link Officer who will arrange for it to be quality assured. Your CIA will be returned to you if further work is required. It is important that your CIA is robust and of good quality as it may be challenged “Sign off” within your directorate Your directorate Equality Link Officer will then arrange for your CIA to be “signed off” within your directorate (see below). Your directorate Equality Lead Officer or other senior manager within your directorate should “sign off” your CIA (below). Name Signature Date Senior Manager Lead CIA Officer Publishing When your CIA has been signed off within your directorate, your directorate Equality Link Officer will send it to Elaine Barber in the Equalities and Cohesion Team for publishing on the council’s website. Monitoring Your directorate Equality Link Officer will also send your CIA to your directorate Performance Officer where the actions identified within your CIA will be entered into Covalent, the council’s performance management monitoring software so that progress can be monitored as appropriate. 38