Support and Aspiration: A New Approach to Special Educational Needs and Disability (v6) Consultation Response Form The closing date for this consultation is: 30 June 2011 Your comments must reach us by that date. -1- THIS FORM IS NOT INTERACTIVE. If you wish to respond electronically please use the online response facility available on the Department for Education e-consultation website: (http://www.education.gov.uk/consultations). Information provided in response to this consultation, including personal information, may be subject to publication or disclosure in accordance with the access to information regimes, primarily the Freedom of Information Act 2000 and the Data Protection Act 1998. If you want all, or any part, of your response to be treated as confidential, please explain why you consider it to be confidential. If a request for disclosure of the information you have provided is received, your explanation about why you consider it to be confidential will be taken into account, but no assurance can be given that confidentiality can be maintained. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the Department. The Department will process your personal data (name and address and any other identifying material) in accordance with the Data Protection Act 1998, and in the majority of circumstances, this will mean that your personal data will not be disclosed to third parties. Please tick if you want us to keep your response confidential. Reason for confidentiality: Michael Peters Head of Service for Special Educational Needs, Disability and Inclusion Organisation (if applicable) Cornwall Council Address: Treyew Road Truro Cornwall TR1 1EB Name -2- Please mark ONE box which best describes you as a respondent. Parent/Carer Child/Young Person School/College Headteacher/Teacher SENCO Governor Children’s Service Professional Association/Union Local Voluntary Organisation Educational Psychologist Parent Partnership Consultant/Professional Academic X Local Authority National Voluntary Organisation Other (please specify) Please Specify: Cornwall Council has organised a range of consultations to contribute to this document: to include Children and Young People, Parents, Parent Support groups, Headteachers, School Governors, Pupil Referral Units, Children Schools and Families Senior staff, SEN Coordinators, Speech and Language Therapy Services, NHS representation -3- Chapter 1: Early Identification and Assessment 1 How can we strengthen the identification of SEN and impairments in the early years, and support for children with them? Comments: Cornwall Council has a wealth of good evidence to show strengths in collaborative working with the other agencies (Children and Young People’s Plan). This is includes a highly effective multi agency forum in Early Years which is regarded as a model of good practice. We recognise that the rurality of the county poses significant challenges to ensure equity of support across geographic areas. The ‘locality pilot based on a cluster’ (of schools and settings) as referenced in the LA’s covering letter indicates how Cornwall Council aims to work with schools to redefine services to schools. The focus of this work is to improve outcomes including the achievements of learners identified with a special educational need. Cornwall’s approach has built up a good interface between services which includes an Associate Director of Community Health sitting on the Children Schools and Families Directorate Leadership Team. We consider that needs are identified early for example Hearing Impairment and we are proposing to share SEN assessment protocols with Health Visitors. This aspect would be would be developed further in the Pathfinder Proposal (detailed in the attached letter) entitled ‘model for multi agency working based on LA practice. Cornwall runs an Early Support programme which has a multi agency steering group. It is resourced through a multi agency funding arrangement. The proposed programme would be extended to further develop identification of need in the early years as well as multi agency support for families with disabled children into the school years Monitoring SEN impairment through to age 25 will be a record management challenge across agencies and across the transition from children to adult services – we consider this to be an exciting opportunity which will be explored as part of a possible Pathfinder proposal. 2 Do you agree with our proposal to replace the statement of SEN and learning difficulty assessment for children and young people with a single statutory assessment process and an ‘Education, Health and Care Plan', bringing together all services across education, health and social care? X Yes No Not Sure -4- 3 How could the new single assessment process and ‘Education, Health and Care Plan' better support children's needs, be a better process for families and represent a more cost-effective approach for services? Comments: This proposal was welcomed by parents although acknowledgement given to the expressed feeling that some parents may have had to fight for services. Our consultation clearly supports a move to create a streamlined single assessment process for children with the most complex needs. Such an assessment needs to be proportionate with placing parents and their child (ren) at the heart of the system. Not every child will need an education, care and health plan – a significant number with less complex needs may require either one or two aspects of the plan. Parents indicated that to help make this work a clear statutory framework and related requirements should now be placed on health, social care and education services to help ensure the success of such a model. Parent consultations identified that pooled budgets and sharing information across agencies would provide greater value for money and improved effectiveness of intervention, shared data and information systems. It acknowledged that there would be a need to invest in the infra structure to make this happen. The reference to the LA establishing a model for multiagency working (covering letter) reinforces this point. Cornwall Council is seeking to place parents and carers at the heart of our approach to reduce to the maximum extent possible administrative or ‘SEN’ processes which can sometimes distance families from engaging and working with us to support their families 4 What processes or assessments should be incorporated within the proposed single assessment process and ‘Education, Health and Care Plan'? -5- Comments: Cornwall Council’s aspiration is to build further on what we know works well to enable children and young people to achieve so that they are, to the greatest extent possible, ‘the author of their own life story’. A clear referral pathway would be required. There should be a menu of available services combined with smart commissioning to address any/all identified service gaps which may be found. Parent Consultation identified that there would need to be liaison between services at key discharge and transition points. Assessment should also take into account the needs of siblings. We have identified that holistic health care assessment should include physical health, milestone development, emotional and psychological well-being. This would be further explored in our outline proposal (detailed in the accompanying letter) most particularly in scoping out and applying a single linear process shared with parents as real and meaningful partners in this development. 5 What is the potential impact of expanding the scope of the proposed single assessment process and plan beyond education, health, social care and employment? Comments: We acknowledge that in principle this is a good idea but plans must be regularly reviewed and recommendations must be acted on. If this is managed appropriately then this plan should support the child throughout his/her life. We have found that a single plan should be based on fewer yet more targeted interventions/supports. Ideally it may also include aspects of housing, leisure and transport where required. -6- 6a) What role should the voluntary and community sector play in the statutory assessment of children and young people with SEN or who are disabled? Comments: The voluntary and community sector should have an enhanced role supporting parents in the needs identification process and support for children with SEN in regards to their progress at school. The role could also involve monitoring performance of the education, care and health plans and/or SEN statements. This would include reporting on specific issues such as plans/statements being issued within 20 weeks; levels of financial support for children with multi agency plans from the NHS, Local Authority and other sources. There should be enhanced responsibility and resourcing for parent partnership functions. 6b) How could this help to give parents greater confidence in the statutory assessment process? Comments: By enabling a greater level of monitoring and reporting responsibilities for independent Parent Partnership Services covering both NHS and LA services and enhancing the role of they have in supporting parents would provide for sharper accountability and parents feeling that they have more of a voice in service improvement. 7 How could the proposed single assessment process and ‘Education, Health and Care Plan' improve continuity of social care support for disabled children? -7- Comments: This is the Council’s driver: to shape Quality Assurance involving parents. By providing that ‘listening ear’ Our consultation indicated that by connecting services together, making assessments less stressful for parents and providing more information about services the arrangements and parental engagement is likely to be greatly enhanced. It would also mean that reviews would need to be more regular than the statutory SEN annual review and guidance is needed to ensure that parents’ voice is well represented in reviews. Clear guidance is also required for transitions from children’s to adults provision in terms of education, care, health and housing 8 How could the arrangements for provision of health advice for existing statutory SEN assessments be improved? Comments: Advice from health could be improved through making clear the health progress a child is expected to make and the interventions that are needed to secure progress (or maintenance) and what the role of the agencies are in supporting this. The health guidance should also be specifically understood and supported by parents. 9 How can we make the current SEN statutory assessment process faster and less burdensome for parents? -8- Comments: We consider that such arrangements can be faster and less burdensome for parents by using parent friendly language throughout and across all our workings with parents. The statement itself could be shorter and smarter through an agreed protocol amongst professionals and parents which focused more on educational outcomes including attainment, progress and well being indicators with related objectives being more solution focused and updated perhaps by using electronic systems. We are keen to explore with parents what we mean and how we can better articulate what is meant by ‘better outcomes’. We consider it essential that we define high aspirations for all children and young people. Reduce the frequency of assessment so that children do not have to be assessed ’32 times’ and parents do not feel that they have to battle with professionals for support -9- Chapter 2: Giving Parents Control 10 What should be the key components of a locally published offer of available support for parents? Comments: 1. Sharing information about what is available and how to access it 2. Confirming budgets available to parents 3. Ensuring that the services are of good quality and represent value for money and have tangible impact We consider it essential that communications and contacts explore and work with parents to increase where necessary understanding that parents do have choices. To do this it is essential that parents have access to clear and unambiguous information. In effect that they access information to help them make a choice, Staff who work with and listen/support parents particularly – SENCOs, are vital in this regard. Greater emphasis could be given to the role of the SEN governor. It is particularly important to be clear as on how children’s needs will be met if they don’t have a statement but do have additional needs, Information provided before you choose schools about what schools can do is vital. It is also helpful to produce/clarify transparent referral criteria, referral/provision routes where appropriate packages of care/ duration of intervention are set out/to be found – for core services. This also links to empowering parents where possible to purchase additional options from personal budget 11 What information should schools be required to provide to parents on SEN? - 10 - Comments: It is vital that information clarifies what schools can offer including physical resources, how children are supported, possible named contact for SEN child e.g. SENCo. This is in addition to the school’s policy and practice on SEN, progress of pupils with SEN from the beginning of one key stage to another; the attainment gap between SEN pupils and their non SEN counterparts; Ofsted judgments on the quality of provision for SEN; provision for extended services for all pupils including childcare; training and specialisms of staff. This would be further explored in our Pathfinder proposals (detailed in the accompanying letter) particularly around multi agency working. The Council would welcome a discussion with the DFE on school information and policy content. 12 What do you think an optional personal budget for families should cover? Our consultation confirms that personal budgets would ideally include suggestions/examples as to what a personal budget could be used for: social care support/health services/education at home/equipment/adaptations/therapy services. We are interested in exploring whether parents will be able to pool personal budgets. If parents decide that they do not want a personal budget then re-assurance should be given that service/support will still be delivered. We consider that personal budgets should not include school placement costs. Some parents will not want this so there would need to be mechanisms to ‘hold’ budgets for parents. Cornwall has a good model through its Short Break Service. 13 In what ways do you think the option of a personal budget for services identified in the proposed ‘Education, Health and Care Plan' will support parents to get a package of support for their child that meets their needs? - 11 - Comments: A personal budget would support parents in being able to select their own personnel to work with their child, we consider it helpful to ensure that parents could work together and pool resources to provide specialist support and activity. Personal budgets enable parents to be more in control of support packages for their children which can be tailored to meet specific need. Some parents expressed concern that personal budgets require a level of capacity that not all families have and should be supported by disabled social work and early support services 14 Do you feel that the statutory guidance on inclusion and school choice, Inclusive Schooling, allows appropriately for parental preferences for either a mainstream or special school? Yes X No Not Sure Comments: The Inclusive schooling document is not widely known about amongst parents and more information about the specialist facilities available in a mainstream school and a special school would be welcome. A requirement for information to parents on inclusion, along with a role for parent partnership services to review and comment on information available would support the effective use of information to guide school choice. Consideration should also be given to increase the opportunity for dual placements. Given the geography of Cornwall, transport issues can make a choice unviable. There is a related issue in that some parents have raised concerns about the quality of 19+ provisions. - 12 - 15 How can we improve information about school choice for parents of children with a statement of SEN, or new ‘Education, Health and Care Plan'? Comments: It would be helpful if options and choices could be discussed at an early stage, planning well in advance with parents on school places. There needs to be more detailed information about transport and escort services. The schools needs to provide parents with more information about a child’s proposed school day 16 Should mediation always be attempted before parents register an appeal to the First-tier Tribunal (SEN and Disability)? X Yes No Not Sure Comments: Parents felt that information about mediation should be more widely available as most issues were felt to emanate from poor communication. Parents felt that mediation would cut the cost of resolving issues at tribunals but ultimately a tribunal may still be needed to arbitrate. In all we found strong evidence to support a move to less adversarial systems 17a) Do you like the idea of mediation across education, health and social care? x Yes No Not Sure 17 b) How might it work best? - 13 - Comments: Joint up working between education, health and social care is a great idea – however this needs to be workable – some kind of joint working arena and shared knowledge – particularly when it impacts on behaviour and wellbeing in school. Smoother systems to share best strategies and practice – particularly with Mental Health issues. - 14 - Chapter 3: Learning and Achieving 18 How can we ensure that the expertise of special schools, and mainstream schools with excellent SEN practice, is harnessed and spread through Teaching Schools partnerships? Comments: As part of our proposal relating to the development of a cluster model (see covering letter) we are intending to focus on improving outcomes for children and young people with SEN. We consider that schools working as part of a cluster will be well placed to utilise and further develop expertise. In a practical way schools working together to identify and share local practice will have impact not least of which will be around increased efficiencies linked to economies of scale. Such developments linked to exploring and developing ways of working with central LA SEN services holds considerable potential in our view. This would be further explored in our Pathfinder proposals (detailed in the accompanying letter) 19 How can we ensure that we improve SEN expertise, build capacity and share knowledge between independent specialist colleges, special schools and colleges? Comments: We consider that capacity can be built by renewing focus and attention on what exactly is required in teaching and learning terms to enable/support a learner to achieve. In this way time and energy is directed on practical and deliverable interventions which can be closely monitored and evaluated to secure necessary improvements. We are keen to explore this focus further and fully acknowledge that each school/setting and related professionals hold a very considerable skills base. - 15 - 20 How can we continue to build capacity and SEN specialist skills at each tier of school management? Comments: We consider that all staff will contribute to the significant skills set available to support children and young people. Considerable investment has been made in the SENCo qualification and we continue to support this model. We are keen to continue to raise with all staff (groups and individuals) evidences which confirm and can be further developed to support learning. We are exploring how Advanced Skills Teachers are able to utilise their acknowledged skills and apply them across curricular areas. We see all teachers and staff sharing a common responsibility to find and apply solutions to improve outcomes. A central information resource with examples of inspirational teachers, expert services and world class practice is helpful to parents and professionals to share such information and knowledge. By having expert guidance on tap to schools as identified within the best practice exemplified by the TaMHS (Targeted Mental Health in Schools) Pathfinder. Where a mental health specialist was available for advice to schools the number of referrals to CaMHS dropped and school based staff felt more empowered to support children There should be a framework for publishing the skills levels of staff in schools on a range of SEN issues (e.g. behaviour, autism, specific learning difficulties etc) These should be tiered in terms of depth of qualifications and experience. Each LA area should have the responsibility of monitoring this and promoting skills exchange among schools. 21 What is the best way to identify and develop the potential of teachers and staff to best support disabled children or children with a wide range of SEN? - 16 - Comments: We consider that sharing information as well as examples of what works continues to be a helpful and useful approach. The cluster model we are keen to develop would provide a useful reference point for staff and help not only to find solutions to increase learning opportunities as well as enable professional discussion to moderate judgements and share good/successful practices as required. We anticipate that parents may also find it helpful to learn about and see how support and teaching interventions work across an area rather than a single school. We intend to focus on how learning can be improved and to share with parents the range and specific teaching interventions on offer/available and being applied. By having a clear idea as to what progress looks like for a learner we can mutually explore and build to secure success. 22 What is the potential impact of replacing School Action and School Action Plus and their equivalents in the early years with a single category of SEN in early years settings and schools? Comments: We prefer to move towards an approach which does not label a child or young person but rather understand and then apply teacher focused interventions to secure a narrowing of any progress/attainment gaps. 23 How could changing the school and early years setting-based category of SEN embed a different approach to identifying SEN and addressing children's needs? - 17 - Comments: We prefer to move towards an approach (including early years) which does not label a child or young person but rather understand and then apply teacher focused interventions to secure a narrowing of any progress/attainment gaps. 24 How helpful is the current category of Behavioural, Emotional and Social Development (BESD) in identifying the underlying needs of children with emotional and social difficulties? Very helpful Helpful Not at all helpful Not sure X Not very helpful Comments: We prefer to move towards an approach (including behavioural, emotional and social development issues) which does not label a child or young person but rather understand and then apply teacher focused interventions to secure a narrowing of any progress/attainment gaps at one and the same time as improving social, emotional and attendance related issues. 25 Is the BESD label overused in terms of describing behaviour problems rather than leading to an assessment of underlying difficulties? - 18 - X Yes No Not Sure Comments: Yes 26 How could we best ensure that the expertise of special schools in providing behaviour support is harnessed and shared? Comments: Special Schools provide vital and essential specialist capacity. Harnessing and sharing such expertise would be further explored in our Pathfinder proposals (detailed in the accompanying letter). 27 What are the barriers to special schools and special academies entering the market for alternative provision? - 19 - We welcome such developments and are actively working to build our newly proposed Special SEBD School to include alternative provision arrangements. We consider it vital that such provision is developed and accountable under school governance. We acknowledge that the funding system is not open ended and that while alternative provision is part of the dedicated schools grant, funding for it is by agreement of the Schools Forum. New commissioning arrangements would need to be developed to support special schools and academies entering the market to provide such provision. Local authorities could be encouraged or required to commission alternative provision services through special schools or academies in their LA area and a requirement placed on Schools Forums to consider proposals 28 What are the ways in which special academies can work in partnership with other mainstream and special schools and academies, and other services, in order to improve the quality of provision for pupils with SEN and disabilities? Comments: They could build local capacity, moderate it and support the commissioning of services. They would also be a contributory part in a cluster model of services This would be further explored in our Pathfinder proposals (detailed in the accompanying letter) 29 What are the barriers to special academies becoming centres of excellence - 20 - and specialist expertise that serve a wider, regional community and how can these be overcome? Comments: See above 30 What might the impact be of opening up the system to provide places for nonstatemented children with SEN in special free schools? Comments: The risk assessment would need to examine the benefits to the child. 31 Do you agree with our proposed approach for demonstrating the progress of low attaining pupils in performance tables? - 21 - X Yes No Not Sure Comments: We consider that outcomes for all children and young people should be focus of open and transparent dialogue and discussion. The progress and outcomes for children with SEN remains central to our proposed developments (see covering letter). 32 What information would help parents, governors and others, including Ofsted, assess how effectively schools support disabled children and children with SEN? Comments: Governors could be given ‘prompts’ which would enable them to ask the right questions. There should be greater clarity on the expectation of progress for SEN children. Information needed includes: Progress of SEN and non SEN counterparts Training and development of staff in specific SEN issues e.g. dyslexia, autism Quality of teaching and learning for pupils in danger of underachieving SEND responsibilities of staff in the school Extended schools provision including childcare Schools use and access to local support services Parental understanding and use of the published local offer - 22 - Chapter 4: Preparing for Adulthood 33 What more can education and training providers do to ensure that disabled young people and young people with SEN are able to participate in education or training post-16? We feel that it is essential to provide a coherent programme of funding which genuinely follows the learner rather than the qualification or programme. Educators and training providers must link with employers and organisations to identify what preparation is necessary to provide SEN young people with a structure sequence to give them the best chance of success in their future chosen workplace or career. 34 When disabled young people and young people with SEN choose to move directly from school or college into the world of work, how can we make sure this is well planned and who is best placed to support them? Comments It is essential that in such circumstances where young people with SEN choose to move directly from school or college into the world of work that this should be developed from and through transition reviews in Y9. Connexions and Adult Social Care need to be involved from early on. More supported work opportunities need to be provided with a phased placement into work to build up skills and experience. : - 23 - 35a) Do you agree that supported internships would provide young people for whom an apprenticeship may not be a realistic aim with meaningful work opportunities? Yes No X Not Sure 35b) How might they work best? We would like to see the encouragement of visits and short, positive “tasters” of a variety of workplaces as this would help individuals to identify what they might like to do in the future. Supported and managed voluntary work could also provide opportunities. Supported internships need to be on a longer term basis to enable young people to have a greater chance of success 36 How can employers be encouraged to offer constructive work experience and job opportunities to disabled young people and young people with SEN? Financial incentives would be helpful as many of these young people can become hardworking employees with the right preparation and training. A proportion of these young people may be quite happy to do tasks which other employees may find boring or insignificant. - 24 - 37 How do you think joint working across children's and adult health services for young people aged 16 to 25 could be improved? It should stem from the year 9 transition reviews with ALL agencies attending and working towards the learner's journey. In a more holistic way. The attendance of all agencies needs to be statutory so that they have to attend and take an active role. There needs to be a central co-coordinator in each local authority that draws the whole transition /multi agency working together, with the appropriate legislation in place Each LA and NHS area should have a delivery plan for transition of every young person with complex needs to include care, health, education, housing and employment. The statutory arrangements including requirements to resource this need to be developed 38 As the family doctor, how could the GP play a greater role in managing a smooth transition for a disabled young person from children's to adult health services? The GP is a crucial cog in the transition wheel but it is not suggested that a GP is the right person to manage a smooth transition from children's services to health. The GP could play an important role through provision of statutory advice to support the transition plan above 39a) Do you agree that our work supporting disabled young people and young people with SEN to prepare for adulthood should focus on the following areas: (please tick those with which you agree) - 25 - ensuring a broad range of learning opportunities transition to adult health X services X X moving into employment none Comments: 39b) What else should we consider? Comments: Smarter commissioning (link to Q. 34) - 26 - X independent living not sure Chapter 5: Services Working Together for Families 40a) Do you agree with the following three core features of the role of local authorities in supporting children and young people with SEN or who are disabled and their families? (please tick those with which you agree) strategic X planning for services none securing a X range of high quality provision enabling families to make X informed choices and exercise greater control over services not sure Comments: 40b) Are there others? If so, please specify. X Yes No Not Sure Comments: Coordinating the health, care, education, housing and transport arrangements for disabled children and young people (supported by legislative, financial and inspection arrangements within the NHS and for LAs to ensure that this happens) - 27 - 41 How can central government enable and support local authorities to carry out their role effectively? Comments: By agreeing a joint strategic direction, decisions about funding should become clearer to all. (NHS consultation) Freeing up local authorities by making statutory arrangements congruent 42 What would be the best way to provide advice to GP consortia to support their commissioning of services for children and young people with SEN or who are disabled and their families? Comments: By information sharing at a strategic level to enable more astute decisions to be made and strengthening the arrangements for the joint strategic needs analysis produce through the Director of Public Health and ensuring that it is specific to the areas covered by the GP consortia. - 28 - 43 What would be the most appropriate indicators to include in the NHS and public health outcomes frameworks in the future to allow us to measure outcomes for children and young people with SEN or who are disabled? Comments: Use Goal Attainment Scores (such as in paediatric therapies) – agree what you are trying to achieve with the families and young people and keep it to half a dozen goals, qualitative and quantitative, and measure whether this has been achieved at the end of the intervention (NHS consultation). 44 What are the ways in which the bureaucratic burdens on frontline professionals, schools and services can be reduced? Comments: 45 In addition to community nursing, what are the other areas where greater collaboration between frontline professionals could have the greatest positive impact on children and young people with SEN or who are disabled and their families? - 29 - Comments: Key collaborators include: Health Visiting School Nursing Family Nurse Partnership Child & Adolescent Mental Health Services Learning Disability Speech & Language Therapy Paediatric Community Services Primary Mental Health Through the use of shared language on outcomes and having a clear shared direction for service development with schools and with LA services and being able to share this clearly with parents through Parent Partnership and other front line services. 46 What more do you think could be done to encourage and facilitate local services working together to improve support for children with SEN or who are disabled? - 30 - Comments: Joint commissioning of Health and Local Authority services would enable them to share priorities and develop pathways of support. This would be further explored in our Pathfinder proposals (detailed in the accompanying letter) 47 How do you think SEN support services might be funded so that schools, academies, free schools and other education providers have access to high quality SEN support services? Comments: SEN support services will need to demonstrate impact/outcomes which represent good value for money, and effective intervention, against national comparative rates. Monitoring of quality against national standards should be carried under the leadership of Schools Forum SEN support services should be outside the LACSEG for academies and free schools but should be allocated on the basis of school clusters agreed by Schools Forum. The services could be funded as a specific grant as part of the Dedicated Schools Grant 48 What are the innovative ways in which new models of employee-led - 31 - organisations, such as mutuals and cooperatives, could improve services for children and young people with SEN and their families? : Services would be able to provide services to families as well as schools, would be able to develop new organisational delivery models that could increase direct contact with schools and young people; could operate across traditional boundaries of health, care and education develop new provision to address gaps in the market and provide competition for others in terms of cost and value for money operate across public sector boundary areas to lever up standards and secure increased value for money draw in investment for the private sector to develop new provision - 32 - 49 In addition to their role in the assessment process, what are the innovative ways in which educational psychologists are deployed locally to support children and young people with SEN or who are disabled and their families? Comments: Below are examples of some of the innovative ways in which EPs are currently, or have recently been, deployed in Cornwall: Contributing to strategic developments within the LA e.g. leading on the changes to Child Development Centres and the restructuring of services to support children with Autistic Spectrum Conditions Line management of other professionals – vital role in the performance management of a number of different professionals, which in turn impacts on service delivery and ultimately the delivery of improved local services which focus and meet the needs of children and young people with SEN or who are disabled and their families (currently this includes EP line management of Early Years Inclusion Service, Services for children with ASD and the Scallywags Service for young children presenting behavioural difficulties at home and at school) Providers of professional support and supervision to colleagues (e.g. advisors, specialist speech and language therapists,) plus recent research into providing solution focused supervision to youth workers and police youth liaison staff. Project management / clinical leads e.g. Targeted Mental Health in Schools (TaMHS), Scallywags Partnership working with colleagues from Child, Adolescent, Mental Health colleagues, Clinical Psychologists working with children and Children in Care Education Team Drop in surgeries professionals Multi-agency teams secondment to locality based teams to support whole school systems work. Psychological input and advice to teams made up of other professionals. Training for other professionals - within Children Schools and Families Services and to colleagues in health and social care Training for Schools/Settings – via direct delivery or via online INSET for school staff on a wide range of educational issues including child development, curriculum development and special educational needs. for parents, young people, school staff, other - 33 - Training/Support for parents – e.g. Early Bird, Early Bird Plus, Scallywags parent groups Running/facilitating local SENCo cluster groups – of particular importance if central funding and LA monitoring become increasingly fragmented Coordination and provision of Bereavement and Critical Incident Support Therapeutic evidence based Interventions – formulation, direct delivery or coordination of individual and group therapeutic interventions, evaluating impact. o Video Interactive Guidance (VIG) o Cognitive Behavioural Therapy based interventions e.g. FRIENDS o Draw and Talk o Support groups for children/parents with a specific condition e.g. ADHD Project Work with schools – e.g. systemic soft systems work, teacher coaching, developing solution focused practice within schools Behaviour for Learning Partnerships Providing psychological advice to the Community and Hospital Education Service Offering a solution focused consultation based service delivery Research projects Championing the voice of vulnerable young people Raising standards of achievement and supporting Government policies on inclusion and social inclusion Academic progress - Pivotal role in understanding how children and young people learn and in supporting all school staff and parents in all settings on how and why young people make progress NB: Many Educational Psychology Services already offer many of the above but it is vital that future deployment of Educational Psychologists adequately takes into account the vast range and different levels across which we are able to apply psychology; that our specialist knowledge and expertise, which spans the whole spectrum of SEND is recognised and that future staffing - 34 - levels/funding enable this to continue. : 50 How do you envisage the role and service structures of educational psychologists evolving to meet local demands? Comments: The role of an Educational Psychologist is to apply psychology to promote the attainment and healthy emotional development of all children and young people from 0-19 years. As Educational Psychologists’ our role requires in depth knowledge of the whole spectrum of special educational needs and disabilities and of school organisations and systems. We are therefore uniquely placed to work with children with SEND and in supporting schools in their work with these children. How the role and service structures of Educational Psychologists evolve is highly dependant on how they will be funded in the future. Cornwall Educational Psychology Service are of the view that Educational Psychologists’ work on statutory assessments (or the proposed replacement) is a necessary and key function, however, we also believe that we, as psychologists, have a crucial role in improving provision for children, improving outcomes for children and in supporting the Government’s education agenda. We believe that Educational Psychologists can make a more effective contribution to improving the wellbeing and achievement of children and young people with special educational needs and disabilities, if we continue to work within the LA structure and remain largely as a centrally funded service, with a complementary traded component. Service structures will be robust enough to continue to provide a high quality core service to all schools/educational settings within the locality. A core service which includes early intervention/prevention work as well as statutory work. Potential negative impact of the changes proposed and implied within the SEN Green Paper: Service structures become increasingly fragmented, leading to inequality in access to EP services across the county, especially for more rural areas, which may not so easily fit within the proposed/implied changes - 35 - Role reduced just to statutory duties – EP Services become reactive rather than proactive (all early intervention and prevention work lost) Decline in effectiveness of Common Assessment Framework – EP attendance reduced if schools have to pay via traded services for EP involvement in multi agency work We envisage conflicts between radical new models e.g. social enterprise models and meeting the needs of the most vulnerable pupils Current and on going uncertainty could potentially affect the calibre of candidates who choose to pursue EP career Potential new developments / expansion of EP services if there is an increase in commissioned work: The following is again highly dependant on who would commission this work: Service structures develop to facilitate partnership working with colleagues in Social Care and Health to carry out joint assessments, planning, provision and training Telephone helpline for parents and other professionals created EP services would evolve to deliver services within the community and work directly with parents and children - access via community bases e.g. one stop shop, library, children’s centres, surgeries etc. Changes in EPs working hours and conditions to enable them to offer an ‘out of school hours’ service Individual Educational Psychologists should develop particular specialisms to support schools, parents, early years providers and LA officers in specific multi-agency initiatives and casework Have a business manager element within team to develop and promote the traded arm of the EP Service 51 What are the implications of changes to the role and deployment of educational psychologists for how their training is designed and managed? - 36 - Comments: Cornwall Educational Psychology Service shares the concerns raised by the House of Commons Education Select Committee in their Behaviour and Discipline in Schools Report about the future availability, training and management of Educational Psychologists. We do not believe that the current system for funding Educational Psychologists (whereby local authorities are allocated non-ring-fenced funding for Educational Psychology training which they voluntarily contribute to a central budget each year) is sustainable as these voluntary contributions have been decreasing over several years. The Select Committee concluded that Educational Psychologists provide critical support and training to school staff on a wide range of educational issues, including child development, curriculum development and special educational needs and that any diminution of their ability to help schools to maintain and improve standards of behaviour could have far-reaching consequences. We therefore propose that Central Government top slice centrally and/or ring fence funding that is currently delegated to LAs Changes to services structures which reduce the size of EP services will adversely affect the capacity of services to take trainees on placement and provide them with high quality support and supervision If trainee placements were commissioned outside of Local Authorities, who would: o Provide the required level of clinical support and supervision? o Ensure that trainees are exposed to a range of appropriate learning opportunities? o Ensure that their practice is firmly grounded in psychological theory? o Ensure that their interventions were evidence based? o Evaluate the impact of their work and identify future improvements? - 37 - 52 What do you think can be done to facilitate and encourage greater collaboration between local authorities? Comments: Joint strategic planning and commissioning of provision for low incidence high cost needs 53 What do you think are the areas where collaboration could have the greatest positive impact on services for children, young people and families? Comments: Joint collaboration between NHS and LA care and education on securing Parent Partnership service. The impact would be that no child would be ‘let down’ by the services. It would ‘raise the game’ of the services by the very act of working collaboratively and having to articulate what was meant by having good aspirations for children and young people. Most importantly, parents can tell us what they think and we can act on this. The SEN Hubs were an excellent model for supporting Local Authorities to work together and to share good practice. Collaboration of the joint education, health and care plans targeted towards the right children and young people with the arrangements being piloted in local areas and tested against delivery by parents Collaboration between Ofsted, schools, parents and SEN support services to develop the framework for inspection of SEN and progress of children - 38 - 54 How do you think that more effective pooling and alignment of funding for health, social care and education services can be encouraged? Comments: This could be achieved by aligning the statutory responsibilities of the 3 services leading to innovation, cost effectiveness requiring a pooled budget for health, care and education targeted at specific groups of children and young people loosening the requirements on health care and education in terms of what the specific resources might be spent on and allowing for a movement towards direct payments and individual budgets across the public sector 55 What are the ways in which a Community Budget approach might help to improve the ways in which services for children and young people with SEN or who are disabled and their families are delivered? Comments: Please see the Pathfinder proposal detailed within the accompanying letter for a locality pilot based on a clusters of schools acting together to provide services for their area - 39 - 56 What are the ways in which we could introduce greater local freedom and flexibility into the ways in which funding for services for children and young people with SEN or who are disabled is used? Comments: Earmarked resources for SEN support services based upon clusters of schools to enable them to develop and be responsible for support services for children and to be accountable to the LA and Schools Forum for effective VfM in terms of progress of children in education, care and health outcomes they have agreed 57 What are the areas where the voluntary and community sector could have the greatest positive impact on services for children and young people with SEN or who are disabled and their families, and what are the ways we can facilitate this? Comments: As previously identified, their role could be in advocacy for parents, at fulfilling services commissioned by the local authority and in working in partnership such as Cornwall’s proposal with Barnardo’s for a SEBD School - 40 - 58 How do you think a national banded funding framework for children and young people with SEN or who are disabled could improve the transparency of funding decisions to parents while continuing to allow for local flexibility? Comments: A national banding framework would achieve ‘portability’ of SEN from one area to another. It would require careful definitions of children’s need and a system of moderation not only within a LA area but across areas. The banding should be in terms of guidance only for the level of additional resource but should not specify what the input actually should be. There should be flexibility in terms of what the resource is spent on. There must also be a clear set of outcomes that should be achieved and how this is monitored 59 How can the different funding arrangements for specialist provision for young people pre-16 and post-16 be aligned more effectively to provide a more consistent approach to support for children and young people with SEN or who are disabled from birth to 25? Comments: By the use of smarter commissioning for FE placements, HE placements and employment training opportunities with a strategic role here for the local Authority. The post 16 arrangements for SEN should match the arrangements for statutory school age SEN - 41 - 60 Please use this space for any other comments you would like to make Comments: We would like to draw your attention to our accompanying letter where we identify how we would like to work more closely with the DfE to make the SEN Green Paper a reality. 61 Please let us have your views on responding to this consultation (e.g. the number and type of questions, was it easy to find, understand, complete etc.) Comments: - 42 - Thank you for taking the time to let us have your views. We do not intend to acknowledge individual responses unless you place an 'X' in the box below. Please acknowledge this reply X Here at the Department for Education we carry out our research on many different topics and consultations. As your views are valuable to us, would it be alright if we were to contact you again from time to time either for research or to send through consultation documents? X Yes No All DfE public consultations are required to conform to the following criteria within the Government Code of Practice on Consultation: Criterion 1: Formal consultation should take place at a stage when there is scope to influence the policy outcome. Criterion 2: Consultations should normally last for at least 12 weeks with consideration given to longer timescales where feasible and sensible. Criterion 3: Consultation documents should be clear about the consultation process, what is being proposed, the scope to influence and the expected costs and benefits of the proposals. Criterion 4: Consultation exercises should be designed to be accessible to, and clearly targeted at, those people the exercise is intended to reach. Criterion 5: Keeping the burden of consultation to a minimum is essential if consultations are to be effective and if consultees’ buy-in to the process is to be obtained. Criterion 6: Consultation responses should be analysed carefully and clear feedback should be provided to participants following the consultation. Criterion 7: Officials running consultations should seek guidance in how to run an effective consultation exercise and share what they have learned from the experience. - 43 - If you have any comments on how DfE consultations are conducted, please contact Donna Harrison, DfE Consultation Co-ordinator, tel: 01928 738212 / email: donna.harrison@education.gsi.gov.uk Thank you for taking time to respond to this consultation. Completed questionnaires and other responses should be sent to the address shown below by 30 June 2011 Send by email to send.greenpaper@education.gsi.gov.uk or by post to: Consultation Unit, Department for Education, Area 1C, Castle View House, East Lane, Runcorn WA7 2GJ. - 44 -