The 39 Steps: SNJ’s guidance to help you respond to the White Paper SEND Consultation

By Matt Keer and Tania Tirraoro

Contents

Watch our SEND Legal webinar recording

The SEND proposals in the Schools White Paper aim make the most sweeping changes to the English special educational needs and disability (SEND) system in over 30 years.

Maybe you like it. Maybe you don’t. Maybe you think it’s the clearest, most coherent piece of public sector reform seen for years, but it just needs a tweak here and there to perfect it. Maybe you think it’s hellspawn designed by psychopaths, drafted by sociopaths and handled by maniacs, and it should be nuked from orbit. The choice is yours.

Any which way, the government wants to hear what you have to say about its policy paper. Its legally required consultation period, which will run until 18^th May. Or possibly longer, as the consultation process itself is now subject to a legal challenge.

We’ve participated in many of these consultations over the years, so here are some top tips on how to pack the most punch with your consultation response.

But before you decide to dive in, we have much more explanatory content to come, plus a legal roundtable we are currently organising, and hopefully, a webinar. So you may want to bookmark this post and wait until you’ve read those posts (we’re volunteers so it’s not possible to make it all happen at once—but you have time)

Is it worth the bother?

The first question to ask yourself is this: Is it actually worth responding at all?

SNJ will definitely be responding. Plenty of other people will be responding, and we’d recommend that if you have enough time and headspace, you should respond too.

But it’s worth asking yourself whether it’s worth the effort. It’ll take plenty of effort and energy to respond properly, and everyone’s energy is in short supply after the torture by leaks we’ve all been through.

This isn’t a job to subcontract out completely to artificial intelligence – although it’s worth considering those tools to ask yourself questions, and it’s worth using them to polish up your language if you’re concerned about that. If you do, ensure you read it through so it actually says what you believe.

No one would blame you if you decide this is one consultation too many. Look at the work people poured into the SEND ‘national conversation,’ and think about the return that everyone seems to have got from that effort.

Will it make a difference?

It’s rare that substantive changes to policy proposals emerge from a consultation process. It happens sometimes – often enough to make it worth the effort – but it’s hard to avoid wondering whether you’re just yelling into the void.

Another important thing to bear in mind: the Department for Education (DfE) will itself be using AI tools to help it analyse the consultation responses. This is what it says about how it’ll use AI:

“The purpose of using AI is to identify themes, trends, and insights more efficiently and accurately, ensuring that all feedback is considered in a structured and transparent way. AI will not make decisions; it will support our analysis process, which will be reviewed and validated by our team to maintain fairness and integrity.”

The DfE hasn’t explained in any detail whose responses it’ll apply AI to. But it’s fairly safe to assume that they won’t be running responses through AI from stakeholders they genuinely value and enjoy meeting over a latte and Belgian biscuits.

But faced with potentially many tens of thousands of responses from parent carers, there’s a very real chance that no human being at DfE will directly read your individual consultation response. That’s not to say it’ll have no impact – but it’s more likely that it’ll be fed into a thematic response tool or a sentiment analysis app, and the slop that gets farmed from that will be read instead.

Do I need to answer every question?

If you do decide to submit a response, then the next thing to think about is this: Do I need to respond to every single question?

Your mileage may vary here, but we’d recommend depth over breadth. There are 39 formal consultation questions – at least, for now – and there’s absolutely no need to respond to all of them if you can’t think of anything to say.

There’s a whole load of questions where I’ve got absolutely nothing worthwhile to add – I’m planning to just leave those questions unanswered, and spend more time on ones where I’ve got more to say.

So, what should I write?

We’re not in the business of telling you what positions you should be taking; they’re after everyone’s opinions, freely expressed—your opinions may well not be the same as ours. But here are a few organisational pointers for formulating what you want to say.

Spend more time thinking than writing: Look at the question, go back to the consultation document, read what they’re proposing, and then step away from the screen.
- How would this proposal affect my child, or children like mine?
- What would help the proposal work?
- What real-life things would get in the way?
- Does the proposal need more time, money, or goodwill to work, and
- why don’t those things exist already?

Once you’ve thought a bit, with luck, your response will start to flow.

Important Note:

The DfE hasn’t included any specific questions on the legal changes it has proposed. We suggest weaving into the questions you choose to answer:

Why your child’s existing EHCP rights must not be removed
How these existing rights have helped support your child
What would happen if they lost them?
What would happen if the SEND Tribunal could not direct the LA to place your child in the most appropriate setting for them in Section I of the EHCP.

My time is limited, and I find it hard to get things down on paper!

That’s perfectly understandable. Here are a couple of tips:

If you think best when you’re writing, do it that way, in draft notes. Then step back or put it aside for a day or so. When you look at it again, you can tweak if/where you need to.
Alternatively, if you prefer to speak your mind, dictate your thoughts into a notes app or document, or record your thoughts, and use a free app to transcribe into text so you can then edit.

Things to bear in mind

Assume no real-life experience from the policy design people: the distance between a minister’s desk, a policy workshop, a stakeholder webinar and gritty, real-life SEND experience is huge. Some system leaders involved in this process have children with SEND of their own, but not many.
Ministers have been out and about in the last few months, visiting schools and talking to people – but often (very often), civil servants will go to huge lengths to ensure that the high-priced help only meet people who won’t rock the boat. Have they done that this time? You be the judge.
Policy people can all can listen to – and sometimes, even use – phrases like “bespoke improvement synergies” without giggling uncontrollably. So when thinking about what to write, assume that you’re explaining to people who have seen a lot of text-heavy slideshow presentations, who have only talked to a carefully-curated range of ‘safe’ people, and who spend their working lives in meetings. Assume that they have sent plenty of unpleasant emails at 4.59pm on a Friday, but have never received any.
Assume that the people who might read your submission do care, if only in the abstract.
Assume that they know SEND jargon.
But also assume that they know the cube root of sod-all about how SEND really works at ground level.
Don’t assume they are aware of, or care about, their ignorance of point 6. They don’t know what they don’t know, but they think that they do know.

So when you write, think about the things that someone high up in a Whitehall meeting room, high on their own supply, won’t know (though think they do) but desperately need to know. Write about the things that could go right that they haven’t thought about – and write about the things that could go wrong that they haven’t thought about—those unintended consequences.

How do I make my contribution stand out?

Write as distinctively as you can

For parents, the challenge here will be to make your contribution stand out. Unlike, let’s say, the Local Government Association, there’s every chance that your contribution will be fed into an AI-powered juicer. This is what happened with the Education Committee’s SEND inquiry, where lots of written evidence submissions from individual families were pushed through Microsoft Copilot and partially-digested slop came out the other end.

The DfE will probably produce a “thematic analysis” of responses from parent carers for their policy leads, probably with some quotes from individual contributors that sum up views particularly well.

You will have much more chance of getting your contribution seen and quoted by a real-life meatsack if your answer to each question is short, precise, and quotable. That doesn’t mean responses that aren’t like that have no value – but it’s more likely that they’ll stay in the juicer and the liquid essence from your response will make its way into DfE’s thinking.

You might think that this sort of approach to consuming consultation responses would be potentially discriminatory. I know I do: it favours the articulate, and it favours people who write for a living. Some day, I suspect there’ll be a challenge to it – but you can’t count on that.

Don’t send in identical responses through different people

This is an approach sometimes used by pressure groups when responding to consultations, and it never ends well. It’s very, very easy for software to detect when groups of people do this – and if you are detected, the chances are high that your responses will simply (and rightly) be binned.

Take care when using personally identifiable information about other people in your responses

You’ll need to give your name, and they’ll ask you whether you’re replying as an individual or an organisation, and they’ll ask you what sort of individual you are (eg student, parent carer, governor). You can mark your responses up as confidential.

So you don’t have to give a lot away about yourself. But policy consultations can sometimes be squeamish about handling responses that include a lot of personally identifying data about other people. So if you give real-life examples, think about anonymising what you say about others, or about linking those other people to named schools or LAs.

What NOT to do for maximum impact

The DfE is not going to do anything with the data you submit other than use it to consider their SEND reforms.

❌ They’re not going to take any action about your individual cases.
❌ They’re not going to read your submission, note the gory details in horror, and send it to (an imaginary) team of crack investigators who will take action.
❌ There’s no value to naming and shaming in this consultation, or about providing hugely in-depth and identifying detail about your own kids or the people who are supposed to support them. It’ll simply make it marginally more likely that your response will have less influence.

Not your last chance

Finally: this consultation won’t be the last word. Once all this is over – probably at some point in the summer – the DfE will publish an evaluation of the responses it’s received to the consultation, and what – if anything – it plans to do differently. After that – and assuming no other legal interruption – the process will begin of turning the White Paper into some sort of draft legislation. There will probably be yet more consultations on individual aspects of future policy.

So if you want to get involved in this consultation but have simply run out of spoons, don’t worry – there will still be other opportunities to get involved. We’ll let you know as and when those opportunities turn up!

Matt Keer

Join us on BlueSky

SNJ WhatsApp Channel

Using an AI Chatbot to help to answer the consultation —some tips. By Tania Tirraoro

Parents are busy people. Many are overwhelmed. Some are autistic, or have ADHD, or other learning difficulties themselves. The thought of answering yet another consultation (official or otherwise) is making lots of you feel like you’re under a cosh. The thought of your child losing hard-fought-for provision is shattering. But still, you want to respond because you have a lot to say-and lots of people are furious; rightly so.

Remember— you do not have to answer all of these questions or even accept the premise the government is putting forward. Additionally, the consultation does not include questions about the current law or the SEND Tribunal or the Ombudsman’s effectiveness and remit— you may want to include this in your response under accountability sections

Matt mentioned using AI and that it’s not only the government that can use large language model (LLM) artificial intelligence (AI)… It’s perfectly valid to use an AI chatbot, such as ChatGPT, Claude, Gemini, Co-Pilot etc, to help you formulate your thoughts if that would help. But to add to Matt’s points, there are some more caveats…

AI can distort or hallucinate, and if you’re not careful, it will bring in information from other sources that may not reflect what you want to say, or in the way you want to say it. AI is a tool, it shouldn’t be thinking for you.

A handy assistant

AI can come in handy if you paste your rough text or transcription into your chosen chatbot app. You don’t need to pay to use these chatbots, but free options have a daily limit so use it well. This is fine anyway if you want to do it bit by bit, thoughtfully. I wouldn’t recommend just pasting the questions in and saying “tell me what to say”—you might as well not bother, as they’re not *your* thoughts.

Clear Prompting is essential

To avoid ‘garbage in-garbage out’ (GIGO), clear prompting is vital. As many of you are not well-versed in this area, I’ve created an example prompt. You will see it’s thought through everything needed.

You could also paste specific links you would like it to reference, such as the Government’s main consultation page (linked below in the resource section), or even something from SNJ or another source that you particularly agree with. That’s up to you.

Here is a basic example AI prompt to use if you have written your thoughts down in a stream of consciousness (yes, we all do sometimes!) or if you’ve pasted the questions into a word doc and have bashed out some unformatted thoughts. You can edit this prompt as you prefer, or use it to get the gist for your own prompt:

“I am responding to the UK Government’s current White Paper SEND consultation and will paste my draft thoughts (or a transcription of them) in one block of text. I will also paste the consultation questions [or, I will paste the questions and my answers to be tidied up, however you’ve done it]

“Please do the following:

Match my content to the correct consultation question.
- Reorder my text where necessary so each section sits under the appropriate question.
Edit only for clarity, spelling, punctuation and grammar.
- Do not change my tone.
- Do not change my meaning.
- Do not add new arguments or outside information.
- Do not strengthen, soften or reinterpret my views.
- Keep this entirely in my voice.
Ensure there is a response under every consultation question. [If that’s what you want]
- If I have not provided enough material for a question, clearly mark that section as “Content needed” (or similar).
- For any missing or very thin answers, provide three short bullet points to help prompt my thinking.
- Only in those prompt bullets may you draw on other information and the official consultation documents.
- Do not insert those ideas into my drafted answers — keep them clearly separate as prompts.
Present the output in a clean format that I can copy and paste directly into an online form with one answer box per question.

“Do not summarise my views. Do not rewrite in a different style. Do not introduce new evidence unless it is clearly separated as a thinking prompt where my answer is incomplete.”

Here are the consultation questions: [paste in from the doc below—if appropriate to you],

Here is my text: [paste in your rough draft—as appropriate to you]

Place your answer in a downloadable word document for me to edit offline [or your chosen format, if that’s what you want]

Some other ways to get your thoughts out using AI as a tool

You can also use it to help you formulate your thoughts logically, by typing in everything you think, examples from your own story (tell AI to anonymise for you).
You can tell it to ask you questions related to the consultation, or to SEND issues, that you answer. Then at the end, tell it to format everything you’ve written or dictated in a way you can use to answer the consultation in a logical way. It’s VITAL to read it all though to make sure your thoughts are captured correctly.

Again, AI is a TOOL. If you choose to use it, read through what it produces very carefully. DO NOT trust any chatbot to get it right without you doing anything but an initial prompt—the government wants YOUR views, not ChatGPT’s.

How to respond

Find where to paste your answers here
Find the DfE consultation main page here
You can also respond to this consultation via email at SENDreform.CONSULTATION@education.gov.uk,
or by post to: SENDAP Reform, Sanctuary Buildings, Great Smith Street, London, SW1P 3BT
Find more links to the consultation info on our SEND Politics page

Promoted

SEND Consultation questions by themselves

Download the questions in one doc: We’ve grabbed all the questions and formatted them for you to use offline.

Download it here as a word docx
Download from Google Docs in your preferred format here. This version is read only. To edit, click “file” then “download” and choose the format you want (doc, .odt, pdf etc).
We’ve also pasted them in the drop down below—click the arrow to reveal

Click to reveal the questions

We want children, young people and their families to be involved in making better, evidence‑based decisions about SEND, both in their local area and across the country.
- How can we make sure children, young people and their families have a genuine say in these decisions?
How can we make sure that high-quality evidence and best practice inform decisions about SEND? Please share examples.
How can we ensure that children are best supported by the Universal offer?
How can we ensure that children in the Targeted layer, are best supported?
How can we ensure that children in the Targeted Plus layer, are best supported?
How can we ensure that children in the Specialist layer are best supported?
How do you think early years settings, schools, and college can best support the mental health and wellbeing of children and young people?
Do you agree that the refreshed ‘areas of development’ will support educators to understand and address barriers to learning and participation? Please explain your answer.
What arrangements would best support effective joint working between early years providers, Best Start Family Hubs, health, local authorities, and parents for children with SEND in the early years?
How can the early years foundation stage (EYFS) two-year old progress check and the Healthy Child Programme development review be improved so that children’s needs are identified and supported more quickly? Please share examples.
What should the top three priority areas be for building and sharing evidence within the National Inclusion Standards?
What are the most important issues for national training to cover, to help support children and young people with SEND?
What practical actions can help teachers, educators and leaders manage workload whilst implementing these changes?
How should the Special Educational Needs Coordinator (SENCO) role evolve to better meet the needs of children and young people with SEND?
What would provide assurance for families that an Individual Support Plan (ISP) is high-quality and contains the essential information?
How can we ensure Individual Support Plans are clear, concise and practical for professionals to use?
How can we best support transition for young people with SEND, so that they are well supported into post-16 provision and further education, training or employment?
How can we make sure that every area can meet the full range of the needs of children and young people through Inclusion Bases?
How can we make sure that Inclusion Bases help children and young people succeed in mainstream settings?
Through the Experts at Hand offer, we want to ensure that mainstream settings can get quick specialist support for children and young people.
- What arrangements are needed between local area partners (education, health, social care) to deliver this Experts at Hand offer effectively?
What needs to be in place so that children and young people with low incidence, highly complex needs can always access the right specialist placement?
How can Specialist Provision Packages be designed to effectively support the main types of need we currently recognise?
We propose that EHCPs will guarantee educational provision set out in a Specialist Provision Package, with day-to-day provision captured in Individual Support Plans.
- What is needed to make these proposals work effectively?
We propose creating a more direct route to Specialist Provision Packages and EHCP assessments for children under 5 with complex needs.
- How can we make sure this works in practice?
What would you expect to be considered as part of the needs assessment, for example evidence and expert or professional input?
What factors should LAs take into account in proposing to parents and young people a list of potential settings to name on a plan?
What information and support do parents need to make a decision about which setting will be best for their child?
What do you think is the right maximum length of time for a temporary placement in Alternative Provision (AP) schools? Please explain your rationale.
We have set out our plans to regulate Independent Special Schools (ISS) sector.
- Do you agree that these proposed changes will lead to suitable placements being available at a fair cost? Please explain why.
How should settings be held accountable for how they spend their Inclusive Mainstream funding?
Do you agree that more SEND funding should sit directly within mainstream budgets? Please explain why.
In relation to pooled funding, we propose that every school becomes part of a local SEND group.
- Do you agree that this proposal aligns with our aim for all schools to be part of high-quality, community-based trusts?
How should disagreements about membership, provision, or funding in groups of schools for SEND be resolved?
How can we ensure the most effective use of these local partnership groups?
Which stakeholders are important for the success of local partnership groups, and why?
How can we build stronger collaboration and a culture of improvement through local SEND strategic plans?
What information, advice and guidance can best support children, young people and their families to ensure greater fairness across the system?
Do you agree that a SEND specialist (e.g. a SENCO) should sit on the school complaint panel, when the complaint relates to SEND support and provision?
- Please explain why.
This consultation outlines a series of measures intended to reform the SEND system. Some of these measures have already been finalised, and this is clearly indicated within the document.
- With this in mind, is there anything further you would like to contribute to help inform the remaining proposals that are still under consideration?

Do you need more help than this?

If you really need more help, we can prepare a more substantial document, complete with links to relevant SNJ articles. Jest leave a comment and let us know

Disabled Children’s Rights are Under Attack.
We’re fighting, but we can’t do it alone: we need your help more than ever.
We’re volunteer-run, but costs are rising. To help us keep going, please consider a one-off or, if it’s possible, a regular donation.
Read more about being a regular donor here.
We use Zeffy to fundraise, which doesn’t charge us a fee, so 100% of your donation reaches us.

DONATE TO HELP
KEEP SNJ ONLINE!

Key Content

a monkey in the jungle with a magnifying glass and a deerstalker hat

image includes graphics from the article

Don’t miss a thing!

Don’t miss any posts from SNJ – simply add your email address below. You must click the link in the confirmation email you’ll receive to activate your free subscription.

You can also keep up with us by following our

WhatsApp Channel!

Want more? Be an SNJ regular donor!

SNJ is a non-profit and everyone who writes here does so voluntarily. We need your support to help us with costs by donating once or as a regular patron. Find out more here

About
Latest Posts

Follow SNJ

Special Needs Jungle

Special Needs Jungle at Special Needs Jungle

Special Needs Jungle was founded in 2008 as a personal SEN blog by Tania Tirraoro. It is now a multi-author, award-winning site covering special needs, disability, mental health and rare conditions in children & young people birth-25 years.

Follow SNJ

Latest posts by Special Needs Jungle (see all)