By Joanna Gibbs, SENsational Tutors
Last week, we analysed part two of the Government’s SEND reform proposals that destroy the principle of Education Otherwise Than At School (EOTAS) in an EHCP. We also revealed how the DfE plans to ditch appealable statutory SEND provision. Later in the week, we looked at the difference between EOTAS in an EHCP, and EOTAS via section 19 alternative provision, and the issues with transport.
We continue with the theme today. Joanna Gibbs is an expert in out-of-school provision, as CEO of an online tutoring company. She’s also part of our Save Our Children’s Rights coalition. In this guest article, Joanna offers a clear-eyed look at the gaps and uncertainties families now face when thinking about this kind of non-school-based provision.
The issues she raises, including the risks of standardised packages for children who cannot be educated in a traditional school setting, continue to shape the debate about SEND reform. Her reflections underline why flexible, bespoke provision matters, and why families still need clarity and for meaningful rights to be maintained as the reforms develop.
Guest post by Joanna Gibbs, SENsational Tutors
The Government’s SEND White Paper has raised important questions for families, specialist SEND tutors, alternative provision providers, and professionals supporting children and young people with additional needs. While the proposals are not even a Bill, let alone law, many families remain uncertain about how any future changes may impact the SEND support and provision their children receive.
In the new EOTAS consultation, the Government states that children with EOTAS in secondary years and beyond will not be affected, but those in primary face a full reassessment of needs in Year 6. Because many of the proposals remain unclear, including criteria and definitions, there is growing anxiety that a more standardised system, with a named school, will make it harder for some children to access the highly individualised support they need.
What do we mean by Alternative Provision?
When people hear the term “Alternative Provision“, they often think of pupil referral units (PRUs) or specialist schools. However, for many children and young people with SEND, alternative provision can include specialist tutoring, therapeutic education programmes, community-based learning, mentoring, online education, and bespoke packages designed around a child’s specific needs.
Some children access these services through school commissioning or local authority direct funding. Others receive support through personal budgets, Education Otherwise Than At School (EOTAS) packages or specific provision within an Education, Health and Care Plan (EHCP). These arrangements exist because a child cannot safely or successfully access a school environment, whether it’s due to severe anxiety, needs from neurodivergence, trauma from previous school experiences, sensory differences, serious health conditions, or other complex circumstances. The new EOTAS proposals show the fears of many families were justified.
The importance of specialist SEND tutors and alternative provision
For many children with SEND, specialist tutoring is not simply an academic intervention. It often provides:
- predictable and low-demand learning environments
- sensory-safe educational experiences
- trauma-informed approaches
- flexible pacing
- trusted relationships
- opportunities to rebuild confidence and engagement with education.
Many children who access specialist tutoring have experienced prolonged periods out of school for many reasons. The effectiveness of specialist tutoring is often rooted in its ability to adapt around the child, rather than expecting the child to adapt to narrow and rigid system. This required flexibility is one of the reasons many families are worried about the Schools White Paper and EOTAS proposals.
The missing conversation
The proposals are ambitious, setting out a vision for a more consistent system, clearer expectations and better support for children with SEN and additional needs. However, the White Paper was perplexingly silent on EOTAS, and now this new consultation is out, its proposals have left more questions than answers, with families who have spent years identifying support that genuinely works for their child feeling angry and fearful. While this consultation discusses making placements time-limited and safeguards, families are left trying to read between the lines, again, with big questions left unanswered about how AP and specialist SEN tutors will work in the new system.
Rachel, mother of two autistic children with complex SEND, described the reality many families face:
I put together a budget of all the provision that I wanted and how much it would cost for the local authority over the year. I sourced all the provision off the preferred suppliers list of the local authority… I submitted like an eight-page kind of EOTAS proposal package… it’s a huge amount of work.
Rachel, SEND parent
For many parents, obtaining suitable support already requires significant time, knowledge and persistence. The lack of indication surrounding future reforms raises understandable concerns about whether those hard-earned arrangements will remain available.
Specialist Provision Packages: consistency or standardisation?
One of the most significant proposals within the White Paper is the introduction of Specialist Provision Packages (SPPs).
The Government describes these as a way of creating greater consistency in SEND support. However, many parents, legal experts and SEND organisations have questioned whether standardised packages can adequately meet highly individualised needs.
At present, many important questions remain unanswered:
- What support will SPPs actually contain?
- How will children be allocated to them?
- How will complex or overlapping needs be accommodated?
- Will specialist tutoring, EOTAS or bespoke alternative provision be included?
- What happens when a package does not meet a child’s needs?
- How will families challenge unsuitable provision?
These are important questions because many children who currently access specialist tutoring or EOTAS do so precisely because standard approaches have not worked for them. The concern is not simply whether support will exist. It is whether support will remain flexible enough to respond to individual circumstances.
SEND parent Yasmin, whose daughter, Safina, has Down Syndrome, highlighted a concern shared by many families: that discussions around Specialist Provision Packages often appear to assume that support will be delivered primarily within a school setting, with little indication of how provision outside traditional settings would fit into the model. The new document is based around every pupil having a named setting, but it is unclear who will allocate or hold any budget, and it is up to the setting to decide how much, if any is EOTAS. While it does say to “involve” parents and young people, the language is a clear step back from “putting the family at the centre”, the premise of the current law. Instead, it seems that decisions could be made by a setting that does not know the family well, and may have little understanding of the child’s needs— just whether provision on an LA approved-list (decided on what criteria?) will fit into the budget.
For families whose children cannot safely attend school, these significant questions must receive better, more detailed, answers.
What happens to EHCP protections?
Alongside concerns about Specialist Provision Packages, many families are increasingly focused on the proposed role of Individual Support Plans (ISPs). Although details remain limited, this new consultation indicates EHCPs would become like a framework, with key provision details moved into ISPs. This shift removes the legal power of an EHCP, stripping away the vital protections families currently rely on. Now, if it’s in the EHCP, it must be provided. If it’s in an ISP, it can be easily be taken away.
EHCPs currently provide important legal safeguards. Parents have established rights to challenge decisions through the SEND Tribunal where they believe provision is unsuitable or insufficient. If significant decisions about support sit within documents that carry fewer legal protections, families will find it considerably harder to challenge provision that does not meet their child’s needs.
Additionally, under these new proposals, if a Year 6-aged child with EOTAS is mandatorily reassessed in 2030, and the LA decides they shouldn’t have EOTAS, then that’s that—no appeal, just a complaints system or, in some circumstances, a judicial review (for which parents would probably need a lawyer). This leaves a child potentially forced back into a school, with any progress made set back. And if they cannot go in? Parents know only too well what that can mean for them.
This lack of essential detail and a deep sense of unfairness lies at the heart of the SEND reform debate. The issue is not simply whether support is offered, but where, and whether families retain meaningful rights to secure provision that genuinely meets their child’s needs.
What about personal budgets?
Many families rely on education personal budgets to access specialist support that may not otherwise be available. Through personal budgets, parents are often able to commission specialist tutors, therapists and alternative provision providers with the expertise required to support their child. There is currently little clarity about how personal budgets would operate within the proposed reforms. For families who have worked hard to secure bespoke support arrangements, this uncertainty is deeply concerning.
If future support becomes increasingly tied to predefined packages, questions remain about how much flexibility families will retain to make decisions based on their child’s individual circumstances.
Relationships, trust and trauma
For children accessing specialist tutoring and alternative provision progress is often steadily developed through building relationships, trust, consistency and emotional safety, rather than through rapid academic intervention. Families are understandably concerned about reforms that may reduce flexibility or prioritise academic attainment, a curriculum, and administrative consistency over individual need.
For many families, the debate about SEND reform is about whether decision-makers fully understand the complexity of a child’s lived experiences. Rachel, quoted earlier, reflected on this reality when describing conversations she has experienced with local authorities:
You’ve got a child who is so poorly and cannot even get out of bed to use the toilet, they’d rather wee on the floor because the demand to get out of bed and go into a bathroom… and you’ve got a local authority saying that they’ll probably name a mainstream school for her.
Rachel, SEND parent
The experiences of many children with complex SEND demonstrate that support works best when it is built around individual needs, trusted relationships and genuine flexibility. Any reform that weakens those principles risks undermining the very outcomes it seeks to improve. As the proposals develop, it is essential that the voices of children, families and specialist providers remain central to the conversation. The future of SEND support should be shaped by what helps children thrive, not simply by what is easiest to standardise.
About the author
Joanna Gibbs is the CEO and founder of SENsational Tutors, a leading UK tutoring agency/alternative provision specialising in PDA tutoring, autism tutoring, trauma‑informed and neuroaffirming support for children and young people with SEND.
She has spent years championing flexible, relational and child‑centred approaches – the kind that help learners feel safe, understood and ready to thrive, even when the system around them feels overwhelming.
Joanna works closely with families, tutors and professionals to design bespoke plans that genuinely fit each child, not the other way around. Her work is rooted in one belief: when children feel emotionally safe, they can learn, grow and reconnect with education on their own terms.
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Key Content
Also read:
- WEBINAR RECORDING! The implications for children’s legal rights to EHCPs and EOTAS of the Government’s SEND proposals
- When things go right: Shining a light on SEND Practitioners making a positive impact [Giveaway!]
- From suspicion to support: why the Government’s child protection reforms matter for disabled children
- Have your say on the future of transport for disabled children and young people
- Unison voices major concerns over SEND reform health plans for sick and disabled children out of school in the EOTAS consultation
- Top Tips for the EOTAS & EHCP consultation: Protect your child’s rights to statutory SEND support
- REGISTER NOW! WEBINAR on the Government’s plans to cut EHCP and EOTAS rights. With SNJ & SEND legal charity, SOS!SEN
- Navigating constraints: Why a former PCF chair thinks the current model is missing the mark for families
- Dear Secretary of State for Education, Lucy Powell: an Open Letter from Special Needs Jungle and SEND legal charity SOS!SEN
- Research: Disabled young people define inclusive education as “learning in the place that’s right for them”
- Why every child deserves Portage, wherever they’re born
- Mainstream SEND Funding: A simple explainer, another consultation, and why it really matters
- WEBINAR RECORDING! The implications for children’s legal rights to EHCPs and EOTAS of the Government’s SEND proposals
- Unison voices major concerns over SEND reform health plans for sick and disabled children out of school in the EOTAS consultation
- Top Tips for the EOTAS & EHCP consultation: Protect your child’s rights to statutory SEND support
- REGISTER NOW! WEBINAR on the Government’s plans to cut EHCP and EOTAS rights. With SNJ & SEND legal charity, SOS!SEN
- What might the SEND reform proposals mean for specialist tutors, alternative provision and EOTAS?
- When Home-to-School Transport Doesn’t Fit: The Reality of Section 19 EOTAS
- EOTAS Consultation: A further assault on children’s SEND rights with cost saving and reintegration to schools at its heart
- Why my daughter’s SEND experience means we’ll take this consultation judicial review fight wherever it needs to go
- SEND reforms: Where are care-experienced children?
- Part 2: The Invisible Lifeline: Why EOTAS is Non-Negotiable for the ‘Sanctuary Cohort’
- The Invisible Lifeline: Why EOTAS is non-negotiable for the ‘Sanctuary Cohort’ Part 1
- Legal challenge launched against government SEND proposals that “significantly weaken the legal rights of children and young people”
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What kind of government is “bold” enough to scrap statutory EHCPs from vulnerable children?May 16, 2025
The SEND reforms in the Schools White Paper reveal rights given, and rights stripped awayFebruary 24, 2026
- WEBINAR RECORDING! The implications for children’s legal rights to EHCPs and EOTAS of the Government’s SEND proposals - September 3, 2026
- From suspicion to support: why the Government’s child protection reforms matter for disabled children - August 28, 2026
- Have your say on the future of transport for disabled children and young people - August 25, 2026
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