SNJ’s Matt Keer was the first to bring the last government’s Safety Valve scheme to light, and we have continued to highlight the issues with it. Today, Matt deconstructs a new report into this highly contentious programme: “By practically any metric you care to use, the Safety Valve scheme has failed to meet its objectives.”
Another week, another expensively authored report on SEND. This time, it’s about the last government’s controversial Safety Valve SEND financial intervention schem
This scheme is still alive, but closed to new arrivals. Here’s the background to it…
By 2020, Whitehall had clocked that some local authorities were spending much more money on education (particularly on SEND) than central government was giving them. Those LAs were racking up deficits in the process. In response, the Department for Education (DfE) launched a new scheme called Safety Valve.
This invite-only scheme provided its participants with a heavily front-loaded multi-year financial bailout. In return, these LAs agreed to run their SEND services differently, managing “demand” more stringently. If an LA participant fails to meet the terms of the agreement, its bailout money gets cut.
When SNJ first wrote about Safety Valve back in 2021, we warned there was a risk this financial intervention scheme would incentivise LAs to suppress demand for SEND support, rather than manage it better.
In all, 38 Safety Valve agreements were signed between 2021 and 2024. Late last year, aware of the issues that we, other sector organisations, and education publications had raised, the new Labour government announced it wouldn’t sign any new agreements—but stopped short of scrapping the agreements that remained in place.
A few months before that decision, the DfE commissioned a report into the experience, operation and impact of Safety Valve agreements at local authority level. This report was published at the end of last week.
Listening to the Good Chaps, instead of the Little People
The report, commissioned for somewhere north of £53,000, was written by coin-operated public sector consultants, the Isos Partnership. Most of Isos’s income comes from consultancy to local authorities, and this has brought it much influence to LA’s SEND thinking. You can see this in the lobbying lines local government deploys with Parliament and central government.
The message Isos delivers is fairly simple. Everyone who works within the SEND system is (apparently) a Good Chap, doing the valiant and largely unsung things that Good Chaps do. Everyone is acting rationally, even the Little People like us. But things are going wrong because the council Good Chaps are operating within a Bad System. This thinking follows that, if the Bad System is scrapped and replaced by a Good System, then the Good Chaps will get to do Good Things, and All Will Be Well—even for us Little People.
The Good System, in Isos’s view, requires the demolition of barriers that stop Good Chaps doing Good Things. These barriers tend to be things that we Little People value: individual rights and meaningful external accountability, for example.
When Isos was commissioned for the Safety Valve report in late 2024, it was handed a dead dog. The Labour government inherited this setup from the Tories, and their interest is probably academic at this point. But Isos has plugged away at it, and some of its findings do matter. Because who knows when a government might next have to pretend that poorly-conceived and ineffective demand suppression is in everyone’s best interest?
The curious and entirely unbiased Isos Way
The Isos Partnership approach to a task like this is fairly straightforward. Interview a range of insider SEND system leaders, leaven the sample with a handful of parents and school leaders, launder and amplify the voice of the leaders during drafting, and present the report as the authentic voice of the frontline.
It’s not immediately obvious why the DfE would need to hear the voice of SEND system leaders and insiders through a report like this. The DfE operates its own multi-million pound networks of SEND professional advisers and Safety Valve advisers who already provide the department with this type of information. System leaders and their professional bodies already get plenty of direct face time with DfE civil servants. There’s also a multitude of pay-to-play network events, conferences and webinars where the same people endlessly and incestuously brief each other.
Unsurprisingly, the voice of the Good Chaps—AKA SEND system leaders—dominates this report. And that’s by design. Because what could the Little People understand, let alone offer?
“…while many families and practitioners will be able to describe experiences of accessing local SEND services, comparatively fewer will be in a position to comment on the links to the Safety Valve programme. While we invited wider views, our research has drawn primarily on the feedback of local SEND system leaders, including local Parent Carer Forums (PCF) and SEND Information, Advice and Support Services (SENDIASS).”
From the report
Needless to say, they didn’t ask for our opinion…
Impact on SEND System Leaders
By and large, these Good Chaps reported to Isos that the Safety Valve scheme was a sticking plaster. Although it provided them with some short-term financial relief, Safety Valve wasn’t a scheme that could remedy all the faults in the SEND system, and the scheme didn’t cause any of those faults. Some LA leaders reported that “being part of the Safety Valve programme had brought greater focus, sharper planning, increased rigour and additional pace” to their work.
This agribusiness-grade bullshit might irritate you. But remember, the authors aren’t in the business of actually evidencing these remarks; they’re merely passing them on to the DfE.
Impact on children and young people with SEND, and their families
When they look at the impact of Safety Valve on the Little People, Isos mostly just reproduces and foregrounds what the Good Chaps have to say, principally LA leaders. The LA leaders that Isos spoke to identified three strategic ways in which Safety Valve contributed positively to outcomes for children and young people with SEND:
- Early Intervention: Isos warmly highlight efforts by LA leaders to strengthen early intervention and inclusion, to provide more timely access to support without the need for EHCPs. They gave some generalised examples to support this, although it wasn’t immediately obvious how an LA’s Safety Valve agreement had made the difference.
One of those examples was in Croydon, a council that’s been through a section 114 financial insolvency process. That was surprising to see, as we were previously informed by one of Isos’s last reports that SEND-driven section 114 processes pose an “existential threat” to councils. It’s encouraging to see Isos confirm not only that Croydon still exists but is, apparently, still capable of delivering SEND services.
- Extra Capacity: LA leaders told Isos that Safety Valve enabled the construction of more local specialist SEND provision, reducing out-of-area placements and/or reliance on more expensive independent placements. This is something that’s happening, although often a lot slower than local leaders would like.
- ‘Better’ Casework: According to some LA leaders, their Safety Valve agreements forced them to improve their casework and implement more ‘robust’ statutory SEND decision-making. Some leaders said that the increased emphasis on timeliness had not always meant higher-quality output, and some had seen an increase in disputes as a result.
If you found the euphemisms on display there a little too greasy to digest, then Isos has plenty more for you: it has identified a ‘conundrum’ with Safety Valve. Isos doesn’t think it’s a real conundrum, just one that’s in our heads; a matter of perception. But it’s a conundrum that it thinks the DfE needs to know about.
Isos reported that:
“A minority of participants—school leaders, and parents and carers—argued that Safety Valve had had a direct negative impact on children, young people and families. They considered that the signing of Safety Valve agreements had coincided with increasing difficulty in accessing support, specifically an increase in the rate of requests for statutory assessments being refused and more stringent decision-making regarding issuing EHCPs or access to certain forms of placements.”
From the report
Safety Valve agreements and SEND cuts
Following up—with drafting and contextualisation that in no way suggests an attempt to lead the witness—Isos continued:
“In our discussions with these groups, they acknowledged that no Safety Valve agreements contained explicit targets to reduce EHCPs, and furthermore that Safety Valve agreements do not set aside existing legislation, including the legal tests to carry out statutory assessments and issue EHCPs. As such, they recognised that that it was not possible to prove that Safety Valve agreements directly had made it more difficult to access support.”
“This perception does, however, exemplify a conundrum and point of tension within the current system, which was recognised as much by LA leaders as by parents and carers.”So, do Safety Valve agreements contain explicit targets to reduce EHCPs? Not in the published capping agreements, sure—but Safety Valve agreements are underpinned by financial plans that LAs must stick to. Additionally, many of these financial plans explicitly require reducing the number of new EHCPs over time, an increase in plan terminations, overall reductions in the numbers and real-terms costs of EHCPs, and percentage targets for particular types of school placement.
These plans are usually RAG-rated (red, amber, green), and poor performance against the numbers in the financial plan risks suspension of the Safety Valve agreement. In any sane definition of the word, these operate as targets. And you can find many examples of them in research conducted by IPSEA last year, including a memorable case where one LA (Cambridgeshire) helpfully explains, in writing, what each condition of the Safety Valve agreement really means.
But you won’t find examples of these in the Isos report, which simply doesn’t bother engaging with the messy operational reality of Safety Valve.
It’s also screamingly obvious that Isos is applying a much higher burden of proof to families and school staff than it does to its own client base. It doesn’t require similar proof of impact from LA leaders for the positive Safety Valve examples.
Examining the (inconvenient) Safety Valve data
With audibly gritted teeth, Isos then looks at some of the data:
“Published data suggest that, on average, the rate of growth in new EHCPs has been slower over the last 5 years among Safety Valve LAs than those without a Safety Valve agreement. Published data also suggests that the rate of new placements in INMSS [independent or non-maintained special schools] has fallen more quickly in Safety Valve areas than in other non-Safety-Valve areas… …This may explain the perception of some parents and setting leaders that, since the introduction of a Safety Valve agreement in a local area, it has become harder to get an EHCP or a place in an INMSS.”
I guess it would, wouldn’t it? It might also suggest that it’s more than a perception. It might even be backed up by more data than just that. Surely, we Little People can’t be right here, can we?
As ever, the authors’ choice of verbs tells us a lot. In this report, the Good Chaps tend to ‘report,’ ‘acknowledge,’ and ‘reflect.’ The Little People are depicted in much more emotive or subjective terms: they tend to ‘feel,’ ‘argue,’ or ‘perceive.’ This is not by accident.
So, when an LA leader on a Safety Valve scheme reported to the DfE that their plans would “turn the tap off” on EHCPs, was that an objective and accurate statement of intent, or just what that leader felt and perceived? It’s just so confusing for us Little People, isn’t it?
Safety Valve’s impact on schools
Isos also asked school leaders what difference they thought Safety Valve had made. Most of the leaders they spoke to were already plugged into local networks, reporting that being involved in Safety Valve had helped them better understand how the local SEND system worked financially. Other school leaders noted that Safety Valve had helped the LA develop new offers of targeted help, and the development of new specialised provision.
Some of the school leaders interviewed did report on the negative impact of Safety Valve, reporting Isos has again chosen to describe as ‘perceptions.’ These leaders reported they found Safety Valve to be mostly an exercise in shifting the cost of the SEND system from the LA to individual schools’ and settings’ budgets. They reported that the financial block transfers required under the Safety Valve deals caused schools genuine pain.
Isos airily dismisses this as something that’s happening everywhere, not just in Safety Valve LAs. But it’s a matter of financial fact that these transfers are proportionately larger in Safety Valve LAs than they are in LAs outside the scheme. The DfE is also much more willing to override local school forums and impose these transfers for Safety Valve LAs than it is for others.
And for whatever reason, there was no space in the report for Isos to explore whether there was a financial impact on schools within the Safety Valve scheme. We know from our own research that almost all LAs in the Safety Valve scheme have inflicted real-terms cuts on high-needs top-up funding at per pupil level, at a far greater depth than has happened in LAs outside the scheme.
Lessons to be learned from the Safety Valve scheme
By practically any metric you care to use, the Safety Valve scheme has failed to meet its objectives. So, how can the Safety Valve experience inform the development of the government’s imminent SEND changes?
Isos has highlighted a few things that can be salvaged. By incredible coincidence, the things it’s highlighted align well with its own reform proposals, including their most fundamental pitch: root-and-branch national reform has to happen.
Other reform proposals that Isos highlighted in its review include: the need for a more inclusive education system with targeted support services; greater council control over building and shaping state-funded specialist provision; tighter regulatory control over independent schools; new mechanisms to strengthen partnership working between education and health organisations, and a review of SEND funding arrangements.
Does this report matter?
When its officials procured this study, the DfE said it wanted a report on the impact of Safety Valve on children and young people with SEND and their families. What it’s ended up with is the Good Chaps Version—and only a fraction of the report is about impact on children. A cynic might conclude that this, also, was no accident.
Somehow, central government has managed to pay the thick end of £50,000 for a set of largely unverified and carefully laundered opinions from SEND system leaders whom Whitehall already knows well, and whose messages it already receives via an advisory consultant network, conferences, webinars and workshops.
The authors weren’t born yesterday. There are just enough alternative opinions in this report from just outside the reality distortion field to fend off accusations of ventriloquism. But there are also enough subtle textual nudges—an emotive verb here, an implication of narrow perspective there—to allow the self-interested reader to discount those alternative perspectives.
It’d be tempting to write this report off as shit in a silk stocking. But there will be further SEND financial intervention programmes. The DfE is already recruiting new battalions of SEND Financial Advisers on four-year gigs. Having a report that says you can suppress SEND demand without any real impact on children and young people will certainly have its uses. You just have to be a Good Chap to be able to use it that way.
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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.
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Matt specialises in SEND stats, data analysis, and in-depth investigations of policies. He has given evidence to several Parliamentary Select Committee inquiries, and his articles for SNJ on SEND funding, local government policy, and the SENDIST Tribunal have been quoted in Select Committee inquiry reports and national media.
- Top Tips for the EOTAS & EHCP consultation: Protect your child’s rights to statutory SEND support - August 19, 2026
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