10 reasons the Change Programme might fail, by experts from across the SEND sector

The SEND Improvement Plan was published earlier this year. We’ve covered this many times but today we’re going to look at the risks it faces. We hope the Department for Education has all these covered, but in case they don’t, perhaps these points will help their thinking.

Many thanks to the experts who have pitched in, in the short time they had to do so.  

1. The Ongoing Cost

This is, arguably, the most important. There is £70 million to test these reforms, but how will that also cover the vast cost of creating and implementing a digital EHCP, new local and national boards, “strengthening” mediation, setting up NPQs for SENCOs when there is already a perfectly good NASENCO in place, continuing teacher training, including adding in-depth SEND training to the Initial Teacher Training framework, all the research that’s belatedly being done on “what works” when there is already a vast selection of existing research apparently being ignored and – crucially – funding the early intervention in mainstream schools that there seems to be no plan for. The f40 group of lowest-funded local authorities, has called for at least £4.6 billion in extra high needs funding.

If you’re expecting mainstream schools to utilise their “ordinarily available provision”, first they have to know what that means, second, they need the training to do it and third, they need the money to fund it. With no improvement to the money schools are given for this in living memory, and without it being ring-fenced so it’s used as intended, it’s a bit like “there’s a hole in my bucket”

“The plan requires mainstream schools to do much, much more, at a point in time when the schools that want to do more don’t have the capacity or resources, and the schools that don’t want to do more will not be compelled to step up.”

Matt Keer, SNJ Accountability and funding expert

“Naturally we hope that the SEND Improvement Plan will be a raging success and the chronic attainment gap between deaf and hearing children will rapidly fall away to zero. But, if so, a lot of change will be required. We think we know a lot of the answers – earlier support for families, clear expectations about reasonable adjustments and more Qualified Teachers of the Deaf to advise families and mainstream nursery and school settings. Getting this right will require additional money, at least in the short term, and it will require DfE to commit to the spirit of co-creation with families and experts in its work – we regularly make offers of help. So why might it not work? I think it’s tough for DfE to find more money. And I think they prefer stakeholder engagement to genuine co-creation. Am I optimistic? Not yet, I deeply regret.”

Mike Hobday National Deaf Children’s Society

“RNIB supports the objectives of the Change Programme and the focus on early identification and effective intervention to deliver better outcomes. Early assessment and implementation of specialist support to meet the needs of learners with vision impairment (VI) (as set out in the Curriculum Framework for Children and Young People with Vision Impairment) relies on specialist VI education professionals such as QTVIs and habilitation specialists being able to provide a suitable level of support to settings. Therefore, it is essential that the Change Programme includes investment in local authority VI education services.

In order for the evaluation of the impact of the Change Programme pilot to be robust, steps should be taken to ensure that evidence relating to low incidence needs groups, such as children with VI, is valid.”

Jane Sharp, RNIB

2. A lack of understanding of what “early intervention” actually means

The Improvement Plan talks about using Alternative Provision staff as “early intervention” but that’s the opposite of “early”. Actual early intervention means having the skills to spot emerging SEND, or to put into place support for children who clearly have significant needs before they start school. This is why trained health visitors and early years providers are key. While the idea for 5,000 A-Level SENCOs is good, it’s limited to certain areas. There is no uniformity of expertise in nurseries and pre-school providers for SEND, and too often parents of children in Reception and Year 1 are told their child is just “young” as a reason not to act. Early years teachers, you may think you’re being reassuring, but it’s actually akin to (unintentional) gaslighting.

 “The SEND Review and its Change Programme rightly place a clear focus on ‘Early Identification and Support’. The vast majority of children who have Down’s syndrome receive a diagnosis at birth (or earlier) and so, in theory, by the time they enter the education system they are a group whose needs should already be clearly identified, with suitable provision to match. However, we hear on a daily basis from families (across Primary, Secondary and Further Education) who find their children’s needs are not being addressed – with vital support, such as much needed speech and language provision, simply not being provided. We look forward to seeing how the Change Programme addresses the systematic issues of early identification in a meaningful way - through the actual provision of timely and specific support for the children and young people who are entitled to it.”

Chris Rees, Down Syndrome Association

“The proposals rely heavily on early identification and intervention, which is something SOS SEN would wholeheartedly support.  They are however very short on information on how this would happen and in particular how it would be funded. This would require funding for more in-depth training for teachers on identifying and providing for SEND, plus smaller classes/better staffing and funding for a major increase in the availability of specialist advice and support from educational psychologists, speech therapists and other experts.”

Eleanor Wright SOSSEN

3. Too many strands to come together and too much consultant-speak

The Change Programme is awash with consultants who may know about change management but know little about SEND. You can’t treat disabled children like widgets. One firm hired was also behind the scurrilous LGA report where none of the problems in SEND were the fault of councils… And we all know consultants like to use word salad, but if you are trying to improve something and get a large and diverse sector to fall in behind you, making sure that children remain at the centre is rather important. We’ve had to raise this a number of times already with the powers that be. Here’s a case in point from the pitch from PA Consulting / CDC / IMPOWER for the DfE SEND Change Programme contract on the risks of too much change:

"We understand the various different in-flight programmes and stakeholders that will provide critical input into the SEND & AP change programme. We will utilise existing relationships to join up the dots between programmes through setting up structures which ensure alignment and knowledge flow. We will also develop “Page one” messaging on strategic alignment and synergy across programmes, and on practical connection" Tender document 'Framework Schedule 2: Framework Tender'

Huh? You okay, hun? As a journalist, my business is words, but I’m really not sure what the above means.

4. Unfinished work from the 2014 reforms

The work of the 2014 reforms still isn’t properly embedded, so piling on more structural change to unwilling LAs who’ve been forced into it in exchange for a cash bailout seems… questionable. And how much will they really help disabled children today reach their potential?

“The Government’s SEND and Alternative Provision Improvement Plan promises to transform support for children and young people with SEND, but there’s very little in it that’s transformational. What would really make a difference is a genuine commitment to implementing the existing SEND legal framework, and making compliance with existing legal duties non-negotiable. We are concerned that the SEND Change Programme sends mixed messages to parents and carers, who won’t necessarily realise that there has been no change in their children’s legal entitlements.”

Ali Fiddy, IPSEA

“We have not been told enough about the proposal for National Standards, and indeed why these are needed in place of or additionally to the law, including the current clear requirement that the needs of each child with SEND must be identified and properly described, and that clear and specific support must be given for those needs.”

Eleanor wright, SOSSEN

“While the plan talks about financial sustainability and value for money, it doesn’t define what these terms mean - and DfE are clearly more concerned about getting spending under control than they are about the other side of the value equation (outcomes for kids)”

Renata Blower, Co-Director SNJ

5. Lack of confidence and trust

The DfE has been fighting off allegations of 20% EHCP cuts, while not explaining exactly how it came to be in a signed contract and then refusing to remove it. But LAs, especially those in financial black holes on the Safety Valve /DBV programmes have been told to reduce spending on EHCPs and expensive provision to cut costs. As the law hasn’t changed, the only way they can really make a dent is to do what we are, unfortunately, seeing – premature ending of EHC plans and more applications for assessments being rejected. But as more parents become aware of their rights (you’re welcome), this will only lead to more appeals to the tribunal and parents prevailing even more than the 96% of the time they already do.

“EHCP cuts will be targeted at mainstream schools and given the lack of auditing/investment in frontline specialist support and schools’ funding difficulties, this is likely to have an adverse impact on inclusion and drive up the need for specialist provision (which already has well-documented issues with capacity). There are no metrics for measuring improvements in outcomes for children.

“Other indicators are also heading in the wrong direction. An increase in complaints and tribunals are causing issues with capacity which then create further accountability issues through LAs’ gaming of the system. It also leads to an increase in kids in Alternative Provision, many of which are unregistered so are not inspected so no one knows how good or safe they are.  

Gill Doherty, SEND Action/ SEND Community Alliance

6. Lack of accountability in the plan

Following on from Gill’s point, there is still little to make LAs conduct proper EHC needs assessments or write EHCPs that are fit for purpose. Lack of accountability is one of the biggest problems in SEND, but if you think “local inclusion boards” are going to force LAs to make the provision children are entitled to, you may need to rethink your position. They’re still bound by the Children and Families Act though, and if this or any successive government thinks raising the legal threshold is a flier, just wait to see how well that goes down…

“The main omission from the current law which needs to be rectified is that of accountability, and it is also omitted from the improvement plan. There needs to be central accountability for local authorities who are repeatedly found by Ofsted to be failing in terms of their SEND duties, and also for specific failures including non-compliance with statutory time limits, failing to produce workable EHC Plans, and failing to deliver special educational provision and full time education”

Eleanor Wright, SOSSEN

7. Still a lack of culture change

If they didn’t change their culture between 2014-2023, why should SEND, health and social care providers do it now? Those brave SEN case officers and managers who did their best to implement the reforms against resistance have long since left defeated or have been edged out. Parental co-production is still haphazard to say the least. And change comes from the top, so if they care more about money than children’s futures, those with good intentions have no hope. When the woman at the very top, the actual Education Secretary, Gillian Keegan, says SEND is “lose, lose, lose” and blames the “tribunal factor,” you really, really have to wonder…

“LAs are key to improved services - but as a sector, they are completely unwilling to admit that their own professional standards and conduct had anything to do with the failure of the 2014 reforms. Until they do, and until they reform themselves culturally, any improvement plan will fail”

Matt Keer, SNJ accountability expert, parent carer

“The improvement plan still continues to be held up as having legitimacy as it will underpinned by co-production. Yet, as we know, there continues to be no agreed definition of what co-production is never mind what good co-production should look like. It’s clear the DfE continues to rely on the model of co-production that led to the 2014 reforms and has continued to be in place since—a model where representatives from the NNPCF are the primary voice—to give legitimacy to the ideological and budget-driven proposals they are wanting to push through. 

“It is clear from Gillian Keegan's comments that parents who want to challenge the system through formal routes of redress as seen as a significant part of the problem. How can parents have any confidence that co-production is being taken seriously when we are spoken about with such derision? 

As parents we need to work together to push for real change. There’s a risk that the narrative of co-production combined with a strong anti-parent message will divide parents into those whose voice should be heard and the rest who are dismissed as being irrational and not to be taken seriously.”

Sharon Smith, SNJ columnist, parent carer, Co-production expert, & PhD Researcher

8. Lack of trained specialists

One of the biggest difficulties for early intervention is getting the SEND specialists in early enough— and this is largely because there aren’t enough of them. While the Change Programme has plans to recruit more Educational Psychologists, this is a long-term project. Ed psychs need a doctorate, and that’s a long, hard slog. The vicious circle is too little early intervention, so their time is taken up doing statutory EHC needs assessments, so they aren’t available for the early intervention work that’s needed.

“From the perspective of educational psychologists, not enough is being put in place to ensure the two key stated principles of the document are achieved – namely inclusion and early assessment/intervention. In the first instance, the plan does not involve a complete review of the whole education system (which is needed), nor does it consider how current curriculum and practices effectively exclude many children and young people. In the second, the plan does not remotely account for how to pay for, recruit, retain and train sufficient numbers of specialists like educational psychologists to provide the levels of early assessment/intervention required.”

Cath Lowther, Association of Education Psychologists (AEP)

9. Not enough focus on health

Ask anyone in the SEND sector and they will tell you that one of the key reasons the holistic EHCP didn’t pan out was insufficient buy-in and input from health providers in the NHS. This time around it’s not much better.

We’re concerned about the join up between education and health. While there are things to welcome in the SEND and AP Improvement Plan, we’re concerned that nothing in the Plan will address the need for better joined up working between education and health, particularly when it comes to commissioning. In fact, joint commissioning is not mentioned once.

It’s crucial that Integrated Care Boards get round the table and start to prioritise services for children and young people with SEND, but aside from the (welcome) requirement for ICBs to have an Executive Board Lead for Children and Young People with SEND, there is little in the plan which speaks to them. The plan says that national standards will apply to ICBs – but seemingly without any underpinning legislation. And while it’s great to see the Department of Health and Social Care working with the Department for Education on a joint approach to SEND workforce planning, we need to see that joined up approach across all areas of the plan.”

Peter Just, Royal College of Speech and Language Therapists (RCSLT)

“One charity I’ve spoken to is picking up the pieces from a lack of capacity in specialist services, with speech and language therapy being the most pressing issue. There is increasing difficulties with thresholds for accessing provision”

Gill Doherty, SEND Action, parent carer

“The plan says next to nothing about how the health sector will improve, and the NHS has bigger concerns on its plate than improving its contribution to SEND.”

Renata Blower, SNJ

10. They will run out of time

We’re heading for an election next year, and the Change Programme is only funded until 2025 because of this. The next government, if it’s not the Conservatives, will then be stuck with a half-finished programme that will have mounting costs that they will have to decide what to do with. Labour hasn’t yet said much about its plans for SEND, understandably so, as they don’t know how this will play out and what cash will be left if they win.

“NASS is concerned that the Change Programme will disrupt and cause stress for families without offering realistic hope of meaningful change for many years. There is a pernicious narrative growing around making parents ‘happier' so that they are 'less demanding' of services, as seen in the DVB contract with its 'non-target’ targets on both numbers of EHCPs and placements in special schools. The aim of reducing overall spend never seems far away and is the key feature of local authority intervention programmes. However, there is no analysis of value for money within the system and too little focus on how we improve the current system.

“The Change Programme Partnerships have been late starting their work and seem unlikely to have got far before next year’s general election halts them in their tracks. In the meantime, the myth factory appears to be in overdrive and its worrying to hear accounts of parents and schools being told that SEND processes and laws have changed as a result of the Programme. Given that most of us in the SEND world felt that cultural reforms were needed to back up existing laws and rights, this is exactly where we don’t want to be. We don’t think its too late to develop some powerful partnerships that include all stakeholders as valued partners but we do want to see some changes in narrative that convince us this is possible.”

Claire Dorer, NASS (the voice of the non-maintained special school sector)

“I'm still puzzled why it's [The SEND Change Programme] there at all, given that it requires investment and creates uncertainty in circumstances where there is no intention to put legislation in place during this Parliament and no certainty at all that the same government will be in power to deal with it in the next Parliament.

“I am particularly concerned that children with SEND in the areas trialling the programmes will be short-changed because their parents are likely to be led to believe that, for instance, in choosing school places they cannot look beyond the tailored lists of schools they will be provided with.

Eleanor Wright, SOSSEN

What are your thoughts on the risks?

Above, we have views from our team of experts and from experts who are leaders across the SEND sector. But what do you think? And if you’re in an LA or even in the DfE 😉, do let us know your views in the comments below.

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