with Annamaria Madera Deputy Head of Education, CandLE
The term “complex needs” is crucial to the Government’s SEND reform proposals. It determines access to Education, Health and Care Plans (EHCPs), the planned Specialist Provision Packages and limited legal protections. Yet neither the Government nor the Department for Education has, so far, provided a coherent definition of the term.
Today’s article is from CanDLE, a non-profit that specialises in teaching and supporting students who use AAC and assistive technology. examines what the proposals might mean for children and young people who use augmentative and alternative communication (AAC). In a system built on classification, they risk being mislabelled and diverted into unsuitable settings, or denied the specialist AAC support they require.
Our concerns over the SEND reforms for learners using assistive tech. By Annamaria Madera Deputy Head of Education, CandLE
Augmentative and Alternative Communication (AAC) users are frequently described as having “complex needs,” often because their communication and physical access requirements are significant.
Many are also labelled as having Profound and Multiple Learning Difficulties (PMLD). The Department for Education (DfE), for example, describes pupils with PMLD as having “complex health needs, severe physical disabilities, and dependencies on technology, including augmentative and alternative communication.”1
However, research shows that AAC users often have typical, or even higher than expected, cognitive abilities2; a lack of speech does not imply a lack of understanding. For many AAC users, the primary barrier is access, not cognition. This means they must have genuine opportunities to access the national curriculum, ideally within mainstream settings where academic pathways are broader and expectations higher. Yet many AAC users fall into a persistent “provision gap” of being too academically able for special schools, where curricula and qualification routes are often limited, but requiring specialist support that mainstream schools frequently claim is beyond their capacity.
No mention of AAC in the proposals
The SEND proposals places strong emphasis on “speaking” as a core foundation of education. Yet AAC is not mentioned anywhere in the document. This omission is striking because the national curriculum review explicitly defines oracy as including nonverbal communication and AAC. By prioritising spoken language without acknowledging AAC, the proposals fail to recognise the communication rights of nonverbal pupils. It risks creating a system where only speech is valued, leaving AAC users invisible in policy, training, curriculum design, and accountability. This reinforces existing gaps in AAC provision, already inconsistent and often under recognised, and sends the message that AAC is optional rather than essential. A national strategy centred on communication cannot be equitable if it excludes the very tools that enable many pupils to communicate at all; and risks removing specialist AAC expertise and support from the scope of specialist provision.
A shift from individualised provision
The proposals say pupils with “complex needs” will receive support through predefined “Specialist Packages.” This marks a shift from individually enforceable provision to cohort based, predetermined models. The assumption that pupils receiving specialist packages will be “mainly” in specialist settings contradicts the government’s stated commitment to inclusive education. But where do cognitively able AAC users fit? Their needs do not align neatly with the proposed packages, and the absence of a clear definition of “complex” creates ambiguity in a system that relies on precise terminology to allocate support, funding, and legal protections.
If specialist packages become the gateway to EHCPs, the threshold for support risks shifting from “necessary” to “meets package criteria.” This creates potential Equality Act concerns. Rigid package criteria may fail to account for the specific barriers faced by AAC users. The system must include a mechanism that allows for additional provision when a child’s requirements fall outside the package structure.
There is also a lack of clarity about what will constitute as ‘specialist’ support. Without transparency, pupils risk being presented with limited, predefined options that may not reflect their actual needs. Packages may also narrow what “counts” as specialist support, potentially excluding essential AAC and Assistive Technology (AT) expertise such as AAC assessment, device programming, communication partner training, or specialist teaching. If these elements are not explicitly included, schools may overlook or under‑resource them. Families could lose agency if decisions are driven by package design rather than individual need. AAC users, whose needs often span multiple domains, may be incorrectly placed within a single package or forced into inappropriate settings.
Undefined terms risk ambiguity and creating provision gaps
The paper also commits to resourcing mainstream schools to meet “common and predictable needs,” reserving EHCPs for pupils with “the most complex needs.” Yet neither term is defined. This lack of clarity risks inconsistent interpretation and budget‑driven decision‑making. “Complex needs” could be narrowed to restrict eligibility for specialist provision such as AAC, while “common and predictable needs” could be broadened to push pupils into universal support even when they require specialised, personalised AAC support. This ambiguity weakens the enforceability of SEND law and increases the risk that cognitively able AAC users are mislabelled as having “complex needs” and diverted into special schools where academic pathways do not match their potential.
The reforms also overlook pupils whose needs cannot be met in either mainstream or special settings and who require EOTAS (Education Otherwise Than At School). EOTAS is a statutory entitlement but without explicit recognition, it will loses visibility in national planning, funding, and accountability. It could also create a reduction in scrutiny for local authorities and deepen postcode inequalities. Many AAC users currently rely on EOTAS to bridge the “provision gap”. Its omission leaves them particularly vulnerable.
Historically, the SEND system categorised pupils by type of difficulty; cognitively able AAC users do not fit neatly into traditional categories. Advances in AT mean many pupils are now better understood as having an ‘access disability’. They may not have a learning difficulty, yet they cannot access teaching, assessment, or peer interaction without specialised communication support and/or AT solutions. Their barrier is communication and physical access, not cognition. Too often, their needs are reduced to equipment provision, overlooking the specialist teaching, technology and communication partner support required to make learning accessible. For AAC users, access extends far beyond providing a device. It includes specialist, adaptive teaching, adapted literacy instruction, trained communication partners, device programming, curriculum adaptation, and ongoing therapy and review. These elements are essential, not optional.
Specialist equpiment is not “ordinary provision”
A final concern is the growing trend to classify AT, including AAC systems, as “Ordinarily Available Provision” (OAP). While this may appear positive, without guaranteed access to appropriate AAC systems and the specialist assessment, training, and ongoing support required to maintain them, students may be left with tools that are ineffective, outdated, or poorly matched to their needs. Reclassifying AAC as OAP risks shifting responsibility onto schools without ensuring they have the expertise, capacity, or funding to deliver it.
National specialist AAC services are typically only commissioned for the most complex cases, leaving many children with emerging or moderate needs without support. AAC support is not provided at a predictable developmental stage, with services often delaying provision until a child “shows readiness,” despite strong evidence that early AAC use accelerates language development. Without clear expectations around AAC/AT, the government risks repeating the same gaps in early intervention.
The wider population of students who rely on AAC are currently funded by local provision, not through NHS AAC Assessment centres—these only make communication provision for the most complex 10%. Therefore, funding for AAC as an assistive technology to support curriculum access and learning also needs to be available.
Ensuring that AAC users are not lost within broad categories, rigid packages, or assumptions about “complex needs” is essential if the system is to uphold their rights to communication, learning, and inclusion. AAC users require personalised, specialist, and legally enforceable support. The SEND reforms, as currently drafted, risk weakening the protections they rely on.
About the author
Annamaria Madera is the Deputy Head of Education at CandLE AAC. Candle AAC is a not-for-profit teaching organisation supporting students across the UK who use AAC (Augmentative and Alternative Communication) and AT (Assistive Technology). CandLE provides training to schools both individually and through the charity Teach Us Too. It has developed and delivered a successful literacy programme specifically designed for AAC users, underpinned by evidence-based research.It helps students achieve their full academic potential by making learning accessible through an individualised approach.
CandLE’s Teachers, Tutors, Teaching Assistants and Resource Developers provide learning support for students who could benefit from AAC and AT.
References
- SEND and Alternative Provision Improvement Plan – Evidence Base (Department for Education, March 2023), Page: 38 ↩︎
- Light, J., & McNaughton, D. (2012). The changing face of augmentative and alternative communication: Past, present, and future challenges. Augmentative and Alternative Communication, 28(4), 197–204. ↩︎
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