After an extended period of review and consultation – and many missed deadlines – at last we have a SEND and AP Improvement Plan. But has it been worth the wait? For the FE sector, the answer has to be no, not really.
It’s no surprise that the Improvement Plan is largely focused on addressing the two key issues that were foremost in the SEND and AP Green Paper: the spiralling costs of the system, in particular the call on the high needs budget, and the rising numbers of children with SEND being educated outside of mainstream schools. Natspec recognises that both of these are critical challenges that the government must tackle.
We thoroughly support the drive to ensure that mainstream schools are more inclusive and better able to identify and more swiftly meet the needs of more children with SEND. National standards setting out ordinarily available provision may well help in this mission. We also appreciate that a system that is both inefficient and ineffective has to be changed. If it cost a lot but children, young people and families were delighted with the service they were receiving, that would be one thing – but that’s not the case. It remains to be seen, however, whether the tension between retaining children’s and young people’s rights and reducing costs can be satisfactorily resolved. The increased focus on accountability, with more oversight of and clearer sanctions for local authorities failing to fulfil statutory duties, is also welcome. Lack of accountability has certainly been a factor in the failure of the current SEND system.
Of course, as the membership body for specialist FE colleges, Natspec was very much hoping that the Improvement Plan would include some bold reforms to address the intransigent issues affecting 16-25 year olds, especially those with more complex needs. Sadly, they are not to be found. There is more post-16 content than in the Green Paper but that is a pretty low bar. There is also evidence that the DfE has read carefully Natspec’s many submissions to the review and understood the concerns of specialist FE colleges. (We can even recognise some of our own words in parts of the commentary). Perhaps by raising concerns about their application in the FE sector, we may have played a small part in ensuring some of the more controversial proposals in the Green Paper, such as tailored lists and mandatory mediation, are trialled before final decisions about implementation are made. But we haven’t seen these off by any means.
Our disappointment is rooted in the missed opportunity to set out a vision for 16-25 SEND provision that addresses the key challenges in meeting the needs of young people with SEND effectively. What the Improvement Plan offers is an assortment of initiatives already announced – investment in supported internships, the Access to Work passport, qualification reform – alongside an acknowledgement of the need for reform without any new commitments, for example, on re-working the dysfunctional FE funding system or providing dedicated funding for FE students with lower-level needs. All we get here is a promise to keep working with the sector to find solutions. The main offer to FE is new transition standards. These may be helpful, but they will need to drive change well beyond interactions between schools and colleges, if young people are to be spared the anxiety caused by late decision-making and missed statutory deadlines.
We were hoping for clear recognition that that the circumstances of FE are very different from the school sector. While only 50% of children with EHCPs are in mainstream schools, 90% of FE EHCP-holders are in general FE colleges. The issue in FE is how to keep it that way; there are already early signs of a slow but steady increase in demand for specialist college placements. We need an equivalent commitment of funding to support SEND learners in mainstream general FE colleges as that going to mainstream schools. We also need similar levels of support for specialist colleges as that shown for maintained special schools. While £2.6bn has been poured into funding new special school places and a new tranche of special free schools will be opening, specialist colleges are in desperate need of capital funding – just to maintain the fabric of their buildings in many cases. Surely the children who benefit from these brand new, purpose-built special schools also deserve high quality facilities when they move on to college. Government could have required local authorities to commit a proportionate amount of funding to those aged 16-25 or at least been explicit in stating that the funding should be used to secure quality provision in local specialist colleges as well as special schools.
Omissions from the Improvement Plan, such as this one, leave us uncertain as to the government’s understanding of and commitment to specialist further education. They tell us that they have heard from Natspec and its members that specialist colleges are often regarded by local authorities as external rather than integral to the FE system. They propose to work with us to review the way the Department for Education defines and manages specialist further education, and to consider what changes could be made to reinforce that integrated position within the wider further education sector. It’s just a pity they didn’t set that in motion within the Improvement Plan itself.
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