Putting children at the heart of SEND reform Whole School SEND response to the 2026 consultation

About this response

Whole School SEND (WSS) works with schools and local areas across England to build inclusive practice from the ground up. Delivered by a national team and a network of Regional SEND Leads and Deputies, WSS brings together experience from school and trust leadership, SENCO practice, special school leadership, and local authority roles. This response is submitted on behalf of the WSS national and regional teams. Our evidence draws on two structured discussions held in March and May 2026, bringing together the extensive conversations our regional teams have with schools across the country.

We welcome the direction of these reforms and share the ambition for a more inclusive, well-supported education system. Our response reflects cautious optimism: the direction is right, but we have serious concerns about readiness, implementation timescales, and the risk that new language replaces old without meaningful change to practice or culture.

We have responded to all questions where our evidence provides a substantive contribution. Where we have not responded, it is because we do not have sufficient direct evidence from our regional network to do so credibly.

Section 1: National Training and Inclusion Standards

Q12. What are the most important issues for national training to cover, to help support children and young people with SEND?

A consistent message from our regional teams is that a significant amount of SEND CPD already exists. The question is not whether training is available but whether it reaches the right people, addresses genuine gaps, and builds on existing provision rather than duplicating it. National training needs to start from an honest audit of what schools are already doing.

The issues we consider most important for national training to address are:

• The graduated approach and assess-plan-do-review process. This is the area where the most significant gap exists. What a genuinely good, needs-led graduated response looks like in practice, not just the process, but what it means for classroom teachers day to day, is largely absent from current training provision. Schools can be told to assess, plan, do, and review without knowing what that looks like when it is done well, including at manageable scale.
• Pedagogy before policy. There is a tendency for training to focus on policy and process at the expense of how children learn. Training must build understanding of child development, learning theory, and pedagogy as the foundation for effective SEND practice, not just tell schools what to do without explaining why.
• High quality teaching as the universal foundation. Understanding and consistently delivering high quality, adaptive teaching remains the single most important lever for children with SEND. Many unnecessary interventions occur because universal teaching is not strong enough. Training should address this honestly.
• A clear ITT-to-executive-leader pathway. SEND training must be embedded across the professional development continuum, from initial teacher training through to NPQ and executive leadership. Currently many leaders have minimal SEND training. SEND should not be treated as the SENCO’s responsibility alone; the goal should be that in ten years’ time every leader holds responsibility for all children.
• Assessment in its many forms. Assessment is consistently raised as an area of need: assessment of need, assessment of progress, assessment of engagement, and tracking small steps of progress for children whose development does not map to conventional academic measures. This complexity is compounded by the loss of P levels, which removed a shared professional language, particularly for learners with more complex needs. Training must help practitioners navigate this complexity, and crucially, must support the development of a common vocabulary across settings.  When specialist settings are asked to support mainstream colleagues, both parties need a shared framework for describing where a child is working and what progress looks like.  Without it, collaboration is harder and continuity of support for the child is at risk.
• Legal and ethical accountability frameworks. Schools’ understanding of their responsibilities under the Equality Act and SEND Code of Practice is variable. The updated Code of Practice is a significant opportunity. We would strongly support a format similar to Keeping Children Safe in Education (KCSIE) - a mandatory, annually revisited document with a clearly directive first section outlining what all staff and leaders must know and do. This gives it appropriate status and guarantees a baseline of engagement across all settings.
• Minimum standards with contextual flexibility. Training needs a defined minimum entitlement that ensures consistency without being prescriptive. Schools should have flexibility to go further based on self-evaluation, but a baseline must exist. A model that uplifts those below par while not stalling those further along the journey is what is needed.
• A leadership-specific strand. There should be a separate strand for school leaders focused on building and sustaining an inclusive culture. Some leaders do not know what this means in practice, and without leadership understanding, classroom-level training will not achieve lasting change.

We caution strongly against national training that operates primarily through one-off CPD days. Evidence from our work consistently shows that coaching, modelling, and sustained professional enquiry, working alongside practitioners over time, has greater and more lasting impact.

Q11. What should the top three priority areas be for building and sharing evidence within the National Inclusion Standards?

The National Inclusion Standards represent a real opportunity to move the sector forward. Our concern is that they become a tick-list: a minimum standard that, once checked off, is treated as sufficient. The child must remain at the centre, not the checklist. Our three priority areas are:

• High quality teaching as the universal foundation. This must come first. Standards should clearly articulate what every child should be able to expect from high quality teaching and what that looks like in practice. Whole School SEND’s Teacher Handbook and online SEND CPD units, which between them have reached over 80,000 teachers, demonstrate that accessible, evidence-based practitioner guidance gets used when it is well-designed and available at the point of need. Practitioners do not always have the luxury of planned CPD time; guidance that can be accessed in the moment, in response to a specific situation, makes a difference.  This is a model worth building on.  
• Early identification and accurate assessment. Evidence of effective early identification alongside robust assessment practice should be a core priority. This includes qualitative data such as pupil voice and lived experience, not only quantitative measures. Case studies from local authorities that have reduced EHCP numbers through strong early intervention are particularly valuable here.
• Meaningful participation and lived experience. Evidence must include children and young people’s voices and the perspectives of families. This means building structures for genuine co-production into how inclusion is planned, measured, and improved. Outcomes for young people post-19, including employment, independent living, and wellbeing, are rarely captured.  Evidence-building through the Standards could begin to address this gap. There are settings already showing what this looks like in practice.  Case studies of settings that have adopted a systematic approach to Preparation for Adulthood, with young people and families meaningfully involved throughout the process shows that this is achievable.  The Standards should draw on and amplify these examples, making visible what effective co-production looks like so that other schools have a concrete model to build from.

We also recommend a differentiated strand within the Standards for leaders, not just classroom teachers. Understanding how to build and sustain an inclusive school culture requires specific knowledge and skills that go beyond classroom practice, covering whole school policies, systems and leadership approaches that make inclusion a lived reality.  

Q13. What practical actions can help teachers, educators and leaders manage workload whilst implementing these changes?

Workload is one of the most significant risks to successful implementation, and our regional teams hear about it consistently. The changes being proposed are substantial, and they are arriving in a sector that is already stretched. Practical actions that would genuinely help include:

• Coaching and mentoring rather than training days. One-off training events add workload without building sustainable capacity. Investment should prioritise coaching alongside practitioners, modelling in classrooms, and supported professional enquiry. This approach builds skills and confidence more effectively and does not require staff to process information in their own time.
• Streamlined, purposeful documentation. Any ISP or graduated approach documentation must be designed to reduce rather than increase teacher cognitive load. This means clear, concise templates that are genuinely useful to classroom practitioners, not bureaucratic compliance tools. Schools and trusts that have developed tiered, proportionate approaches to individual planning should be able to share these as models. A one-size-fits-all document for every child on the SEND register is not the answer.
• Phased and sequenced implementation. Introducing multiple changes simultaneously creates impossible workload pressures. Implementation should be carefully sequenced, with adequate time between phases and clear communication about what is required and when. The 10-year programme gives an opportunity to do this properly. It should be used.
• SENCO supervision and professional support. SENCOs carry enormous workload and responsibility, often in isolation. Structured supervision and peer support, as some trusts are already beginning to invest in through Inclusive Mainstream funding, should be formally embedded as part of the reformed system.
• Reducing unnecessary bureaucracy. Schools are already managing increased volumes of FOI requests, SARs, and complaints. Any new system must be designed to reduce, not increase, this administrative burden. If day-to-day provision accountability shifts fully to schools, the volume of complaints and formal processes will increase significantly without robust systemic support.

Q14. How should the Special Educational Needs Coordinator (SENCO) role evolve to better meet the needs of children and young people with SEND?

The SENCO role has grown unwieldy. It has become, as our discussions described, an odd mix of highly bureaucratic and deeply strategic demands that sits uncomfortably in many schools. We welcome the work being done with sector partners to examine the role, and our regional network has clear views on the direction it should take.

• The SENCO should be a strategic leader, not a caseworker. The current system has pushed SENCOs towards individual casework, paperwork management, and compliance. The reformed role should position the SENCO as a strategic leader of inclusive practice across the whole school; building teacher capacity, leading the graduated approach, and sharing the school’s ambition for all children. Day-to-day administration should be supported by appropriate resource.
• SEND cannot remain the SENCO’s sole responsibility. The reforms offer a real opportunity to demystify SEND and build genuine shared responsibility across all leaders and teachers. The ambition that SEND becomes a shared responsibility across the whole workforce, rather than sitting with a designated specialist, reflects the right direction of travel. The SENCO’s role should evolve into one that leads and develops others, rather than carrying the system alone.
• Workload must be addressed structurally. The proposed shift of accountability for Specialist Provision Packages and ISPs to schools and trusts will add substantially to the SENCO’s burden without corresponding resource. The risk that an inexperienced or under-supported SENCO is expected to develop provision packages, manage ISPs at scale, and handle complaints is serious. The role must come with adequate time, status, and support.
• Qualifications and professional standards must keep pace. As the role becomes more complex and strategically important, the qualification framework must reflect this. SENCOs need a clear professional development framework that maps how knowledge and expertise deepens over time, grounded in the understanding that the SENCO role is a leadership role. One area requiring urgent attention is the shift in responsibility for complaints.  As the reforms shift more responsibility for early dispute resolution into schools, SENCOs will need to understand and manage the complaints process in ways that were not previously expected of them.  
• Specialist support must be available to SENCOs. SENCOs should not be expected to be experts in every area of need. Ready access to specialists -educational psychologists, SALTs, OTs, and others, as colleagues and advisors rather than as services to be purchased or waited for is essential to the role functioning as intended.

Q15. What would provide assurance for families that an Individual Support Plan (ISP) is high-quality and contains the essential information?

Families’ trust in the reformed system will depend significantly on whether they have confidence in ISPs. Our regional teams and practitioners raise several important points about what would genuinely provide assurance:

• Clear national expectations about what a high-quality ISP contains. Without a clear framework, not a rigid template, but a set of expected features, ISP quality will vary enormously between settings. Families need to know what to look for and what they are entitled to expect. Guidance should be direct and accessible, not written for specialists alone.
• Meaningful involvement in developing the ISP. Families must be genuine partners in developing their child’s ISP, not recipients of a completed document. This requires time, accessible language, and a culture of co-production rather than compliance. Currently, many families have low trust in the system; rebuilding that trust requires processes that feel collaborative rather than administrative.
• Regular review and honest updating. A significant weakness of the current system is that EHCPs are often not updated frequently enough and outcomes become stale. ISPs must be reviewed regularly and updated honestly, including when provision has not been delivered or has not worked. This requires sufficient time and resource to be explicitly built in.  Without it, reviews become a tick-box exercise no matter how well the framework is designed.  Families will have more confidence in a system that is honest about challenges than one that presents a glossy picture that does not reflect their child’s experience.
• Independent recourse where quality is poor. With accountability for provision shifting to schools, families need accessible, genuinely independent mechanisms to raise concerns. The risk of schools ‘marking their own homework’ on ISP quality is significant. Whatever replaces tribunal processes for the ISP tier must be genuinely impartial and accessible to families without specialist knowledge.
• EHCP protections must not be eroded for those who need them. Many families fought hard through appeals to secure an EHCP. The assurance that comes from statutory protection, independent oversight, and legally binding provision cannot be replicated by an ISP. Families of children who retain EHCPs must see those protections maintained in full.

Q16. How can we ensure Individual Support Plans are clear, concise and practical for professionals to use?

The goal of a clear, concise, and practical ISP is one we strongly support but we are concerned that the proposals as described risk creating the opposite: unwieldy, time-consuming documents that add to teacher cognitive load rather than reducing it. Evidence from practitioners who have developed effective systems offers useful principles:

• Clear guidance is needed on which children require an ISP and under what legal duty.  The proposals must address a long-standing confusion in the sector between the Equality Act duty to make reasonable adjustments for disabled pupils and the Children and Families Act duty to provide special educational provision for pupils with SEN.  These are distinct legal frameworks with different thresholds and different implications for the register.  A child whose needs are met through reasonable adjustments alone does not necessarily have SEN.  ISP guidance that fails to clarify this distinction will drive register inflation and generate paperwork for children who need adjustments, not individual plans.  For this to work, the sector need to understand and implement reasonable adjustments consistently.
• Tiered, streamlined approaches work better than one-size-fits-all. Schools and trusts that have developed effective systems tend to use a tiered model where the level of documentation is proportionate to the complexity of need, aligned with the APDR (assess, plan, do review) process, and embedded in the school’s broader teaching and learning strategy. These approaches create less but more meaningful paperwork for SENCOs, and less cognitive load for classroom teachers.
• The document must be genuinely useful to classroom teachers. An ISP that a teacher cannot read, understand, and act on in the context of a busy classroom day has no value. Documents should be concise, jargon-free, and focused on what a teacher needs to know and do, not a comprehensive record of every assessment and intervention.
• Digital systems must enable rather than constrain. The proposal for digital ISPs has potential if it means accessible, easily updated documents that follow children through transitions. But digital does not automatically mean simple or useful. Common standards for digital ISPs should focus on what information needs to transfer and how, not just on creating a prescriptive national template.
• Exemplification is essential. Any guidance on ISPs must include worked examples across different phases and settings. Without exemplification, schools will fill the format in whatever way feels familiar, and quality will remain variable.

Section 2: Funding and Accountability

Q30. How should settings be held accountable for how they spend their Inclusive Mainstream funding?

This question requires clarity about what Inclusive Mainstream funding is for. There is a real risk that schools see it as a substitute for EHCP-linked funding, or that it is directed at Targeted and Targeted Plus provision rather than systemic strengthening of the universal offer. The accountability framework must prevent this.

• Accountability must be outcomes-led, not financial. Inclusion strategies must not become an accounting tool. We have seen this happen with Pupil Premium strategies, which in many settings became compliance documents rather than genuine tools for school improvement. Accountability for Inclusive Mainstream funding should focus on what changes for children, not on what money was spent on.
• Funding should strengthen universal provision systemically. This is not a large pot of money, but it can make a difference if used to build coaching infrastructure and mainstream-specialist collaboration - things that strengthen the whole school’s approach rather than funding individual interventions.
• Schools need to genuinely understand their cohort. Effective spending requires schools to understand their pupils’ needs, their own challenges and strengths, and their local context. The EEF implementation framework offers a useful model for how schools should be expected to identify problems, plan evidence-based responses, and evaluate impact.
• Mindset change is needed around EHCPs and funding. There is still a tendency to see the EHCP as the mechanism for securing funding rather than as a tool for meeting need. Accountability frameworks must actively work against this.
• Avoid perverse incentives. Accountability systems must be carefully designed to avoid schools gaming them. Inclusion strategies must not become the SEND information report of the new system - a formulaic compliance exercise that says little about what actually happens for children.

Q31. Do you agree that more SEND funding should sit directly within mainstream budgets? Please explain why.

We broadly agree with the principle that funding should be closer to children and to the schools that work with them every day. However, we have significant concerns about the conditions that must be in place for this to work safely and equitably.

• In principle, yes - with important caveats. Funding that sits within mainstream budgets can enable faster, more responsive decision-making, reduce bureaucracy, and embed inclusion as a whole-school responsibility rather than an add-on. Schools that already think inclusively will use this well.
• The risk is greatest for the most vulnerable children. For children with the most complex needs, statutory ring-fencing provided by the EHCP system offers protection that a school’s general budget cannot replicate. Moving provision accountability to schools without guaranteed resource means that when budgets are under pressure, it is the most vulnerable children whose provision is most at risk. Statutory protection for those who need it must be maintained in full.
• The system must not ‘mark its own homework’. If schools hold both the funding and the accountability for delivering provision, without independent oversight, the risk of under-provision going unchallenged increases significantly. Transparent reporting, accessible complaints processes, and genuine independent scrutiny are essential conditions for this model to work.
• Sustainable, longer-term funding commitments are needed. Year-on-year funding creates nervousness and prevents schools and specialist providers from making the sustainable investments in staffing, training, and partnerships, that improve outcomes over time. Longer-term funding commitments would enable the kind of systemic change the reforms seek.

Q32. Do you agree that every school should become part of a local SEND group?

We broadly support the principle of every school being part of a local SEND group, and see it as consistent with the collaborative, community-based approach to inclusion that our regional teams promote. However, we have reservations about how it works in practice:

• Collaboration only works if it is genuine. Mandating membership does not guarantee meaningful collaboration. Groups must be built on real shared purpose and mutual accountability, not compliance. Where strong local collaboration already exists through cluster models, trust partnerships, and local alliances, the reforms should build on and formalise these, not replace them with a new structure.
• Governance and decision-making must be clear. There are legitimate questions about how disagreements are handled, how funding is governed equitably, and what happens when the interests of individual schools or trusts conflict with the group’s collective responsibilities. These need to be resolved before the model is implemented.
• MATs present specific challenges. Some large multi-academy trusts are already pooling resources for SEND, for speech and language therapy, for example, but concerns remain about equitable distribution and governance. The relationship between MAT-level arrangements and local SEND group responsibilities needs to be clearly defined.

Q34. How can we ensure the most effective use of local partnership groups?

Our regional teams have direct experience of what makes local partnerships work and what causes them to fail. The most effective groups share several characteristics:

• A genuine theory of change. Effective partnerships start from a shared understanding of what they are trying to achieve and how. Groups that convene without a clear theory of change tend to become forums for information-sharing rather than vehicles for improvement. The reforms should require local partnership groups to articulate and test their theory of change, not just produce a plan.
• Psychological safety to name challenges honestly. Local SEND strategic plans will only be useful if they are honest about what is not working as well as what is. This requires a culture of trust where partners can name challenges without fear of blame or penalty. Building that culture takes time and active leadership.
• The right people in the room. Effective partnerships include education, health, and social care, but also families, parent carer forums, and voices from the specialist sector. Crucially, education voices need to be present in commissioning spaces, including ICBs, where funding decisions are made. The postcode lottery in specialist services is partly a commissioning problem.
• Build on what already works. There are well-functioning examples across the country, eg. cluster models, Leeds Inclusion Alliance, Haringey Education Partnership, and others. The reforms should identify, learn from, and formalise these rather than starting from scratch. The momentum that the consultation is already generating, bringing parties into the room who have not previously worked together, should be harnessed.
• Avoid tokenism. Parent carer representation must be genuine participation, not a tick-box. Plans that claim collaboration but are written by the local authority alone and presented to others for sign-off will not drive improvement.

Q35. Which stakeholders are important for the success of local partnership groups, and why?

Based on our regional teams’ experience, the following stakeholders are essential and each brings something that others cannot substitute:

• Schools and trusts - all phases. The day-to-day reality of inclusion lives in schools. Both mainstream and specialist perspectives are essential, and the voice of school leaders who walk the talk of inclusion, not just those who talk strategically about it, must be heard.
• Integrated Care Boards (ICBs). ICBs hold significant commissioning power for the therapeutic and clinical services that are essential to effective SEND support. Without ICBs as active partners, the Experts at Hand offer and specialist provision will remain underpowered. Education voices must be strong in ICB commissioning spaces.
• Parent carer forums. Families bring the lived experience that no professional group can replicate. Parent carer forums that are genuinely resourced and empowered, not just invited to meetings, strengthen planning, reduce adversarial dynamics, and build trust. Evidence from the West Midlands shows that parent carer forums are broadly supportive of reform when they receive genuine reassurance about quality and staffing.
• The specialist sector. Special schools and specialist settings bring expertise in meeting complex needs that mainstream cannot develop alone. They should be positioned as genuine partners and contributors to the local system, not just providers of outreach or recipients of funding conditions.
• Local authorities - as conveners, not owners. Local authorities have a vital convening and co-ordinating role, particularly in sufficiency planning and managing the transition to the new system. But plans that are seen as LA-owned rather than genuinely collaborative will not command the buy-in needed for implementation.
• Post-16 providers. The transition to post-16 is one of the most significant gaps in current provision. Further education colleges and other post-16 providers must be full partners in local groups, not an afterthought.

Section 3: Specialist Placements, Provision Packages, EHCPs and ISPs

Q21. What needs to be in place so that children and young people with low incidence, highly complex needs can always access the right specialist placement?

This is, in many ways, the linchpin question. Getting it right requires the whole system to be working effectively. Our regional teams identify the following as essential:

• Genuine multi-agency ownership. True collaborative working between education, health, and social care is essential. Currently, complexity is too often pushed back to schools, with health and social care professionals directing families towards EHCPs as if that is sufficient. If a health professional identifies a need, they must own part of the response. ICBs, not just local authorities, are key players in commissioning the services that enable the right placements; education voices must be strong in those commissioning spaces.
• A properly resourced specialist sector. Special schools need support to expand their offer, reduce long-distance placements, and be genuinely multi-disciplinary. Currently many lack adequate speech and language therapy, on-site nursing support, educational psychology, therapeutic packages, and, for children with life-limiting conditions, end-of-life support. The reforms talk about special schools being valued but do not yet make that concrete in terms of investment.
• Context-aware, strategic sufficiency planning. Local areas need a strong multi-disciplinary team (MDT) approach to sufficiency planning that starts from genuine knowledge of local children, families, and community. Too many children are held in placements that are not right for them because there are no better alternatives nearby. At the same time, there are children in special schools whose needs could be met in well-supported mainstream settings. Sufficiency planning must address both directions.
• Quality assurance for specialist outreach. When specialist schools go into mainstream settings, there is currently no robust quality assurance. Leaders in our regional network report direct experience of specialist outreach that has a negative impact on mainstream schools, where specialist practitioners lacked sufficient understanding of the mainstream context. Any outreach model, including Experts at Hand, must include quality standards and accountability for the support provided.
• Fluidity between settings. Children’s needs change over time. The system needs to support movement between mainstream and specialist provision in both directions, including building parental confidence in that fluidity, rather than treating placement as a fixed destination.
• Training for commissioning staff. Those responsible for commissioning services and placing children need time and genuine understanding of local needs and what different provisions offer. The postcode lottery in specialist access is partly a problem of how local health services are planned and funded, and who has a voice in those decisions.

Q22. How can Specialist Provision Packages be designed to effectively support the main types of need we currently recognise?

We welcome the development of Specialist Provision Packages as a means of creating greater consistency and transparency, but have significant concerns about design and implementation. Key considerations include:

• Local voice and planning must be central. Packages cannot be purely nationally prescribed. Area-level planning must drive how packages are developed and commissioned, led by people with genuine, close-to-practice knowledge of SEND, not solely by those with strategic or commissioning roles.
• Focus on outcomes, not process standardisation. The concern raised strongly in our discussions is that standardisation of specialist provision tends to focus on process rather than outcomes, and risks limiting the innovation that genuinely complex needs require. Packages should set high expectations for what children should achieve and experience, while leaving flexibility for practitioners to be responsive.  It is important that Specialist Provision Packages are not framed – explicitly or implicitly – as being only for rare or ‘low incidence’ conditions.  Many children with complex autism, for example, will require this level of specialist support and the framework must be broad enough to reflect that reality.  Each child with complex needs is an individual and the package framework must be designed with that at its centre.
• SENCOs must not be left to build packages alone. There is a serious risk that developing and implementing provision packages falls to individual SENCOs without adequate support. A potentially inexperienced SENCO, working in isolation, could not and should not be expected to do this. Packages must be built through well-funded local collaboration with clear stakeholder roles.
• Investment in research and evidence. Specialist provision changes as knowledge of conditions and needs evolves. There should be funding within specialist packages to enable schools to engage with research and work with universities, so practitioners are supported to keep pace with emerging understanding.
• Exemplification, not just frameworks. Guidance must include clear worked examples of how packages are intended to be used by local authorities, by teachers, and by SENCOs across different phases and settings.

Q23. What is needed to make the proposals for EHCPs, Specialist Provision Packages and Individual Support Plans work effectively?

This is one of the areas of greatest concern across our regional network. Our response is honest about the scale of the challenge.

On Individual Support Plans:

• Scale is the fundamental challenge. In a large secondary school, an ISP requirement could mean 200 or more individual documents. Even with a capable, experienced SENCO, the extraneous cognitive load placed on classroom practitioners who need to understand and act on all of these is enormous. There is currently nothing in the proposals that credibly addresses this.
• If needs can be met fully through reasonable adjustments within the universal offer an ISP should not be needed. In practice, this distinction is widely misunderstood.  Many schools place children on a SEND register when reasonable adjustments alone are sufficient.  Others fail to make the reasonable adjustments they are legally required to make regardless of SEN status.  ISP proposals risk deepening this confusion by appearing to create a documentation requirement that applies across both frameworks without clarifying which legal duty it serves.  Clear guidance must address this directly, setting out explicitly when an ISP is required, for which children and under what legal basis.  Without this, schools will default to applying ISPs to every child with any identified need – inflating registers, generating paperwork that serves compliance rather than the child’s needs and obscuring the very distinction that the current SEND Code of Practice sought to establish.
• The EHCP has value beyond the funding attached to it. For children with the most complex needs, the EHCP provides structure, expertise, security, and statutory protection that no ISP can replicate. The further a child is from the mainstream offer, the more fragile their educational position without statutory protection. EHCPs arguably matter more for children with complex needs in mainstream than they do in special schools, where specialist provision is the core function.
• Parental complaints and accountability risk. If day-to-day provision is captured in ISPs held by schools and those plans are not met, parental complaints will increase significantly. Schools are already managing increased volumes of complaints, partly driven by AI-generated correspondence. The accountability risk of schools assessing the adequacy of their own provision, without independent oversight, must be addressed.
• Digital ISPs are not a substitute for transition planning. A digital ISP system may support continuity of information but it does not do transition for children. Serious thought is needed about what good transition looks like when a child moves between schools, phases, or local authorities.

On the broader accountability shift: the proposed transfer of legal accountability for provision from local authorities to schools and trusts creates significant anxiety, not least for trustees. If schools carry statutory accountability for delivering provision, they must also have guaranteed access to specialist support and funding sufficient to deliver it.

Q17. How can we best support transition for young people with SEND, so that they are well supported into post-16 provision and further education, training or employment?

Transition is one of the most significant gaps in the current system and our discussions surfaced strong views on what would make a genuine difference.

• A plan does not do transition for a child. Even a high-quality digital ISP with full historical information does not ensure a successful transition. What matters is the relational continuity; knowing who has worked with a child, what has worked, and ensuring the receiving setting has the skills, resources, time and desire to build on that. Guidance on transition processes must be concrete and practical, not limited to information transfer.
• Transition between phases needs the same attention as transition to post-16. Primary to secondary transition for children with SEND is a significant point of risk. Cross-phase collaboration (primary and secondary schools genuinely working together on curriculum, provision, and relationships) is where practice is strongest. The reforms should formalise and resource this, learning from the specialist sector where curriculum adaptation across phases is well developed.
• Post-16 aspirations and pathways are underdeveloped. The current system does not know enough about what children with SEND aspire to post-16, or whether post-16 provision is delivering what young people actually need. There is a risk that general FE is described as inclusive without asking whether it is delivering meaningful outcomes. The reforms need a dedicated focus on post-16 pathways, ambition, and what independent living, employment, and adult life look like for the young people we are educating.
• Curriculum breadth matters. Children who may not achieve GCSEs need curriculum pathways and qualifications that are valued and visible. The current focus on GCSE attainment as the primary measure of success creates pressure on schools to narrow provision. DfE should actively promote and celebrate alternative pathways and outcomes, not leave this to individual schools to defend.
• Accountability frameworks must recognise diverse outcomes. School leaders are nervous about being truly inclusive because they fear what it does to their accountability position. Published case studies of schools where inclusion is working well, including the alternative pathways and outcomes for children, would give leaders permission and confidence.

Q18. How can we make sure that every area can meet the full range of the needs of children and young people through Inclusion Bases?

Inclusion Bases are one of the most contentious elements of the reforms, and our regional teams have concerns that must be addressed if they are to be effective:

• The terminology is actively unhelpful. The term ‘inclusion base’ is strongly disliked across the sector because of its association with internal exclusion spaces. Without clear guidance and robust quality standards, there is a real risk that schools simply rename existing withdrawal or isolation spaces as inclusion bases without changing their function. This must be addressed directly and early.
• A clear framework for what an inclusion base is, and is not, is urgent. There has been a significant proliferation of resource bases and inclusion spaces across schools, largely without any framework for what they should deliver. The DfE has acknowledged this. Guidance must make clear the two distinct purposes; specialist provision within the specialist layer, and school-led provision within a school and what each requires in terms of staffing, environment, curriculum, and integration.
• Staffing quality is the primary concern for parents and schools alike. Parent carer forums are broadly supportive of inclusion bases in principle, but consistently ask for reassurance about the quality and training of staff. An inclusion base staffed primarily by supply staff or staff without specialist training is not fit for purpose. Staffing standards must be part of the framework.
• Inclusion bases must not become segregation bases. The risk of children spending the majority of their school day in a base, effectively separated from the mainstream school, is real. The framework must set clear expectations about integration - how children use the base alongside full participation in mainstream life - and these expectations must be monitored.
• Sufficiency planning cannot be left to individual schools. Local areas need a strategic approach to inclusion base planning that considers the range of need across the area, avoids duplication, ensures geographic coverage, and plans for quality. Last-minute requests, in July for a September start, are not strategic planning. This requires local partnership groups to play a genuine commissioning and quality assurance role.

Q19. How can we make sure that Inclusion Bases help children and young people succeed in mainstream settings?

This question gets at what inclusion bases are ultimately for. An inclusion base that does not help children succeed in the broader mainstream school is failing its purpose. The conditions for success are:

• Integration must be the goal, not the exception. Every child who uses an inclusion base should have a clear and reviewed plan for how they participate in mainstream school life. The base is a resource, not a placement. Where children are spending the majority of their time in a base with minimal integration, this should be treated as a concern, not an acceptable outcome.
• Staff in inclusion bases need both specialist and mainstream knowledge. Our discussions make it clear that specialist outreach is only effective when practitioners understand the mainstream context they are working in – good intentions and specialist expertise alone are not sufficient. Staff in inclusion bases need to understand what a mainstream classroom looks and feels like, what teachers can realistically do, and how to support a child to access and succeed in that environment. Cross-sector professional development, including time spent in both mainstream and specialist settings, should be a formal expectation.
• Curriculum must be considered carefully. Children in inclusion bases who are not following standard curriculum pathways need clear, ambitious, personalised approaches to curriculum and assessment. The specialist sector has developed strong practice here.  The reforms should facilitate the transfer of that knowledge into inclusion base settings rather than leaving each school to start from scratch.
• Fluidity in both directions. Building confidence in a base should be a step towards broader mainstream participation, not a permanent arrangement. Schools and families need support to plan for and manage that transition, including when it is appropriate to move to a more specialist setting if mainstream with support is not meeting a child’s needs.

Q20. What arrangements are needed between local area partners to deliver the Experts at Hand offer effectively?

Experts at Hand has the potential to be one of the most significant and impactful elements of the reforms. The investment is substantial, nationally £1.8 billion over three years. But getting the model right matters enormously, and our discussions identified clear risks as well as opportunities.

• Coaching and co-working, not training delivery. The evidence is clear that one-off training has limited impact on classroom practice. Experts at Hand must operate on a coaching model - specialists working alongside teachers and school leaders over time, building capacity and changing how practitioners think, not just adding to what they know. This is harder and more resource-intensive than delivering training, but it is what drives lasting change.
• The definition of ‘specialist’ must be broadened. The current implementation plans risk a significant missed opportunity by limiting Expert at Hand role to specialist sector professionals, overlooking the deep and contextually relevant expertise that exists within the mainstream sector itself.  Experienced SENCOs, Inclusion Base teachers and other practitioners in mainstream settings often have a profound understanding of how to meet complex needs within the environments where most children are actually taught.  This expertise is currently under-utilised and where it is shared it tends to happen informally or at a cost to individual schools.  A more effective model would create formal, funded pathways for mainstream specialists to provide outreach and coaching to colleagues across schools and settings. Experts who understand the pressures, structures and constraints of mainstream classrooms are often better placed to drive lasting change within them than specialists whose primary experience is in separate provision.  The reforms should harness this, not overlook it.
• Local authorities as conveners, not gatekeepers. Local authorities should play a convening role - mapping what exists, identifying gaps, and bringing partners together. But the Experts at Hand offer must be genuinely responsive to schools’ needs, not filtered through LA priorities or constrained by existing commissioned services that schools have found ineffective. We have seen local authorities simply compile lists of what schools could offer without any quality planning. This cannot be what the model becomes.
• Quality assurance is essential and currently absent. There is currently no robust mechanism for ensuring that specialist outreach support adds value. We have heard evidence of outreach that has set schools back rather than moving them forward. The Experts at Hand guidance must include clear standards for what good looks like, how impact is evaluated, and what happens when support is not effective.
• Sustainable funding commitments are essential. Specialist sector organisations need longer-term funding guarantees to free up their best staff for outreach work. Year-on-year funding creates nervousness and prevents the sustainable investment in outreach capacity that the model requires. Short-term project funding has a poor track record of creating lasting change.
• A granular understanding of what exists is needed first. There is currently no comprehensive national picture of what specialist services are available where, and where the gaps are. The first year of Experts at Hand should be used to build that understanding as a foundation for strategic commissioning, not to rush delivery before the evidence base exists.
• Funding should develop local specialist offer within settings. We would support an approach where a significant proportion of Experts at Hand funding is directed towards developing the local specialist offer within settings themselves, rather than funding external support alone.  Building capacity that stays in the system is more sustainable and more likely to drive lasting change.

Q25. What would you expect to be considered as part of the needs assessment, for example evidence and expert or professional input?

A needs assessment that genuinely informs provision must draw on a wide range of evidence and involve the right people at the right stages. Our key points:

• Multi-professional evidence, not just educational assessment. Needs assessments must draw on evidence from education, health, and where relevant social care. The current frustration that health professionals direct families to seek EHCPs without contributing substantive evidence to the assessment process must be addressed. If a health professional is named, they should be required to contribute.
• The child’s voice, not just observations about the child. Children and young people must be active participants in the needs assessment process in ways that are appropriate to their age and communication needs. This is not a nice-to-have; it is a legal requirement and a practical necessity for a plan to be effective.
• Educational Psychology input should be a standard expectation. Access to educational psychology is variable, with some local authorities charging schools for EP time that should be a statutory entitlement. EP input in needs assessment provides an important independent and specialist lens that school-based evidence alone cannot replicate.
• Evidence of what has already been tried and its impact. A needs assessment should include a clear record of what provision has been put in place under the graduated approach, what the evidence of impact is, and why that provision is insufficient. This ensures that the assessment process builds on rather than replaces what has already been learned about a child.

Section 4: Layers of Support (Universal, Targeted, Targeted Plus, Specialist)

Q3. How can we ensure that children are best supported by the Universal offer?

A strong universal offer is the foundation on which everything else rests. Our key points:

• Expertise and knowledge exist - what is missing is a plan for embedding it. The knowledge needed to improve the universal offer largely exists. What is missing is a clear implementation plan for how it becomes embedded practice across the system. Pockets of excellent practice exist alongside schools where the universal offer is poor, and the gap between them is too wide.
• A minimum standard for high quality adaptive teaching must be defined. Interpretations of what a strong universal offer looks like vary enormously. Some schools interpret inclusivity as lower standards for pupils with SEND rather than as maintaining high standards and enabling children to reach them through appropriate support. A clear, non-negotiable minimum standard is needed.  Impact depends on that standard being understood and applied consistently across all stakeholders.  Critically, this includes Ofsted. Where inspection frameworks and school practice are not aligned around the same expectations, schools face conflicting pressures that undermine the very consistency the universal offer requires.  Expectations must be defined, shared and agreed across the system – not handed to schools in isolation.
• Language and shared understanding matter. New terminology must be accompanied by shared understanding of what it means in practice. The word ‘universal’ is used differently across schools, trusts, and local areas. Without shared meaning, the universal offer will remain inconsistent regardless of what guidance says.
• Outcomes must include lived experience, not just academic progress. What a strong universal offer delivers for children should be measured in terms of belonging, participation, and wellbeing as well as academic attainment. Families and children should feel the difference.

Q4. How can we ensure that children in the Targeted layer are best supported?

• Clear language that families can understand. The language of SEND tiers is not intuitive for families. There is real work to do to ensure that parents understand what a Targeted offer means for their child and what they can expect from it.
• Early, needs-led support with a strong graduated approach. Targeted support must be proactive and strategic, based on genuine assessment of need rather than reactive crisis response. A strong assess-plan-do-review process is the engine of effective Targeted provision.
• Ready access to specialist professionals. At the Targeted level, schools need timely access to specialists who advise on provision and work alongside teachers, not just issue reports and wait lists. This is part of what Experts at Hand should deliver.
• Clear accountability. Accountability for children at the Targeted level needs to be clearer. Schools should be able to demonstrate what provision is in place, what the evidence of impact is, and what the next steps are.

Q5. How can we ensure that children in the Targeted Plus layer are best supported?

• Targeted Plus must remain connected to the universal offer. Support at this level should explicitly aim to enable children to use skills and confidence back in the classroom and in the broader life of the school. There is a real risk that the layered model is experienced as a series of discrete silos. A continuum, not a set of separate tiers, is what children need.
• Specialist professionals must work in and with the classroom. Professionals supporting children at Targeted Plus must work alongside classroom teachers, not just run withdrawal sessions or produce reports. Changing this professional mindset is essential and will not happen without clear expectations in guidance and commissioning.
• The risk of linguistic substitution without practice change is acute. When new phrases come in, settings tend to swap the terminology without changing what they actually do. Guidance must be concrete and exemplified.
• Know the whole child. Children must be known as individuals: their strengths, their context, their aspirations, and their specific needs. Targeted Plus support must not default to standardised interventions that are convenient for adults rather than right for the child.

Q6. How can we ensure that children in the Specialist layer are best supported?

• Family partnership is foundational. Families must understand the system they are operating in and what provision at the Specialist level means for their child. Infrastructure for genuine, joined-up working between services is needed. Good pockets of practice exist but operate in isolation far too often.
• Expectations must be matched with resource. The expectations placed on schools at the Specialist level must be matched with the support, staffing, and funding needed to deliver them. Without this match, schools will default to risk-averse compliance rather than ambitious provision.
• Specialist provision must be properly quality-assured. What makes a specialist setting or resource genuinely specialist must be clearly defined, and quality must be actively monitored. Inclusion bases that are staffed by supply staff and separated from the mainstream school are not specialist provision.

Q7. How can early years settings, schools, and colleges best support the mental health and wellbeing of children and young people?

While our discussions did not focus primarily on mental health, several important points emerged that we want to contribute:

• SEND and mental health are deeply interconnected. Unmet or unrecognised SEND is a significant driver of mental health difficulties in children and young people. Investment in early identification and effective SEND support is therefore also investment in mental health. The reforms should make this connection explicit.
• Early help and pastoral systems must be aligned with SEND provision. Children and young people with SEND often have mental health needs too. KCSIE, early help frameworks, and mental health in schools provision need to be coherently aligned with SEND support rather than operating as parallel systems. Schools that are supporting a child with complex SEND should not also have to navigate separate referral pathways for related mental health support.
• The Experts at Hand model offers an opportunity. The mental health support teams (MHST) model offers a cautionary lesson: new specialist services were welcomed but often arrived offering support at a level schools were already providing, without genuine responsiveness to what schools actually needed. The Experts at Hand model must learn from this and ensure that specialist mental health support is truly additional and genuinely responsive.
• Whole-school approaches to wellbeing support inclusion. Schools that create genuine cultures of belonging, where all children are known and valued, tend to have better outcomes for both SEND and mental health. The inclusive culture these reforms seek to build is, in itself, a foundation for good mental health.

Q8. Do you agree that the refreshed ‘areas of development’ will support educators to understand and address barriers to learning and participation?

We see the intention of the refreshed areas of development as positive and share the ambition to move away from a purely diagnostic or medical model. However, we have significant concerns about sector readiness and implementation.

• The intention is right; the sector readiness is not yet there. The knowledge and conceptual readiness in the system to work with a developmental, strengths-focused framework is not yet there at scale. Strong examples exist but they are a minority. A theory of change for how the system will develop this readiness is not yet visible in the proposals.
• The language of the proposed categories reads as more medical, not less, to some practitioners. This concern was raised by experienced practitioners in our discussions. The semantics matter: if the areas of development are received as a new version of a medical categories model rather than a shift towards educational and developmental thinking, the intended change will not happen.
• Understanding of child development must be built into training and professional practice. For the areas of development to work as intended, practitioners need a genuine grounding in how children develop and learn. This is a significant training and culture change challenge that must be addressed explicitly.
• Clear, timely guidance with exemplification is urgent. Local authorities and schools are already making decisions and writing plans without the guidance they need. The 10-year timeline is welcome in principle but the sector cannot wait years for the guidance that would enable confident, consistent implementation. Early, clear communication about what the areas of development mean in practice is needed now.
• The framework must keep the child, not the category, at the centre. Whatever framework replaces the current diagnostic categories must be used as a tool for understanding an individual child’s strengths, barriers, and needs not as a new set of labels. Guidance must make this explicit and exemplify what it looks like.

Section 5: Local Collaboration and SEND Strategic Plans

Q36. How can we build stronger collaboration and a culture of improvement through local SEND strategic plans?

Strong local collaboration and a culture of improvement emerge when SEND strategic plans are shared, honest, aligned, and actively used. Plans must create psychological safety to name challenges, align partners around shared outcomes, and focus on learning and improvement rather than compliance alone.

• Plans must not be owned only by local authorities. Good examples of local collaboration already exist where plans are genuinely co-produced and used as live tools. These tend to be in areas where there is trust, shared purpose, and existing relationships. In areas where those conditions are not yet in place, plans risk becoming documents that local authorities produce and others sign off without real co-ownership.
• Clarity about roles and responsibilities is overdue. We do not yet have real clarity about how different actors within a local area - MATs, maintained schools, local authorities, ICBs, schools in groups - are expected to interact in developing and delivering local plans. This must be addressed before June 2026 deadlines create plans that are, in effect, done deals.
• Build on what works. There are well-functioning examples of local collaboration, eg. cluster models, trust partnerships, local alliances like those in Leeds and Haringey, that the reform process should identify, learn from, and build on. The reform provides momentum; the task is to use that momentum to bring parties into the room who have not historically worked together.
• Plans must be evidence-led and honest about gaps. Local SEND strategic plans must include an honest picture of what is working, what is not, and where there are gaps in provision. Low exclusion rates are not the same as inclusion. Plans that define inclusion narrowly or claim success without honest self-evaluation will not drive improvement.
• A clear theory of change is needed. The reforms describe outcomes but not always the mechanisms by which those outcomes will be achieved. For local areas to build effective strategic plans, they need a clear theory of change: what actions, at what scale, will move the system in the intended direction?

Q37. What information, advice and guidance can best support children, young people and their families to ensure greater fairness across the system?

Families cannot advocate effectively for their children if they do not understand the system. Our regional teams work with families who are confused, frightened, and have lost trust. What would genuinely help:

• Plain language communication about how the new system works. The language of the reforms - Targeted, Targeted Plus, Specialist Provision Packages, ISPs - is not accessible to most families. Clear, jargon-free explanation of what each tier means, what families can expect, and what their rights are must be produced and disseminated early and widely. This is not the same as a summary document; it requires accessible formats, community languages, and trusted messengers.
• Families need to understand what good looks like at every tier. Without this, families cannot distinguish between a school that is genuinely meeting their child’s needs at the universal or targeted level and one that is doing the minimum. The National Inclusion Standards have a role to play here if they are written in a way that is genuinely accessible to families, not just professionals.
• Parent carer forums need resourcing to play their role. Parent carer forums are a critical bridge between the system and individual families. They translate policy into reality, advocate collectively, and build community trust. They must be genuinely resourced, not just invited to meetings, if they are to fulfil this function under the reformed system.
• The narrative around inclusion must change. There is a significant challenge in wider public understanding of SEND and inclusion. Parents of children without identified needs sometimes perceive inclusive practices as damaging to their child’s education. Without addressing this wider narrative, including through DfE communications, media engagement, and school leadership, the reforms will face cultural resistance that goes beyond the SEND system itself.  A related concern is the increasing use of ‘vulnerability’ as an umbrella term that groups children with SEND alongside other cohorts.  While the intentions behind this framing may be well-meaning, there is a real risk that it dilutes the specific focus on SEND, obscuring the distinct needs, rights and statutory entitlements of children with special educational needs and disabilities within a broader and less defined category.  The narrative needed must protect the integrity and visibility of SEND as a distinct area of policy, practice and professional responsibility.

Q38. Do you agree that a SENCO should sit on the school complaint panel when the complaint relates to SEND support and provision?

Yes, we strongly agree. A SENCO should be present on a school complaint panel where the complaint relates to SEND support and provision, and we would go further in some respects.

• SEND complaints require specialist knowledge to be considered fairly. A complaint panel that does not include someone with specialist SEND knowledge cannot adequately assess whether provision met the required standard, whether the graduated approach was applied correctly, or whether a child’s needs were properly identified and addressed. Without this, panels risk making uninformed decisions that are unfair to families and do not give schools accurate feedback.
• The SENCO must be genuinely independent within the panel. The SENCO sitting on a complaint panel about their own school’s provision requires careful thought about independence and objectivity. Where the complaint involves the SENCO’s own decisions, an external SENCO or SEND specialist should be considered. The principle that specialist knowledge must be present is more important than which specific individual provides it.
• Complaints will increase as accountability shifts to schools. As provision accountability moves from local authorities to schools, and as ISPs create explicit, documented commitments about day-to-day provision, the volume and complexity of complaints will increase. Schools and trusts need both the expertise to handle these complaints well and the structural support, including SENCO supervision, legal advice, and peer support, to manage this workload sustainably.
• This is part of a wider accountability question. The presence of a SENCO on complaint panels is a positive step, but it is not sufficient on its own to address the accountability gap created by the reforms. Accessible, genuinely independent external review remains necessary for cases that cannot be resolved internally.

Q39. Is there anything further you would like to contribute?

We want to close with a concern that runs across all sections of our response. The reforms, by their very nature, focus on changes within the SEND system - expanding the universal offer, upskilling mainstream settings, creating new structures for specialist support. All of this is necessary. But we are concerned that it is not sufficient.

The changes in education as a whole that are needed in order to truly receive greater inclusivity are not yet visible in these proposals. Behaviour guidance, attendance guidance, curriculum and assessment reforms, and accountability frameworks all need to reflect and support the inclusive intent of the SEND reforms or that intent will be undermined at a systemic level. Schools that genuinely include children with SEND need to know that doing so will be recognised and valued within the accountability system, not penalised by performance metrics that still treat GCSEs as the only measure of success.

More broadly, the schools, trusts, and local areas that already think inclusively, work relationally, and take accountability for all children seriously will probably adapt to the new system and make it work well, just as they have made the current imperfect system work. The question is what will reach the settings that have not yet understood inclusion as their own core responsibility, not a specialism to be borrowed from elsewhere, but a non-negotiable part of what it means to educate all children. New language and new documents will not do that on their own. Culture change requires investment, time, permission, and leadership from the school level up to the Department itself.

We are cautiously optimistic about the direction of these reforms. We remain committed to working alongside the DfE, regional partners, and schools to help make implementation as effective as possible. We ask that the consultation is taken seriously as an opportunity to develop and improve the proposals, particularly in the areas of ISPs, specialist provision packages, and the implementation timeline. 

You can submit your own response below. Please note the deadline is 18th May 2026.