School Accountability Reform: a nasen response
nasen is pleased to contribute to the Department’s consultation on school accountability reform.
In our response, we highlight the importance of placing genuine inclusion at the heart of accountability measures, ensuring that progress is assessed in context and that the experiences of learners with SEND are fully recognised. We support reforms that promote sustainable improvement without increasing unnecessary workload and caution against approaches that could undermine inclusive education, and we believe this consultation presents a significant opportunity to strengthen inclusive practice across the system.
Our full response can be found below, and please remember, it's not too late to submit your own response!
The number of unique responses to consultations of this nature really matters. The more often common themes are voiced, the more loudly our message will be amplified. You do not have to answer all of the questions - our response focuses on those questions we feel most passionately about, and this may help you to prioritise what matters to you, too.
The consultation closes at 11.59pm on Monday 28 April.
Effective School Accountability
The membership and community of nasen (The National Association for Special Educational Needs) would agree that all of the principles suggested are sensible, pragmatic solutions to offering an indication of how well a school is doing. Additional to this, we would stress the importance of inclusion being a key criterion for consideration. We are firmly of the believe that an inclusive offer for all will improve educational outcomes for the masses.
If a school is to support “all children and young people to achieve and thrive”, it is vital to promote accountability systems that reward genuine inclusion rather than performative compliance. This means widening criteria to include specific evidence of access, presence, and belonging—not just academic outcomes. For example, the use of contextualised data: admission figures for children with SEND, rates of exclusion and part-time timetables, and parent and pupil voice metrics that show how feedback is used to drive improvement. We believe that it is more favourable that progress should be measure from a learner’s individual starting point rather than outcomes being measured against Age Related Expectations.
School Profiles
Among the membership and community of nasen (The National Association for Special Educational Needs), there is strong consensus that incorporating data into school profiles can be valuable, especially when it reflects how well children and learners achieve rather than focusing on attainment alone. There is also a belief that such data should account for learners’ individual starting points and context to ensure fairness and relevance.
It is vital to ensure that school profiles recognise the full journey of a school. Our members have highlighted concerns that aspirational but subjective language—terms like "exemplary" or "strong"—can disadvantage schools making real, albeit incremental, progress in inclusive practice. A school on the path to embedding inclusion, especially in a high-need community, should be celebrated for its direction of travel, not penalised for not yet achieving idealised outcomes and it is imperative that principles of school accountability and the information available in school profiles reflect this.
While attendance is a long-established metric, nasen would advocate for a more nuanced use of this data. Instead of surface-level figures, profiles could include information about how learners with low attendance rates are supported, whether some learners are on part-time timetables or attending alternative provision. If these arrangements are inclusive, appropriate, and regularly reviewed, these practices should not be to the detriment of a positive school profile. Rather, the school might receive recognition and praise for its safeguarding and wellbeing provision. We believe that the interrogation of attendance data should be focused on why rather than numerical statistics alone.
Over-reliance on attainment data can be damaging and uninformative, particularly for learners with SEND.
The membership and community of nasen would emphasise that the definition of "data" should go beyond academic attainment and include aspects such as wellbeing, personal development and access to opportunities outside of the classroom and beyond school hours. The question of clarity on what constitutes data—whether it refers strictly to numerical measures or also qualitative elements– has also been raised.
Other information that might be considered useful to understand about a school setting might include:
- Continuing professional development (CPD): evaluating how all staff are equipped through CPD to deliver inclusive teaching.
- Extracurricular access: understanding participation of learners with SEND in wraparound and enrichment activities.
- Resourced provisions: understanding whether such provisions are integrated and built in or bolted on.
- Transitions and admissions: considering how schools manage transitions and support learners with SEND through changes in setting or phase.
- Coproduction and collaboration: understanding how a school collects and responds to pupil and parent/carer voice, and places coproduction as a central pillar to improvement.
These metrics collectively provide a more holistic picture of inclusion in schools. They place important emphasis on experiences, outcomes, and systemic responsiveness.
The membership and community of nasen (National Association for Special Educational Needs) would caution against creating additional workload for schools. Past practices resulted in schools being required to generate excessive documentation purely for inspection / accountability purposes. Our belief is that there should be an understanding of the kinds of data and evidence already being used internally by schools, and integrating those examples into profiles without imposing new documentation requirements.
We would also advocate for not producing a framework that can become a tick box exercise. Sustainable change and behaviours with demonstrable impact should be valued as core measures of successful provision.
Intervention
Agree
The membership and community of nasen (National Association for Special Educational Needs) is of the opinion that every child has the right to a good education which provides them with the experiences and tools to reach their potential. Settings which do not meet the standards set should be supported by proven and strategic intervention, allowing them to improve their offering in line with the needs of their cohort. This should be ‘done with’ and not ‘done to’ the school and the leadership.
We do not think that one size fits all, nor do we believe that school improvement is a formulaic exercise.
All too often high performance is considered at odds with the aims of an inclusive setting. We firmly believe that a school can be both. All schools should be judged for how well they meet the needs of their most vulnerable learners. The offering for them should never be seen as a bolt on after the offering for others is improved.
Agree
We would advocate strongly that the RISE intervention focuses on the improvement of the offering for all vulnerable learners, including those with SEND, with specialist support given when needed.
Neither agree or disagree
The membership and community of nasen (National Association for Special Educational Needs) would value the importance of achievement over attainment as a definition of how well a school performs.
Strongly agree
While the membership and community of nasen (National Association for Special Educational Needs) sees the need for change, we are concerned that some of the proposals could return schools to the era where inclusion was considered a risk to achieving high levels of pupil outcomes, and where reasonable adjustments were considered to be at odds with consistent policy.
Our concern would be that learners with SEND become singled out as a group that makes success difficult to achieve and that unsavoury practices such as off-rolling and disapplication return.
We see the reform as an opportunity to highlight the importance of inclusive education with learner needs considered by providers. We see that there is great opportunity for increased celebration of inclusive practice and that there should be more clarity in defining what that means.
