Any accountability framework for inclusive mainstream funding must be proportionate and must not place additional administrative burdens on schools that are already stretched. However, we wish to raise a more fundamental concern about the quantum of the funding itself.

For SEND provision to function effectively, real capacity must be built, covering both staffing and physical space. Sensory areas and specialist staffing are integral to a child's development. The £1.6bn allocated over three years equates to a very small amount for each individual school. At approximately £14,000 per school the inclusive mainstream funding will make little material difference to the schools that need it most.

Any accountability framework must therefore be accompanied by an honest acknowledgement that the current funding envelope is insufficient to deliver the inclusion ambitions set out in this consultation. Accountability without adequate resourcing risks penalising schools for failures that are structural rather than a result of poor practice.

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

Yes. Schools are best placed to identify children who need SEND support at the earliest opportunity. In our experience, schools routinely respond to presenting need by investing in staff and facilities, rather than waiting for a formal diagnosis or a Education, Health and Care Plan (EHCP), even if they aren’t being properly funded to make that provision. This can leave schools with significant shortfalls in funding; we find this is a common source of conflict between schools and local authorities.

Having SEND funding within mainstream budgets would therefore allow schools to respond in real time to the needs of children in their care, provided that funding is sufficient.

However, careful thought must be given to equity across schools with different levels of SEND need. The method by which mainstream SEND funding is distributed is critical. Any formula must properly account for schools with particularly high levels of SEND need, to avoid a situation where a school's budget is inadequate to the challenge it faces.

Q32. Do you agree that the proposal for every school to become part of a local SEND group aligns with the aim for all schools to be part of high quality, community-based trusts?

We have reservations about this proposal as currently drafted.

The requirement to join a local SEND group is widely perceived as a mechanism for pushing schools into a MAT, and the broader benefits of this structure beyond SEND are not particularly evident from the consultation document.

There are also fundamental unanswered questions about governance: what exactly will these schools be expected to do, and how will the groups be governed? The purpose and remit of these groups must be clearly defined, with clear monitoring, rather than creating another layer of meetings that consume time without delivering outcomes for children. While it is proposed that this group will involve resource sharing, this is inevitably much more difficult to do outside of a formal governance structure. 

Are you ready for SEND reform?

As the reforms raise fundamental questions about how SEND groups and trusts will be governed, now is the time to review your governance arrangements. Discover how we can help you with governance for schools.