Consultation Point 1 - Inclusion
(Reference: paragraphs 3.1 to 3.8)
1 Do you agree with the introduction of an
inclusive framework based on the wider concept of additional educational need
(AEN)?
Comments:
The
term Additional Ed. Needs is only another way of expressing the wide range of
needs teachers already have been experiencing and supporting in schools . However, given that the introduction implies a
concern about the increasing number of children being labelled as SEN and
therefore increasing
resources required to meet this need, it is difficult to see what
this proposal does to address these matters. The UTU is concerned as to how
schools are going to be developed to cope with this increasing diversity of need , accountability and bureaucracy.
The timing and implications for work –overload are both of major concern for all principals and
teachers.
Consultation Point 2 - Key Principles of the
Proposed Policy
Framework
(Reference: paragraphs 4.1 to 4.6)
2 Do you agree with the key principles on which
the policy proposals are
based?
Comments:
The
key principles under-pinning these policy proposals will only work if there is
funding, high quality training delivered by appropriate experts, resources and
effective sharing of expertise (with teacher release sub-cover built in). The
number of health professionals, especially speech and language therapists and
occupational health therapists, needs to be dramatically increased to provide
the joined-up services recommended. The proposed shift away from placing all of
the responsibility on the SENCO will mean that the whole staff, teachers and
classroom assistants will need additional training as well as time to carry out
the job. These policy proposals need to be delivered within the framework that
includes the educational needs of all children to ensure that all children
benefit from their educational setting.
Consultation Point 3 - Early Identification and
Intervention
(Reference: paragraphs 5.1 to 5.5)
3 Do you agree with the proposals relating to
early identification and
intervention?
Comments:
Early identification and
intervention are essential if pupils with special needs are to be properly
supported in schools. However the current practice of 30 pupils in Foundation
and KS1 classes is too high, especially if a number of Special Needs pupils are
included within that number. The employment of the large number of UNEMPLOYED
Newly Qualified teachers would play an invaluable role in helping to reduce
class size. The Learning Support teacher would require intensive training to
carry out initial diagnostic testing and time provided to carry out the
testing. Class size, adequate training and resources are the key ingredients to
PLPs being properly implemented.
It is clearly recognized that within the
current system the referral process is slowed down considerably by the funnel
through the Ed Psych service. Allowing
schools to take on this role would certainly help – however the fact that a
majority of the current children who are referred to the statementing process
actually become statemented would suggest that the current process though slow
is fairly robust. If in the new system
schools are given the responsibility for effectively statementing will they
also be given the ability to draw on the additional resources which would be
required? Also what would this mean for
parental input ? Often it is the parents who are most demanding, who get the most and it is not always based on
the needs of the child.
The UTU would also have concerns
with regard to proposed electronic based records and would need reassurance
that this would help schools keep records more efficiently and not create more
bureaucracy.
Consultation Point 4 - Pre-School Settings
(Reference: paragraphs 6.1 to 6.3)
4 Do you agree with the proposals relating to
pre-school settings?
Comments:
All
children irrespective of the setting in which they receive their preschool
provision should be treated in the same manner. However the UTU wishes to
highlight the fact that the Chief Inspector’s report for 2006-2008 recognises that the
highest quality provision is in the statutory sector, provided by professionally trained teachers. Special
Needs provision is a complex area and in the pre-school setting this can best
provided for under the care and direction of qualified teachers, who have been
trained and supported by proper funding and resources. The ratio of pupils to
teacher must be addressed very carefully if all pupils are to be
provided with the education best suited to their needs. It is essential that
the proposal to establish and maintain a core of well-trained “early
intervention officers” is carried through.
Consultation point 5 - Primary and Post Primary
(Reference: paragraphs 7.1 to 7.5)
5 Do you agree with the proposals relating to
primary and post primary?
Comments:
These
proposals significantly impact on workload and accountability for staff and
principals. The resources of all schools will have to be enhanced dramatically
if these proposals are to succeed.
Teachers urgently need to be given the recommended 10% preparation and
planning time and this needs to be fully funded.
Schools need to have the same resources as alternative education facilities.
The variation in class size within and across schools needs to be addressed. If, as appears to be suggested, that the way
to deal with those children, who have real difficulties coping with education
in the traditional setting is through Nurture Groups (adult/pupil ratio 1 to 4)
then how can schools with class sizes in excess of 1 to 25 be expected to deal
with these children?
Consultation Point 6 - Training and Development
(Reference: paragraphs 8.1 to 8.5)
Comments:
Awareness of the whole spectrum
of needs and behaviour must be raised at Initial Teacher Education. The CPD of
staff will be crucial to this process to ensure teachers are constantly being
updated and up-skilled and must be seen as a key part of any role out programme
if the diversity of need is to be encompassed.
It is essential that all teachers receive this training and that it is
not added on at some point. It is impossible for one adult to support the
diverse needs of all learners under current class sizes. If a child has an
individual learning plan there needs to be provision of individual support. The
complex and diverse needs of many pupils in mainstream schools would be more
adequately met in the small class situation in the
Consultation Point 7 - Learning Support
Coordinators
(Reference: paragraphs 9.1 to 9.4)
Comments:
The
key element here is not what we call these teachers but rather the need to
properly resource and equip them, as well as ensuring that teachers are
safe-guarded against an intolerable work-load.
Funding is essential if the LSC is to be released from class for a
realistic amount of time in order to bear the responsibility and accountability
that this role is going to encompass. It is incumbent that there is enough
ring-fenced funding in school budgets to enable governors and principals to
release LSCs from full-time class commitment. The employment of NQTs could make
this a reality. The UTU welcomes the view that an area based LSC would support smaller schools, where it is completely unacceptable for
this role to be dumped on the Principal by default. Perhaps, in larger schools,
it might be better for SMTs to be encouraged to have regular reports from/
meetings with the LSCs rather than a dedicated place on the SMT. Obviously different schools will have reached
the membership of their SMT through different routes, but the question must be
posed as to why it should be more important to have the LSC than, for example,
the Numeracy Coordinator.
Consultation Point 8 - Co-ordinated Support Plans
(Reference: paragraphs 10.1 to 10.6)
Comments:
This would appear to be the crux of the
matter. Essentially there are too many
children requiring additional provision.
Schools and parents do not readily or easily go down the route of
statements. The process is too difficult
and tortuous at present for it to be followed just to get extra resources. This proposal would appear to simply want to
remove the demands for additional resourcing to cope with meeting the needs of
some pupils or at the very least make it even more challenging than at present.
Para 10.2 suggests that the key factors for
progress are, in fact: the involvement of an experienced/qualified teacher;
good assessment; work tailored to challenge pupils sufficiently; and commitment
for school leaders to ensure good progress for all pupils. While the UTU agrees with this,
it
must be highlighted that the school needs to be able to provide for this and
with current staffing levels this is not possible. Maybe the lessons from
Consultation Point 9 - Transition Points
(Reference: paragraphs 11.1 to 11.7)
Comments:
While
qualified teachers are competent in carrying out pupil assessments in the statutory
sector –concern must be raised regarding the level of expertise available in
the voluntary and private sectors. The UTU would welcome the appointment of
Transitions Co-Ordinators, Career managers and specialist Advisors to support
and prepare pupils in their move to adulthood, but these services must be
accessible to all children with SEN and no just those with a CSP.
Consultation Point 10 - Developing Effective
Partnerships
(Reference: paragraphs 12.1 to 12.30)
10 Do you agree with the proposals relating to the
development of effective
partnerships:
(a)
Within school and pre-school settings? (paragraphs 12.3 to 12.5)
Comments:
The
UTU would welcome this across all the proposed partnerships. Teachers are
already experiencing huge challenges in schools with the implementation of the
revised Curriculum and therefore it is essential that time and funding are made
available for collaboration to take place to ensure it does not become yet
another add on at the end of a busy day.
10 Do you agree with the proposals relating to the
development of effective
partnerships:
(b)
Across educational settings & learning communities? (paragraphs 12.6 to 12.7)
Comments:
While the UTU would generally welcome
these proposals, there are strong fears that huge administration issues may be
involved, consuming valuable teacher-time. The UTU recognises the role that
special schools could play in learning communities, but while the expertise of
these teachers should be maximized the actual logistics of sharing expertise
will need to be carefully and effectively managed. Schools will need financial
support to encourage collaboration and the sharing of expertise and resources
in order to deliver improved provision for children with barriers to learning.
However it must be remembered that a class teacher has responsibility for
access to learning of all the children in the class. Again class size is an
important issue.
10 Do you agree with the proposals relating to the
development of effective
partnerships:
(c)
Between mainstream and special schools? (paragraph 12.8)
Comments:
The UTU would support this proposal and would
endorse the proposal that opportunities should be created for Special Schools
to achieve recognition as centres of expertise within learning communities.
10 Do you agree with the proposals relating to the
development of effective
partnerships:
(d)
Between Education and Health and Social Care (e.g. Education and Skills
Authority and proposed Regional Health Boards)?
(paragraphs
12.9 to 12.17)
Comments:
The UTU recognises that this is a very important proposal
and if achieved would lead to significant improvement to the current position.
The “Team around the child” approach is an excellent model but in reality there
are both time and resource implications. Schools would welcome improved access
to expertise and support from experts e.g. Speech and Language therapists.
10 Do you agree with the proposals relating to the
development of effective
partnerships:
(e)
Between the Department of Education (DE) and the Department of
Employment
and Learning (
Comments:
Effective partnerships between these two bodies
must provide
an essential core for all effective educational policy development in
N.Ireland.
10 Do you agree with the proposals relating to the
development of effective
partnerships:
(f)
Through the establishment of Multi-disciplinary Groups? (paragraphs 12.19
to 12.25)
Comments:
This
is essential if “ The Team Around The Child” is to be
followed through to provide a more joined up, focused and systematic approach
to assessment and provision. The appropriate support needs to be given as soon
as possible after the identification of the need. Current waiting time causes
difficulties in schools especially in the area of behavioural support. The UTU would
be supportive of having ‘real’ teachers on the MDGs rather than just
educational professionals – many of whom will have very limited classroom
experience. Obviously the membership
would need to rotate particularly if a child from a
teacher’s school was being discussed.
10 Do you agree with the proposals relating to the
development of effective
partnerships:
(g)
With parents and carers? (paragraphs 12.26 to 12.28)
Comments:
The UTU firmly believes that it is vital that
good relationships are
developed with parents and carers in their role as
educational partners and there must be highly developed levels of mutual trust
and respect.
10 Do you agree with the proposals relating to the
development of effective
partnerships:
(h)
With children and young people? (paragraph 12.29)
Comments:
This is central to the very core of all educational
rationale.
10 Do you agree with the proposals relating to the
development of effective
partnerships:
(i)
With voluntary organisations? (paragraph 12.30)
Comments:
The UTU firmly believes that this could prove to be the
very proposal which will be instrumental in helping to raise the overall
capacity of the system to support children with special educational needs. The
importance of sharing expertise must be highlighted here for the good of all
pupils.
Consultation Point 11 – Outworking of the
Proposed Model
(Reference: paragraphs 13.1 to 13.9)
11 Do you agree with the replacement of the
sequential stages of 1-5 of the
current COP by the proposed 3 strand model (Within School,
Within School
plus External Support, Co-ordinated Support Plans)?
Comments:
The
UTU believes that the current 5 stage process is difficult to understand so a
simplified model such as the 3 strand model would be an improvement. However, the UTU would have concerns that
this may be a means of making it harder
for schools to access additional resources.( Ref. 13.8 ) and time may be wasted
by a school having to complete forms to prove that it has taken appropriate and
reasonable action to meet a child’s needs, before being able to access any
external support. The UTU has reservations
about some of the interventions suggested in relation to strand 2 in that this
model of help from others has been tried in a Board Area and the report from
those schools involved was less than positive.
Consultation Point 12 - Resolution and Appeal
Mechanisms
(Reference: paragraphs 14.1)
12 Do you agree that the current informal appeal,
dispute avoidance and
resolution and formal appeal arrangements (SENDIST) for
children with SEN should remain unchanged?
Comments:
The UTU realises that DARS and SENDIST arrangements will still play a role, but would have concerns that principals and Boards of Governors will be increasingly involved in appeals if accountability for funding is shifted to schools.
Consultation point 13 - Funding
(Reference: paragraphs 15.1 to 15.5)
13 Do you agree with the proposals relating to
funding?
Comments: Funding is one of the key
issues in all of these proposals, bringing with it greater accountability for
principals and Boards of Governors. However any formulaic approach to moving
funds from ELBs etc to schools must be sufficiently robust as to allow for the
variations within schools and between schools. For example there is an earlier
suggestion about LSCs to be employed by a number of smaller schools but careful
consideration would be required as to how schools would cover the cost . Would it be a matter of dividing the costs or would
school A pay more than school B because it had twice the number of children
with special needs? In any case the funding for Special Needs needs to be
“ring-fenced” so it cannot be used to fund another area of the school’s costs.
Consultation Point 14 - Monitoring, Review,
Evaluation &
Accountability
(Reference: paragraphs 16.1 to 16.5)
14 Do you agree with the proposals relating to
monitoring, review, evaluation & accountability?
Comments:
The
UTU is concerned about the lack of detail on quality indicators and regulations
to support the implementation of the proposals. What is the quid pro quo of the
increased accountability? Is this just
something else for principals to have to do? Concerns are also mounting
regarding the amount of time ESA will take to “bed-in” and how this might
affect the amount and quality of support available.
Consultation Point 15 - Roles and
Responsibilities
(Reference: paragraphs 17.1 to 17.19)
15 Do you agree with the proposals relating to the
roles and responsibilities for:
(a)
The Department of Education (DE)? (paragraphs 17.1 to 17.2)
Comments:
The UTU would like to see some sort of assurance that the training will
be of high quality and that funding will
be adequate with a review of Common Formula Funding and inadequacies addressed
e.g the difference in funding of a year 7 pupil and a year 8 pupil.
15 Do you agree with the proposals relating to the
roles and responsibilities for:
(b)
The proposed Education and Skills Authority (ESA)? (paragraph 17.3)
Comments
ESA does not have a proven track record and
therefore there is no way of gauging how supportive it will be to schools
.
15 Do you agree with the proposals relating to the
roles and responsibilities for:
(c)
The Department of Health, Social Services and Public Safety (DHSSPS)?
(paragraphs 17.4 to 17.6)
Comments:
The UTU commends the thinking behind these proposals and acknowledges that the
implementation will require the employment of an adequate number of fully
trained professionals.
15
Do you agree with the proposals relating to the roles and responsibilities for:
(d)
Multi-disciplinary Groups (MGs)? (paragraphs 17.7 to 17.8)
Comments:
The role of the Multi-disciplinary Groups needs be more clearly
defined. Concern must be expressed as to the funding of such groups as it
should not mean that there will be less money in the pot for schools.
15 Do you agree with the proposals relating to the
roles and responsibilities for:
(e)
Mainstream schools and other educational establishments? (paragraphs 17.9
to 17.16)
Comments:
These
proposals place very significant responsibilities upon all teachers and in
particular upon principals. Where is the
additional time to be found to ensure that these responsibilities can be
carried out effectively? For those in
DE or ESA who have to take on new responsibilities, there may be the expectation
that existing ones will be passed on to someone else. But that is not how it works in school.
15 Do you agree with the proposals relating to the
roles and responsibilities for:
(f)
The Education and Training Inspectorate (ETI)? (paragraphs 17.17 to 17.18)
Comments:
The
roles and responsibilities seem appropriate with little change in the current
remit.
15 Do you agree with the proposals relating to the
roles and responsibilities for:
(g)
Children’s Services Directors? (paragraph 17.19)
Comments:
The UTU recognises that these people will be very vital in working
collaboratively to ensure that schools and pupils receive adequate support.
Clarification of their roles would have been helpful.
Consultation Point 16 - Proposed Phased
Introduction of
the Policy
(Reference: paragraphs 18.1 to 18.7)
16 Do you agree with the proposed phased
introduction of the policy?
Comments:
A
phased introduction is a must. The UTU
is unsure that the proposed timing i.e. for a pre-implementation year 2009-2010
is practicable. At the earliest the
pre-implantation year should be 2010-2011.
However I think
the key to all of this lies in the concluding paragraph. 18.7 states: “It is recognised that the
full policy proposals can only be implemented as and when the necessary
resources become available to both the education and health and social care
sectors. The facilitation of a co-ordinated education and health and social
care service which is effectively planned, commissioned, delivered and
monitored, will probably require co-ordinated bids for resources to inform
Programme for Government and the associated Budget.”
Given
that we are about to enter a period of significant budgetary pressure it is
very unlikely that the necessary resources will be found, but the UTU cannot
support the introduction of a new regime
with only partial funding because inevitably it will be schools and
teachers who will try to make it work at tremendous cost to themselves.
The
UTU represents in excess of 6000 teachers in
Class
size is an issue of concern, which must be highlighted at a time when it is
acknowledged that the diversity of needs in classrooms is on the increase and
that quality of teaching and learning is paramount. It is increasingly
difficult for one teacher in a classroom to cope with the variety of needs and behaviours being
presented in a class, when regulations still permit 30 pupils at Key Stage
1. It is not acceptable that statemented
pupils are not included in this number, nor in the
enrolment number of a school. The
employment of the many unemployed NQTs would provide:-
1. An effective way of reducing class size.
2.
The means to release LSCs from full-time class commitment.
3.
The facilitation of 10% planning and preparation time, which all teachers
urgently need.
Ring-fenced
funding for special needs is an essential ingredient if any of these proposals
are to be implemented effectively and attention must also be paid to the
current inequalities in the current financial provision for primary schools
–namely the huge difference in funding between year 7 and year 8 pupils.
An
extensive programme of training will be imperative for all who work in schools
with children if these proposals are to be effective. Some sort of career
structure would need to be inbuilt for the LSC if they are to take on an
accredited training course. While shared
expertise would be welcome, this too must be managed so that no pupils are
disadvantaged by the fact that their teacher has been released to support and
advise another school. There needs to be a large element of trust between
parents and schools in order to achieve the best provision for pupils – be it
in mainstream or in special schools. At present the statement does provide some
sort of security for parents in terms of recognition of the need, with some
provision for
additional help and support.
The
additional responsibility, workload and accountability for teachers, principals
and Boards of Governors is a major concern for Teacher
Unions. There is an imbalance of accountability between that of the schools and
that of the Area Boards/ESA with little reference made in the document
as to the increased probability of litigation by dissatisfied parents.
The
workforce in schools is already coping with a range of educational issues and initiatives including the implementation of a Revised Curriculum
.The implementation of the proposals in the SEN and Inclusion Document provides
the opportunity to address the issues identified in this response.