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This is a submission to the Department for Education from SCHOOLS NorthEast, the UK’s only regional schools network representing all 1,250 schools in the North East of England.

1. About SCHOOLS NorthEast

Established in 2007, SCHOOLS NorthEast was set up by head teachers to create a unique culture of collaboration and mutual support amongst North East schools to ensure the best possible outcomes for all of our region’s young people. It represents the views of all 1,250 schools in the North East region.

SCHOOLS NorthEast is schools-led, governed by serving head teachers and guided by a 28-strong advisory board comprised of school leaders from all types of schools and representing each of the 12 local authorities that make up the North East region.

A registered charity, SCHOOLS NorthEast works to connect schools to each other and external organisations such as business, to facilitate new projects and additional support, to provide a strategic voice for our members and promote a wider understanding of the issues facing education in the North East.

2. Information

This SCHOOLS NorthEast submission is based on the collective input of schools from across the North East of England – from north Northumberland to the southernmost tip of the Tees Valley and coastal schools across to rural schools in the Pennines. It has taken into account the views of urban and rural schools from the most deprived areas to the least, the largest schools to the smallest and from all 12 local authority areas. It represents the most comprehensive picture of schools input on this consultation from the North East of England.

Qn 1) Do you agree with our proposed principles for the funding system?

Yes, although the practicalities and implications of this reform are fraught with issues. Any significant redistribution of high needs funding is likely to have considerable detrimental impact on those schools which are adversely affected.

The Government also needs to do more work to understand why there have been considerable differences between LA-level distribution of high-needs funding. Decisions taken at school forum level are based on the factors that are relevant in that area at a given time. DfE shouldn’t rely solely on the data, they need to explore context.

At this point, we would also like to register deep concern that the timeframes for this consultation are woefully inadequate to properly canvass school opinion on this important area. The consultation period, spread across the Easter holidays, allowed for just 17 school days in which to respond on both the overall national funding formula and the high needs formula. This isn’t conducive to getting the best outcome.

Qn 2) Do you agree that the majority of high needs funding should be distributed to local authorities rather than directly to schools and other institutions?

No. The erosion of LA involvement in education and the redistribution of higher needs funding outlined in this consultation will inevitably lead to a reduction in staffing and expertise in LAs. SEND providers operating across LA boundaries already report capacity concerns in the LAs and the reality is this is only going to worsen. The expertise is there in the schools system to ensure that funding directly to schools and other institutions is more appropriate.

However, it is essential that decisions regarding high needs provision dovetail with health and social care and so we would recommend the Government focuses thoughts on how to ensure the connect between schools and the LAs is suitably co-ordinated.

Qn 3) Do you agree that the high needs formula should be based on proxy measures of need, not the assessed needs of children and young people?

Schools would urge caution here. This appears to be driven by two factors – 1) that the decision on how to fund is driven by the need to deliver a simplified formula at the expense of targeting investment where it is actually need; 2) a distrust of assessment should funding be linked directly to actual need.

Proxy measures are at risk of not identifying where the true need lies.

It should also be noted that a concern with the current system identified by schools, particularly highly specialist institutions is that there has in the past been a disincentive to fund specialist provision due to its high cost despite this being the best option for the child in the long-term.

Qn 4) Do you agree with the basic factors proposed for a new high needs formula to distribute funding to local authorities?

Yes. We agree broadly with the factors, however, as indicated in the answer to qn2 we are not convinced that the funding must go directly to LAs due to capacity concerns.

Other aspects the Government should consider are that low attainment, while being an indicator of SEND at KSs2/4 does not support early intervention at nursery, reception & KS1. A focus on attainment does not identify all SEND needs e.g. children with Asperger’s.

In the SCHOOLS NorthEast response to the main schools funding consultation, we highlighted concerns regarding FSM as a deprivation indicator given the move to Universal Credit and the requirement on parents to identify their child as being eligible for FSM. Our preference would be a move to an ‘auto-enrol’ system instead.

Qn 5) We are not proposing to make any changes to the distribution of funding for hospital education, but welcome views as we continue working with representatives of this sector on the way forward.

Consideration should be given to funding going directly to schools where they deliver provision to a child on their roll who is in hospital. Some specialist providers currently deliver education services to long-stay patients and funding them directly rather than via the LA should be considered.

Qn 6) Which methodology for the area cost adjustment do you support?

SCHOOLS NorthEast does not support an area cost adjustment, either in mainstream school funding or a high needs setting, on the basis that the underlying rationale is flawed.

We recognise that it can be difficult to recruit staff in more expensive areas but this is one element of decision making by the individual when they chose their location to work. Recruitment is equally difficult in other, less expensive areas of the country but for different reasons.

There is a concern among schools that adding an area cost adjustment multiplier will encourage migration of specialists to areas with greater SEND funding.

Qn 7) Do you agree that we should include a proportion of 2016-17 spending in the formula allocations of funding for high needs?

Yes. This will help to smooth disruption during the transition period. Greater clarity on what will happen after the 5 years is important though for longer term planning.

Qn 8) Do you agree with our proposal to protect local authorities’ high needs funding through an overall minimum funding guarantee?

Yes.

Qn 9) Given the importance of schools’ decisions about what kind of support is most appropriate for their pupils with SEN, working in partnership with parents, we welcome views on what should be covered in any national guidelines on what schools offer for their pupils with SEN and disabilities.

Partnership working between schools and LAs should be used to specify the areas of SEND where there are strengths as well as identifying where specialist providers can better support needs.

Qn 10) We are proposing that mainstream schools with special units receive per pupil amounts based on a pupil count that includes pupils in the units, plus funding of £6,000 for each of the places in the unit; rather than £10,000 per place. Do you agree with the proposed change to the funding of special units in mainstream schools?

No. While we understand the move to simplify the overall formula calculation, and recognise the beneficial approach of not funding places that may not be in use, our concerns regarding area cost adjustments for the main formula give us little confidence that schools in non high-cost areas will not be adversely affected under this approach.

Qn 11) We therefore welcome, in response to this consultation, examples of local authorities that are using centrally retained funding in a strategic way to overcome barriers to integration and inclusion. We would be particularly interested in examples of where this funding has been allocated on an “invest-to-save” basis, achieving reductions in high needs spending over the longer term. We would like to publish any good examples received.

We do not have specific examples to contribute

Qn 12) We welcome examples of where centrally retained funding is used to support schools that are particularly inclusive and have a high proportion of pupils with particular types of SEN, or a disproportionate number of pupils with high needs.

We do not have specific examples to contribute

Qn 13) Do you agree that independent special schools should be given the opportunity to receive place funding directly from the EFA with the balance in the form of top-up funding from local authorities?

We see no great harm in this approach, nor do we perceive a great deal of benefit.

Qn 14) We welcome views on the outline and principles of the proposed changes to post- 16 place funding (noting that the intended approach for post-16 mainstream institutions which have smaller proportions or numbers of students with high needs, differs from the approach for those with larger proportions or numbers), and on how specialist provision in FE colleges might be identified and designated.

Schools are keen to see post-16 and pre-16 funding allocation brought into line. From the child’s perspective, the needs do not change from 15 to 16.