Cyflwynwyd yr ymateb hwn i'r Pwyllgor Plant, Pobl Ifanc ac Addysg ar Llwybrau at addysg a hyfforddiant ôl-16
This response was submitted to the Children, Young People and Education Committee on the Routes into post-16 education and training
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Ymateb gan: Natspec and TSANA
Response from: Natspec and TSANA
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Natspec is the membership association for organisations which offer specialist provision for students with learning difficulties and disabilities. Natspec provides training, quality improvement consultancy and resources for member colleges and the wider FE sector. There are seven specialist colleges in Wales, all of whom are members of Natspec. Additionally, six out of Wales’ thirteen Further Education Institutions (FEIs) are Affiliates of Natspec.
TSANA, Wales’ Third Sector Additional Needs Alliance, is a coalition of third sector organisations working with, supporting and representing a broad range of children and young people with additional learning needs. Facilitated by Children in Wales, TSANA believes that all children and young people, regardless of their abilities, educational needs or circumstances should be able to realise their rights under the United Nations Convention on the Rights of the Child. TSANA membership includes:
We welcome this consultation by the Children, Young People and Education Committee into post-16 routes into education and training. Both Natspec and the TSANA have long held concerns that ALN reform will result in a drop in the number of young people with learning difficulties and disabilities having the opportunity to progress from special schools to purposeful education and training. We have previously highlighted to the Committee our concerns around access to impartial information and guidance, transport and access to additional learning provision. As ALN reform is implemented, this response provides further evidence on our concerns relating to the quality of information given to learners, equity of access, post-16 destination data and Welsh Government’s role.
Quality of information given to learners
Under ALN reform, Careers Wales Advisors have lost their statutory roles in facilitating routes to further education and training for learners with complex ALN so that they can attend mainstream and specialist FE colleges. Instead, the default position is that learners from special schools, regardless of their personal aspirations and preferences, will progress to their local mainstream FE college (FEI) ‘independent living skills’ provision. Where an FEI is unable to meet a learner’s ALN, local authority officials are required to make assessments of a ‘reasonable need’ for education and training. Where reasonable needs are confirmed, the LA can then secure additional learning provision (ALP).
Natspec has previously highlighted that a lack of clear guidance for local authority officials tasked with assessing a reasonable need for education and training will result in postcode lotteries of access to specialist further education. Different FEIs have different offers to learners with learning difficulties and disabilities and we remain concerned that a prevailing place-based assumption that inclusion means ‘all learners being educated in a mainstream setting’ risks denying some young people with the most complex needs the specialist further education they need. It could even lead to young people whose needs cannot be met by a mainstream FE college being excluded from further education altogether and instead referred to a social care setting straight from school. We must not allow the principle of educating all young people in a mainstream setting to take priority over the right of learners with learning difficulties and / or disabilities to a learning experience of equally high quality to their non-disabled peers.
Estyn’s Thematic Review of the ALN system (2023) recommended that local authorities should develop and publish their strategy for post-16 learners, but only a minority have done so. Where LAs have published strategies, information on processes for when an FEI is unable to meet a learner’s ALN is often omitted. Natspec’s own research has revealed that two thirds of parent respondents rated the overall quality of the information, advice and guidance that they or their young person received as poor. They were critical of the timeliness, availability, sufficiency and quality of the information and guidance received, and felt that they and their young people had not been fully involved in decision-making. The experiences they described are a far cry from the expectations set out in the ALN Code.
Equity of Access
The ALN Code
The ALN Code fails to uphold the discretionary powers that under the SEN system have ensured that all learners with complex learning needs who stay in special school until they are 19 years old will be able to progress to further education colleges in either the mainstream or specialist sector. The guidance also fails to define what further education means for a young person with complex ALN and when it is deemed to have commenced. It does not clearly explain whether a stated two-year entitlement to education and training is a post-16, or a post-school entitlement. This leaves the door open for the interpretation that a 19-year-old special school leaver who as is the norm, has stayed in school until that age because of the complexity of their learning needs, can be deemed to have already had further education, even though they may have been in the same special school for all their compulsory school lives and never had access to a specifically FE environment or curriculum.
It is inequitable that those whose ALP is an FEI will have an uncontested route to FE while their peers whose ALP is more specialist provision in a specialist college are subject to LA officials’ assessments, made without clear parameters in the statutory guidance.
The default position laid out in the ALN Code that learners will attend their local FEI unless the FEI states they are unable to meet a learner’s needs is likely to result in a rise in failed placements and an increase in young people with ALN becoming NEET. We are increasingly aware of learners who, unable to cope with the demands of a busy FEI, are stopping attending. In these circumstances, there are no provisions in the ALN Code for a learner’s IDP to be reviewed and the right ALP sought. Procedures should be put in place to support such learners access the ALP they need. For some learners it may be that a combination of specialist and mainstream FE is what they need, and barriers should be removed that currently prohibit the person-centred aspirations of the reforms to allow this to happen.
The ALN Code states that a two-year limit to FE learning is the norm. Since the initial draft of the ALN Code, we have highlighted, along with many other stakeholders, that in reality, this is simply not the case. Many learners with complex ALN access ILS provision in mainstream FE colleges for multiple years. We recognise that indefinite programmes are undesirable but stress that some learners with ALN simply take longer to learn and it is not unusual for them to require three years to complete programmes of education and training that would typically be achieved by their less or non-disabled peers in two years. Crucially, learners with ALN whose ALP is a specialist college should not be prohibited from being able to undertake three-year vocational programmes in line with their aspirations and life goals. We are aware of multiple examples of young people with ALN wishing to pursue vocational 3-year FE courses and learners with profound and multiple learning disabilities who need three years to complete their programmes being refused funding. It is hugely disappointing and frustrating that these long-standing concerns are now manifesting and adversely affecting the lives of young people with ALN and their families.
Wales’ young people with learning difficulties and disabilities must not be excluded from further education and training simply because of the complexity of their needs. When we talk about inclusion in education, it is the system, rather than individual settings, that must be able to accommodate and provide high quality provision for all learners. Specialist FE providers are essential to achieving an inclusive FE system. Natspec is wholly supportive of the vast majority of learners with ALN accessing high quality FE in FEIs and we are actively supporting FEIs to meet a wider breadth of ALN. Alongside this, specialist colleges, established specifically to meet the needs of learners with complex ALN provide some of the most inclusive learning environments in education. Assumptions that such providers are ‘anti-inclusion’ are limiting, discriminatory and should be challenged.
Individual Development Plans
Learning and Skills Plans (LSPs) written by Careers Wales Advisors under the SEN system constituted a highly personalised summary of a learner’s education and training needs. They also effectively served as a commissioning tool for specialist colleges. LSPs are in no way replaced by even high quality IDPs. Disparity in the sufficiency, quality and content of IDPs is adversely affecting transition planning and routes to appropriate ALP for learners with complex ALN.
Anecdotally, we are already hearing of examples of:
· IDP outcomes being written only for post-school contexts and lacking ambition for learners’ post-school education and training
· learners having neither an LSP or an IDP
· ALNCos being told to remove learners therapeutic learning needs from IDPs. This means learners’ needs for specialist interventions that will support their access to and engagement in learning are not formally recognised
· IDPs being ended when an FEI has said they are not able to meet learners’ needs.
Transport
Our members are telling us about an increasing number of learners whose funding at a specialist college has been agreed by Welsh Government, but who are unable to commence study programmes because of a lack of transport to and from college. Specialist colleges are not permitted to include transport costs in their fees and parents often do not have the financial resources to cover these costs.
Findings from a UK survey of Natspec member colleges published in December 2024show that up to 65 % of specialist colleges were directly affected by learners not being able to attend college due to transport issues. 82% of respondents to Natspec’s transport survey stated that transport issues were causing noticeable stress and anxiety to learners. 67% believed that transport issues were reducing learners access to learning. In Wales specifically, 75% of respondents stated that it was getting more difficult to access transport support, with one stating that transport difficulties were the number one reason for an application not progressing.
Post-16 destination data
Welsh Government collects no destination data on learners leaving independent living skills (ILS) programmes in FEIs, and only limited information on the post-college destinations of young people who have attended specialist colleges. Learners who drop out of colleges during the first eight weeks of the academic year are not included in college retention data and the ALN Code has no mechanism for reassessing the ALP of learners who drop out of FEIs and/or recording whether IDPs were ended or suitable ALP secured. It follows that the number of learners across Wales who become NEET because of inappropriate ALP is not collated.
Learners at specialist colleges and those on ILS provision in FEIs predominantly access non-accredited personalised study programmes. They do not leave college with formal qualifications that for mainstream learners are a measure of achievement. This means that data on learners’ post-college destinations is of increased importance as it will provide insight into how effective further education programmes are at preparing young people for their post-college adult lives. This kind of information will also help us shape a shared understanding of what successful outcome looks like and means for this group of learners.
Additionally, the lack of national post-college destination data makes it impossible to assess:
· the impact of specialist interventions such as speech and language support, assistive technologies or occupational therapy on learner outcomes
· the wider impact on families and carers of learners accessing high quality education and training
· value for money
· the relationship between different curriculum offers and learner outcomes
· how curriculum offers support the aims of ALN reform.
The Lifelong Learning Wales Record (LLWR), the official source of statistics on post-16 learners in Wales, is devoid any data for this group of learners, and as a result they are excluded from evidence available to Medr, the Commission of Tertiary Education and Research and data monitoring the Wellbeing of Future Generations Act.
Welsh Government’s role
We welcome the Cabinet Secretary’s recognition that parts of the ALN legislative framework are complex and unclear and that a review is taking place to identify next steps to provide greater clarity. To ensure young people with learning difficulties and disabilities have equitable routes into post-16 education and training, Welsh Government should recognise that:
· learners with ALN take longer to learn and statutory guidance should clearly uphold the prerogative maintained under the SEN system that education and training should be a post-school not post-16 entitlement.
· learners with low incidence and complex ALN and their families should be able to easily access information and guidance on post-16 options. This should include arrangements for when a regional FEI is unable to provide the additional learning provision they need.
· a lack of transport is resulting in some learners being unable to attend colleges. A post-16 transport policy should be in place to ensure learners with ALN are not discriminated against by the nature of their additional learning needs and additional learning provision.
· Welsh Government should collect meaningful data on the post-college destinations of learners with learning difficulties and disabilities and use that information to inform improvement planning.