· Ceredigion strategy will need to change in response to the changes in the ALN Bill and the Code of Practice.

· Pupils with weak basic skills only - monitoring for two terms before they would be put on the SEN register.

· Happy with no mandatory template for the IDP but with a list of required contents.

· Delighted that the role of the educational psychologist has been made statutory.

· No new group of learners or needs? What about specialist FE provision? This isn't currently in place so it is likely to attract a new group of learners who are not already attending FE colleges.

· Issue regarding entitlement of 19 - 25 - make it clearer that this relates to FE only and not university or work-based training.

· Education or social services provision? Do LAs have to meet the needs of young people who are currently not accessing education who are 21 - 25 years old? There is not enough clarity around this more details are required.

· Implications for the capacity of the central LA team.

· Careers Wales service? Their expertise is not mentioned in the Bill - will there still be a role for Careers Wales?

· Q1:

· a) yes but more clarity required.

· b) yes but more clarity required - especially for effective interventions in FEIs

· c) yes but more clarity is required.

· Q2: yes they are the right aims but will this be possible in practice with the current financial climate?

· IDPs before children start school - Will health workers or TPA write them? Or are education responsible even before school start age?

· 6: Less adversarial system – not necessarily as we are opening the door to a whole new tranche of pupils and parents and in our experience parents sometimes insist on  provision that is not appropriate to or required by the children's needs.

· 7: “collaborate and integrate” - requires funding and needs more clarity.

· Multiagency working: DECLOs what teeth will this role have and at what level - admin or clinical? Will they have funding available to meet provision needs?

· It is difficult to know how this will work in practice however it will be an improvement compared with the current situation.

· ALNCo - will the role still have a teaching commitment or not?

· We agree in principle.

· The issue of confidentiality in sharing information? Currently it is only with parents’ agreement will this remain the case or not?

· We are happy that the duty has been included for provision made by health.

· We need to strengthen the term “enable” to become “provide” so that this is statutory.

· What about funding?

· Happy with the inclusion of all plans.

· IDP's: clarity regarding when IDP responsibility transfers to the local authority is required.

· The expert group will need to look at criteria for this.

· At preschool will it be an IDP or a health care plan?

· Securing ALP for pupils not attending school - we need to remove this or specified that it is when it is due to illness only. The current wording is far too ambiguous and looks as though it could include preschool and elective home education pupils.

· Otherwise many children/parents could request home provision which would undermine mainstream provision and the funding available for this.

· Reviewing IDPs on request is unmanageable.

· A timescale will be required or include the wording “if needs or circumstances change” in order to specify more clearly.

· The Bill should not allow a pupil parent to request a review of an IDP without criteria or the workload for ALNCOs and outside agency staff will be unmanageable.

· This needs to be qualified.

· 0 – 25: “Care plan” - will this be the IDP or will it be different?

· Will health visitors be turning to education staff to write them?

· Will education be involved? If so we don't currently have the capacity to do this.

· “Education responsibility 0-5” - what does this mean in practice?

· IDPs “irrespective of whether in Education” – could this imply that LAs need to maintain an IDP post-16 on the off chance that the Young person may choose to return to FE later on?

· This situation would be an unmanageable.

· What about the situation for pupils who are home educated? -they might suddenly decide that they want to attend FE when they are 16?

· Criteria will be needed along the continuum of need.

· Funding for this? - additional costs will be incurred for those aged 19 - 25.

· Capacity? Phasing would be required to allow the development of local provision for those aged 19 - 25.

· Will the Welsh government to be able to say to FEIs you must provide?

· Could FEIs simply turn to local authorities for additional funding?

· If so this would undermine the local authority's ability to meet the needs of all pupils.

· Rights to appeal at a local level: yes we agree.

· Extending the remit of the tribunal to the age of 25: this will be more expensive for the taxpayer and for the local authority in preparing for more disputes.

· May be difficult to fill the ALNCO role due to the large commitment to training?