Consultation

NNPCF Consultation Response – An Early Years National Funding Formula: Government Consultation – September 2016

NNPCF Response to Government Consultation on an Early Years National Funding Formula

The National Network of Parent Carer Forums (NNPCF) is made up made up of local Parent Carer Forums from across the 152 Local Authority Areas of England, and has a steering group which consists of 10 Parent Carer Representatives from each of the nine regions in England, and the Co-chairs of the Network. These parent carers representatives link into the regional Parent Carer Forum Networks, The NNPCF Steering Group has where possible worked within their region to gather views and information to inform this response. We therefore believe that our response helps to identify the most common experiences and views of Parent Carers who have supported their son or daughter through the early years of their child’s development. At the NNPCF Annual Conference in October 2015, delegates were asked to provide the Steering Group with their ‘Burning Issues’. ‘Burning Issues’ were defined as being the most common and current issues that forums were focussing on at that time. These issues were collated in a national report. This report highlighted that childcare is a real problem for parents of children with SEND in terms of availability, cost and quality. Families with disabled children often find it difficult to access childcare. There are many reasons for this: they may not be able to find a childcare provider to suit their child’s specific needs, many childcare settings are not inclusive and many don’t offer childcare at times that are suitable. In May 2014, Contact A Family carried out research with families of disabled children. This research showed that 92% of families reported that finding childcare for their disabled child is more difficult compared to their non-disabled children. Before we respond to the specific questions of this review the NNPCF would like to set the context in which we are responding.

Context

For parent carers early and effective identification of a special educational need or disability is imperative. As parents we know that the emotional journey can be very difficult in the early years. As part of their SEND Pathfinder work, the LB Bromley worked with their Parent Carer Forum, Bromley Parent Voice, to follow a number of families’ journeys. This project highlighted the importance of early and effective intervention. 

One of the key parts of the Children & Families Act 2014 is how the new SEND system will improve life outcomes for children and young people from birth-25 years who have a Special Education Need (SEN) or disability.

“Our vision for children and young people with special needs is the same as for all children and young people – that they achieve well in early years, at school and in college; lead happy and fulfilled lives; and have choice and control.” (Department for Education)

The Key Principles set out in the Children & Families Act are that:

* Children and young people should be at the centre of planning for and making decisions about their future. Discussions should focus on what they want to achieve, and the support they will need to get there. This should start from the earliest age.

* There is now a single system of support for children and young people with SEN from birth to 25. This means that no one should lose the right to extra support for their educational needs simply because they are in a pre-school setting.

Chapter 5 of the SEN Code of Practice states that: All children are entitled to an education that enables them to:

* Achieve the best possible educational and other outcomes, and

* Become confident young children with a growing ability to communicate their own views and ready to make the transition into compulsory education.

All early years providers are required to have arrangements in place to identify and support children with SEN or disabilities and to promote equality of opportunity for children in their care. These requirements are set out in the EYFS framework yet forums have advised that many pre-school settings have real difficulty with early identification of children’s needs. We are concerned that if settings do not pick up on a child’s SEND, they will not make appropriate referrals and a child may start school without appropriate support in place or in a placement that cannot met needs.

Early Years funding plays an importance role in supporting the identification of SEN for very young children and ensuring the right support in put in place in a timely way. 

Response

The NNPCF welcomes more funding that goes into mainstream settings to support all children with SEND, however, we are concerned that this will result in a reduction in funding to specialist central services for Early Years. Whilst many early years settings give all children a real quality offer whatever their needs, this is very often possible only because of the support they receive from LA specialist central services. This may be in the form of an additional support assistant or more importantly from advice/training they receive from a specialist education keyworker, who knows that individual child and family well. Without that specialist expertise, the NNPCF has concerns that Ofsted will be the only organisation monitoring the quality of support to very young children with SEND. If Ofsted do not visit a setting for several years then many children in the meantime may have a very poor early start to their education and care.

As parents we know that early intervention truly works and if young children we do not get quality SEND support at the earliest opportunity they will not reach their potential.

This consultation must be read in light of what Local Authorities are considering regarding the use of the High Needs Block funding moving forward. The idea of an “Inclusion” pot for early years, coming from both High Needs Block and Early Years Block, seems a sensible approach but are we just redistributing resources when actually what we need is it ensure that Local Authorities and Early Years providers have sufficient funding to meet the needs of the increasing numbers of children with SEN and disabilities coming through the system.

In addition, Local Authorities will need to consider their approach to when the EHC needs assessment process is started, as this consultation assumes that LAs will have EHCPs in place for children with the most complex needs by 2 and therefore an Early Year setting will get funding through this route. However, some Local Authority areas do not begin the EHC Needs assessment until the year before the child is due to start school. The needs of preschool children are met through a robust Local Offer of support.

We will now respond to the consultation questions that specifically relate to SEND.

Should there be a Disability Access Fund to support disabled children to access their free entitlement?

The NNPCF welcomes the creation of a Disability Access Fund. There would need to be clear criteria for accessing this fund and resources to utilise.

Should eligibility for the Disability Access Fund be children aged 3 or 4 which are a) taking up their free entitlement and b) in receipt of Disability Living Allowance?

The NNPCF have concerns regarding using DLA as eligibility for the Disability Access Fund as not all young children with a disability receive DLA? Thresholds are high for DLA and do not always reflect the difficulty a child may be experiencing in a larger group setting. In addition, to receive DLA for a child under 5 years, the family need to be able to demonstrate that the child’s needs are ‘over and above’ the needs of another child of the same age without a disability or additional need. This can sometimes be difficult to prove in very young children.

Some families may not be aware that they are entitled to claim DLA or may feel that there is a ‘stigma’ attached to claiming benefits. If so then the child may miss out on the free early year’s entitlement.

The NNPCF has some concerns regarding using Disability Living Allowance as the measure for calculating which children receive additional funding as this may present a barrier to receiving timely support. In some Local Authorities young children with SEND can receive additional support as part of the Local Offer without needing either DLA or an EHC Plan to be in place. This promotes early intervention and enables assessment to take place over time. This current support is funded from the High Needs Block.

When it comes to delivering the funding for the Disability Access Fund, is the most appropriate way the existing framework of the Early Years Pupil Premium?

No. Pupil Premium focuses on those children who are socially disadvantaged not who have a physical or learning disability which prevents them from accessing universal early years provision.

To what extent do you agree that a lack of clarity on how parents / childcare providers can access financial support results in children with special educational needs not receiving appropriate support? (We mean children who do not already have an Education, Health and Care Plan)

This is a concern; however, parents have advised that there is a real problem with finding trained, experienced and affordable childcare.

There needs to be a stronger link with information as part of the Local Offer. Area SENCOs (or equivalent) working with pre-school settings are an important component in achieving early identification and timely intervention for children with SEND in settings. They also support settings to access appropriate training. 

Further clarity is needed around promoting and achieving meaningful access for children beneath the EHC threshold receiving SEN support.

When it comes to establishing an inclusion fund…

* Should local authorities be required to establish an inclusion fund? 

* Would an inclusion fund help improve the supply of appropriate support children receive when in an early years setting?

An established Inclusion fund would benefit many children with lower level needs to access provisions especially where early years provisions are mostly PVI settings and not formal nurseries attached to mainstream schools. This would benefit children with SEND to access appropriate support.

If you envisage any barriers, arising from existing practice or future proposals, to introducing a new requirement on local authorities to establish an inclusion fund, please tell us what they are and how they might be overcome.

Barriers would include:

* Requiring DLA to be in place before a child could access support

*Establishing processes and sufficient funding to enable access to free child care for 30 hours for working parents of 3 and 4 year olds as in the proposals ensuring equity and access. Ring fencing funds for SEND children.

When it comes to the SEN inclusion fund, should local authorities be responsible for deciding…

* The children for which the inclusion fund is used?

* The value of the fund?

* The process of allocating the funding?

The NNPCF believe that local authorities are in the best position to make decisions on the criteria for access to resources but that this should be done in partnership with their Parent Carer Forum.

The NNPCF would like LAs to have a well-established audit system to ensure fair access. There needs to be clear thresholds established and published which support the decision making based on the value of the resource/fund and its allocation.

Where specialist SEN or SEND services are delivered free at the point of use, should they be considered as funding passed directly to providers for the purposes of the 95% high pass-through?

The NNPCF have some concerns regarding this proposal. It would only work if there is extensive training of providers to deliver plans that will realise aspirational outcomes.

Specialist services delivered free at the point of use need to continue to ensure identification, early intervention and timely assessment as appropriate (this prevent families from having to seek early EHC Plans in order to draw down additional support and promote effective early intervention before statutory processes are sought).

Where specialist services are required e.g. additional support in pre-school or therapy input to access the early years offer, processes around achieving a joint pot from Early Years Funding and the High Needs Block would need to be further developed.

Some final thoughts

The NNPCF welcomes the Government’s commitment to extending free entitlement to childcare from 15 to 30 hours a week for working parents and ensuring that all children can benefit from high quality early education. But all should mean all!

Currently, parents of children with special educational needs or disabilities struggle to access universal pre-school settings or childcarefor all ages for their son or daughter, due to lack of quality and affordable childcare. Furthermore, many parents are unable to return to work because of their caring responsibilities and/or the numerous appointments that they have to attend with their child. These families may be, therefore, disadvantaged as they will not be entitled to the extended free entitlement.

Funding needs to be targeted to children who require extra support so that they can benefit from the same opportunities as their peers. How that funding is used is also extremely important. Parents need to be confident in the ability to access quality childcare and know that their child’s needs are being met.

The NNPCF would welcome the opportunity to work with Early Year providers to help them to understand the needs of young children with special educational needs or disabilities and their families. Disability Matters is a free and flexible learning resource coproduced with parent carers to help those who work, volunteer or engage with disabled children and young people (from 0 to 25 years) and their families to support them as effectively as they can. It encompasses both physical and intellectual disabilities and is available as both online learning for individuals and face-to-face training for groups.

Annex A – The NNPCF

The National Network of Parent Carer Forums (NNPCF) was launched in 2011, and is funded by central government. We became a formally constituted Group in November 2013. The NNPCF membership is made up of Parent Carer Forums of which there is one in almost every local authority area in England. Each parent carer forum in receipt of the Department of Education participation grant is a member of the NNPCF. The function of the NNPCF is to develop cohesive good practice and effective participation and a solution focused approach at all levels, locally, regionally and nationally.

The aims of the NNPCF are to:

* Ensure that good practice, knowledge and shared expertise about parent participation continues to grow and strengthen.

* Develop a cohesive and coherent structure to sustain and develop the effectiveness of parent carer forums across England.

* Strengthen the pan disability, parent/carer led model of local forums and boost our collective voice.