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Response to the Department for Education’s stage two consultation on high needs funding formula and other reforms

The High Needs National Funding Formula (NFF) proposals will be in place for at least four years, according to the Stage 2 consultation documents. Therefore, it is essential that the NFF provides a robust and equitable method of funding provision and services for children and young people with special educational needs and disabilities and vulnerabilities.

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Key points

  • The fundamental issue that needs to be resolved is that for several years the High Needs Block funding has been insufficient to reflect rising needs. In the past four years there has been a substantial increase in the proportion of pupils with special educational or disabilities (SEND) who attend specialist school setting, up from 5.6 per cent in 2012 to 8.5 per cent in 2016. The proportion in independent schools has moved from 4.5 per cent to 6.3 per cent.
  • In acknowledging rising needs, the Government needs to provide additional funding to meet the pressures. Otherwise councils may not be able to meet all aspects of their statutory duties. We acknowledge the Department for Education (DfE) has provided some extra funding since 2015/16, but this has been allocated on the basis of the total number of children in an area, rather than any measure of the number of children with complex needs.
  • If councils do not receive sufficient funding to cover high cost SEND, they will not have the resources to allocate extra funds to highly inclusive schools that take higher than average numbers of pupils with additional needs. Equally, mainstream schools may find it difficult to accept or keep pupils with SEND because they cannot afford to subsidise the provision from their own budgets, as they are already under significant pressure.
  • The DfE has missed the opportunity to use their own independent research, undertaken by the ISOS Partnership, to develop a responsive formula, and have made some simplistic assumptions which cannot be justified. This will not target funding to the needs of individual children and young people. There are significant questions over the suitability of indicators, the weightings and timeliness of the data used.
  • The potential for transfers of funding from school budgets for a limited period to fund high needs pressures may not be realised, depending on the outcome of the Schools National Funding Formula in local areas.