Our response to the SEND Reforms Consultation

Dear Secretaries of State,

Whole Education is a network of educational leaders working to support the holistic development of children and young people. We are using our collective voice to share our hopes and cautions about the proposed SEND Reforms, in a spirit of working productively to ensure the best possible education for all children and young people.

Welcome signs of change

We are passionate about every child and young person succeeding in school, and welcome the White Paper’s focus on both achieving and thriving. Within our current system, there can sometimes be a conflict for school leaders between learners achieving and learners thriving; one can come at the expense of, not in tandem with, the other.

We welcome the desire for every child to receive an education that meets their needs. We believe the proposed SEND reforms contain several elements that make this aspiration more likely in reality.

We welcome the focus on educators fully understanding and ably supporting children and young people. We see the focus being placed on providing support earlier, on the importance of belonging and on the need for children and young people to have secure and trusted relationships in school. We welcome the support available to children and young people at the proposed ‘Targeted’ and ‘Targeted Plus’ layers, which is higher than may be possible at the ‘SEN Support’ tier currently.

We recognise the emphasis on supporting and developing staff working in early years settings, schools and colleges. We welcome the additional training for all staff members around SEND and Inclusion, including through providing greater access to external, specialist staff, and including where this comes through an enhanced outreach offer from special and AP providers. We see great benefit in a wider range of experts supporting teachers and leaders with provision linked to the proposed ‘areas of development’ at every layer of support.

Networks are vital to us, and we endorse the expectation that all settings work in partnership with others in their local area. We welcome the desire for collaborative working that runs through the proposed reforms: between MAT and Local Authority; between specialist and mainstream settings; between education, health and social care.

We are pleased to see the desire for children and young people’s voices to be heard, where too often they are not.

We are broadly in favour of children and young people’s needs being defined in terms of child development, rather than primarily through a diagnostic label.

While currently expectations around inclusive practice vary greatly between schools, we see the potential of the Inclusive Mainstream Fund, a published Inclusion Strategy and a mandatory Inclusion Base to drive every school towards inclusive practice, rather than some schools ‘opting in’ to inclusion and others not feeling a need to (Sutton Trust, 2026). 

Concerns to share

Our network also has some concerns about the potential unintended consequences, or implementation challenges, around some of the proposed reforms.

Reassurance for families

Though we recognise the benefits of being able to provide support early, and without waiting for the outcome of statutory assessment, there are families expressing concern about thresholds for EHCPs changing. There are families expressing concern about the protections parents will be afforded under the legal changes proposed, including their right to redress. We would like to be able to reassure them. 

We hear concerns from families that ‘packages of support’ will depersonalise their child’s EHCP; that they’ll lose the sense of the individual and their needs within these new documents. We would like to be able to reassure them.

Transition

Our network is all too aware of the risks for children and young people around transition, particularly for many with SEND. National data on engagement, attendance, suspensions and more (DfE, 2024; ImpactEd, 2026) suggest this is an incredibly tricky time for children and young people, especially in the transition from primary to secondary school. 

We believe reviewing their needs at transition points will become a time of conflict – for parents concerned about how their child will succeed in a new setting; for schools concerned about how the child’s needs will be met in their next stage of education - which may even delay an effective transition process from commencing. We see sense in students with an EHCP having their needs reviewed after the transition, rather than prior to it.

Accountability and inspection

Many of the schools in our network pride themselves on their inclusive practice, and yet are punished through accountability and inspection measures for being so inclusive (NAHT, 2026). Though we are pleased to see the acknowledgement that, currently, accountability measures can be a barrier to inclusion, we await further information around how this will change, so that inclusion is recognised and rewarded, rather than punished. This includes the Department’s proposal to make changes to the Progress 8 measure.

‘Experts at Hand’

While we are pleased to see a greater role for external specialists (clinicians, therapists, leaders in special schools and others) in supporting mainstream schools, our network members feel the current lack of service acutely, and await to see how considerable additional capacity can be delivered here. This will have to include making these professions attractive enough for people to train and to remain. Our members are also keen to see how these services will be commissioned locally under a new system.

We also worry that the language of ‘Experts at Hand’ risks undervaluing the considerable expertise that exists already in many mainstream schools, situating expertise outside of schools and in specialist domains only.

The SENCO role

We are pleased to see recognition of the difficulties inherent in the SENCO role as it currently stands. These difficulties may increase further, with SENCOs needing to prepare for national changes, and the potential increase in EHCNA requests that may come in the medium-term, as a result of changes to EHCP thresholds.

In light of those changes, we are unclear currently what changes will be made here, and hope to see proposals that can support effective leadership of SEND. While these may include proposals to protect SENCO time, they should also explore models of schools and MATs building teams to drive SEND provision in their setting(s). 

While we broadly welcome the move towards Individual Support Plans for all children and young people with SEND, clear guidance will need to be provided around how these can be implemented without adding to the paperwork demands of SENCOs, and without placing strain on schools’ relationships with their families. Due consideration must also be given to the inherent differences between how an ISP can support provision in primary, and how it may need to be different in secondary.

With all these changes and more, we see a need for SENCOs to be supported to implement any new changes.

Staff training and development

We are keen to see how the much-needed improved training offer will align with research evidence around effective professional development, away from one-off sessions and towards longer-term, embedded support that builds on colleagues’ current practice and that embeds health and social care expertise where required. 

We are keen to understand how this training will assist those colleagues supporting pupils with higher levels of needs, including through Inclusion Bases.

We are particularly keen for the Department to consider any relevant contractual issues, where schools need to commit additional time to staff training and development.

Investment

Finally, of course, this is about investment. While we agree our sector can spend its finite money well by focusing more of it on high-quality, local and early support, we also hear the concerns of our network that, when breaking down the total new investment into what it means per school, the work it allows may not match the high ambition of the Department.

We are keen to work in positive cooperation with the Department, as the proposed reforms enter their next steps, using the collective power of our network to support the best possible changes for children and young people with SEND.

We welcome your response.

Yours faithfully,

Whole Education’s MAT SEND Leadership Network

Signatories:

  • ACT Trust

  • Alice Crawford, Senior Educational Psychologist and Inclusion Team Lead, Laidlaw Schools Trust

  • Alison Monkley, Trust Director of SEND (Secondary), Turner Schools

  • Amy Daniels, Director of Inclusion, Cornwall Education Learning Trust

  • Amy Wright, Assistant Director for SENDV, Meridian Trust

  • Andrew Cooper, CEO, South East Essex Academy Trust

  • Anna Mackenzie, Chief Education Director, Northern Star Academies Trust

  • Antonia Drysdale, Director of SEND, CAM Academy Trust

  • Ben Spinks, CEO, Middlesex Learning Partnership

  • Beth Tanton, Director of SEND (Mainstream), Compass Eko Trust

  • Claire Attrill, Director of Inclusion, New Collaborative Learning Trust

  • Daniel Copley, CEO, Emmaus Catholic Multi Academy Trust

  • David Bartram, CEO, Prescient Education

  • Dean Jones, Chief Strategy Officer, Turner Schools

  • Debbie McGloin, Director of Education and School Improvement, True Learning Partnership

  • Debra Roscoe, Head of Inclusion, Pioneer Educational Trust

  • DOWMAT

  • Emma Morrogh-Ryan, Education Director

  • Emma Neagle, SEND Director, CAM Academy Trust

  • Emmaus Catholic Multi Academy Trust

  • Esther Messinger, Headteacher

  • Fahema Hussain, Inclusion School Improvement Lead, St John Paul II Multi Academy

  • Faith Buckley, Lead SENDCO, Newman Catholic Trust

  • Gary Aubin, Director of SEND, Whole Education

  • Ivy Education Trust

  • Jane Goodfellow, Trust Director of SEND, Prospere Learning Trust

  • Jude Macdonald, Director of Inclusion, Keys Academies Trust

  • Kate Hinks, Head of SEND, Excalibur Academies Trust

  • Kate Woods, CEO, White Woods Primary Academy Trust

  • Kelly Nash, School Improvement Director - SEND, Maiden Erlegh Trust

  • Kelsey Clark-Davies, Director of Inclusion, Anthem Trust

  • Ladan Shirazi, Director of SEND and Safeguarding, Scholars Education Trust

  • Lisa Henshall, SEND Strategic Lead, St Bart’s Multi Academy Trust

  • Liz Stewart, Senior Leader SEND and Inclusion, Emmaus Catholic Multi Academy Trust

  • Lorna Croucher, Director of SEND, LiFE MAT

  • Lou Coles, Trust SEND Lead, Cabot Learning Federation

  • Marios Solomonides, Director of SEND

  • Melanie Wicks, Executive Principal (Secondary), Stamford Park Trust

  • Mike Garlick, Director of Strategy, Development and TKAT ACE, The Kemnal Academies Trust

  • Natalie Conway, Head of SEND, The Pioneer Academy Trust

  • Nicola Keeler, Director of Education, Ted Wragg Trust

  • Nicola Taylor, Trust Lead for SEND, Bishop Bewick Catholic Education Trust

  • Pam Doyle, Trust Director for SEND

  • Paul Cornish, Executive Director of Education, Ivy Education Trust

  • Pele Trust

  • Rebecca Bliss, Director of Inclusion and Safeguarding, ACT Trust

  • Sara Walton, Director of SEND and EAL, The Kemnal Academies Trust

  • Sarah Milne, Director of SEND & Safeguarding, Three Spires Trust

  • Severn Academies Educational Trust

  • Shonogh Pilgrim, CEO, Whole Education

  • St Bart’s MAT

  • Stamford Park Trust

  • Susie Weaver, Education Director, Cabot Learning Federation

  • Ted Wragg Trust

  • The White Horse Federation

  • The Keys Academies Trust

  • Tina Murphy, Trust SEND Leadership Group Lead, Swale Academies Trust

  • Verity Lush, Assistant Headteacher: Inclusion/SENDCO

  • Vicki Shelley, CEO - DOWMAT

  • Vicky Prudham, Multi School SEND Lead

  • White Woods Primary Academy Trust

References

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Our thoughts on the proposed SEND Reforms