Clybiau Plant Cymru Kids’ Clubs consulted with its staff team to collate evidence to inform the Consultation, drawing on their experience of supporting Out of School Childcare settings throughout Wales as well as personal and previous experiences.

· The general principles of the Additional Learning Needs and Education Tribunal (Wales) Bill and whether there is a need for legislation to deliver the Bill’s stated policy objectives;

The training of school, nursery and care staff varies widely, and the observations of these workers could be essential in identifying a need as children may not be in regular enough contact with medical professionals who can make a diagnosis.

Colleagues are aware of cases when the statementing process has taken months or years and support is withheld until the statement is finalised. Some have worked in areas where a diagnosis would not be issued until the children had reached 8 years in the case of neurological disorders.

 Once a statement is finalised as a legal document, it can be difficult to get any changes made.

· any potential barriers to the implementation of the key provisions and whether the Bill takes account of them;

Colleagues have accounts of services being poor, underfunded or unavailable even after a statement is in place. Budgetary constraints on Local Authorities leads to cases of services not being offered or enacted upon. Key posts such as Learning Support assistants and Day Centre staff are filled with unqualified staff who often are not offered training. While many are good and most have the child or young persons best interest in mind, they are left to use their own devices and initiative without a clear code of practice.

Services that should be available are not such as, for example, where there are insufficient Speech and Language Therapists. This leads to those with SALT on their statement not receiving therapy regularly and consistently enough and the programmes not being passed on to school staff to enact upon.

There has been a reluctance to issue Statements, possibly by budgetary constraints with the knowledge that once a service is identified as necessary in a statement then the Authority will be responsible for implementing that service.

· whether there are any unintended consequences arising from the Bill

No-one raised any concerns with this question

· the financial implications of the Bill (as set out in Part 2 of the Explanatory Memorandum

Many of the comments regarding implementation of the current system revolve around budgetary constraints.

· whether the Welsh Government’s three overarching objectives (listed at para 3.3 of the Explanatory Memorandum) are the right objectives and if the Bill is sufficient to meet these

Colleagues saw the benefit of these objectives, as currently families often have only one agency such as a school or social worker to whom they can turn and may be unaware of other agencies and services, including third sector services and charities.

· the provisions for collaboration and multi-agency working, and to what extent these are adequate;

No one raised any concerns with this question

· whether there is enough clarity about the process for developing and maintaining Individual Development Plans (IDPs) and whose responsibility this will be;

Colleagues were aware of individuals who have ALN not qualifying for a statement under the current system, and that those without a statement were unable to access support, causing division and tension.

· whether Bill will establish a genuinely age 0-25 system;

As training providers we are encouraged and required to constantly update the Individual Learning Plans of our students in the light of changing circumstances, and colleagues expressed that the same should be true of any support plan, particularly where relating to ALN

Colleagues expressed that a plan should be flexible enough to recognise different levels of need to avoid some being stuck between different plans or systems

There is a view, sometimes expressed by professionals, that getting a statement is ‘labelling’. Hopefully a new system can work to remove any stigma

· the capacity of the workforce to deliver the new arrangements;

Sometimes a child is supported by numerous other bodies that can have a valuable input into a child’s wellbeing.

In an ideal world, all relevant agencies would indeed work together and provide services around the most needy. However conflicting priorities inevitably lead to tensions and as consequence silo mentality often wins.

· the proposed new arrangements for dispute resolution and avoidance

No-one raised any concerns with this question.