1. Pre-school

· There is currently not enough detail/clarity in the Bill on the process from birth to entry into school, particularly for Health and preschool providers.

· How will OPPs and subsequently IDPs be developed pre-school?

· Who will be responsible for developing them and who will take on the co-ordinating role for the plans?

· Is this likely to be the ‘Lead Officer’ model, or will there be a designated ‘Support Co-ordinator’?

· How will training service-providers in PCP etc. be undertaken?

2. Inclusion

All teachers are teachers of ALN: One of the strategic drives for ALN reform is to dovetail with ‘Donaldson’ and his ‘Successful Futures’ agenda for the benefit of ALL pupils.  The Bill outlines that support should be provided from the moment it is recognised as being needed i.e. there should be no ‘false barriers of waiting’ created. How will this actually work on the ground?

3. Health

Links with health still do not appear to be strong enough through the Bill.  It needs to be worded in order to tie in commitment from health.

4. Parental engagement

· Transparency, advice and advocacy for parents are vitally important. The Welsh Government should consider something along the lines of the English system’s ‘local offer’ for ALN, and also consider co-production to engage children and parents more effectively.  Organisation of ‘parent forum’ and ‘children’s forum’?

· Information, advice and provision locally need to be revised and mapped out, with regional websites considered to share this information.   Can this be linked in/integrated with the same requirement for the Social Care and Wellbeing (Wales) Act?

5. Tribunals

The Bill provides increased opportunities to go to tribunals and it is felt that there are now too many stages, with more options for challenge by parents/young people.  This is likely to elongate the process further.  This is also likely to incur additional cost.

6. Disability

Looked After Children are considered in the Bill, but the same degree of detail is not applied to protecting children/young people with disability.  It is felt that the same amount of detail/support should be applied to this group of children so that their needs are as fully considered, and are as fully protected through the requirement of an integrated plan from birth to transition to adulthood.

7. Educational Psychologists Role

There is a mandatory role in the code, but what exactly will the role entail?

There is a challenge to attract more people to train as EPs and to work for LAs.   With this in mind, EP salaries need to be reviewed as a matter of urgency, in order to bring them in line with our skill set (currently other professionals, who are less qualified, are being paid far more). Perhaps we could consider the use of the person-centred tool ‘Roles and Responsibilities’ to clarify the future EP role.  There are also implications here for training - Cardiff University/WLGA – may need to consider an increase in the size of the cohort of trainees, increased funding for training etc.

8. Workforce Planning

Links to above. This is seen as being central to the reforms. Will there be enough ECPs/teachers of visually and hearing impaired? This is very unlikely given the current difficulty with recruitment and austerity measures being implemented by LAs. Will the WG consequently direct LA/Councils to employ more EPs and expand services, rather than making cuts?

9. Costing

Are the figures realistic? Have the reforms been costed thoroughly, in order to take into account probable increased workforce, training and embedding of PCP etc.

10. Raising capacity of schools – universal provision

The majority of authorities have special provisions at full capacity. The initial ‘rainbow diagram’ proposed by WG focused on development of universal services.  What is planned with regards to raising capacity in mainstream schools, working in collaboration with SCIMP, Social Services etc.?

11. PCP

· How are LAs and WG going to monitor consistency of PCP?  We are already witnessing diverse practice, some of which is already diverting away from a truly person-centred approach.  How will LAs and the WG ensure good quality PCP?

· If we are advocating person-centred practice, should the LAs become person-centred organisations to embed the process?

o Person-centred team meetings

o Person-centred supervision

o Person-centred documentation