Scotland's Ten Year Strategy for the Learning Provision for Children and Young People with Complex Additional Support Needs 2017-2026

As presently structured, the document is not as clear as it could be. It assumes considerable pre-existing knowledge of the Doran review, and it would be more helpful to have a section clearly stating the action that has to be taken, who is to take action, the nature of the action, and the timescale. The inclusion of flowcharts and diagrams at relevant points in the document would be useful.
On page 6, the function of the National Strategic Commissioning Group is alluded to, but the NSCG is more fully described for the first time on page 8. Logically, this order should be reversed so that the NSCG is introduced first. Similarly, the description of the functioning of the NSCG on page 11 might be better placed earlier in the document.
A Glossary would be very helpful, especially as the term ‘parent,’ for example, is not defined before it first appears in the document, and thus where the term ‘parent’ is used in isolation it could be read to exclude carers who are not also parents.

See response to Q1 and subsequent comments.

It would be helpful to know if the four objectives all have equal weight. Objective 2’s wording is unclear. Objective 3 is unclear due to the use of the phrase ‘across local authorities’: what does this mean? In what way is this different from ‘national level’?
The link between this strategy and improved outcomes for children and young people are not clear, as noted below.

The use of the term ‘this group’ masks the fact that there is not a homogenous group. The key to adequate resourcing for children with complex additional support needs is that those needs are highly individual. The use of the phrase ‘attainment gap’ raises questions about the nature of the gap. Does the gap only relate to poverty, or does it relate to wider issues related to attainment? How will those wider issues be addressed in the strategy?

General comment: NB list is on page 9, not 8?
Alternative services (such as Applied Behaviour Analysis (ABA) or trauma-informed services) should also be available. Would these be provided under specific headings, or would they be included within the 5 headings below?

Education: A specification of the upper age limit, e.g. 18 or 25 years, would give this a much clearer focus.
It is not clear whether this is seen as part of an Education, Care and Health combined service or separate services. The mention of a national need adds to the uncertainty. Also what is the link between Education, Care and Health services and the Broader Services mentioned later but not referenced here?

As above

As above

This is a confusing statement and the nature of the research is uncertain. Is it about resolving learning difficulties for instance or about providing ways to support better learning or both?

This is not well defined and so it is difficult to comment further. Is it to be aligned with other training e.g. teacher training? Is it linked to the attainment gap or about more general support?

The section headed 10-year strategy only contains an ultimate aim for 2026, and does not describe the stages by which that aim will be achieved. There should be short, medium and long-term aims included, with relevant time-periods assigned. There is, for example, reference to a first phase of ‘pathfinder activity’ but there lacks any detail of when this will occur and what activity will be involved.
The following headings appear without any introduction, so their significance to the 10-year strategy is lost.

There are currently major changes proposed in relation to Education Scotland, SCEL, GTCS etc. The strategy may need to be adapted in its early stages, and some reference to, or explanation about, this should be included.

As this starts with the words ‘This objective’ without explanation, the significance of this paragraph is impaired. As noted above, many of the bodies referred to here are currently subject to review – how will this impact on the strategy?
This section introduces the term ‘optimum outcome,’ which is a different measure than previously mentioned. Fewer, better-articulated outcomes within the whole document would be preferable, and as SHANARRI has previously been referenced, that may be more appropriate here.
There is a requirement for ‘evidence’ but it is not clear whether evidence relates to outcomes, self-evaluation or collaboration. A table or flow-chart to illustrate how the strategy will work in practice would help to clarify the language.
Although the strategy is said to be a phased approach, no indication is given here to show how ‘by 2026’ the national leadership programme will be arrived at. More detail of this is required, and the use of the word ‘should’ leaves it open to question whether this is a mandatory part of the strategy.

The second sentence says ‘they will be developed’ without setting out who or what will be developed. ‘The expectation within an evolutionary Masters Programme’ requires explanation. As previously observed, GTCS’ role is under review – could this impact on the strategy? Further, the strategy appears to focus narrowly on teachers, but ALL practitioners who work with children and young people with complex additional support needs should be included – e.g. classroom assistants, lunch and playground supervisors and transport providers. FE college courses relating to ASN should be brought within the scope of the strategy.

’The comprehensive definition of parent to include carer and corporate parent’ should be set out at the start of the document in a Glossary.
What would the role of the named person be in relation to parental engagement?
The use of the word ‘should’ introduces ambiguity about what is required: the strategy should set out the steps to be taken throughout the ten-year period so that, by 2026, evidence of strong partnership working is available.
A commitment into research over 2016-2018 into the theme of transition is valuable and welcome. However, this statement does not make it clear what action research has been/is being undertaken and by whom – more plain language and concrete detail would be extremely helpful.

There is reference to attainment and achievement outcomes for children and young people, but this seems too narrow a focus, and a broader set of measures that include health, happiness and wellbeing would be preferable. In addition, the fact that some young people with complex additional support needs may also be high achievers should be recognised.
The draft suggests that ‘a range of assessment models’ will be developed. However, at national level there is a move towards standardised assessment, and it is unclear how the assessment models to be developed in this strategy will interact with the move to standardisation.
The role of, and aspiration for, children and young people to be involved and informed about their own assessment, and to plan for the next steps could be set out here.
The strategy sets out some actions to be taken up until 2019, but there is no indication of how the strategy will proceed after those initial steps.

The focus on inter-agency collaboration seems too narrow, and inter-sector collaboration should also be emphasised.

This section begins with the word ‘this’ without indicating what that means, and the whole first paragraph ought to be expanded to make it clearer what sort of performance information is required, from whom, and for what purpose.
Similarly, the second paragraph sets out the wider context but does not make it explicit why the roles of Education Scotland and the Care Commission are highlighted.
This section also uses the term ‘these aspirations’ without explaining what the aspirations are. It would be helpful to provide a table or other graphic to show the stages, throughout the life of the strategy, of the development of relevant performance information, and expected outcomes.

The document leaves open many questions that could be addressed by more detailed explanation. For example, the document could use diagrams, tables or flowcharts to make it clear what actions are envisaged, when action should be taken and or completed, who is responsible for each action, and what the staging points will be along the way to 2026.

The description of the way the NSCG will function, on page 11, raises some questions. For example, there is no mention of collaborative work with health and social care integration bodies, so it is unclear what the role of those bodies in the commissioning process will be, if any. The first sentence of this section is too long, and as a result the meaning is clouded. The final sentence of that paragraph refers to ‘partner agencies’, without any explanation of what agencies could be involved (e.g. statutory, health, voluntary). Similarly, there is reference to ‘the programmes,’ but no preceding explanation of what the programmes will be.
The third paragraph of page 11 reads ‘Changes…will engage,’ leaving the meaning and intention of this sentence unclear.
In the fifth paragraph of page 11, third sector agencies are described as acting as ‘agents of local authorities’ in delivering services. Clarification of this is required, as some local authorities have clear commissioning arrangements, while others do not, and there may be uncertainty about which third sector agencies will be regarded as an agent of the local authority for the purposes of delivering services to children and young people with complex additional support needs.

The definition of ‘complex additional support needs’ on page 6 would benefit from a more expansive explanation. For example, ‘factors’ is not defined, nor is ‘severe.’ Where the definition refers to ‘the impact of specific contexts in different local authorities,’ there is no clear sense of whether it is the impact of the factors or of the local authority context that is relevant. The working definition of complex additional support needs relates to CSPs and local authority decisions around significant additional support; does this bring the potential to put the NSCG in conflict with a local authority, especially in relation to the interpretation of what is ‘significant’? Similarly, there would appear to be room for conflict in relation to paragraph 3: who should attend a grant aided or independent school? How would any such conflicts be resolved?

The explanation, on page 8, of National Strategic Commissioning refers, in para 3, to ‘appropriate research and professional learning,’ leaving it open to question who should undertake either the research or the learning.

The use of ‘home education authority’ in para 5, and ‘residential authority’ in para 6 on page 8 need explanation. As suggested above, a Glossary of terms would be useful.

At the top of page 9, there is a phrase which indicates benefit can be ‘adopted and developed at direct provider level,’ but it is not clear what this means in practice. Further, the next paragraph begins ‘in recognition of this,’ but it is not clear what is being recognised.

The intention of the paragraph on page 9, which begins ‘Broader services which support’ is unclear. Could an example/examples be provided to show what is meant, including the meaning of ‘national need’ and ‘broader services’?

The Commissioning Process is described on page 9, but it would be extremely helpful to indicate the legal and procedural commissioning frameworks that will apply. This links to the description on page 10 of a ‘package of nationally commissioned’ services, which is an unclear description.

In the first bullet point list on page 10, there is a statement that the commissioned services will be able to support parents and carers, but there is no explanation of how this will be achieved, or what such support might look like or be designed to accomplish. Bullet point 5 refers to ‘support’ without specifying the type of support that is envisaged here. Bullet point 8 highlights a need to prevent duplication, but is there a guarantee that this focus will at the same time ensure equality of access to services?

In the section ‘Transition period’ there is reference to three education support services, is this a reference to the three National Services on page 7? It may be that the strategy is not the right place, but will the processes and legislation in relation to grant-making, procurement and transfer of undertakings etc. be set out or referenced, to ensure transparency and good governance?

The strategy refers to a managed transition from the ‘current commitments,’ but the current commitments are not set out in detail, nor is the transition process. There is reference to cycles of commissioning, but again no detail as to which services, or which periods are included in any one cycle. The strategic approach to be taken is not apparent from the document, therefore.

None of the current grant-aided special schools are named, and their future remains unclear to a lay reader. The strategy remains a very ‘broad brush’ document, rather than a practical guide to the future for provision of specialist services to children and young people with complex additional support needs.