APPENDIX 8
Memorandum from the National Deaf Children's
Society
The National Deaf Children's Society is the
leading voluntary organisation concerned with the education and
well-being of deaf children, their families and carers. We run
an information, advice and training service for parents, deaf
young people up to 25 and professionals. The Society has 10 regional
staff which includes a Development Officer in Northern Ireland
who is assisted by the Society's Education Adviser. Our response
has been added to and agreed by four local Deaf Children's Societies
in Northern Ireland. We hope you will accept this as a holding
response until such time as we receive case study evidence
from contacts with Northern Ireland. We received the document
only very recently.
We are pleased to be invited to comment on the
above. However, given our role as a voluntary organisation, we
feel it is appropriate to restrict ourselves to addressing the
following three issues identified in your letter of 9 March 1998.
1. Delays in the assessment and statementing
process.
2. The implications of parental right to
request an assessment.
3. Shortfalls in provision.
1. GENERAL COMMENTS
1.1 Whilst we approve any measures to improve
financial planning in SEN and the most cost-effective use of public
funds, we are disappointed by the implied notion of reduced access
to the assessment and statementing process. Without clarifying
the purpose of reviewing the effects of the parental right to
request a statutory assessment, parents may be forgiven for thinking
that access to a statement is likely to be restricted. We would
welcome clarification on this or indeed any reassurance that the
Committee can give.
1.2 We would strongly oppose any proposal to
establish a mandatory or non-mandatory quota on the proportion
of children issued with a statement. This is a feature of Green
Papers in England and Wales. The Society believes that such quotas
will remove an essential safety net and guarantee of some provision
from outside the school's resources for many children with moderate
to severe hearing loss. The quota in England and Wales is actually
based on a figure from work by educational psychologist Cyril
Burt based on London's special school population in the immediate
post-war period. It would have no validity for Northern Ireland
today. Again we would welcome any reassurance that the Committee
may be able to give to parents.
1.3 However, we are pleased to see that the
Committee will be looking at shortfalls in provision and the causes
of delays in assessments and the production of a statement.
2. DELAYS IN
THE ASSESSMENT/STATEMENTING
PROCESS
From our experience delays are caused by:
— lack of information and awareness
by health and by social services staff in referring newly diagnosed
deaf children, largely of pre-school age, to education services;
— parents' lack of information about
rights and procedures;
— complex and multiple needs which
may require highly specialist reports/input;
— ELBs proposals to issue several amended
draft statements;
— lack of clear criteria as to when
a reassessment is needed, e.g., following an annual review;
— parents receiving details of school
options just before issue of draft statement (which means parents
may need more time to visit schools before expressing a preference);
— difficulty in finding a suitable
placement.
3. PARENTAL RIGHT
TO REQUEST
A STATUTORY
ASSESSMENT
NDCS is very strongly opposed to any proposal
to withdraw the parental right to request an assessment. In the
past we have seen schools refuse to instigate the process despite
the fact that changes to Stage III provision have not worked.
Relying totally on the school's decision would seem to go against
principles of democracy and the notion of parents working in partnership
with professionals.
4. SHORTFALLS IN
PROVISION FOR
DEAF CHILDREN
4.1 NDCS would like to see more accurate measures
of the academic attainments and personal achievements of deaf
children. Whilst there exist many instances of good practice throughout
the UK, we are aware that there are no nationally agreed standardised
assessment tools to measure the real cognitive abilities of deaf
children, regardless of communication method. NDCS is to be involved
in a national initiative which is to begin this year to try and
resolve this issue and to set standards in assessment. However,
we are also aware that there is a need for all professionals,
including mainstream staff and learning support assistants, to
be aware of appropriate methods of testing, how to apply them
correctly and to draw the right conclusions. We recommend therefore
that the Committee and Department of Education for Northern Ireland
consider the training needs of such staff in this area.
4.2 Although a high proportion of deaf children
may have additional needs, deafness itself is not a learning difficulty.
Deaf children may find themselves disadvantaged in terms of access
to the curriculum on account of prior language input difficulties
and because the major part of lessons is delivered through the
spoken word. We would therefore recommend that DENI investigates
the training needs of school boards, mainstream staff, educational
psychologists, school inspectors and education officers in appropriate
communication methods and the educational, social and developmental
implications of deafness. They will also need training in listening
to and involving parents and deaf children.
4.3 We recommend that consideration be given
to the national shortage of teachers of the deaf and speech and
language therapists. Deaf children's needs for such therapy is
rarely medical unless, for instance, they have a disfigurement
which requires physical rehabilitation or medical intervention.
Despite guidance in the Code of Practice, speech therapy continues
to be specified in Parts V and VI of a statement as a non-educational
need. As language and, for many children, speech are the building
blocks of learning and fundamental to expressive and receptive
communication, without such educational therapy deaf children
will fail to access the Northern Ireland Curriculum and the overall
school curriculum. This may even jeopardise requirements on Part
III of a child's statement of needs and school board's legal duty
under the Education Order 1995 to ensure that children with SEN
are able to join in the life of the school. Research by the Royal
College of Speech and Language Therapists revealed that there
are only 38 therapists with the Additional Clinical Skills Qualification
in administering such therapy to deaf children.
4.4 Advances in medical science now mean that
congenital hearing loss can be detected within days of birth.
Early identification of deaf children has great implications for
pre-school provision. Parents will need high quality information,
advice and specialist input to develop language as early as possible.
The early stages are critical for language acquisition and, if
deaf children are to keep up with their hearing peers, Early Years
Development Forums and Plans will need to consider how they apply
specifically to deaf children in order to avoid the specific needs
around deafness becoming lost or diminished within a generic plan.
4.5 We would like to see a legal duty on children's
services to provide post-diagnosis support in terms of the educational,
social and development implications of deafness.
4.6 We recommend that all schools with deaf
children should have a text telephone, fax, CD Rom and video telephone.
This would allow educators to develop early keyboard skills. There
should also be national and international link-ups with the Internet
and a phased introduction of video telephony which would help
deaf children in rural areas.
4.7 We recommend that all Education and Library
Boards be required to carry out regular, perhaps triennial, audits
of adaptations for deaf children in order to make mainstream and
unit learning environments more accessible. It is important that
schools and Boards work towards improving acoustic environments
and creating quiet spaces so that deaf children can make maximum
use of residual hearing.
4.8 NDCS maintains a policy of parental right
to choose a communication method and hence a type of school placement.
Such decisions should be made upon the basis of clear, high quality
and impartial information on the full range of options to enable
patents to express an informed choice. Parents' concerns need
to be listened to and it is our experience that many lack adequate
awareness of help and provision available during the statementing
but particularly during the school based stages of assessment.
4.9 We recommend therefore, that parents are
made aware of rights, procedures, options and sources of help,
i.e., NDCS, at all stages of assessment. Access to independent
support at the earliest possible opportunity may help head off
or defuse conflict between parents and professionals. Advocacy
support and unbiased and timely information may prevent parental
anxiety and suspicion that Board staff are acting unilaterally
and without regard to parental viewpoints and observations.
4.10 Many deaf parents have deaf children. Deaf
parents will need equal access to the range of information about
assessment/statementing and this may need to be provided through
alternative formats, e.g., signed and subtitled videos or through
communication support workers or staff with appropriate communication
skills. Similar consideration needs to be given to deaf parents
from ethnic communities whose first language is not English.
4.11 The new independent tribunal system is
a much fairer system of appeal. However, tribunals may be hamstrung
by the fact that they are unable to specify a date by which an
ELB must comply with an order/decision. In England and Wales where
the tribunal system has been in operation for over three years,
some LEAs have resorted to inordinate delays in placing children
or even failed altogether to fulfil provision on Part III of a
Statement, thus causing the family to have to appeal directly
to the Secretary of State. Tribunals should establish timescales
in consultation with parents and providers.
4.12 NDCS is concerned by the proposal in the
current draft Education Order concerning local management of schools
which allows schools to vire money for SENs to other categories
of expenditure; the only requirement being that delegated funding
is spent "for the purposes of the school". We therefore
recommend that LMS funding for SENs be ringfenced.
4.13 We believe there is a conspicuous shortfall
in provision for under twos. For all children this is a critical
time in language acquisition and development. However, parents
of deaf children take longer to learn new skills to help their
child's communication and development so many early language learning
opportunities are lost. We therefore recommend that there should
be some statutory provision for deaf children under two
in the form of a peripatetic teacher of the deaf conducting home
visits to empower parents to take responsibility for their child's
learning and development. With new money coming into the Province
for nursery placement for three-year-olds, we believe that deaf
children should be a funding priority. Similarly, many four year
old deaf children in nursery provision will require enhanced funding
above the current £1,100 allowed if they are to be integrated
or have their special needs met in a specialist setting.
4.14 A particularly important aspect of education
for many deaf pupils is the development of self-esteem and a positive
deaf identity. Much of this hinges around good communication and
language skills, an age appropriate deaf peer group, deaf-aware
staff and access to deaf culture and deaf adult role models in
education settings.
2 April 1998
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