SUPPLEMENTARY MEMORANDUM FROM THE NORTH
EASTERN EDUCATION AND LIBRARY BOARD
At the meeting of the Northern Ireland Affairs
Committee held on 22 July 1998 we agreed to forward our response
to the Northern Ireland Audit Office investigation into Special
Education[3]
which was forwarded to the Department of Education.
I enclose a copy of the response for your information.
NORTHERN IRELAND AUDIT OFFICE REPORT
GENERAL COMMENTS
It is pleasing to note that some of the issues
raised in relation to the previous draft have been addressed but
there are still areas of concern.
Many of the recommendations are staff intensive
and as staff are already over stretched how can these be taken
forward without taking funding away from children and schools
to appoint additional staff?
The timing of this document is strange as it
is reporting on a system that is in the process of change. Many
of the issues raised will be addressed by the implementation of
the new legislation.
BY PARAGRAPH
Paragraph 2.4
Clarification is required as to the meaning of
a "better point of contact". Within the NEELB there
is normally a member of staff available who can deal with enquiries,
but often people are unwilling to accept an answer other than
one from the head of the Branch. Furthermore the present level
of staffing cannot cope with any increased level of personal contact.
Also it is important to highlight the use of the word "perceived"
in this paragraph with regard to parents' perceptions of the cohesion
with education and health services. The Special Education Branch
in the NEELB has good lines of communications with the Health
Trusts covering the NEELB.
Paragraphs 2.8 and 2.9
It is difficult to see how the suggestion of
a panel, which would sit on an ad hoc basis, would work
as resources are allocated on the basis of the needs of individual
children.
Paragraph 2.11-2.12
The Board, in line with DENI policy as outlined
in Circulars issued at the time of the 1984 Order, has always
maintained that statements will only be required to protect resources
which are not normally available. To do other than this would
increase the number of statements far beyond the 2 per cent target
which is used as measurement. Where assessments have taken place
and no new resources are required, Notes in Lieu can be written.
If this is not the case, it raises the question who should be
responsible for the monitoring of children who do not require
additional resources provided by the Board? Following the logic
of this through would mean all children with special educational
needs should be monitored by the Board. Where then does a Note
in Lieu fit in? There would be significant staffing implications
for the Board if monitoring any greater number of children.
Paragraph 3.12
A very slow process and health representatives
are very reluctant to address individual issues. The health approach
is that the levels of service provision should be negotiated locally.
Figure 3
Are the comparisons with equivalent local education
authorities?
Paragraph 2.18
Reference is made to "greater precision"
being required in criteria but is this what is meant? Precision
will not change rates for assessing or maintaining statements,
but higher thresholds in the criteria should.
Paragraph 2.20
There is a need for clear criteria, and the Designated
Officers from all the Boards have met to discuss this issue and,
as in other cases where this has been attempted, found it extremely
difficult. If standardisation is an issue why is this not through
the legislation or Code of Practice?
Paragraph 2.21
Will clear criteria help when it comes to a Tribunal?
Paragraph 2.25
Educational psychologists recognise the importance
of maintaining the highest professional standards in the delivery
of their service to schools, pupils and their families and on
a province-wide basis, there are already in existence a number
of mechanisms to support educational psychology services in this
endeavour.
All psychologists have the opportunity to come
together under the umbrella of the Northern Ireland Educational
Psychologists Group to discuss issues of common professional consideration.
The Principal Educational Psychologists from
the five Boards meet on a regular basis to discuss issues of a
professional nature. Presently a sub-group of the Principal Educational
Psychologists Group is meeting to look at methods for identifying
pupils with dyslexia and hopefully this will provide a common
framework for psychologists' work in the future.
Queens University of Belfast provides continuing
Professional Development Courses for all educational psychologists
across the five Boards. This provides a common form of continuing
training. Indeed, the majority of educational psychologists employed
in the province have received their post-graduate professional
training at QUB.
The majority of practising educational psychologists
in Northern Ireland are members of the British Psychological Society,
which provides to its members a Code of Practice of professional
behaviour, and information and guidance on professional practice
issues. On this latter point, a division of the British Psychological
Society, (The Division of Child Psychologists) and the Association
of the Educational Psychologists have produced a joint guidance
document, presently in draft form, which provides guidance to
psychologists on assessment and on reporting. Psychologists in
the Boards are giving cognisance to this document in their daily
practice.
It should also be noted that the clinical decisions
which psychologists make regarding individual children would have
a high degree of commonality from one psychologist to another.
However, the practical implications of those clinical decisions
have to be moderated within the context of each Education and
Library Board's Special Educational Needs Policy and, within each
Policy, the criteria which each Board uses for making provision
for pupils who fall within the various categories of learning
difficulties. In other words, how the needs of individual children
will be met will be determined by local Board policy and criteria,
and through the Designated Officer for special education. The
implication of this process is that there should be a good working
relationship between the Designated Officer and the Principal
Educational Psychologist in each Board—this is the case
in the NEELB and certain objectives in the Education Department
Business Plan have been agreed by these officers so that on certain
issues there can be co-ordinated action.
Also, Education and Library Boards will deploy
their psychology services differently. In the NEELB, the Educational
Psychology Service is moving towards strategic deployment and
its activities are becoming increasingly integrated with other
Board services for example, the Education Welfare Service, the
Youth Service and the Curriculum Advisory Support Service. This
provides the Board with a framework for strategically deploying
its staff so that schools and children's needs can be met appropriately
across all stages of the Code of Practice. Using this thinking
it is likely that educational psychologists will become increasingly
involved in INSET with CASS officers, consultation with schools
on broader educational issues (e.g., discipline/behaviour, child
protection, bullying), and working with individual pupils prior
to Stages Four/Five of the Code of Practice. This refocusing of
the deployment of the Educational Psychology Service in this Board
is consistent with views put forward in the recent Green Paper
entitled "Meeting Special Educational needs" published
in October 1997, in which it is recognised that educational psychologists
employed by LEA's have wide responsibilities. The Green Paper
says "We will explore ways of changing the balance of the
work of educational psychologists (away from statutory assessment),
so that they can use their expertise as productively as possible."
In summary, three general points can be emphasised:
1. There are mechanisms for developing and enhancing
common professional standards among psychologists already in existence,
and there is room for future development along these lines.
2. Each Board should have the freedom to deploy
its psychological service appropriate to local needs and local
structures.
3. It is likely that there will be changes to
the nature of educational psychologists work as the recommendations
of the Green Paper are implemented.
DENI, in its discipline strategy document "Promoting
and Sustaining Good Behaviour" published in February 1998,
has indicated that the current functions of the Educational Psychology
Service in each Board will be examined to determine the most efficient
ways of working and making recommendations on freeing up educational
psychologist's time. Those engaged in that task may wish to develop
a common five-board approach in deciding the functions of the
Educational Psychology Service, but which will allow flexibility
on the deployment of the Educational Psychology Service in each
Board to reflect local needs and structures.
Figures 4 and 6
Shows NEELB taking about 24 months for the statementing
process over the period 1994-1997. However, the Special Education
branch was only established in 1994 and that now there is no backlog
of statements and the Board is working within the recommended
timescale.
Paragraph 2.28
This paragraph would appear to be inaccurate
regarding the Code of Practice and time scales.
Paragraph 2.33
NEELB has the SIMS management software so that
there is compatibility with the software in schools which should
facilitate electronic transfer of information in the future.
Paragraph 2.35
Indicates that "where educational and developmental
objectives were stated in psychological advice these were weak".
It is noted that this comment resulted from the examination of
a random sample of statements across the five Boards from 1994
to 1996. Reference has already been made to the draft guidance
for educational psychologists on the preparation of statutory
advice, which only was circulated in the early part of 1996. Also,
in March 1996, DENI published the draft Code of Practice on the
identification and assessment of special educational needs. The
draft regulations set out in this document indicate clearly what
should be included in each part of the statement of special educational
needs. Using these two documents as a framework, the educational
psychology service in the NEELB is, developing a working document
which provides psychologists with clear advice on carrying out
assessments and on writing statutory psychological advice. This
is ongoing work and should result in the enhanced quality of advice
being submitted as part of formal assessment.
Paragraph 2.37
Refers to the lack of clearly established objectives
in statements, but this is only a requirement this year.
Paragraph 2.40
There is no recognition of the difficulty with
parents and schools when it is proposed to no longer maintain
a statement.
Paragraphs 4.13-4.15
Devolution of resources would increase the monitoring
of resources and probably require additional staff.
Paragraph 4.16-4.30
This is an area of on-going debate and as yet
no definitive answer as to the most equitable method has been
found. Each proxy has advantages and disadvantages. It is imperative
not to reward schools for failure and penalise those doing a good
job.
Paragraph 5.16(a)
States the information is not used in this way—to
whom are they referring? In the NEELB, the unit costs are examined
to facilitate comparisons of schools for the same learning difficulty
and size. When there is a noticeable discrepancy, it is investigated.
Paragraph 5.17
In this report, what is seen as performance and
improvement? This would depend on your perspective. If it is simply
in financial terms there would be conflict with schools and parents
regarding the needs of the pupils being met.
Paragraph 5.22
Consultative procedures are already in place
in the NEELB.
Paragraph 5.36
With the limited number of staff available, the
recommendation in this paragraph is unreasonable. If all psychologists
and special education officers were to attend the annual reviews
for all children attending special schools it would entail at
least 27 hours of additional meeting time. This may not seem
much but everyone already has more work to do than time allows.
Paragraph 5.37
As Boards are under pressure to reduce central
administration, it is unlikely that there would be a redeployment
of staff particularly at an appropriate level.
Paragraph 5.41
Does the legislation require schools to include
Targeting Social Needs Funding in the report on their special
needs provision?
Appendix 1
Is confusing. The first heading in the first
column includes education psychology, and if the two asterisks
are followed up the Central Support Services heading also includes
educational psychology services. This casts doubt on the validity
of the figures.
28 August 1998
3 Published as "Special Education in Northern
Ireland: Report by the Comptroller and Auditor General for Northern
Ireland", HC 898 (1997-98). Back
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