SUPPLEMENTARY MEMORANDUM FROM THE SOUTH
EASTERN EDUCATION AND LIBRARY BOARD
NORTHERN IRELAND AUDIT OFFICEREPORT
ON SPECIAL EDUCATION
1. A review by the Northern Ireland Audit Office
of Special Education is to be welcomed. However, the report is
confusing in that it is based on practices and procedures operated
prior to the introduction of the Education (Northern Ireland)
Order 1996 and the Education (Special Educational Needs) Regulations
(Northern Ireland) 1997. As a result of this new legislation,
which came into operation on 1 September 1997, the Board has revised
its procedures and consequently addressed many of the issues highlighted
in the report.
The investigative work on which the report is
based took place early in 1997 prior to the introduction of the
new legislation. The report does not establish clearly this timeframe.
2. The Board would wish also to record that
the report does not take into account all expenditure on special
educational needs. A substantial proportion of the Board's expenditure
on transport results from arrangements for children with special
3. Paragraph 1.7 Prior to September 1997,
there were also statutory requirements on the Board. This paragraph
implies that little if anything took place pre-1997. The report
needs to establish the statutory requirements prior to September
1997 and the new requirements after the introduction of the 1996
Order and emphasise that the review is based on pre-September
4. Paragraph 1.11 The management of special
educational needs resources is also becoming increasingly difficult
because of limited finance available generally and the difficulties
that the Board has in managing conflicting priorities.
5. Paragraph 1.12 The report is not an
examination of recent performance but of performance early
in 1997 prior to the changes introduced by the 1996 Order. A number
of "improvements" identified in the report have already
6. Paragraph 2.4 Reference is made throughout
the report to the "statementing process". This is a
misnomer which reflects the view of many people, including parents,
that the outcome of a statutory assessment of special educational
needs will be a statement. Indeed the Code of Practice makes it
clear that the outcome may not be a statement but a recognition
that the child's needs can be met within his/her school's existing
resources. Use of such terminology can lead on the one hand to
unrealistic expectations among some parents and schools that the
child will require/is entitled to additional resources and on
the other to increased anxiety amongst other parents that their
child will be "labelled".
7. Paragraph 2.9 The Board is actively
reviewing its practice in relation to this recommendation.
8. Paragraph 2.10 The drive among schools
to refer children for statutory assessment is related to the pressures
created by open enrolment and the publication of results.
9. Paragraph 2.13 The Board would be
concerned if consideration was being given to the introduction
in Northern Ireland of the Scottish model, whereby education purchases
speech and language therapy from health authorities. There would
be a concern that such arrangements could lead to a significant
increase in both the number of children assessed as requiring
speech and language therapy and in the amount being advised. The
Board would question whether such a model provides value for money
10. Paragraph 2.20 The Board is supportive
of the concept of standardisation across the Education and Library
Service of criteria for identifying and assessing special educational
needs. The Board believes that there is a need to establish a
strategic plan for special education within Northern Ireland and
would welcome the establishment of a representative group at senior
level from the Boards and DENI to progress this matter.
11. Paragraph 2.23 The Board is committed
to ensuring that resources spent on the statutory assessment process
are used effectively. Given the introduction from September 1998
of timescales for conduct of the statutory assessment process,
the number of referrals, and the array of professionals involved
(including employees of other organisations) the Board would question
whether moderating panels could operate in both a time- and cost-effective
manner. However consideration is being given to this issue.
12. Paragraph 2.25 The Board does not
understand the recommendation in Paragraph 2.25 that DENI should
consider the regionalisation of the management of Educational
Psychology Services. This recommendation appears to sit in a vacuum
and there appears to be no rationale or evidence in the report
for such a recommendation. It is not clear how the service would
be delivered by individual Board teams while being managed by
a regional management structure.
13. Paragraph 2.31 Educational psychologists
in the SEELB have already prepared draft performance targets for
providing advice to the Board to take account of timescales outlined
in the draft Code of Practice. Discussions are on-going with other
advice-givers on the establishment of timescales.
14. Paragraph 2.33 The inter-Board Designated
Officers Group is reviewing administrative methods and procedures
to identify good practice and possible areas of co-operation.
15. Paragraph 2.35 The Board would strongly
refute the suggestion made in this paragraph that educational
and developmental objectives stated in psychological advice are
weak. The Board would also take issue with the statement that
"psychological advice tended to be much stronger on cognitive
functioning rather than emotional and behavioural difficulties."
16. Paragraphs 2.36 and 2.37 Prior to
September 1997, there was no requirement for statements to be
specific in terms of objectives, nor was there ever guidance given
on the content or formulation of objectives. Since September 1997,
the Board has been setting clear precise objectives and therefore
feels that the comments in these paragraphs are irrelevant and
17. Part 3 Given the different types
of provision available in each Board and the fact that reciprocal
arrangements exist between Boards whereby children with certain
specific needs from across the Province are catered for in one
particular Board area, valid comparisons of costs and placements
of pupils cannot be made in any accurate fashion e.g. SELB does
not have any special schools for children with moderate learning
difficulties; children requiring long-term speech and language
provision from the whole of Northern Ireland are provided for
in the NEELB; BELB provides for children with physical disabilities
in Fleming Fulton and Mitchell House; the Lindsay School is financed
and managed by the SEELB but provides for children from the whole
of Northern Ireland and occasionally elsewhere.
18. Paragraph 3.10 The Board would contest
the suggestion implicit in the last sentence of this paragraph.
Children are placed in the provision which is most appropriate
for their needs.
19. Paragraph 4.3 The SEELB can provide
information which enables comparisons to be made of the costs
of different types of provision for children with special educational
20. Paragraph 4.5 The SEELB would not
accept this assertion and would wish to see the information which
led to the comment that schools were subsidising special units
from their own LMS budgets.
21. Paragraph 4.11 The Board strongly
supports this recommendation.
22. Paragraph 4.15 The Board would strongly
oppose this recommendation.
23. Paragraph 4.17 The Board has not
been aware that DENI has been pressing it to switch to entitlement
to free school meals as a "proxy" measure.
24. Paragraph 4.22 The Board understands
that this system is posing considerable problems in GB and suggests
that this statement should be reviewed following the receipt of
more recent information.
25. Paragraph 4.31 Agreed but not convinced,
given experience in GB that an audit approach is necessarily the
best way of achieving this situation.
26. Paragraph 4.32 Agreed.
27. Paragraph 5.4 The Board agrees that
the Northern Ireland Curriculum assessment arrangements do not
give sufficient recognition to the special school sector.
28. Paragraph 5.15 The Board strongly
agrees and would urge DENI to provide funding to ensure standardisation
of computer systems as well as access to appropriate information
relating to children with special educational needs held on CLASS
e.g., Special Educational Needs Register/Education Plans. The
Board believes that there is scope for using CLASS to streamline
procedures for assessment and annual review.
29. Paragraph 5.18 The Board is currently
reviewing how data might be used for benchmarking and target-setting
30. Paragraph 5.19 Strongly agree with
31. Paragraph 5.20 Agreed.
32. Paragraph 5.22 the Board would wish
to emphasise that it already discusses issues surrounding special
educational needs with its schools. Examples can be given if required.
33. Paragraph 5.32 The Boards are working
in partnership towards the production of common documentation.
34. Paragraphs 5.36 and 5.37 The Board
is concerned at the very significant financial implications of
this suggestion. In special schools alone the Board has over 1,200
children with statements of special educational needs. Even if
the Annual Review was to take only 30 minutes (a very conservative
estimate) a minimum of 120 days would be required to participate
in these Annual Reviews.
35. Paragraph 5.39 The Board considers
that there is an anomaly between the statement in this paragraph
and that in paragraph 4.13.
36. Paragraph 5.41 The Board welcomes
the fact that such a group has been established, but was unaware
of the fact. Any such group should have representation from the
Education and Library Boards.
37. Paragraph 5.44 Agree wholeheartedly.
The Board sought to achieve such a situation with its proposals
for the review of the LMS Scheme.