Skill Scotland: National Bureau for Students with Disabilities

Skill Scotland: National Bureau for Students with Disabilities

Consultation: Developing and Implementing a Needs-led Model for Funding the Activity of Students with Additional Support Needs for Learning in Colleges

Skill Scotland: National Bureau for Students with Disabilities promotes opportunities to empower young people and adults with any kind of disability to realise their potential in post-16 education, training and employment across Scotland. Skill Scotland works by providing information and advice to individuals, promoting good practice, and influencing policy in partnership with disabled people.

Skill Scotland welcomes the broad thrust of the consultation proposal to move towards a needs-led model for the funding of students with additional support needs. We believe that, in line with recent developments regarding access and inclusion, to continue with a funding system based on a ‘label-driven’, medical model of disability would be inconsistent and outdated.

Consultation questions

Q1: How will the proposed needs-led approach affect students in terms of meeting their additional support needs?

Skill Scotland broadly welcomes the proposal to move towards an approach that focuses on needs. Such an approach has the potential to ensure that all students who require additional support, for whatever reason, are able to make the most of their education.

A move towards a needs-led approach in colleges is in line with recent developments in the school sector, in which the Additional Support for Learning (Scotland) Act 2004 aims to introduce a framework of support based on the idea of ‘additional support needs’ rather than ‘special educational needs’. The proposed approach will help to ensure that pupils with additional support needs moving from school to college will receive a similar level of support.

Does the proposed process outlined ensure that the support needs of students are identified appropriately and accurately?

Skill Scotland welcomes the proposal to adopt a wider definition of additional support needs (as defined in the Further and Higher Education Act 2005), which takes account not only of ‘difficulties in learning’, but also ‘difficulties in participating in learning’. This is in accordance with the spirit of the Beattie recommendations, which aim towards the full inclusion of all young people in post-school learning.

(Skill Scotland notes that this definition does not include those students for whom English is a second or other language (ESOL).

Although this is not a disability-specific matter, we trust that the following observations may prove useful:

• following the implementation of the ASL Act, children with language difficulties are likely to be regarded as having ‘additional support needs’ and will therefore be provided with additional support at school.

• this definition is also inconsistent with the Scottish Executive’s ESOL strategy which states that:

“The importance of supporting the acquisition of English language skills for those for whom English is a second or other language is at the core of participation in a democratic society. Without adequate language skills, people can neither fully participate in their local and national communities, nor are they given the opportunity to meet their full potential.”[1]

• we therefore suggest that a caveat could be added to the definition of additional support needs, stating that students with language barriers are included in this definition.)

What effect will it have on the student’s experience?

The proposed process could result in students who were not previously eligible for claiming ELS or DPG 18 now being able to access additional support.

However, Skill Scotland is concerned that the implications of using a support grid for ‘assessment’ purposes may result in some students being likely to fear ‘failing’ the assessment if they are placed in levels 1 or 2. In our experience, there is a risk that some students may fear that they will not be accepted on to a course.

Skill Scotland therefore suggests that it is made clear to colleges that the support grid is for funding purposes only - and that a separate, person-centred planning process should be carried out for each student.

Communication with the student should therefore focus on a discussion of their needs and abilities in relation to their chosen course, rather than on a formal ‘assessment’. This would ensure that the needs-assessment process is person-centred rather than needs-led, and takes account of the fact that individual needs are different for every student, even when they may have the same ‘diagnosis’ as another individual.

Q2: How will the proposed approach ensure that the needs of students are approached and assessed consistently and appropriately?

To some extent the proposed approach will ensure consistency, in that all assessments will follow the same procedure rather than different practice in different settings.

However, Skill Scotland is concerned that a single approach to all assessments could leave less room for flexibility.

We suggest that where a student falls within the borderline area of levels 2/3, the assessor should be able to exercise their professional judgement as to whether the student should qualify for ELS or is likely to require ELS in the near future.

In addition, we suggest that the Funding Council allows for a feedback mechanism in the first year of implementation, to allow assessors to suggest amendments to the grid following actual assessment experience.

Q3: Is the proposed approach an improvement for students compared to the current approach?

Skill Scotland believes that the proposed approach has the potential to be an improvement - by broadening the definition of ‘additional support needs’, and encouraging colleges to make their everyday provision more inclusive.

Skill Scotland strongly supports any proposals for colleges to move towards a system where students do not always have to draw down individual support but rather, wherever possible, additional needs are met within the normal provision. There will always be some needs that can only be met on an individual basis, but there are many aspects of support that can be included within mainstream provision, making the college experience more accessible for all learners.

Many disabled students are somewhat wary both of disclosing their disability and of being assessed by college staff. Skill Scotland believes that the proposed approach has the potential to lead to an environment where the needs of a significant number of students can be met through good organisational practice, without the need to disclose or be assessed. Such an approach would be in line with colleges’ legal duties under Part 4 of the Disability Discrimination Act (DDA), which requires that education providers anticipate what sort of adjustments may be necessary for disabled people in the future and, where appropriate, make adjustments in advance.

Q4: How should the short-term, mid-year or transitional needs of students be assessed?

It is important to recognise that many disabled students are often not aware of their full support needs until they start a course, and also that their needs may change throughout the course.

Skill Scotland suggests that academic staff should receive training in basic needs assessment in order to identify students who may require additional support. Such a process would ensure that staff who have a detailed knowledge of the course are able to identify the match between the student’s needs and the demands of the course. Such students could then, if appropriate, take part in further discussions with support staff to discuss specific support needs and to determine whether ELS or DPG 18 would be appropriate.

Students who have been placed in levels 1 or 2 should have a follow-up assessment, during term one - to take account of their actual experience of the course and to see if their support needs have changed.

Q5: What effect will the proposed changes have on colleges’ ability to meet the support needs of students?

Skill Scotland recognises the intention of the proposals to move away from a label-driven model and to make everyday college provision more inclusive.

However, Skill Scotland is concerned that without a commitment to an increase in core funding, colleges will find it difficult to commit adequate resources to inclusive practice (such as staff training, learning support and physical adaptations or facilities).

This situation could be exacerbated by increased numbers of students being defined as having ‘additional support needs’, and less students actually qualifying for ELS under the new support grid - resulting in an increased demand for support but with less funding to provide it.

Although colleges have received inclusiveness funding through Beattie allocations, the HMIE report on the impact of this funding found that in most colleges there is scope to develop inclusiveness further[2]. In particular, the report found that although colleges had used the additional funding and guidance effectively to develop more inclusive approaches, a significant minority had focused their work on DDA legislation and had given less attention to the full range of additional support needs.

Skill Scotland suggests that core funding is increased, to allow colleges to further develop inclusive practice, and that the funds claimed against ELS are ring-fenced, to ensure that the funds are used for the purpose given.

Q6: Is the ‘Toolkit of Quality Indicators for Needs Assessments’ appropriate for making needs-led assessments for ELS and DPG 18?

Skill Scotland believes that a needs-led assessment process that is consistent throughout all colleges is both necessary and practical. The Toolkit appears to be an effective means of making assessments based on individual needs rather than categories of disability, and has a clear focus on consulting the student throughout the process.

However, Skill Scotland suggests that for students requiring DPG 18 support, there should be some degree of flexibility for colleges to take account of the fact that such students are likely to have already had extensive assessments at school.

We therefore recommend that students who have had a Co-ordinated Support Plan (CSP) at school, which is based on a needs-led assessment, should not automatically need to undergo further assessment under the Toolkit.

Q7: Is the ‘support grid’ appropriate for determining when ELS should be applied and when students’ support needs should be met through inclusive organisational practice as part of the overall funding package?

Skill Scotland recognises that it is necessary to apply a threshold to determine when ELS should be awarded for funding purposes. However, as outlined in question 1, we suggest that it is made clear to colleges that the grid is used for funding purposes only, and that a full student-centred assessment needs to be carried out subsequently. This will ensure that colleges fully explore students’ detailed, individual needs, rather than only considering those set out in the grid.

Are the examples given useful and appropriate?

Skill Scotland recommends that the support grid should not contain any examples at all - to avoid any implication that students with particular disabilities automatically have the same needs.

Q8: How practical and appropriate is it to apply ELS from the point when at least one support need is reflected in level 3 of the support grid?

As per our response to question 2, Skill Scotland suggests that where a student falls into the margins of levels 2/3, a degree of discretion should be introduced to allow assessors to exercise their professional judgement as to whether the student should qualify for ELS.

Would any transition measures be required?

As per our response to question 2, Skill Scotland suggests that the Funding Council allows for a feedback mechanism in the first year of implementation to allow assessors to suggest amendments to the grid following actual assessment experience.

How can we move all colleges towards meeting level 1 and 2 needs?

Skill Scotland suggests that all colleges should be provided with further guidance and support on inclusiveness. Although colleges receive inclusiveness funding (Beattie funding) as part of their main teaching grant, limited guidance is provided on how to become truly ‘inclusive’. Many colleges use this funding to purchase equipment or provide for adaptations, often resulting in limited funding for additional staff training. Although staff are able to attend SFEU and BRITE training events, Skill Scotland suggests that where colleges require specific support which is outwith the remit of SFEU or BRITE, such support should be funded directly by the Funding Council.

The HMIE report found that although staff development had had a significant impact on how support staff addressed and met the needs of students with additional support needs, most academic staff required continuing training in recognising individual learning needs and difficulties.

Skill Scotland recommends that all college staff, both academic and support, should undertake Disability Equality Training.

We also suggest that all teaching staff undertake training on accessible curriculum delivery (perhaps related to the Teachability programme and similar developments in the college sector).

The Funding Council could also usefully refer to the Disability self-evaluation toolkit (circular letter SFC/17/05), which aims to assist colleges and universities to plan for the Disability Equality Duties that comes into force in December 2006. This toolkit provides suggestions for institutions on meeting legal requirements, involving disabled students and staff in planning decisions, and creating accessible physical environments.

Skill Scotland suggests that colleges be encouraged to carry out access audits to help them identify gaps in provision.

Q9: Is the support grid currently robust enough to create consistency in the application of ELS across colleges?

Skill Scotland welcomes the proposals to create a single assessment procedure for qualifying for ELS. However, we are concerned that, unless additional funding is provided through colleges’ core grant, some colleges will be less able than others to meet the needs of ‘level 1 and 2 students’ through good organisational practice.

The HMIE report found that, in terms of developing a culture of inclusiveness, there was a considerable gap between the most and the least effective colleges.

Skill Scotland suggests that any transitional period for implementation of the proposed approach should include careful monitoring of colleges’ progress in developing ‘inclusive environments’. Any colleges which had made little or no progress should then be given further support during the transition period.

(There is, perhaps, also a concern that the least effective colleges may be more likely to place students in level 3 - in order to qualify for ELS funding.)

Q10: Are the revised definitions of DPG 18 and ELS appropriate and robust enough to help consistent application across colleges.

Skill Scotland believes that the revised definitions are more appropriate, taking into account the wider definition of students with additional support needs without placing students into categories. The revised definitions also make a clearer distinction between ELS and DPG 18 programmes, making it clear that students should only be placed on non-mainstream courses if their needs cannot be met through ELS.

However, Skill Scotland recommends that further guidance should be produced on the requirement to achieve agreed educational aims and progression on DPG 18 programmes, to ensure that students’ needs are met appropriately.

Q11: What implementation costs do you foresee at colleges (in terms of training and staff time and resources)?

Skill Scotland believes that, without additional core funding, the implementation costs for colleges will be significant, both in terms of staff training and resource costs for meeting level 1 and 2 needs.

Staff training (please see response to question 8):

• Training for all support staff involved in carrying out needs assessments based on the new Toolkit and support grid. Given that all students who have been defined as having ‘additional support needs’ will need to undergo assessment, it will be necessary for increased numbers of support staff to undergo such training
• Training in Teachability (or an FE equivalent) for all academic staff to ensure that students have access to a fully accessible curriculum
• Disability Equality Training for all staff (academic and support) to better equip staff to meet the needs of disabled students
• Other specialised training for academic staff, such as deaf awareness training, mental health training, etc.

Other costs:

• Potential costs for some colleges in relation to making the physical environment accessible
• Costs of modifying the curriculum and providing specialised resources which are not provided for in levels 1 and 2, such as extra copies of lecture notes
• Significantly increased input from learner support staff, to meet the needs of students who do not qualify for ELS but nevertheless require additional support.

Skill Scotland recommends that an initial award be allocated to colleges for staff training (which is outwith the remit of available SFEU training) to prepare for developing or furthering good organisational inclusive practice. A ‘train the trainers’ approach would ensure that costs for colleges are reduced, and that training is tailored to the needs of each individual college.