A number of recent Ofsted reports note that a common feature of the most successful schools surveyed was the attention they gave to developing speaking and listening
earlyyears

Summary of responses

The Trust responds to key developments in Government policy to ensure the best opportunities are available for children with speech, language and communication needs and to maximise these opportunities.
 

Residential Special Schools, March 2017

The Government asked Dame Christine Lenehan to carry out a review into the experiences and outcomes of children and young people in residential special schools and colleges. TCT would like to see concerted action to improve the education, care, lives and future opportunities of children who attend residential special schools.

Our response called for better data collection in relation to the characteristics of children who attend residential special schools and colleges, mandatory training in speech, language and communication needs for all staff and better sharing of good practice. You can read the full submission here.

 

Children and young people’s mental health – the role of education, January 2017

The Health Committee established a new inquiry into the role of education in promoting emotional wellbeing in children and young people and preventing mental ill health.TCT submitted a response highlighting the relationship between speech, language and communication needs (SLCN) and mental health.

The impact of speech, language and communication difficulties on children’s lives can be devastating; adversely affecting wellbeing, resulting in mental ill health and making the usual support mechanisms unsuitable or even more challenging to access. Our response made clear that these consequences are not inevitable, many children with SLCN, given the right support at the right time, will catch up but it is essential that meaningful steps are taken to improve early identification of SLCN as well as providing sufficient support and intervention to improve education outcomes and wellbeing. You can view our response here

 

Schools that work for everyone, December 2016

The Department for Education announced a consultation on proposals to create more good school places. The proposals included:

  • expecting independent schools to support existing or open new state schools, or offer funded places to children whose families can’t afford to pay fees
  • asking universities to commit to sponsoring or setting up new schools in exchange for the ability to charge higher fees
  • allowing selective schools to expand, or new ones to open, while making sure they support non-selective schools
  • allowing new faith free schools to select up to 100% of pupils based on their faith, and introducing new requirements to make sure that faith schools include pupils from different backgrounds

We responded highlighting how important it was for the government to consider the impact of its proposals on children with SLCN. We set out a range of challenges for schools policy such as early identification of SLCN and the relationship between disadvantage and language delay. We also included evidence about the under-representation of children with SEN in grammar schools.  You can view our response here.

 

Labour Party Review of reformed SEND system, July 2016

The Labour Party set up a review group to examine the implementation of the reformed SEND system. The group hosted two roundtable meetings (one of which The Trust presented at) and then launched an official call for written evidence. The review is focussed on 7 key areas of the reforms;

  • the impact of "every school an academy", which remains the Government's goal, on SEND admissions and provision;
  • the drafting of EHCPs;
  • the transition from Statements to EHCPs;
  • the variability in the 'Local Offer';
  • the SEN Code of Practice;
  • provision of SEND in Initial Teacher Training (ITT) and;
  • accessing specialist services within the school setting.

In our response to the review we used evidence gathered from surveys we ran with the children's workforce about implementation through 2015 and also from feedback we've been receiving from our Consortium members. We highlighted concerns around the involvement of children and young people with SLCN in decision making, issues for those in the SEN support category and issues around thresholds for EHC plans for children and young people with SLCN as their primary need. You can find our response in full here


The review will publish a report in the autumn which will feed into the Labour Party's National Policy Forum; a key component of policy development towards the Party's manifesto for 2020.

 

Labour Party Policy Forum consultation on early intervention and the early years, June 2016

This consultation from the Labour Party Children and Education Policy Commission sought views on a variety of different policy points, including targeted services to overcome disadvantage, delivering high quality and affordable childcare, and supporting vulnerable children. For further information about the consultation please click here

The Communication Trust used this response as an opportunity to highlight some of our key arguments and the big issues around SLC/N for children aged 0 - 5. We  also set out particular concerns we have around policy passed/proposed under the current government and put forward solutions to challenges we believe these have created for the early years. You can access our response in full here.


 

30-hour free childcare entitlement consultation, June 2016

This consultation from the Department for Education sought views on some key elements of the operation and delivery of the 30 hour extended free entitlement to child care for three and four year olds. For further information about the consultation please click here

The Communication Trust submitted a response to this consultation focussed on the unacceptable emphasis the proposals place on flexibility of early years provision over quality. We highlight the importance specifically of quality early education for children from disadvantaged backgrounds and also the additional support children with SLCN require. We outline our concerns about the current proposals' ability to guarantee the level and quality of support these two groups of children and their parents are entitled to. You can access our response in full here.      

Alongside our response we also submitted a cover letter to the consultation team to more directly emphasise our position. You can access a copy of the letter here.

 

Joint Inquiry into Foundation years and UK Government's life chances strategy, March 2016

The Commons Work and Pensions and Education Select Committees are running a joint inquiry into the Government's life chances strategy and the role that early or foundation years intervention plays in shaping people's lives.

The committee invited evidence on:

  • the relationship between early years education and the life chances strategy
  • Cross-departmental co-ordination on early years interventions and interaction with the benefits system and public services.

You can find out more  here.  

Our response highlights the links between early language development and social disadvantage, positioning an effective approach to supporting children's speech, language and communication development and needs as central to any meaningful life chances strategy. We focus on the importance of high quality Early Years settings, with well qualified staff in addressing this issue as well as the importance of support for parents in more clearly understanding the role they can play in supporting their children's speech, language and communication development.

We also draw attention to the impact wider childcare changes might have on disadvantaged children's outcomes, particularly around their communication development and the importance of the opportunity the two year old progress check presents for early identification and intervention is recognised and built on. You can find our full submission here

 

Inquiry into the purpose and quality of education, January 2016 

The Education Committee are leading an inquiry into the purpose and quality of education in England. As part of the inquiry they invited written submissions on the issue focussed on three questions;

  • What the purpose of education for children of all ages in England should be
  • What measures should be used to evaluate the quality of education against this purpose
  • How well the current education system performs against these measures

You can find out more about the inquiry here.

We responded to this inquiry highlighting the fundamental importance of speech, language and communication skills within any quality education system. We've drawn strongly on evidence around its impact on educational attainment, further education, employability and wider social outcomes for children and young people.

You can find our full submission here

 

Implementing the English Baccalaureate, January 2016

This consultation from the Department for Education sought feedback on proposals around the implementation of the English Baccalaureate. The English Baccalaureate (EBacc) is a performance measure, not a qualification. The measure shows where pupils have secured a good C grade (grade 5 when new GCSEs are in place) or above across a core of specific academic subjects at key stage 4. You can find out more about the EBacc and the proposals in the consultation document here.

We have submitted a response to the consultation highlighting the challenges some students with SLCN will face in taking the EBacc subjects and the pressure a performance target based on entry to the EBacc of 90% (as proposed by the Government) will place on these students to enter the EBacc, even where it's not the decision that's best for them. In particular we highlight the conflicts between the EBacc subjects and the emphasis placed on preparation for adulthood and independent living by the reformed SEND system. For some students with SLCN, vocational subjects provide an excellent starting point for living independently and it's important schools support them to do this. 

We also use our response to make clear the importance of ensuring teachers of Ebacc subjects are aware of the increase in students with SLCN that are likely to be taking their subjects as a result of the introduction of the Ebacc measure and that they have the right training and support to teach them effectively.

You can access our full response here

 

Local Area SEND inspections consultation, January 2016

This consultation from Ofsted and the Care Quality Commission (CQC) sought feedback on their proposals around joint inspection arrangements to evaluate how well local areas are meeting their responsibilities to children and young people with SEND. The consultation document and further information is available here.

This was an extremely important consultation for the sector and we very much welcome the local area inspections as a crucial part of the accountability structure of the reformed SEND system. Our response is comprehensive and we make a number of key points, some of the headlines include;

  • Raising concerns that the evaluation of social care and health responsibilities in the inspections is limited only to how these services have contributed to meeting the needs of children and young people who are being assessed for, or are subject to, education, health and care plans
  • Highlighting the important distinction between initial identification processes and subsequent assessments, for getting an accurate picture of the effectiveness and timeliness of identification practices
  • Pressing for further clarity on how strategic level arrangements for identifying and meeting needs, such as the joint strategic needs assessment and joint commissioning arrangements will be held to account through the inspections
  • Highlighting the importance of thoroughly scrutinising the Local Offer in each area to ensure all children and young people with SLCN and their families have access  to the services they need
  • Raising the important issue of inspection team training, knowledge and skill, particularly with regard to effective communication with and involvement of children and young people with SLCN.

You can access our full response here.  

 

Draft National Framework for Children and Young People's Continuing Care consultation, submitted October 2015

This consultation from The Department of Health sought feedback on the National Framework for Children and Young People's Continuing Care (including a tool to ensure all relevant needs are assessed and support decisions about care). The framework helps clinical commissioning groups and other professionals to assess the care required for children and young people with health needs that are not met by existing or specialised services and has been updated in line with the refomred SEND system.

Further information on this consultation can be found here.  

The Trust submitted a response to this consultation, taking a slightly broader focus than our usual very specific SLCN input. The children impacted by continuing care arrangements are likely to have complex needs and significant SLCN. Though of course much of our focus in this response is on ensuring accessibility and participation for children with SLCN, particularly in around the question about the communication care domain descriptors, we've also included some broader points around ensuring the system works well for children and families and that the framework is as clear and detailed as possible.

You can access our full response here.

 

A standard for teachers' professional development: a call for evidence, submitted October 2015

The Teachers' Professional Development Expert Group, an independent group of teachers, head teachers, academics and education experts, is seeking to develop a 'Standard for Teachers' Professional Development' in England. The new non-statutory standard will allow schools to define their approach to professional development based on their needs, but will set out a description of effective practice in professional development for teachers.

Further information on the call for evidence can be found here.

The Trust has submitted a response, to highlight the importance of including professional development around speech, language and communication needs in the standard. Our response draws on examples of professional development activities which we, and some of our members, are or have been involved in which show an impact on outcomes. We highlight the importance of teachers having a universal understanding of speech, language and communication, and SLCN, and also the importance of a whole school approach with senior leadership commitment for effective professional development. In our response we also make note of the particular importance of SLCN within the context of recent policy developments including the SEND reforms, the Carter Review of 2015 and the introduction of the new national curriculum in England in 2014.

You can access our full response here.

 

Community Child Health project call for evidence on design of community paediatric services, submitted October 2015

The Royal College of Paediatrics and Child Health (RCPCH) and the British Association for Community Child Health (BACCH) are developing a resource to support workforce planning for community paediatric services.   

The project team sought in this call for evidence examples service modelling and workforce planning initiatives as well as examples of good practice in all areas of community paediatric and child health services to inform the guidance. Further detail on the call for evidence is available on their website here.

The Trust has submitted a short response to highlight the importance of ensuring community health practitioners who provide universal services for children and young people are aware of issues around speech, language and communication development and SLCN. Our response highlights the central role these practitioners can play in providing early support and signposting where children are struggling with this vital aspect of development. We chose to do this outside of the submission form as our points are intended to support the team in reading examples of practice submitted. We encouraged our members to send in relevant examples of their work to the call for evidence directly.

You can access the letter we submitted here.  

 

The Public Health Outcomes Framework consultation, submitted Ocotber 2015

This consultation from the Department of Health seeks to review the existing indicators on the Public Health Outcomes Framework (PHOF) and also allows the opportunity to highlight gaps in what the indicators cover. You can find out more about the consultation and the PHOF here.

We used our response to highlight in particular improvements that should be made to the indicator around school readiness to reflect the recent introduction of the reception baseline assessment and also to highlight the importance of collecting data about children's speech, language and communication skills beyond that gathered in the year 1 phonics check. We also welcomed the inclusion of the child development indicator in the framework and highlighted the importance of clear cohesion between data which will be collected as part of the child development check at 2.5 and that which relates to the school readiness.

Responses to this consultation had to be entered via an online survey on the Department of Health website. You can see a word document outlining our final response here.

 

Targeting funding for disabled students in Higher Education from 2016/17 onwards, submitted September 2015 

The Department for Business, Innovation and Skills have launched a consultation that seeks to inform the development of options to target Government funding for disabled students in higher education (HE) more effectively. It seeks views on the balance of the source of support between the help available for all disabled students via HE providers, and specific aspects of the personalised support available via Disabled Students' Allowances (DSA).

A number of proposals are put forward by the Consultation, including ending DSA funding for support workers providing Non-Medical Help in bands 1 and 2. These include important roles for young people with sensory impairments. There are also concerns that the proposals could erode the requirements and incentives for HE providers to make reasonable adjustments for disabled students. You can find out more about the proposals in the full consultation document available here.

The Trust endorsed submissions to this consultation led by our members at the British Association for Teachers of the Deaf (BATOD) and the National Deaf Children's Society (NDCS).

You can read the response from BATOD here and the response from NDCS here.

 

Local authority public health allocations 2015/16: in-year savings, submitted August 2015

This consultation from The Department of Health sets out possible options on how £200 million savings might be spread across reductions to the Public Health Grant to local authorities (LAs). You can find out more about the consultation here.

The Trust co-signed a response to this consultation from the National Children's Bureau.  

The response outlines our concerns that the proposed saving will have a disproportionate impact on children and young people. This is both because of the importance of public health services to this group's long-term health and well-being and also because the confirmation of the saving for each local authority will coincide with the transfer of responsibility for public health for children under 5 to local authorities.

Concerns are also highlighted about the implication of the announcement for future Public Health Grant allocations and the message it may send about the importance Government attaches to work to prevent ill health and tackle health inequalities. We therefore advise caution in how feedback over the next six months is used to inform future spending decisions, and seek a clear commitment from Government that funding for children's public health will be protected.

You can access the response in full here.

 

Call for evidence: review of the cost of providing childcare, response submitted August 2015

The government is carrying out a review of the cost of providing childcare as part of its commitment to extend the availability of free childcare and to increase the average childcare funding rates paid to providers. This call for evidence formed part of the process of gathering information to improve understanding of what factors contribute to the cost of providing childcare for early years providers. You can access the call for evidence paper here.

The Trust submitted a response to the call for evidence, outlining how crucial it will be that the 'hourly rate' for early years providers reflects the additional costs of effectively supporting children with SEN and SLCN in particular. We highlighted the importance of investing in a skilled and knowledgeable children's workforce, able to provide quality childcare for all children, including those with additional needs.

We rooted our response within the context of the reforms and principles already in place under the reformed SEND system, including the strong focus on early identification of needs particularly. We highlighted that for early identification to take place effectively in early years settings, the cost of providing  childcare must reflect the additional skills and competencies staff will need to have. We also drew on research recently published for the Department for Education which states that some providers are already finding it difficult to fund the full free entitlement for children with SEN because the standard per-child funding they received did not reflect the cost of meeting the needs of these children.

You can read our response in full here.

 

GCSE English Language - Consultation from Ofqual on Conditions and Guidance, response submitted July 2015

This consultation sets out further detail on the proposals around the format and assessment of the spoken language assessment. You can find out more and read the consultation document here. We use our response to highlight our ongoing concerns about the impact the proposed assessment and its format could have on pupils with SLCN.  In particular we raise concerns around the chosen pass, merit, distinction levels and the criteria required to meet these and also press for further detail on information about 'reasonable adjustments' that can be made to the form of the assessment for students with SLCN who might struggle to access it or show case their speech, language and communication skills to the best of their ability.

We also highlight the importance of providing training and support to teachers marking the assessments to ensure they have a strong understanding of spoken language skills in order to mark robustly and accurately. We offer in our response to support Ofqual in providing this support and offer the expertise of ourselves and our members to help in any further ways around the reform of the English Language GCSE to ensure it offers the best possible opportunities to children and young people with SLCN to achieve well and to support schools to prioritise the spoken language skills of all their students. You can access our response here.

 

Developing the national reading strategy - A call for evidence, response submitted June 2015

This call for evidence invited submissions from all individuals and organisations with an interest in promoting children's reading and early language development to help identify key issues and strategic priorities for action to help achieve the goals of the Read On. Get On. National reading strategy for England. The Trust submitted a detailed response highlighting the importance of early language development for reading. We included detailed information and evidence gathered as part of the National Year of Communication - Hello and also from the Early Language Development Programme (ELDP), as well as other key pieces of evidence and research.  You can access the response here.

 

Developing the teaching profession to a world-class standard, response submitted Feb 2015

This Department for Education consultation outlines a number of proposals around improving the quality of teachers' professional development and learning including a proposal to establish a new independent professional body for teaching. You can find out more here.

In our response we have welcomed the proposals intentions to improve access to high quality and regular CPD for schools and teachers. Whilst supporting the proposal to introduce an independent professional body for teachers, we also make a case around the importance of continued Government presence in this vital area.

We've highlighted some best practice about how CPD can work most effectively in schools, particularly around supporting teachers find out more about areas such as speech, language and communication development and SLCN that they may not know, about in a structured and progressive way. We've also highlighted some of the existing barriers we know to exist in providing high quality CPD to teachers in busy school environments. The response also includes a really useful case study from our members Kids Company outlining an effective approach they've taken to CPD in schools they work with.

We've also used the response to highlight the overlap between the proposals and existing resources for SLCN CPD that The Trust has including our programme of work around ITT, the What Works virtual library and the SLCF.

You can read our response in full here.

 

Performance descriptors: key stages 1 and 2, response submitted Dec 2014

Following the removal of levels for determining pupil attainment, the DFE are seeking views on the practical use and implementation of statutory teacher assessment performance descriptors at the end of key stages 1 and 2 for the academic year 2015/2016. You can find out more about the consultation here.

We are very disappointed that the proposals in the consultation do not include performance descriptors for spoken language. Performance descriptors for key stage 1 spoken language progression were promised as part of the Departmental response to the primary accountability consultation earlier this year, and we highlight this inconsistency in our response.

We make the case clear around why it is essential teachers are provided with performance descriptors for spoken language both in respect of holding schools to account on the progress of all their pupils in this vital area but also in ensuring that teachers have defined expectations of progress in spoken language so that they are able both to track the progression of children who are developing typically but also crucially to identify pupils who may have SLCN.

Our response also highlights concerns we have around the terms used within the performance descriptors for the curriculum areas where they do exist. We feel they lack clarity or detail and will be difficult for both parents and teachers to accurately interpret. In particular we are concerned that the use of the term 'below national standard' is a negative way to describe the attainment, progression and real achievements of any children, and especially those with SEN.
You can read our response in full here.

 

Ofsted Consultation on Proposals for a New Framework, response submitted Nov 2014

This consultation proposes key changes to the way Ofsted inspect schools, further education and skills providers and registered early years settings from September 2015 including proposals around the introduction of a common framework assessment process. You can find out more here. The Trust has submitted a response to the consultation.

Whilst we recognise the value of a coherent approach to inspections and the aim for improved comparability and consistency across providers and settings, in our response we articulate a range of concerns about how this will be achieved through the suggested framework and undefined proposals for remit guidance.  

We feel there are inherent difficulties with the proposal to implement a new common inspection framework for maintained schools, academies, further education and skills providers, non-association independent schools and registered early years settings. We argue that whilst we understand that there will be inspection handbooks with detail specific to each remit, we are concerned that as a principle, the overarching common inspection framework covering all age ranges in this way is not sufficiently 'common' and therefore the level of detail required in the handbooks to make them applicable and relevant to different settings/ages will minimise the possibility of making clear comparisons.

We also use the response to highlight the reasons why there should be a greater emphasis on the role of language and communication skills.

We also recommend a key emphasis within the framework on provision for SEND. Evidence has shown that SLCN are a SEN, where the gaps have not narrowed - they've widened - and it is essential that all settings and schools are accountable for their pupils with SLCN making good progress through the Ofsted inspection.

We'd be very happy to work with Ofsted around our suggestions and especially that we'd be keen to input to the remit handbooks they will be developing.
You can read our response in full here.

 

Developing a set of standards for teaching assistants: call for evidence, Nov 2014

In early October the Department for Education launched a review of teaching assistant standards, and later in the month issued a call for evidence to which the Trust has submitted a response. More information about the review is available here.

In our response the Trust welcomed the development of a set of professional standards for all teaching assistants and expressed our hope that these standards will be clearly linked to available qualifications and sit within a clear context of effective deployment, training and direction within schools and settings. We noted that recent research studies have examined how to maximise the impact of TAs on pupils' learning, and we see these standards as being an important way of promoting the effective role of TAs in supporting pupils' speech, language and communication. 

We stated that, as language development is central to all learning, we want the Review Panel to ensure that there are minimum standards for all TAs to have the knowledge and skills to support pupils' speech, language and communication (SLC) development.

In addition, we would also like to see specific minimum TA standards relating to the knowledge and skills required for those TAs offering targeted or more specialised support to pupils with SLCN, particularly as speech, language and communication needs (SLCN) is now the most prevalent special education need.

Drawing on the expertise and input of the Consortium, we also provided six case studies of best practice in TAs supporting SLC development effectively.

Read our response in full here

 

SEN and disability: detained persons regulations and revised code, Nov 2014

This consultation sought views on draft regulations and amendments to the Code of Practice which embed the requirements laid out by the Children and Families Act. You can find out more about the consultation here.

Our response is detailed and provides feedback on a number of issues. However our key arguments are focussed on ensuring that detained children and young people with identified SEN have their needs met appropriately whilst they are detained. This is both for those with pre-existing EHC plans, those who secure an EHC plan whilst detained and for those who do not have an EHC plan but do have identified needs that require SEN support from the education provider.

We also press strongly, along with the RCSLT, on the need for clarity around the responsibilities of NHS England to commission and provide SLT provision in youth custody. We also support the position of SEC on the arrangements that must be in place for children and young people who move between local authority boundaries either on release from custody or whilst detained.

Throughout the response we highlight issues of workforce development and training support needs that YOTs and others working with detained children and young people will need to have in order to carry out their role effectively. We also push strongly for a greater recognition of the levels of SLCN in the youth justice system, and a proportionate requirement on local authorities and relevant youth accommodation to assess for these needs and other SEN in all children and young people entering the system, and not to rely too heavily on prior records (or in many cases lack of such records) of SEN to trigger an assessment process.

Additionally, we also support the position of our members NDCS in highlighting concerns about proposed revisions to the wording in chapter 6 of the Code of Practice around children and young people's 'entitlement'  to an education that enables them to make progress.

Read our response in full here.

 

Making health and social care information accessible, Nov 2014

NHS England are writing a new guidebook or 'Information Standard' for health and social care organisations to ensure patients, service users, carers and parents receive information in a format that they can understand and communication support if they need it.  This consultation was to gather views on the draft of this standard. You can find out more about this consultation here.

In our response we warmly welcome the standards positive intent. We recommend specific reference within the scope of the standard to those with communication support needs as their primary need, where there is no underlying disability causing the need in addition to those with communication support needs relating to a disability, impairment or sensory loss. We also push for a specific assertion of how the vision applies equally to patients and service users of all ages as opposed to a generic, all age group standard. 

We also argue that there needs to be clear guidance on the range of communication support needs a patient can have.  It is certainly welcome that there's an explicit reference to specific support such as advocates or BSL interpreters, but they may benefit from a little more use of examples of more subtle reasonable adjustments - there's nothing about how people are spoken to for example.  It talks about format of information but not about the use of language and vocabulary.

Read our response in full here.

 

Knowledge and skills for child and family social work, Oct 2014

This consultation from the Department for Education sought views the draft statement of knowledge and skills for child and family social workers. The statement is intended to outline:

  • what a child and family social worker needs to know at the end of a first year in practice
  • and to inform the teaching content of qualifying programmes, to properly equip those studying to become effective child and family social workers

You can find out more about the consultation and read the statement here.

We focussed our response around question 1, putting forward an argument that section 2 of the statement should be amended to recognise the importance for social workers of understanding language and communication development. We also recommend that 'special educational needs' is included in that section in relation to the interaction between the environment and genetic factors, and that  the term 'cognitive abilities' is used instead of IQ.
You can read our response in full here


The conduct, marking and grading of spoken language skills in GCSE English language, Sept 2014

The Trust has submitted a response to this Ofqual consultation. Our response does answer the questions posed by the consultation thoroughly, though also reiterates our disappointment that spoken language will not contribute the overall English/English language grade. You can find out more about the consultation here.

Julie Swan, Head of Regulatory Policy at Ofqual, attended a meeting of our Consortium to discuss the consultation in person and this was a really important session and the points raised are reflected in our response. 

We submitted a detailed response to the consultation and some of the key points raised in it include;

  • We agree that spoken language assessments should be recorded and strongly agree that recordings should be audio and visual
  • We strongly disagreed with the proposal to grade students performances using three positive grades such as pass, merit distinction and a category for a fail.
  • We proposed that a numerical system be used, reflecting that used for other areas of the GCSE grade ensuring that there was parity between spoken language and other areas of GCSE English.
  • We were very disappointed by the suggested advantage of the non mark approach and the criteria suggested. We suggest that a mark should be awarded, using a clearly defined set of descriptors based on linguistic and communicative features and progression.
  • Where a student has not undertaken the assessment, this should be clearly indicated on their certificate rather than leaving the certificate blank. However, we would expect that every step possible is taken to ensure that all centres are fulfilling the spoken language elements of the qualification completely and that strong measures were in place for centres that did not.

As ever, we offred in our response to work closely with Ofqual in developing any of these points further or supporting them to implement them in practice should they wish to be in touch.

You can read our response in full here.   


The Carter review of initial teacher training (ITT)  

The Trust submitted evidence to this review following up on our attendance at a round table focussed on the same thing earlier in the summer. We structured our response as a letter rather than using the response form as we were better able to follow up on points and issues raised at the round table and that we were asked to buildon in response to this review in this format.

The Trust very much welcomed the opportunity to attend the roundtable event and the opportunity to share evidence and information for the review. We raised points about not only speech, language and communication needs within SEN, but also on the crucial importance  for all emerging teachers, whatever their route of entry into the profession, of understanding the essential role of spoken language skills and development for all pupils. You can read our submission here.


Special Educational Needs and Disability Data Descriptors, September 2014

The Trust has submitted its reponse to the DfE consultation on SEND data descriptors, which looks to address inconsistencies between the descriptors used for school census and individualised learner records. Find out more about the consultation here.

In its response the Trust welcomed the inclusion of Speech, Language and Communication Needs within the ILR. We are also pleased that descriptors will be consistent for schools and colleges in relation to census data and ILR.

We noted, however, that it is essential that at relevant points in the SEND process, there is greater detail underpinning these descriptors so that schools and settings are able to effectively identify pupils' needs and so complete data collection activities accurately.

There are well-evidenced challenges for schools and colleges in effectively identifying pupils with SLCN, with many children and young people's SLCN being missed, misinterpreted or misunderstood. Additionally, SLCN, as well as being a specific area of need for around 5-7% of all children and young people, is also a feature of many of the other descriptors of SEN, for example hearing impairment, learning difficulties, autism, social, emotional and mental health and some physical disabilities.

The Trust emphasised that it is therefore very keen that all settings completing census and ILR information have access to clear information which supports their understanding of SLCN both as a descriptor of SEND and as part of other descriptors, particularly at a time of change with wider SEND reforms.

You can read the Trust's full response here.

 

Early Years Pupil Premium response submitted, August 2014

The Trust has submitted its response to the DfE consultation on proposals to introduce an Early Years Pupil Premium (EYPP). You can find out more about the consultation here.

The Trust welcomed the proposal of the EYPP, noting that, if used effectively, it could both support the development of children's early language and communication skills, and improve early identification and intervention for those children with speech, language, and communication needs; both of which could help minimise the need for longer-term, costly support and intervention. However, in our response we emphasised that effective use of the EYPP would depend on the knowledge and skills of practitioners and that EYPP should be accompanied with clear guidance for providers, and access to up-to-date evidence on what works.  We share the early years sector's hope that, over time, the £300 a year premium will be increased to match, pro rata, the Primary Pupil Premium of £1,350. 

We also noted that robust monitoring to ensure that the EYPP was being used effectively would be essential, reiterating that the Early Years Foundation Stage Profile (EYFSP) is highly useful for monitoring children's language and communication development; the Better Communication Research Programme noted the effectiveness of the EYFSP's communication, language and literacy scale in monitoring progress in language and communication, and in predicting later attainment.

You can read the Trust's full response here.  

 

Consultation on a new fund to support the sustainability of voluntary, community and social enterprise sector organisations

The Office for Civil Society recognise that many medium sized voluntary, community and social enterprise (VCSE) sector organisations, supporting vulnerable and disadvantaged groups, are struggling to plan for the future and maintain their services in challenging times. They know these organisations are delivering important services, both for their service users, as well as the wider community in which they are working.

This consultation was seeking views on the design and delivery of a proposed new fund, which will aim to support these organisations. You can find out more about the consultation here.

The fund will only receive final go-ahead once a final design and business case has been established. We have collated views from within the Trust and across the consortium and submitted a  response which you can access here.  

 

Completing GSCE, AS, and A level reform 2014 response submitted, July 2014

Ofqual has set out its proposals for completing GCSE and A level reform. Following circulating the draft to the Consortium for comment, the Trust has submitted a response letter highlighting some ways in which we feel the proposals could be doing more to support the speaking and listening skills of all pupils. 

Ofqual has set out its proposals for completing GCSE and A level reform. This follows on from DfE's consultation on the subject content for English Language and Maths, which the Trust responded to at the turn of the year. Ofqual's proposals cover the remaining subjects, so as to bring them into line with those already being reformed. The consultation proposes:

  • Requiring core content for any subject in which a GCSE, A level or AS qualification is developed
  • Allowing exam boards to develop core subject content collaboratively through a regulatory framework
  • Setting out how Ofqual judge in advance of which remaining or new subject areas can be developed under the GCSE, A level or AS qualification brands.
  • Introducing a cut-off date of summer 2018 for the last award of all 'unreformed' qualifications; and
  • Removing any qualifications now that are unlikely to meet regulatory expectations in the future

The consultation is a continuation of the Government's agenda to streamline school qualifications and make GCSE and A-levels more robust by removing what it deems to be superfluous and/or undervalued courses.

This aspect of the proposals have caught the bulk of the press attention, but the aspect that the Trust has picked up on is whether the proposed 'core content' could include a spoken language element across all courses to build the speaking and listening skills of all pupils.

Further detail can be found at http://ofqual.gov.uk/news/gcse-level-reform-consultation/.

The Trust's letter of response can be found here.

 

Childminder agencies and changes to the local authority role response submitted, May 2014

This DfE consultation sought views on changes to the provision of early education and childcare as a result of the Children and Families Act, focusing on the introduction of childminder agencies and new draft regulations around them, and also seeks views on draft regulations which make changes to the way local authorities discharge their duty. You can find out more about the consultation here.  

The key concern we highlight in the response is how to ensure that childminder agencies enable their registered childminders to provide a high quality service, particularly to disadvantaged two-year-olds.  You can read our response in full here.

 

Child poverty strategy response submitted, May 2014

The Child Poverty Strategy was published for consultation by the DfE and DWP in February.  The consultation is broad and essentially provides an overview of Coalition policies used to address child poverty, from school autonomy to SEN reform. You can find out more about the consultation here.

The consultation says: "This Government is focused on breaking the cycle of disadvantage - where you start in life should not determine where you end up. Ending child poverty is an essential part of this vision. We firmly believe the way to end poverty is to tackle the root causes now and across generations so we can transform lives. We want to know what more can be done and how we can work together to end child poverty. Only by working together can we transform the lives of the poorest children in our society."

We used our response to highlight how investing in services and support which improve children's health and educational outcomes can prevent and reduce child poverty and prevent poor children growing into poor adults. Read our response in full here.

 

Ofsted introduction of separate graded judgements for early years and sixth form response submitted, May 2014

In April Ofsted published their consultation on the introduction of separate graded judgements for early years and sixth form in academies and maintained schools, which would begin from September. You can read our response to the consultaiton here.

In our response we express concern over the difference between these new criteria and those of the early years inspection framework, which means that the new criteria don't align with criteria used in non-maintained settings, and also don't include the essential focus on meeting all children's needs. Hence we feel that the criteria may not be entirely appropriate for use in early years settings. These differences will also make it difficult for parents to make informed judgements about various settings. We also express our belief in the importance of early years inspectors having access to the information and training that will make them skilled and confident in understanding the quality of a provision's support in regard to speech, language and communication development.

 

Ofsted ITE response submitted, May 2014

In February, Ofsted issued a consultation on revising the framework for inspecting initial teacher education (ITE), found here. They are proposing to transform the inspection arrangements from simply looking at the quality of training by the provider to also evaluating the outcomes of their NQTs after the first year.

The Trust submitted a final response to the consultation on Tuesday 6th May 2014 which you can access here.

The current ITE framework was introduced in 2012, including the new teacher standards that trainees need to achieve to gain QTS. Changes in this consultation include: strengthening judgements on ITE provision by directly observing trainees in the classroom, not just while they are training but also in their first job; and making changes to the judgements they make within the framework. It is also proposing to place a stronger emphasis on the importance for emerging teachers of managing pupil's behaviour and discipline. 

We have structured our response around four key areas in the form of a letter because the form provided did not lend itself to addressing the key points we felt needed to be raised from the SLCN perspective.

  1. Two-stage approach to the inspection of ITE partnerships
  2. Highlighting the role of speech, language and communication skills to support proposed revisions to the ITE handbook
  3. Focus on management of behaviour and discipline in the framework, handbook and guidance for focussed monitoring inspections
  4. Reflecting changes in assessment requirements and the national curriculum more strongly in the proposed revisions to the ITE framework


Revised SEND code of practice response submitted, May 2014

In April 2014, the Government released a revised draft of the SEND Code of Practice for a short 6 week consultation period. This revised version incorporates feedback from the previous consultation has a short consultation period and includes information around the amendments that were made to the Children and Families Bill later in its passage, including the extension of the Act to all disabled children and young people and to the youth justice system.

The consultation sought responses on only 9 specific questions focussed on aspects of the Code relating to these amended sections. You can view a full list of the questions here and the revised code itself here.

We submitted our response on Tuesday 6th May and focussed on some key points we welcomed as well as those key issues we felt needed strengthening in the revised code. These include;

  •  How the code will work in practice; this is still unclear and would benefit from further clarification
  • The lack of focus on children age 0-2 - we make a number of suggestions throughout the response on how this could be improved to ensure these children are identified, supported and that information and advice is available for parents
  • Lack of clarity around securing support for children and young people without an EHCP, which will be the majority of children with SLCN.
  • Lack of clarity around process and timescales which means the positive ethos of the code for early identification and support may be undermined
  • Continued concerns around overall accountability in terms of oversight and scrutiny of delivery; collaboration across organisations and structures is difficult and without careful accountability systems in place, it is very easy for children and services to fall through the gaps
  • Need for more visual support and aids for navigation through the code and the system would be useful
  • The need for significantly more work to be done on the section in relation to youth justice. We support the SEC and SCYJ position that further time is needed to develop the statutory framework for these provisions and that this section of the Code should not be published until these can be reflected in it.  

You can read our response in full here and we will keep our website up to date with information about the 2014 SEND reforms and the final Code of practice.

If you're interested in finding out more about the work we're doing around the reforms visit our SEND reforms pages here. If you have views in particular on the revised code of practice please do share them with us via our online survey https://www.surveymonkey.com/s/SENDreforms
This survey is open until Monday 19th May.    

 

Inspecting Childminder Agencies response submitted, March 2014

Provisions in the Children and Families Act allow for the creation of childminder agencies, to act as a support service and local overseer for childcare providers. Ofsted is anticipating such agencies beginning operation by September 2014, given that the necessary legislation is passed by Parliament.

The Trust submitted a final response to the consultation on Wednesday 19th March which an be downloaded here.

The consultation confirms the outcome of a debate that took place over the role of agencies at the Report Stage of the Children and Families Bill in the House of Lords, where from September childminders who register with agencies will have the choice of whether or not they register with Ofsted. The regulatory body will continue to inspect childminders who are already registered or those who choose to sign up, but responsibility for monitoring the work of childminders will lie with the agencies themselves. The Government argument is that it would be too burdensome and bureaucratic to have agency registered childminders overseen by two separate bodies. Of course the key will be whether the standards set by agencies themselves will be good enough, which is why strong guidance is crucial although this has yet to be published.

Ofsted will inspect the quality of an agency as a whole using the same four-point scale it uses when inspecting other types of childcare providers. Ofsted will also have to take into account the overall effectiveness of the agency's services to childminders, including: 

  • the effectiveness of the agency's arrangements for assuring itself of the quality of the care and education provided by childminders registered with it
  • the quality and standards of the services offered by the childminder agency to childminders registered with it
  • the quality of leadership and management of the childminder agency.

 

KS4 programmes of study for English and Maths response submitted, January 2014

The consultation sought views on the draft programmes of study for English and Maths at KS4 which have been changed in line with the review of the national curriculum that has been taking place since January 2011. The reforms focus on making the curriculum 'less prescriptive and more rigorous and challenging' for pupils. Further information from the Department for Education on this Consultation including the consultation document itself can be found here.

This consultation is also closely linked to the Ofqual decision to remove the speaking and listening element of GCSE English from counting towards the final grade and we've ensured our response recognises this.

Other key points made in the response include:

  • Concern about the way the proramme of study for English at key stage 4 supports progression either from KS3 or onto further education and study.
  • Highlighting again concerns around the removal of attainment levels in helping teachers, young people and their families adequately measure and evidence progress for children with SEN and SLCN in particular.
  • A call for explicit recognition in the programme of study of the central role spoken language has in supporting children and young people to build and develop all other skills needed for academic and social life.
  • The need for an inclusive definition of the term 'spoken language' which recognises that speech using all alternative systems is equally valued and supported.

You can read our repsonse in full here.

 

New A Level subject content response submitted, December 2013

In March 2012, the Secretary of State for Education set out a programme of reform for A levels to help ensure that the qualifications equip students for higher education. In March 2013, the Secretary of State confirmed his intention that new linear A levels should be available for first teaching from 2015.

A review of A level subject content was therefore conducted between April and July 2013 by the 4 awarding organisations for A levels in England, working with representatives from a range of higher education institutions. The review was independently chaired by Professor Mark E. Smith, Vice Chancellor of Lancaster University.

This consultation seeks views on the outcome of Professor Smith's review and the subsequent work undertaken by awarding organisations to translate recommendations into changes to the subject criteria content and highlight the criteria content for AS qualifications. 

The Trust has responded to this consultation to highlight a number of key issues around speech, language and communication:

  • we have highlighted that whilst the A-Level English Language subject content does feature spoken language as a core part of the proposed curriculum, we believe spoken language should be recognised as a crucial part of a young person's learning across the A-Level curriculum.
  • We are concerned about the removal of 'spoken language' from section A03 in the English Language subject content, and the effect this may have on the incentive for teachers to ensure oral communication skills are developed in the classroom.
  • We are also concerned that the specification of an 'unseen text' may be disadvantageous to pupils with SLCN.
  • We would welcome the inclusion of the new section in A05 that requires students to 'demonstrate expertise and creativity in the use of English in a range of different contexts', should this section specifically mention 'including spoken language'.

You can read our response in full here.


Draft 0-25 Special Educational Needs (SEN) Code of Practice consultation response submitted, December 2013

The Communication Trust has submitted its response to the Draft 0-25 Special Educational Needs (SEN) Code of Practice consultation from the Department for Education and Department of Health. The SEN Code of Practice is an essential document for practitioners, service providers, local authorities, schools and families and outlines to everybody involved in supporting children and young people with SEN what the law says they have to do and how they should be doing it.

As part of the Children and Families Bill, the SEN Code of Practice which was last reviewed in 2001, is being updated and extended. This is a vitally important opportunity to make sure children and young people with SLCN have their needs met with the reforms making the most significant changes to SEN law in 30 years.

In our response we welcome the improvements that have been made to the Code from the indicative draft, including its focus on putting children, young people and their families at the centre of the process and the recognition of communication and interaction as one of the four areas of SEN.

Our response also focuses on some key areas we feel the Code is lacking, and with particular consequence for children and young people with SLCN. These include concerns around the:

- Accessibility and structure of the Code
- Accountability for families if things go wrong
- Accountability for training and professional development
- Responsibilities within joint-commissioning
- Accountability for the Local Offer
- Insufficient support in early years, particularly the 0-2 age range
- Lack of guidance on early identification

To find out more and read our response in full please click here. We've also prepared a key issues document outlining the above and more key areas in summary, you can access this here. If you would like to read the draft Code of Practice document itself, please click here.  


Primary assessment and accountability under the new national curriculum consultation response submitted, October 2013

The Trust agrees wholeheartedly that effective assessment is part of good teaching and that there is a need for formative assessment and meaningful feedback.  However we do not believe that the proposals represent an effective assessment system.  We do not agree that the proposal reflect the latest evidence or best practice and are particularly concerned on the potentially negative impact on the one million children with speech, language and communication needs.

If national curriculum levels are removed and not replaced there are significant damaging and impactful implications for how possible it will be to monitor progression for pupils with SEN and SLCN in particular. At worst, the recommendations negate the possibility of effectively monitoring and supporting effective progression for these children; at best they make it incredibly difficult.

We would like to see a fair and equitable system introduced for assessment and measuring progress and would encourage Ministers to look at the systems recommended by the Better Communication Research Programme as a way of achieving that for speech, language and communication.

The Trust would also argue strongly for the continued use of the EYFS profile data to as a baseline assessment; we have serious concerns around the introduction of a baseline check at this stage and particularly around the proposal to make the EYFS Profile non- statutory.

The recent BCRP concluded that the Early Years Foundation Stage Profile (EYFSP) provides a valid measure for predicting educational success, when teachers are trained to implement it effectively and therefore could be considered a useful tool to identify children at risk of later educational difficulties, particularly in literacy.

We would strongly encourage the Government to use the opportunity for more guidance for primary schools in how to support spoken language generally and children with SLCN specifically.

Read our response in full here.

 

Trust submission to the Department for Education Regulation of Childcare consultation, September 2013

This Department for Education consultation asks for views on proposals to make changes to the regulations for out of school providers and settings. The consultation has come out of the More Affordable Childcare proposals and seeks to relax regulations around out of school childcare to make it easier for parents to navigate and make more childcare available. To find out more please click here.

The Trust has some serious concerns about a number of the proposals outlined in this consultation and we have outlined some of them below;

• Proposal to increase the amount of time children can spend in informal care settings from 2 to 3 hours per day
• Removing the requirement for children aged 5-7, for providers to have a minimum of two staff on the premises when children are present
• Removing the requirement for providers of wraparound and holiday care to meet the learning and development requirements of children attending school reception classes in their care
• Removal of the requirement for childminder training courses to be local authority approved
• Removal of the requirement for settings to have a behaviour management policy and a named practitioner responsible for behaviour management
• Remove requirement for regular appraisals, or support to improve qualification levels for staff working with children
• Removal of requirements for providers of out-of-hours care to provide regular appraisals and support to improve qualification levels as well as an exception for managers in out of hours care to hold at least a level 3 qualification

To read a more detailed account of these concerns please read our full submission here.

 

Trust response to the Intellectual Property Office disability exceptions technical review, September 2013

The proposed changes to the Copyright act seek to extend the current exemptions for visually impaired people to have accessible versions of printed works to all disabled people and all forms of copyrighted works.

The Trust is strongly supportive of the widening of the exemptions in current provisions to encompass all disabled people and their access to all forms of copyright work and have outlined specific comments on the suggested clauses in the legislation in our response. To read our response in full please click here.
 

Trust submission to Department for Education consultation on proposed changes to the National Curriculum, August 2013

On 8th July the Dept for Education began its latest phase of consultation over reforms to the National Curriculum. This consultation focused on the overall Framework which Ministers wish to see for the Curriculum and added layers of detail via the draft Programmes of Study for English, Maths and Science. The Trust has been actively engaged in this process since it began with an Expert Panel review in 2011/12 and we have continued to make the case, understood by the Expert Panel, that speech, language and communication needs (SLCN) must be a top priority for any changes.

In our response, which is available here, the Trust has welcomed the positive statements about communication skills and their importance to learning and development. We have however expressed concern about the fact that the emphasis on speaking and listening remains significantly below that of reading and writing and that listening is overlooked. We do not see sufficient evidence that pupils will be taught the component elements of language nor that there will be adequate protection for those children who communicate effectively but not fluently. We believe that with minimal detail set out in the Curriculum for communication it will not be a priority in the classroom and we have called on Ministers to look again at this part of the document and to also offer up comprehensive guidance for teachers, large numbers of whom report finding it difficult to identify and develop children's SLCN.

Our largest concern however, and one that overlaps with the Department's current consultation on Primary Assessment and Accountability, is the removal of the attainment level system. The Framework as currently drafted merely states that pupils must be able to know, apply and understand the matters, skills and processes specified in the relevant Programme of Study but, crucially, does not provide a system to help teachers benchmark progression or attainment. If implemented in this way the Trust fears that large numbers of children's SLCN will fail to be identified and neither parents nor teachers will understand individual progress in this crucial area. We have therefore called on Ministers to look afresh at this proposal and to work with the sector via the Trust to understand better the consequences of removing attainment levels and to assess the most appropriate way forward.

 

Ofqual consultation on the removal of speaking and listening assessment from GCSE English and GCSE English Language, June 2013

In this repsonse the Trust has stated that oral communication is the foundation of written language; without strong spoken language, children will struggle to read and write well, accurately and with meaning. It is the vehicle by which teachers teach, fundamental to professional engagement and provides the gateway to children's learning. It is the basis of social interaction, necessary for wider development as well as learning. To read the Trust's response in full please click here.

The Trust has referred to evidence supporting  a focus on spoken language impacting positively on educational outcomes. The Trust maintains that oral communication remains poorly understood and is an element that is all too peripheral to educational assessment.

We strongly believe that the proposal to remove the requirement for speaking and listening from contributing to the overall GCSE English/English language grade is a backward step that would negatively impact on children's educational outcomes and sideline oral communication in the classroom significantly. Keeping it as an integral part of the high-stake English GCSE will ensure it is an area which teachers and schools will promote and develop. Speaking and listening should be actively developed if the UK is looking at 'best educational practice.'

 

Consultation on proposed changes to the role of the local authority in early education and childcare, May 2013

This consultation proposes changes to the role of the local authority in early education and childcare. It proposes that decisions to fund early education providers to deliver places solely on the basis of Ofsted inspection judgements including settings judged 'satisfactory'.  It is proposed that LAs will not undertake separate assessments of the quality of early years provision, and that Ofsted will be the sole regulator. Whilst many of the specific questions outlined in this consultation were not of direct relevance to the work of The Trust, its response highlights areas it believes the proposals will affect the quality of support for children's speech, language and communication development, and for children with speech, language and communication needs (SLCN). To access the Trust's full response please click here.
 
The Trust has outlined its three major concerns  - the proposal to remove the quality assurance role for local authorities, funded places for 2 year olds and the proposal that front line early years professionals will be judging their own training and development requirements when evidence shows that practitioners have low levels of skills, knowledge and confidence in supporting children's speech, language and communication development.

• In terms of quality assurance, we know quality is reliant on knowing settings, rather than merely inspecting them. Every Child a Talker, a local authority-led programme was based on a thorough understanding of local context and the needs of local children. Experience has shown that ongoing development of quality around children's speech, language and communication stems from such an integrated approach.

• In terms of training and development, evidence has shown that many early years staff feel inadequately equipped to help children with language delay with over 60% of teachers reporting they lacked confidence in their ability to meet children's language needs despite this being such a critical stage of a child's development. Therefore, we strongly disagree with that early years professionals on the frontline are the best judges of their CPD requirements. Clear and robust structures need to be in place to ensure that all practitioners are able to access relevant and effective CPD to help them support children's development, identify children who are struggling and support children with communication needs.

• The decision to fund places for two year olds in settings judged to be satisfactory where there are insufficient good or outstanding settings is also raised as cause for concern. The Trust argues that funding in this way sends the wrong message to families and providers, making it difficult to see how this will actually drive up the quality delivered by these settings, particularly around children's speech, language and communication in areas of social disadvantage.



DfE consultation outlining changes to Secondary School Accountability, April 2013

The Government is currently consulting on its proposed changes to Secondary School Accountability. The secondary school measures will reflect the significant reforms to GCSEs, with the new qualifications taught from 2015 and first exams taken in 2017. The consultation also asks how the DfE should publish and use data about schools' performance. Please find the Trust's response here.

The Trust welcomes the notion of widening accountability beyond the current measures of schools being judged on how many pupils achieve 5 A-C grades in GCSEs. However we are concerned that the new headline accountability measures only serve to reinforce the current situation, albeit over a wider range of subjects. We are concerned that headline measures such as these often mask unacceptable variations for specific groups of children, such as those with SLCN/SEN.

Good spoken language skills are strong predictors of later academic success; children with poor language and literacy development at 5 years are at substantial risk of low achievement at 7 years and beyond. Good spoken language predicates reading and writing, with literacy gaps often widening as children progress through school. The proposed accountability measures don't appear to give consideration to how schools will be held account in capturing progress for these children. The concern is that with similar accountability across a wider range of subjects, these pupils will continue to be left behind. As the most prevalent childhood disability, this adds up to a lot of children, which is why schools should be made accountable for how well they support them. The new measures of accountability in no way meet the need for accurate profiling and monitoring of children with SLCN, evidenced as fundamental to ensuring progress and attainment for these children in the Better Communication Research Programme.

 

Trust's response to Transforming Youth Custody: Putting education at the heart of detention, April 2013

The Trust has responded to the Green Paper on youth custody which aims to put education at the heart of detention. The document looks at the free schools programme, as well as the academies programmes, as models to improve education standards for youth in custody. The paper describes the Government's plans that aim to punish young offenders while also equipping them with education that will help to rehabilitate them and to live law-abiding lives after their period of custody. This will involve creating 'Secure colleges' which will be at the heart of the new system. Please find our response here.

In its response, the Trust makes the case that at least 60% of young people in custody have communication needs. In the majority of cases, these young people's communication difficulties have not been identified and their needs go un-met at great cost to both the public purse and the young people themselves. The Communication Trust sets out how better meeting these young people's needs will help deliver the ambitions set forward in Transforming Youth Custody.  Within Secure Colleges, given the prevalence of young people with entrenched speech, language and communication needs, it is essential that communication skills (speaking and listening) are explicitly highlighted as a basic skill, alongside literacy and numeracy. The Communication Trust would therefore recommend that:

  • Educational programmes in Secure Colleges include a clear and explicit focus on developing communication skills at their core- that communication skills are seen as basic skills, underpinning academic, vocational and other learning, rather than merely as 'wider skills'.
  • A balanced curriculum needs to ensure that adequate time and expertise is included on enabling young people to develop pre-requisite language skills to allow educational programmes to be effective.
  • Staff within Secure Colleges are effectively supported to develop the skills and competences, systems and processes, tools and resources they need to make sure that the educational opportunities they are providing are accessible and successful for the 60% of their young people with speech, language and communication needs.

Also, the Trust is pleased that the proposals in the Government's Children and Families Bill would require all local services to co-operate on SEN provision including Youth Offending Teams. In Transforming Youth Custody the importance for ensuring joining up of services and information sharing for the benefit of improving young people in custody's education- 'However, the current wording of the Bill (clause 69) states that the plans will be suspended if a young person enters custod; this is particularly worrying given the prevalence of SLCN amongst those in the youth justice system and needs to be addressed.

 

Trust's response to the Consultation on Teachers Standards - Early Years, April 2013

The Communication Trust has responded to the Government's consultation on standards for Early Years Teachers which sets out the standards that trainee teachers will have to meet on the Early Years Foundation Stage to reach Early Years Teacher Status.  Please find our response here.

The proposals sets out eight broad standards, each underpinned by several principles, several of which ask for Early Years Teachers to develop children's communication skills and be aware of their communication needs. The full criteria may be found here.

The Trust feels that overall, these standards will support the training and assessment of early years teachers and we welcome the approach to these standards more strongly than those set out in the early years educator criteria.

However, we feel that there are a number of areas which should be developed further including:

• ensuring rigorous training and assessment towards these standards;
• guaranteeing the detail underneath the standards is clear and explicit, ensuring that both the depth and breadth of knowledge, understanding and skill are fully included in training and assessment;
• highlighting knowledge, understanding and skills practitioners need to support speech, language and communication development more explicitly, given the vital importance of communication development for children's overall learning, behaviour, social and emotional development. This is particularly important as it is a prime area of the EYFS yet is often an area in which early years practitioners and teachers feel under-confident and indeed lack skills and knowledge.

We have significant concerns over the limited relationship between these standards and the proposed full and relevant criteria for early years educators.  We are also disappointed that early years teachers qualifications will not relate to qualified teacher status. Early years teachers have a critical role in ensuring the early development of children at a crucial time and we feel that this should be reflected in their relationship to teachers of other phases.

 

Consultation on the 'Full and Relevant' Criteria for new Level 3 qualifications for Early Years Educators- The Communication Trust's response, April 2013

The Communication Trust has submitted a response to the Government's consultation on the 'full and relevant' criteria for new Level 3 qualifications for Early Years Educators. This consultation proposes the 'full and relevant' criteria to underpin new Level 3 qualifications from September 2014, which will qualify individuals to become Early Years Educators.

Please find the Trust's response here.
 
The Trust believes that these criteria only partially set appropriate expectations, and do so mostly in relation to health and safety elements rather than in other areas of the qualification. They lack an overall vision and understanding of the role of the Early Years Educator in terms of nurturing, promoting and supporting the effective development of babies and young children. It also over-focuses on promoting 'school readiness' rather than a baby or young child's well-being and potential future outcomes.

It is essential that any early years educator fully understands how speech, language and communication develop and is able to actively and effectively promote and support the speech, language and communication development of every baby and child in their care. For this to happen in practice, the criteria for the qualification need to explicitly and clearly reflect this.

Given that this is a prime area of the new EYFS, and that evidence shows that over a third of children are not secure in communication, language and literacy on school entry, we feel it is essential that criteria for this qualification explicitly reflect the knowledge, understanding, skills and practice which are needed to support this fundamental life skill.

 

Consultation on National Curriculum Framework - The Communication Trust's response, April 2013

The Department for Education has been consulting on the National Curriculum Framework which sets out how the Government intends to approach finalising its revised curriculum - here.

The Trust has submitted its response to the National Curriculum Framework, please click here to view.

The Trust is pleased to see spoken language recognised as being fundamentally important to the learning and development of all children; we were heartened by the Secretary of State's intent for all children to have a strong command of the spoken word and the acknowledgement of the importance of spoken language in pupils' development - linguistic, cognitive and social - across the whole curriculum.

However, we are concerned that these good intentions are not fully reflected in the Curriculum framework and therefore risk being lost in the translation into classroom practice. We feel that some areas such as grammar and phonics have a lot of detail and prescription compared to the lack of specificity more generally, and particuarly in the references to spoken language in the Programmes of Study. We believe this issue requires an explicit language strand introducing into the Curriculum to give teachers the structure from which to drive improvement.

 

Children and Families Bill - The Communication Trust's Position Paper for Second Reading, March 2013

The Communication Trust has worked with its Children and Families Bill Task to develop a position paper in advance of the Second Reading of the Bill. Please click here to view.

The Task Group includes representatives of The Communication Consortium (a coalition of 47 voluntary organisations with expertise in speech, language and communication), on the Children and Families Bill, The Royal College of Speech and Language Therapists and Every Disabled Child Matters Campaign (EDCM).

The Communication Trust is committed to working collaboratively and is a member of EDCM; we endorse their briefing and through this paper add specific issues for speech, language and communication.

The Trust welcomes the Government's overall vision to improve outcomes for children with SEN and we broadly support the intention of the clauses in Part 3 of the Bill. However, the Trust has specific concerns about the effect of some of the changes on the one million children and young people in the UK with speech, language and communication needs (SLCN), the most prevalent special educational need in primary-aged children.

 

Consultation on Early Education and Childcare Staff Deployment- The Communication Trust's response, March 2013

The Communication Trust welcomes the drive for improving qualifications for the childcare workforce, but urges the government to ensure that they have a clear focus on how best to support children's speech, language and communication development. For our full response to the More Great Childcare consultation click here.

 

Consultation on the review of Youth Justice National Occupational Standards (NOS) - November 2012

The Communication Trust is delighted to comment on Skills for Justice's proposed amendments to the Youth Justice National Occupational Standards (NOS), which would replace the current standards from both the Youth Justice and Resettlement of Offenders suite.

We warmly welcome the specific mention of speech, language and communication needs (SLCN) in the NOS. The Trust has undertaken pioneering work with young people with communication needs in the youth justice sector through Sentence Trouble and its partnership with the Youth Justice Board. Research shows how young people with communication needs are disproportionally represented in the youth justice system, often due to the fact that their needs have not been identified or met[1].

We are very pleased therefore that SLCN is recognised in both the performance and knowledge and understanding criteria. We would be delighted to work with Skills for Justice further to discuss how we can ensure the workforce is supported to meet these criteria.

Please click here to read the full submission for our comments on the specific standards relevant to The Communication Trust.

 

Children and Families Bill - October 2012

On 3rd September, the draft legislation on 'Reform of provision for children and young people with Special Educational Needs' was released which will form part of the Children and Families Bill.

On 7th September, the Education Committee began the Pre-legislative Scrutiny into Special Educational Needs. 

The Trust submitted a response to the Education Committee on 10th October, please click here to view. 

 

Extending free early education to more two year-olds - October 2012

The Government plans to introduce a legal entitlement to free early education for two-year-olds and has been seeking views on proposed eligibility criteria for the second phase of the new entitlement from September 2014.

The Communication Trust welcomes the extension of the entitlement to two year olds with additional needs. However, we have a number of concerns relating to children with speech, language and communication needs. We consider that the proposed extension is too narrow - only a very small number of children aged two have a statement of SEN, and we consider that the legal entitlement should therefore be extended to any 2 year old child with an additional need that could affect their long term outcomes, who has been referred through a recognised multi-agency assessment process. 

We also have a number of suggestions on how the entitlement may be most effectively delivered in practice and as to how we can avoid the situation in which that the funding for the extended 2 year offer is not re-directed to other areas.

Please click here to read our submission.

 

Childcare Commission - August 2012

The Trust has submitted comments to the joint DfE/DWP Childcare Commission inquiry which is looking at improving access to childcare, reducing its cost and de-regulating the sector.

The Trust is concerned that as the Government seeks to implement these changes that there is a danger that the quality of childcare could be reduced and may undermine many of the very positive recommendations about improving support for SLCN that were contained in the Nutbrown Review of Early Education and Childcare Qualifications.

Please click here to readour response.

 

Response to Draft Primary Curriculum  - July 2012

Following the publication of the draft revised primary curriculum documents for English, Maths and Science in June, the Trust submitted an initial response to the primary draft curriculum.

The Trust are pleased to see spoken language recognised as being fundamentally important to the learning and development of all children. We were heartened by the letter of the Secretary of State reflecting the intent for all children to have a strong command of the spoken word and the acknowledgement of the  importance of spoken language in pupils' development - linguistic, cognitive and social - across the whole curriculum.

However, we are concerned that these good intentions are not fully reflected in the shape of the current programme and therefore risk being lost in the translation into classroom practice.

Our response around the following areas with some specific suggestions:
• Spoken language and attainment
• Defined areas of the curriculum
• Teacher quality and innovation

Please click here to read our response.

 

Letter to Sarah Teather - SEN Green Paper Response - June 2012

Following the publication of the Government's SEN Progress and Next Steps documents in May 2012, The Communication Trust wrote to Sarah Teacher, Minister for Children, setting out our response and concerns that the new proposed 'clearer definition' of SEN does not inadvertently exclude children with speech, language and communication needs (SLCN), whose difficulties may be "hidden" and concerns over how the 'local offer' responds to the needs of the children with SLCN. 

The Trust also produced a briefing for the Education Committee's Oral Evidence Session with Sarah Teather on Wednesday 20th June.

Please click here to read the letter to Sarah Teather and please click here to read the briefing.

 

The Trust has recently submitted a response to Ofsted and Her Majesty's Inspectorate of Prisons on proposals for a revised framework for the inspection of secure training centres

In our response, the Trust outlined the fact that at least 60% of young people in the youth justice system are likely to have communication needs, and that for the vast majority, these needs have never been identified.  We highlighted the link between communication needs and the behaviour of children and young people, and the need for the workforce to be aware of young people's likely communication needs in order to meet the welcomed proposal of an emphasis on consultation with young people to ensure their safety, well-being and improved behaviour and attainment. 

Just as the new Framework for The School Inspection brought in from January 2012 puts a great emphasis for the first time on 'communication skills', we stated that the same principle should be brought to the inspection of secure training centres. We also highlighted the fact that in partnership with the Youth Justice Board, the Trust has been delivering communication needs workshop training to staff across the secure estate and outlined some of the achievements and outcomes of this work.

To read our response, please click here.

 

Initial teacher training in PRUs - May 2012

The Trust has recently submitted a response to Government consultation on allowing initial teacher training in PRUs highlighting the recent Let's Talk About It publication and the need for need for those training in PRUs to be particularly aware of SLCN.

Read our response here.

 

Children and Young People's Health Outcomes Strategy - April 2012

The Children and Young People's Health Outcomes Forum has been gathering views from children, young people, parents, carers, doctors, nurses and other professionals. They have been gathering their views on the health outcomes that matter most for children and young people and how the different parts of the health system will work together to deliver these. The Forum will report to the Government with independent advice that will inform the Children and Young People's Health Outcomes Strategy. The Strategy will ensure that the outcomes measured are the ones that matter most to children, young people, their families and the professionals responsible for their care.

The Trust has submitted a response to the Forum highlighting the needs of children with speech, language and communication needs (SLCN). Please click here to view.

 

Joint strategic needs assessments and health and wellbeing strategies submission - February 2012

The Department of Health has been seeking views on draft statutory guidance on joint strategic needs assessments (JSNA) and health and wellbeing strategies. The Trust has submitted a response to this consultation, highlighting the importance of including speech, language and communication skills within the JSNA and joint health and wellbeing strategy guidance and referencing the guidance for commissioners that has been done by Jean Gross, the Trust and RCSLT.

Please click here to view.

 

Further submissions

Please click here to read The Communication Trust's letter to Sally Smith with regard to Ofsted's Consultation on School Premises Regulation

Please click here to read The Communication Trust's response to Ofsted's Consultation on revised inspection arrangements for initial teacher education partnerships

Please click here to read The Communication Trust's response to  the Department for Education's Consultation on Proposed Changes to the Entitlement to Free Early Education and Childcare Sufficiency





Children and young people’s mental health – the role of education, January 2017