The scale of proposed SEND reforms alongside other policy changes risks “smothering” the school system, the government has been warned. School leaders’ union NAHT, the Association of School and College Leaders (ASCL) and the Confederation of School Trusts (CST), as well as teaching unions NASUWT and the NEU have published responses to the Department for Education’s SEND consultation which closed on 18 May. All responses welcomed the move to create more inclusive environments with early intervention. But they also warned that funding and resources may not match up to expectations. Here’s everything you need to know. 1. ‘System-level smothering’ Leadership unions have warned that the SEND reforms – alongside changes to curriculum, enrichment and suspensions guidance – will be overwhelming for schools. The NAHT and CST both said implementing everything at once represented a “cumulative burden”, while ASCL said it had “serious concerns about the scale of expectations being placed on schools”. CST described this as “system-level smothering”, while the NEU said reform was “unsustainable before it has got off the ground” without protected and funded time, and argued the proposals were dependent on staff who “didn’t exist yet”. Clearer alignment is needed across education, health and social care, otherwise there is a “risk that expectations continue to fall disproportionately on schools and trusts”, the union added. The NASUWT said it did not believe the timeline for reform is realistic, and suggested reforms should be piloted and independently evaluated before wider implementation. 2. Funding ‘gaps’ will remain Funding for the reforms include £3.5 billion in extra high needs funding by 2028-29, a £1.6 billion inclusive mainstream fund, £1.8 billion “experts at hand” service and £200m in teacher training. ASCL and the NEU said it was not clear whether funding will be enough to implement the reforms. The teacher training funding in particular is a “drop in the ocean”, according to ASCL. CST also warned that current gaps in funding “will remain”. It proposed a two-layer model that creates separate funding for commissioned provision and meeting individual needs through the universal offer. 3. ‘Confusion’ on experts at hand Unions have also welcomed the experts at hand service, which aims to make more external professionals including educational psychologists and occupational therapists available to support schools. The NAHT said clear, nationally consistent response times must be set, with clear protocols on how to escalate concerns when response times are missed. CST said there was “potential” in the model, but also “significant confusion” in the system about how it will operate in practice. 4. Inclusion bases One of the main proposals in the white paper is for all secondary schools to have an inclusion base to support pupils with additional needs. ASCL said it supported this in principle, but warned such bases are “not a silver bullet”, and inclusion must be system-wide. The union also said inclusion bases “should not become holding pens, standalone units or exclusion by any other name”, but welcomed the attempt to simplify the language used for the bases. At present they can be called SEN units or resourced provision. While the NAHT said inclusion bases had a critical role to play, it “fundamentally challenges the assumption that inclusion bases can meet the full range of SEND”. CST said guidance must clearly differentiate between support bases commissioned by schools, and those commissioned by councils. 5. ‘Light’ EHCPs? Reforms will require schools produce an individual support plan (ISP) for every pupil with additional needs, including those with an education, health and care plan (EHCP). While an EHCP would be secured for pupils with the “most complex needs”, this would be through a nationally defined specialist support package. But the NAHT raised concerns ISPs risk becoming a “light EHCP”, adding complexity rather than reducing bureaucracy. As ISPs will be looked at during Ofsted inspections, the union also outlined concerns the plans will evolve into accountability tools, rather than supporting provision. CST said the relationship between ISPs, EHCPs and new specialist support packages “requires much greater clarity”, as it is not clear how they will interact. The NASUWT said reducing EHCPs “is likely to compound the problem of schools being accountable when things are outside of their control”. ASCL warned that an average secondary school may have around 200 ISPs. 6. Complaints process Government has said parents will have to appeal decisions on ISPs through their school’s complaints process. But CST said this risks an “exponential rise” in complaints, which could “overwhelm” schools. ASCL said school complaints should be independent, put through the local government ombudsman. The leadership union also did not agree that a SEND specialist should sit on the complaints panel, warning the “focus on schools and colleges to self-monitor is unfair for them and for families”. 7. Health ‘must play more active role’ The NASUWT said the health and social care sectors “must play a more active role” in delivering and resourcing support for SEND. “The extent of [Department of Health and Social Care] involvement with, and ownership of the reforms, is unclear,” its consultation response said. CST agreed there should be more clarity on the role of health services, ICBs and local authorities in the reforms system. 8. More resource needed for SENCO aims Ministers want to make the role of special educational needs coordinators (SENCOs) more strategic under the new system. The NAHT said this would only work if schools had more resources and staff members, while ASCL said guidance and examples of how SEND responsibility can be spread throughout school leadership should be shared.