Leaders have raised serious concerns about government plans to create specialist provision packages, which they fear will lead to children “falling through the gaps”.

These packages are set to be a key new element of a reformed system, and will underpin the support available for pupils with the most complex special educational needs.

But, with the consultation on the government plans closing in just over a week, sector leaders have identified a range of flaws and problems.

The leaders warn that the “bizarre” proposals could group pupils who have very disparate needs, and that literacy and numeracy support needs risk being overlooked.

The leaders also question why mental health is no longer being considered as an educational need.

The Department for Education has said that packages are being introduced to address the lack of a “clear or consistent approach” in identifying and supporting pupils with complex needs.

The packages are aimed at being “nationally defined and evidence-based”, setting out “exactly what interventions, resources and standards are required”.

However, there are concerns that this could result in an overly standardised approach.

Risk of standardisation

Nic Crossley, the CEO of Liberty Academy Trust, which runs three special schools for pupils with autism, said the plan appears to be based on a “core assumption” that “children’s needs can be broken into discrete packages, and that stacking the right ones produces an effective response”.

She added: “However, the packages are arranged, packaging carries an inherent risk of standardisation...SEND reform is necessary and overdue. But when packages become viewed as solutions rather than supports, the system risks fitting children to provision rather than provision to children.”

A report produced by the National Association of Independent Schools and Non-maintained Special Schools (NASS) in response to the government reforms, seen by Tes, also raises concerns about the provision package approach.

It says: “NASS believes that one of the strengths of the current SEND system is that each EHCP [education, health and care plan] is tailored to the specific needs of each child or young person.”

But NASS is “concerned about the proposal to reduce this rich, bespoke framework for support to only seven categories of specialist provision packages”.

The organisation says it is unclear why the government has limited specialist provision packages to seven categories, and also “how those categories were conceptualised and chosen”.

Susan Ebbels, director of Moor House Research and Training Institute, which is linked to Moor House School and College special school in the South East, warned that “having seven packages covering every child with special educational needs just seems impossible”.

“It’s going to be fitting far too disparate a group of children into the same package,” she said. “Many children risk falling through the gaps between the packages; they may not fit neatly into any package at all, and then would not be able to access the specialist layer of support.”

Plans for SEND reform

Earlier this year, the government announced plans for wholesale SEND reform aimed at making mainstream schools more inclusive.

Under the proposed system, there would be three tiers of support for pupils with SEND: targeted, targeted plus and specialist, the latter of which would be provided through specialist provision packages.

Pupils on the specialist tier would be the only children to receive EHCPs, and could be taught in either special or mainstream schools.

The government published an indicative list of seven package areas in February, which it said was developed by a panel of experts from the specialist sector. Its consultation on SEND reforms closes on 18 May.

The initial package areas are: Profound and multiple learning difficulties; Significant executive function; Complex executive function and communication; Social and emotional development focused on externalising behaviour; Social and emotional development focused on internalising behaviour; Sensory impairment; and Physical disability.

Pupils on a specialist provision package in a mainstream school are likely to have some of their education in an inclusion base, of which the government wants one in every secondary school, with equivalent places created in primaries.

But leaders have raised concerns about whether mainstream schools will have the capacity to deliver the provision set out in a package.

Questions over mainstream capacity

Amanda Hulme, headteacher of Claypool Primary School in Bolton, questioned whether schools would have “the capacity, the room and the expertise to do this”.

She added: “The government has said that they want every school to have an inclusion base, and I am sure schools will set these up with the best of intentions, and some will be done very well, but I do worry that they could also end up being the most challenging pupils being supported by the least qualified staff.”

Hulme also raised concerns about the government’s “experts at hand” programme, which is expected to support mainstream schools.

She said: “If the packages are based on the idea that schools can access outside experts, then this is a concern. We have been advertising for educational psychologists in Bolton, and they simply don’t exist - the people are not there.”

‘No rationale’ for removing mental health

The government is also suggesting changing the “areas of need” in the SEND Code of Practice for schools.

There are currently four areas, including social, emotional and mental health (SEMH), but the proposals would create five areas of development. While these include social and emotional needs, the new definition omits mental health.

NASS describes the removal of SEMH - which was introduced as a category in 2014 - as “a very significant change”. It warns that the “government has given no rationale for making it, nor a steer on what this will mean in practice for special schools currently designated as supporting children with SEMH.”

More than 350,000 learners are currently identified as having a mental health-related educational need, according to NASS’ official response.

It added: “Since 2014, schools have had to work hard to define mental health as an educational need and to develop responses that use school-based mental health therapists to integrate therapeutic and trauma-informed responses in the classroom. The proposed reforms leave the future of this work uncertain.”

This concern was shared by Nicola Whitcombe, regional director at Reach South Academy Trust and headteacher of the Springfields Academy special school. She said: “Reframing SEMH solely as a health need fails to acknowledge the expertise schools have developed in this area.”

The refreshed Code of Practice “gestures towards a health‑led response but provides no evidence that the NHS is resourced, trained or mandated to deliver it,” she warned.

“The shift feels ideological rather than practical - and risks dismantling a decade of hard‑won progress,” she added.

Fears over literacy and numeracy support

Another concern is that cognition and learning - a main area of need in the existing Code of Practice - has no equivalent in the SEND reform areas of development being put forward, according to Ms Ebbels.

“For children with specific, moderate, severe and profound and multiple learning difficulties, their primary barriers to learning - literacy, numeracy, cognition and learning - do not appear anywhere under the new areas of development,” she said.

This “may mean that any child with difficulties in these areas may not receive the support that they require,” she warned, calling this a “big concern”.

She also felt there were problems with the “significant executive function” specialist provision package category.

This, Ms Ebbels said, was aimed at “children with severe learning disabilities and lifelong language disorder”. But for these pupils, executive functioning “is not their core difficulty”.

‘Bizarre’ grouping of need

In addition, she said these two groups “don’t need the same provision” - with one requiring a “majorly modified curriculum”, but the other usually able to access a mainstream curriculum, “as long as it’s delivered with supportive strategies and the language is broken down”.

“Putting those two groups in the same package just seems bizarre,” she said.

Some leaders see the plans in a more positive light. Simon Knight, co-headteacher of Frank Wise special school in Oxfordshire, hoped that specialist packages would support the system to “act with greater predictability and consistency” and set out “the broad, evidence-informed characteristics” of provision.

However, the consultation would be crucial in “further refining thinking in this area”, he added.

Moving to a system of packages with national bands of funding could also help to remove the current “postcode lottery”, said Warren Carratt, CEO of Nexus Multi-academy Trust, which runs 20 academies, including 18 special schools.

But he added: “However - and this is a size-500-font ‘however’ - I am really worried that this is an exercise that is fixed on reducing costs, as the DfE tries to assure the Treasury that it can control high needs spend while not changing the law that governs the current system, or reducing the pressure valve that is the accountability system for mainstream schools.”

Are changes driven by cost-cutting?

The government is reforming the SEND system amid warnings that local councils would otherwise have to declare effective bankruptcy.

And headteachers’ leaders have stressed that the packages should not be limited by local funding pressures.

Rob Williams, senior policy advisor at the NAHT school leaders’ union, said it will be “essential” for specialist provision packages to be underpinned across education, health and social care, “with the funding, staffing and flexibility needed for schools to deliver consistently for all pupils”.

“Without this, they risk becoming aspirational documents rather than deliverable guarantees,” he warned.

Mr Williams added that the packages should not constrain professional judgement or limit access to the provision required. A “really clear baseline entitlement is essential, which must not be suppressed by local resource pressures,” he said.

The DfE has been approached for a comment.