Abstract:

This document is a response from a teachers union and professional association, The Association of Teachers and Lecuturers to the Teacher Training Agency's consultation on 'National Standards for Special Educational Needs Co-ordinators' with a closing date of October 1997.

For any further information/comments on the response, please contact:
Meryl Thompson, Head of Policy Unit, Association of Teachers and Lecturers, 7 Northumberland Street, London, WC2N 5DA E-mail: Mlowe@atl.org.uk

1. The Association of Teachers and Lecturers (ATL) is a teachers' professional association and trade union with 150,000 members, who are teachers in maintained and independent schools, lecturers in further education and student teachers. As we said in our 'Response to the Teacher Training Agency on Approaches to the Continuing Professional Development of Teachers Consultation', new approaches to continuing professional development have very significant implications for teachers and for the future status and character of the teaching profession. We do not think that ATL's commitment to the concept of high quality comprehensive, continuous professional development (CPD) for all teachers as an integral feature of teachers' conditions of service and as a demonstration of teachers' professionalism, can be called into question.

   A PROFESSIONAL FRAMEWORK FOR TEACHERS

2. We wish to comment first on the nature of the professional framework, of which this set of standards is just a part, It is said that this framework has a central role to play in raising the professional status of teachers and in ensuring high quality relevant training. However, we are not convinced, as we have said before, that the standards framework supports sympathetically enough the concept of CPD. In many respects, we believe, the concepts of 'awards' and 'qualifications' and 'needs', that have been assessed or met, may work against or divert attention from, the continuous and unpredictable need to maintain and enhance knowledge, expertise and competence, when knowledge, expertise and competence themselves are subject to constant change. The personal agenda may too often be set just as the external environment re-prioritises it.

3. The role of CPD in the management of change in the teaching profession requires that constant thought is given at the national level to future system-wide needs; to the infra-structure that first needs to be in place for effective professional development - the preparation of the trainers, mentors, coaches and assessors ; the future direction of the curriculum and its implications for CPD; and the fast and effective dissemination of research findings. Without these, no framework can raise standards. There seems to us to be a danger in these standards that there is, in Michael Fullan's terms, 'pressure' but without 'support'. In our view the TTA should be unequivocal in that its focus is not assessment but development.

4. ATL will place its emphasis on ensuring that the context and conditions always promote teachers' professional development for, as we have said before quoting Fullan, 'educational change depends on what teachers do and think; it's as simple and complex as that'. 'Excellence in Schools' makes a welcome commitment to making sure that teachers understand the best methods and how to use them but the practical reality is not yet in evidence.

5. It remains ATL's view, too, that the implications of a national framework of professional standards and qualifications for the teaching profession, as set out in the Foreword, has been insufficiently explained to the teaching profession and, so far, their introduction has been subject to no negotiation with the teachers' associations. This makes consideration of these innovative proposals, as with those for subject leaders, particularly complex. The situation has not been helped by the publication of the Government's Green Paper, 'Excellence for all children: Meeting Special Educational Needs' (SEN), only days before the closure of this consultation and the statement there that 'All SENCOs, with the support of their senior management and governing body, will be expected to work towards the standards, once these have been agreed'. We believe on the basis of this information the consultation with our members might have resulted in increased reservations as to the realism of some of the expectations encompassed in these standards.

   STANDARDS FOR SPECIAL EDUCATIONAL NEEDS CO-ORDINATORS (SENCOs)

6. The introduction of the SEN Code of Practice has led to the evolution of a job unique in schools - that of the SENCO. The implications of the SEN Code of Practice and the SENCO role were not adequately thought through before the imposition of the Code. The content of the current consultation paper amply demonstrates the necessity to look in depth at the requirements flowing from the SEN Code of Practice and the enhanced SENCO role.

7. Although we welcome more effective, efficient and targeted professional development for SENCOs, for it is long overdue, we, nevertheless, find ourselves unable to welcome the introduction of the these national standards for SENCOs, under the present conditions. We commented in our 'Response to Consultation on Standards and a National Qualification for Subject Leaders' that it seems to us that the TTA has quite unhelpfully fused two discrete, if inter-related, issues which are first the outlining of a framework against which to plan professional development activities and second the introduction of a totally novel set of awards or qualifications.

8. The former could, as we have said, for example, quite non-directively but professionally, enable any SENCO in either sector, from whatever level of experience and over any time-scale to select areas of the framework that were relevant to their particular responsibilities, as set out in the job description, to guide their own self-evaluation, needs assessment and professional development needs and, where this was wished for and appropriate, have that professional development accredited. ATL sees positive benefits in such a professional development framework. If this is what is envisaged in 'Excellence for all children' and if the headteacher's accountability for motivating and enabling teachers, including SENCOs, to develop their expertise through CPD, mentioned therein is to be a position of integrity, then ATL would support the principle and purpose of standards to promote more effective and targeted professional development

9. The latter, the award or qualification, introduces, it seems to us, an entirely different set of issues, which are further complicated by possibly being applied to both aspirant SENCOs and SENCOs, including very experienced SENCOs, in post.

10. We shall be responding in greater detail on the issue of whether the TTA's work on national standards should be taken forward as the base for a qualification for SENCOs in our response to 'Excellence for all children'. However, we made it clear in our previous response on standards for subject leaders that we would look to a situation where: -

    i) the full range of national standards is known and, as the School Teachers Review Body think appropriate, all of the interested parties are confident that they would work in practice;

    ii) recommendations as to their relationship, if any, to teachers' pay and conditions have been made by the STRB following consultation with the relevant bodies, including evidence on the possibility of linking excellence points to such criteria and on their consistency with the requirements of the statutory conditions for teachers and headteachers.

    iii) there is further information on the following, where it can be provided in isolation from the above:

    a. whether it is intended that this qualification will be a compulsory expectation for all existing post holders;

    b. whether it is intended that it will be a qualification/award required of those seeking such a post;

    c. what exactly is to be the relationship of national standards, the introduction of target-setting and any changes to the appraisal Regulations and greater clarity on the nature of target-setting and the future of appraisal;

    d. the intended resourcing and provisions for access to the training programmes;

    e. the provisions for the effective monitoring of the equal opportunities implications;

11. As with the standards for subject leaders, we believe that if a qualification was an expectation it would require our members to radically rethink whether or not they were in a position to accept, as reasonable, a request from a headteacher for them to act as a SENCO, certainly in the absence of clearer guidelines on the related requirements and entitlements for training and the potentially punitive uses of this framework. SENCOs may take on this position, not on the basis of a distinctly differentiated, recognised subject expertise, as envisaged here, but on the basis of sheer professionalism and commitment to the joint purposes of the school.

12. As well as nationally accepted standards for SENCO training, it will be necessary for the execution of this complex job to have nationally accepted standards for status and remuneration. There is a management, leadership, training and co-ordination role for every SENCO regardless of school size or type. Training alone will not encourage people to do this job. Suitable remuneration and a recognition of status are also necessary. No matter what philosophical principles are agreed, the practice will fall short if these things are not given equal priority. In this respect, decisions in relation to Advanced Skills Teachers will be relevant.

13. We also find it difficult to believe that the TTA has considered the conditions of service interrelationships in relation to the primary sector, arising from, for example, the implicit assumptions in the standards as to the availability and use of non-contact time. We consider that some national agreement as to the prioritisation of key outcomes is likely to be necessary. It must be clear to all by now that where SENCOs have a large teaching commitment in proportion to the number of children on the SEN register, the tasks awarded to the SENCO can never all be completed. It would exercise everybody's mind if they had to put these tasks in a prioritised list and it would help schools in identifying precisely the resources needed by a SENCO to work efficiently and effectively. Otherwise, in primary schools where the SENCO is also a class teacher, not infrequently devoid of non-contact time, the formalisation of requirements from SENCOs could lead, over a short period of time, to there being no applications at all for advertised SENCO posts.

14. There are other features on which we would want to be satisfied before these standards could be regarded as a qualification, the most significant of which is quality assurance. We are yet to be convinced that the TTA can, as it says, ensure national consistency, reliability and rigour of assessment arrangements and the validity of the qualifications awarded. For example, we now have lists of skills and attributes, previously abilities, in which, for example, 'prioritise, plan and organise' and 'use appropriate leadership styles in different situations' are listed for headteachers, subject leaders and SENCOs and yet there is no indication of how these can be differentiated.

15. We agree that skills and abilities cannot be seen in isolation. But surely it cannot be intended to be implied that these skills and abilities are exactly the same for the SENCO, NPQSL and the NPQH? There must, we would have thought, be some gradation in the complexity of the skills and some differentiation. It is this that we feel is lacking. It is simply not possible to see how the skills of leadership, communication skills, management skills, mentoring skills - identify which area of skills and professional understanding you might - are conceptualised as developing over time and how they integrate, inter-relate, over-lap and build-up over a career and across the profession. This will not be able to be seen in outline until all the standards are in place. Whether this list in finely differentiated enough will not be able to be seen until a great more developmental work has taken place.

16. Other factors that would be of concern to us are:-
    • the existence of effective methods of accrediting prior learning and recognising the existing qualifications of SENCOs in the framework of any qualification;
    • the way in which the particular contribution of HE would be reflected, especially in relation to the professional knowledge and understanding that underpins these standards, for we share the Sutherland Report's vision that teacher education is a continuum, which at every stage should draw upon the contribution HE makes especially in relation to professional, skills and understanding. Without greater clarity, for example, on the knowledge base which should underpin 'the characteristics of high quality in the teaching of pupils with SEN and the main strategies for improving and sustaining high standards of teaching, learning and pupil achievement', it is impossible to assess the quality and applicability of these standards; and
    • the future role of the General Teaching Council, which we consider should take responsibility for the development of the framework of professional standards.

17. In the absence of such clarity, although, once again, we welcome the general aspirations towards providing greater consistency and coherence for the SENCO, nothing we say in this response should be indicated as concurrence with the introduction of a new set of professional qualifications.

    2. CORE PURPOSE OF THE SENCO

    Whether the core purpose captures the essence of what is expected of a SENCO or should there be additions or deletions?

18. Although it is said that the standards have been designed to be consistent with the structure of the standards for subject leaders and headteachers, we do not see that this is so. For example, the Core Purpose of Subject Leadership in the revised draft, July 1997, has an entirely different structure. We suggest that this section is rewritten, to be consistent to read, perhaps, 'to provide professional leadership for Special Educational Needs, to secure high quality teaching and effective use of resources and to ensure improved standards of achievement for all pupils and to take responsibility for the day to day operation of provision made by the school for pupils with SEN'.

19. We prefer the phraseology in the Core Purpose of Subject Leadership that the SENCO plays 'a key role in supporting, guiding and motivating teachers' to the wording in a). The final sentence encapsulates the core tasks of the SENCO as envisaged by the Code of Practice, but it must be emphasised that the SENCO cannot ensure that all of the pupil's SEN 'are being met'. This is because the SENCO has little control over the size of her budget and cannot be held responsible for in-depth diagnosis of every child's SEN. The expertise of most SENCOs is general. The psychological and advisory services, their quality and availability, impact strongly on the effectiveness of schools.

20. We note that there is no reference in the Core Purpose for Subject Leadership to accountability for resources, which appears to us inconsistent, since both the SENCO and the subject leader will have this responsibility. The particular emphasis here on accountability for financial resources suggests distinctive implications for training, in that SENCOs need to be able to understand the school's budget documents and to be able to keep elementary accounts in a clear and methodical fashion.

21. We would emphasise the importance of the SENCO being knowledgeable about, and involved in, budget discussions. There appear to be numerous establishments where the SENCO has no idea whether the money she is allocated has anything to do with LEA levels of provision for SEN. Some SENCOs are not even aware of what funds are attached to statements of SEN, so they are unable to fulfil their duty to make effective provision within the resources available. The local authority, in making a certain sum of money available, cannot ensure that it is reaching the SEN budget within the school. We would emphasise that although the SENCO may be accountable for the use of resources, 'The SENCO Guide' (DfEE, 1997) makes it quite clear that the capacity of the SENCO to work effectively is crucially dependent on tangible support from the head and governing body.

22. There is no mention of record keeping in the core purpose although for many reasons record keeping has become central to the SENCO's role. We suggest the addition of: 'The SENCO is responsible for the maintenance of records of pupils identified as having SEN and of the actions taken to meet their needs from Stage 2 of the SEN Code of Practice onwards.'

23. Some SENCOs wish to see here a clarification of the role and responsibility of the class teacher in relation to children with SEN, to assist in the SENCO's management of the learning needs of SEN pupils. We believe that our members will welcome the acknowledgement in 'Excellence for all children' that a SENCO cannot do everything single-handedly and its emphasis on the essential element of a 'whole school approach'. It is, as the Green Paper says, the responsibility of all teachers and support staff in a school to be aware of the school's responsibilities for children with special educational needs; and to have regard to the guidance in the 'Code of Practice'. We consider that the text should be re-written to reflect the Green Paper and to explicate that the essence of the SENCO's role cannot be delineated without reference to the over-riding accountabilities of headteachers and governors. As we say later, the text on pages 9-11 is more helpful in this respect.

    3. KEY OUTCOMES

    Whether:

    the outcomes should be restricted to those pupils on the SEN register;

    the outcomes for pupils and teachers are sufficiently demanding;

    the key outcomes are applicable across phase, size and types of school, including special schools.

24. We much prefer the phraseology of the Subject Leaders' standards and if this were implemented the heading here would read 'Effective Co-ordination of Special Educational Needs results in:' An inference may be drawn from this statement that a SENCO is ineffective if she does not achieve all these things.

25. The delineation of outcomes, and we must assume accountabilities, in this way unhelpfully confuses the co-ordinators role with the overall management of SEN in the school. Part 1 of 'The SENCO Guide' (DfEE 1997), as we have said, consistently emphasises the role of heads and governors in enhancing the quality of special needs provision and that the SENCO's work is crucially dependent on the tangible support received from the head and governing body, as does page 16 of this consultation paper. It is clear that the SENCO cannot be the only factor in effective SEN co-ordination. We recommend that these key outcomes are re-written to discriminate more appropriately between the effectiveness of the SENCO and effective SEN co-ordination, which is a 'whole school' issue.

    a) Pupils on the SEN register.

26. We have reservations about the final clause; 'ultimately, revert to an earlier stage on the register or no longer require special help'. Depending on the student's needs, progress may well not result in the student reverting to an earlier stage, but this outcome may be in no way failure, nor does it necessarily reflect a lack of progress. Increasing numbers of pupils with severe SEN are surviving to school age, and wish to be educated in mainstream schools. Children are identified not only with physical disabilities, allergies, and medical problems but also with dyspraxia, dyscalcula, dyslexia, Downs Syndrome, a very wide range of speech and language disorders, ADD and ADHD, autism and many other special needs which lead to learning difficulties. The very wide spread of disability is, of course, demonstrated in different ways by different pupils, and the severity of the disability will differ from person to person. It is therefore quite inappropriate to imply that all students with SEN may, through effective teaching, reverse the effects of conditions which may be congenital, or even deteriorating.

27. The attributes of child development mentioned here are no different from schools' aspirations for every pupil. We recommend that, in the light of the aspirations set out in 'Excellence for all children', the TTA should consider the purpose of this section and seek to distinguish outcomes specific to children with learning difficulties, disabilities and special educational provision, which are the specific interests of the SENCO.

    b) Teachers

28. For the reasons set out above, we do not consider that the SENCO's effectiveness should be judged by many of these outcomes. It is for the headteacher to establish a climate in the school which encourages high expectations of all pupils' progress, sets realistic but challenging targets in all aspects of the school's work and provides support to recognise and reward success and to foster pupils' self-esteem and confidence. This cannot be a task delegated to the SENCO, unless we are to read the key outcomes here to be outcomes for the school and not solely for the SENCO. We agree that they are the former. We do not agree that they are the latter.

29. Where responsibilities such as subject leadership and SEN co-ordination are as wide-ranging as these ideas suggest, then it must be clear where the interface with managerial responsibilities begins and ends. Many of the characteristics of teachers mentioned here have little to do with the effectiveness of the SENCO, and are more closely related to an ethos of general staff development within a school. We do not think that it is the individual co-ordinator's responsibility to establish these features in a school.

30. We suggest that the second item be amended to the following: 'identify pupils who may require special provision and help to prepare individual education plans as appropriate;'

31. It seems unrealistic, given the current low status of most SENCOs, to require of them that to be deemed effective they ensure that staff 'participate in a range of training opportunities'. They have no power to do this. 'The SENCO Guide' supports sensitivity to already pressurised colleagues. Similarly, the ability to make effective use of information technology will depend upon managerial decisions and not those of the SENCO.

32. How is it proposed that SENCOs ensure that teachers communicate effectively? What training criteria would cover this requirement? Is this really the duty of the SENCO? This paragraph also appears to be advocating individualised learning, while other influential bodies are applying heavy pressure towards whole class teaching for a significant percentage of time. These tensions must be recognised and Government agencies should send clear messages on whether or not they support the mix of teaching method which has been discovered to be the usual mode in schools, namely a mixture of whole class teaching, group and individual work.

33. In view of the variety of special educational need, any expectation that the class teacher, or even the SENCO, shall be able to differentiate effectively for all SEN within any given class implies a huge training and development programme for all staff and, as it stands, is too demanding. Although, to 'set realistic but challenging targets, provide appropriate support' sounds sensible, the actual implications are extensive for the expertise required of the SENCO, teachers and support staff.

    c) Learning Support Assistants

34. Again we believe that there is a confusion between the role of the SENCO and the desirable outcomes for SEN if well co-ordinated in a well-managed school. Some schools are fortunate in being able to afford and/or find teachers as learning support assistants (LSAs). In perhaps a majority of cases, LSAs are local mums, who may be the only people willing to do the job for love and low pay. We need to think through very carefully how the effectiveness of a SENCO can be judged by whether the LSAs within a school are 'skilled and knowledgeable in ways of supporting pupils and helping them to achieve maximum levels of independence'. SENCOs do not, at present, have the power to demand these levels of excellence in LSAs. In many schools, the training of LSAs takes place within fifteen minute playtime breaks, because there is no money to pay them to remain at work when the children are not there. Many local authorities run very good courses for LSAs, but the turnover of these staff will lead to a continuing training need for which the school may not be funded. There should be recognition that SENCOs need time to ensure the effective deployment of LSAs, and to train teachers to work effectively with these support assistants. Unless SENCOs are not only trained but also have time themselves to train support assistants, there cannot be effective provision. These outcomes cannot be expected. A more appropriate outcome, here, would be 'A SENCO should be able to analyse training needs and present these to management as budget priorities.'

    d) Governors

35. Our members find it astonishing that it seems to be proposed that a SENCO's effectiveness is to be measured by whether the governors discharge their statutory responsibilities towards pupils, whether they support the SENCO in the implementation of the SEN policy and whether they establish appropriate staffing and funding arrangements and maintain a general oversight. A SENCO has no power to ensure this and cannot therefore be held responsible. It would be more appropriate to suggest that a SENCO be able to demonstrate that she has developed a mechanism for liaison with the governors in order to advise them of their responsibilities and to suggest appropriate methods of discharging them.

    e) Parents

36. Once again, the SENCO can only contribute to the confidence any parent can have that the school has the ability to meet their child's needs. The climate will have been set by the headteacher and governors and it may be the lack of support of senior management which results in the lack of confidence from parents. Although this could quite properly be a key outcome related to whether the whole management for schools is effectively co-ordinating SEN, it is not reasonable to regard this as an outcome of an effective SENCO. Parents will have confidence in the school's ability to meet their child's needs where the school has not only the expertise but also sufficient other resources to meet the needs presented. Again, a SENCO can suggest, for example, that parents be fully informed of their rights and responsibilities within the school prospectus but cannot ensure that this takes place. A SENCO has no ultimate authority and cannot be judged as ineffective if her managers do not choose to follow her advice. It would be more appropriate to have as an outcome that a SENCO demonstrates that appropriate advice has been given to senior management on all aspects of communication and involvement with parents. These may be outcomes relevant to the SENCO but they need greater clarification.

    f) LEAs And Other Responsible Bodies

37. The expectations of local authorities and other local services could usefully be defined with more clarity and uniformity across the country. SENCOs in schools should be aware of what may, and what may not, be expected of the local authority in terms of support and special provision. For instance, schools need to know what help may be provided from specialist units for visual and hearing impairment, behavioural difficulties or autism. Schools need to know what outreach services are available in their area and the breadth of expertise available from the learning support services run by the local authority. It is difficult to see any logic behind the judgement implied here that a SENCO is effective when the local authority and other responsible bodies are 'able to make an effective contribution in areas of specialism, such as speech therapy, educational psychology and so on.' A SENCO may ask for these services, but cannot be judged as ineffective if they are not forthcoming.

    'should outcomes be restricted to those pupils on the SEN register;'

38. The SENCO cannot be held responsible for the outcome of the education of every pupil in the school, except as that is the case for any teacher in a school. The SENCO's specific responsibility must be limited to SEN as defined by the school and in the light of the relevant legislation. She can be responsible for provision, but cannot ensure progress.

    'the outcomes for pupils and teachers are sufficiently demanding;'

39. The expectations implied in this Key Outcomes section, although inappropriate for SENCOs, appear to demand the highest level of training, skills and educational outcomes. As yet, it is not clear what input will be provided by the DfEE or TTA which will ensure support for these outcomes.

    'the key outcomes are applicable across phases, size and types of school, including special schools'

40. We believe that special schools, like special children, should have their needs individually assessed. It is not appropriate to impose upon special schools the arrangements and expectations which apply to mainstream education. The failure of the OfSTED framework to address the real inspection needs of special schools has demonstrated this already.

41. As general statements, and with the caveats written above, those statements we have not criticised would appear to be applicable across the range of educational establishments. However, there is a difficulty in arriving at agreed outcomes and in measuring effectiveness within a system where the stages are variable. For example, child A may be at stage 1, move school, and his 'relative need' within his new school may lead to his being placed at stage 3. This does not indicate the effectiveness or otherwise of either of the SENCOs, but a change in his position relative to his peers. There are not enough objective criteria to guide SENCOs as to which stage to place a pupil and there are wide variations. The criteria that exist are measurements of provision, not need. Consequently, schools in socially deprived areas, often with fewer resources, are able to provide less, and so place a pupil on a lower stage than one in an affluent area. These vagaries are clearly set out in 'Excellence for all children' and it could be argued that effective SEN co-ordination cannot be assessed until there are national criteria. We look forward to that debate.

42. We consider that this section would have been improved if each item had been listed on a separate line. Each Key Outcome should be able to be linked with other areas of the standards and the layout can facilitate cross-checking and analysis.

    4. PROFESSIONAL KNOWLEDGE AND UNDERSTANDING

    whether the aspects of knowledge and understanding are appropriate and if there are any others which you consider are essential for SENCOs

43. We accept that SENCOs should have knowledge and understanding of items a - h. However, the SENCO, like other teachers, will also need to acquire knowledge and understanding which underpins other areas of these standards. This is no less an aspect of a teacher's professional knowledge than the factual emphasis of this section as it stands. For example, 5. a. v. expects the SENCO to use appropriate leadership styles and yet knowledge and understanding of leadership styles is not included as part of their professional knowledge, although it is for that of headteachers. We consider, too, that knowledge and understanding of school governance and health and safety requirements, including work to obtain expert advice, apply equally to SENCOs and subject leaders. There should be a consistency between the requisite professional knowledge and understanding and all other aspects of these standards.

44. However, SENCOs will also need to be supported in acquiring other necessary knowledge and understanding, including:

    i) the acquisition of a wide range of management skills, for example, in negotiating training schedules for SEN within the school development plan and in the management of support workers, both qualified and unqualified;

    ii) skills in training and supporting, for example, faculty heads, class teachers, support assistants and, more specifically, newly qualified teachers (NQTs) if SENCOs are to play the important role in providing specialist support to new teachers during their first year, suggested in 'Excellence for all children';

    iii) developing an overview of the school community and the place of the SEN department therein; and

    iv) understanding negotiation techniques, for example, with faculty heads and other colleagues, for the investment of time and other resources in pursuit of raising standards of teaching and learning.

45. SENCOs will also need to acquire knowledge and understanding of:

    i) the wide range of disabilities now presenting within mainstream, including speech and language disorders, visual and learning impairments and physical and psychological disabilities;

    ii) self help groups, parent partnerships and other organisations, such as those described in Chapter 2 of 'Excellence for all children';

    iii) the tribunal process;

    iv) the information and communications technology required to administer their role.

    v) the information and communications technology available to assist the learning of pupils' specific SEN;

    vi) the whole process of financing special needs, from government agencies and grant aid to bidding for funds annually when the school budget is being set;

    vii) schools' budgeting systems; and

    viii) the purpose, best practice and constraints of outside agencies.

46. We recommend that the professional knowledge and understanding required by SENCOs as described in these standards is reviewed critically.

    5. SKILLS AND ATTRIBUTES

    The extent to which:

    any of the above should be omitted or revised or should any other be included?

    the level of delegated responsibility is appropriate.

47. We see no reason, in principle, why the skills and attributes of the SENCO should be different from those for subject leaders, with the possible exception of devolving responsibilities and delegating tasks, as appropriate. In essence, in the whole area of skills and attributes, there seems to be no distinction between what is required of the SENCO and what is required of any other subject leader, who is also a subject co-ordinator. Unless any omission can be justified, there should be entire consistency between these two sets of standards. If a level of delegated responsibility is appropriate for a subject co-ordinator in a primary school, then it is appropriate for the SENCO. Therefore, we recommend use of the same list of skills and attributes as in the subject leaders' standards.

48. Indeed, we would suggest that it is now time to look more closely at the purpose of the lists of skills and attributes across the standards. The heading refers to skills and attributes which are essential but are not exclusive to a role and that the ability is demonstrated by the ability to apply these skills and attributes in the Key Areas. It is difficult for us to see why a headteacher needs intellectual ability, personal impact and presence, vigour and commitment in that role but subject leaders and SENCOs do not in their roles. The TTA should look again at the inconsistency across the standards and justify the differences in the Consultation report.

49. Specifically, in xv. and xvi., since it is not the SENCO who is personally applying good practice, it might be more appropriate here to talk in terms of 'disseminating and encouraging', rather than 'applying'. We notice that in relation to b., decision making skills, 'collect and weigh evidence, make judgements and make decisions' and 'analyse, understand and interpret relevant information and data' are omitted from this list and yet it is what is expected of a SENCO in Key Area a) v. and iv. respectively. We do not see why this is the case. We also question why, under 'self-management' the subject leader is required to be self-motivated but the SENCO is not.

50. Skills which are omitted seem to us to be skills related to record keeping and information technology skills related to the bureaucratic aspects of the role.

51. It is agreed that these skills and attributes are important in the work of the SENCO. However, we question, as we have before, how will they be tested. Not all attributes are amenable to objective testing, but if these attributes are to be laid down, then it should be made clear how they will be assessed in an objective fashion. How, for instance, will anyone be able to assess 'adaptability to changing circumstances and new ideas' and 'integrity'? As we have said before, it seems to us that many aspects of the standards could not be evidenced except by drawing upon the contributions of other colleagues by data collection through, for example, surveys and questionnaires. It would be our expectation that any such methods, however, would be covered by a Code of Practice, similar to the 'Guidance and Code of Practice on the Collection of Information for School Teacher Appraisal', annexed to Circular 12/91, 'School Teacher Appraisal'. However, these are very sensitive and unexamined areas.

52. We do not entirely understand what is being asked as to the appropriate level of delegated responsibility. We have made it clear in earlier sections that the expectations of the SENCO are constrained by many considerations. We do not think that levels can be established from these standards and this is one of our chief reasons for considering them unsuitable as standards and qualifications.

    6. KEY AREAS OF SEN CO-ORDINATION

    The extent to which:

    the Key Areas describe adequately the expectations of the role of a SENCO, without being over-prescriptive about the methods. If not, are there any revisions or additions that you would wish to propose?

    the accountabilities for SENCOs are clear and appropriate?

    SENCOs demonstrating expertise as described by the standard should be able to seek a nationally recognised professional qualification. If so, should the target group be those wanting to become SENCOs or existing SENCOs?

53. It seems to us that the 'professional knowledge and understanding' and the necessary 'skills and attributes' flow from the Key Areas of a role and that, therefore, the standards are unhelpfully organised. Furthermore, the text on page 16 would have made a better preamble to the paper than that on pages 9-11. The preamble to a 'Strategic Direction and Development of SEN Provision in a School' looks remarkably like a Core Purpose. We consider that the TTA should consider the structure of the paper and seek as much concision and clarity as possible.

54. We would add 'analysis and assessment' to b. Teaching and Learning, Accurate assessment of a child's SEN must be the basis for all extra provision.

55. We would not take issue that these are areas relevant to SEN co-ordination. Our concern remains whether the totality can be regarded as a reasonable expectation of those teachers undertaking the role of SENCO and whether and how these teachers can acquire the necessary knowledge and understanding skills and attributes to meet these expectations. We do not understand what is being referred to in the reference to over prescription above methods.

56. The areas of accountability may be clear and appropriate but this does not make the standards of effectiveness clear.

57. It is difficult to see how the SENCO can achieve all the requirements of the job without becoming a member of the Senior Management Team (SMT) of a school. Where the job of SENCO is shared between a member of the SMT and a teacher, then it would be necessary, in our view, for the member of the SMT to retain overall responsibility for co-ordination of SEN within the school. This must be taken into account whenever these standards are applied to teachers who share responsibilities. Without significant input from the SENCO, the current lack of understanding in many establishments will continue, and the effectiveness of the SENCO will be inhibited. The four Key Areas require a person with a high level of both qualifications and expertise and to deny the status which should flow from these is short-sighted.

58. The qualities required of postholders are clearly on a par with those of senior management and should be acknowledged as such through the creation of a specialist qualification, and training to support it, with subsequent recognition of status. Individuals already holding the post of SENCO should be supported financially and with dedicated time, in acquiring the qualification.

59. We would propose a series of credits to be gained in each of the various areas of SEN co-ordination, which teachers could undertake over a period of time. Those with the personal qualities which would lead them to the role of SENCO as a vocation could take more credits and study in more depth. Those who wished for a fuller understanding and more skills to add to their career profile might wish to take fewer credits. Any acting SENCO should have an annual entitlement to further training quite outside the school's INSET budget.

60. As to the target group, we have argued before that if those in post do not have the first opportunities to proceed to the training, most importantly, and the qualification, then we will not see the greatest impact on the overall standards in the system.

    This document was added to the Education-line database 10 November 1997