1.
Resource
implications
RCSLT is supportive of the development of single statutory
plans and a focus on collabotarive working to improve outcomes for
children and young people. However members have a number of
concerns about the resource implications of such a development with
particular regard to attendance at meetings.
Under the current system, SLTs who treat children with
non-complex needs attend schools to assess the needs of the child
and prepare written care plans which are often sharedby post and by
e-mail. Under the new legislation, we understand that SLTs
could be invited to attend a far higher number of meetings in
person given that all children with ALN will now have
multi-disciplinary Individual Development Plan (IDP)
meetings. Approximate calculations within one local health
board in Wales suggest that we may move from a system where SLTs
multidisciplinary team meetings for 25% of current case load
(statements of educational need and a minority of School Action
Plus) to a situation where SLTs would be invited to attend meetings
for 90% of the caseload. This would translate to
approximately 2 full time equivalent members of staff to be
employed to attend the meetings at a cost of £70,000.
Given this likely impact, we strongly recommend that consideration
be given to other ways of promoting collaborative working between
health and education such as IT infrastructures.
We also share concerns about the impact on services of
extending the legislation to cover children and young people aged
0-25. We are aware that the issue of transition planning,
supporting young people to move from children’s to adult
services, and commissioning gaps regarding speech and language
therapy services for young people aged 19-25 have been an issue of
concern in England, where similar legislative reforms have been
introduced. We believe that there needs to be a scoping
exercise undertaken to ascertain the numbers of children in each
local health board/ local authority area who could need access to
adult services, and what impact this would have on staffing
levels. This should consider whether learning difficulties
services are more set up and skilled to support these learners,
rather than adult SLT health services.
Given these considerations, we strongly dispute the findings
of the impact assessment which suggest that the legislation will be
cost neutral. We urge that further work is undertaken to consider
these factors prior to the formal introduction of the bill. Such
work should include a proportional consideration of time
requirements on healthcare professionals for IDPs.
2.
Designated medical Officer
We would welcome clarification regarding the role and
responsibilities of the Designated Medical/Clinical Officer and how
their work will sit alongside other professionals within the
additional learning needs/special educational needs support system,
for example:
·
Who will this person be?
·
How will the role be funded?
·
Will this role have the ability to financially commit health
services to deliver what is included in an IDP?
·
Will this person have to ‘gatekeeper’ advice on
IDPs from health services?
In our view, in order to promote joint up working and be more responsive to young people’s
needs, the focus should be on strategic planning at a population
level between health and education.
Following the recommendations made
in the Working Together consultation document in 2005, Welsh
Government established pilots across Wales to explore approaches to
the implementation of joint commissioning services for children and
young people with speech, language and communication
difficulties. RCSLT believes that following the pilot
programme and the establishment of a SLT action group,
collaboration between agencies has significantly improved.
ELKLAN training programmes now run across much of Wales and have
increased understanding of how to support children with speech,
language and communication needs within schools. Initiatives
such as communication friendly schools have also paid dividends in
supporting the development of SLT services. Much has been
achieved in relation to collaborative working over the last decade.
RCSLT is keen to ensure that the proposed legislation builds
on these improved relations and does not serve to undermine these
positive developments.
3.
Involvement of children and families in the development of
IDPs
RCSLT is committed to promoting person-centered planning and
welcomes the emphasis within the bill on supporting the
participation of children and young people with speech, language
and communication needs and their families in the development of
IDPs. We suggest that in order to encourage the increased
participation of children, young people and families in the IDP
process, there is a need to provide training and tools to
mainstream and special schools to improve teachers’ skills
and knowledge regarding how to sensitively and appropriately
involve children in the discussions. Packages and tools which could
be used to support children to participate in the planning process
include Talking Mats; a communication symbols tool developed by
speech and language therapists, the use of symbols and appropriate
language.
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