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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