Solving the SEND Crisis – Seashell’s Submission of Evidence

Seashell is committed to the ethos that every child and young adult, whether an attendee of Seashell or not, deserves the right to proper education, care and support.

Recently, the Solving the SEND Crisis inquiry was set up to assess all stages of education and development in SEND individuals, from early childhood to age 25.

Below is our response, in full.

You can read more about the Solving the SEND crisis inquiry on the Parliamentary website here.

Submission of Evidence to the Education Committee Inquiry: Solving the SEND Crisis

Seashell is pleased to represent the views of the Trust and families to the Education Committee’s Call for Evidence on Solving the Special Educational Needs and Disabilities (SEND) Crisis.

This submission presents evidence on the key challenges and provides policy recommendations to support informed decision-making by the Education Committee.

Our expertise in working with some of the most vulnerable young people provides valuable insight into the needs of students with complex learning disabilities and the systemic improvements required to enhance outcomes.

1. INTRODUCTION
   Sector Leaders: Seashell is a leading national centre of excellence in Cheadle Hulme, Cheshire dedicated to supporting children and young people with some of the most complex needs in the country. We provide specialist education, care, and health and wellbeing services through our outstanding school, college, and residential services. With a focus on unlocking potential and promoting independence, Seashell Trust empowers children and young people to achieve their educational outcomes and to develop skills which will enable them to achieve maximum independence and participate in meaningful activities and transition to supported employment or the best destination for them to be an active member of their communities.

Complex Needs: Children and young people supported by Seashell all have severe to profound intellectual disabilities along with complex sensory impairment, mental health difficulties and behaviours of distress and complex physical health needs such as requirement for medical devices including tracheostomies and gastrostomies. A high percentage of individuals have an autism spectrum condition diagnosis along with many other low incidence high needs conditions. The young people who we support, come from just under 50 different local authorities, and represent only a small percentage of the wider (Special Educational Needs and Disabilities) SEND population.

Education, health and care services: We operate the Royal College Manchester, which is a non-maintained residential and day college for ages 16 to 25, the Royal School Manchester which is a non-maintained specialist residential school offering multi-sensory learning, education, and care for students aged 4 to 19, along with training for professionals, and support for families. We offer short breaks respite provision for children and young people and a variety of weekend and holiday sports clubs from our specialist accessible facilities including hydrotherapy pools, cycle track and gym.

A Holistic Approach: By combining education, therapy and nursing, and care under one roof, Seashell aims to ensure that those with the most complex needs—whose needs cannot be met in mainstream or maintained specialist settings—have access to a nurturing and highly specialist environment where they can thrive.

2. SUMMARY
Sector Sufficiency: Mainstream or maintained specialist settings cannot support the extreme, high-intensity needs of our pupils. There is not sufficiency across maintained special schools to meet the level of health or behavioural needs presented by our cohort due to a lack specialist facilities, access to teaching and therapy staff with the level of specialist expertise and environment and curriculum to be able to deliver bespoke educational programmes that enable CYA with the most complex needs to achieve their EHCP outcomes.

High levels of supervision and significant expertise needed: Our learners require 1:1, 2:1 or 3:1 supervision – sometimes 365 days a year, 24 hours a day with night time support. They also require integrated therapies, multi-sensory facilities, and regular health or behavioural interventions—beyond mainstream or maintained specialist capacity.

The Main Challenge Is Money: Despite numerous reports on systemic issues, insufficient investment remains the core problem. This lack of investment is resulting in CYA with less complex SEND being unable to receive the support they need in their local mainstream or maintained specialist schools which is increasing the demand on the maintained specialist sector and non-maintained specialist providers such as Seashell.

Sharing Expertise and Resource: Seashell can help with addressing some of these systemic issues through single key stage placements, to deliver early intervention to enable a child to return to their local maintained setting. We can also provide collaborative placements delivered in partnership with local maintained settings, and training and advisory support to upskill staff within maintained educational settings. A good example of this is Seashell’s launch of the mandatory qualification for teachers in MSI. The delivery of a second programme (alongside Birmingham University), accredited by Liverpool John Moores University doubles the number of places available on this essential teacher training and enables schools to fufil their legal requirements of the children and families Act and deliver on EHCP requirements.

Low Incidence High Need Children and Young People: This cohort is small in number but their needs are significant. Systemic reform is vital to ensure that CYA can receive the right support, in the right location at the right time to enable them to achieve optimum outcomes in the most cost effective way to LA.

3. SUPPORT FOR CHILDREN AND YOUNG PEOPLE WITH SEND

VARIABLE QUALITY OF SPECIAL EDUCATIONAL NEEDS (SEN) SUPPORT

• Urgent Improvement Needed: Urgent improvement is needed in mainstream, maintained specialist and early years settings with a focus on staff training and access to specialist therapy support such as Speech and Language Therapy, Occupational Therapy and behavioural support (beyond what is currently available through school funded and NHS community paediatric services)
• Requirement Breakdown: Many children reach us after placement breakdowns and without their statutory entitlements due to the lack of sufficiency in the sector and limited good quality early intervention
• Failures Increase Demand: Delays in support increase the demand for more specialist, high cost services for CYA and families

LIMITS OF MAINSTREAM AND MAINTAINED PROVISION

• Not Enough Resource: Many schools do not have the facilities, staff or expertise to meet complex needs and recruit and design and execute a workforce strategy can provide high quality educational support to this cohort.
• Role of Non-maintained Specialist Schools/Colleges/Provision: Specialist settings like Seashell fill this critical gap.

ACHIEVING INCLUSIVITY

Participation: Services must be designed through meaningful co-production with children and young people and their families. The focus should be on enabling full participation in all aspects of school life, not just physical integration.

Adaptation: True inclusivity means designing and delivering a bespoke curriculum to target each CYAs individual aspirations from an environment tailored to each child’s needs including specialist facilities and bespoke visual communication tools.

Specialist MDT workforce: The wide ranging and diverse needs of this population can only be effectively met through specialist teaching, therapy and behaviour support staff working in an integrated manner. Multidisciplinary teams often require specialist roles such as QT MSI, assistive technologists, positive behaviour support practitioners and creative psychotherapists along with teachers, therapy staff and nurses with a high level of experience in working with CYA with complex needs.

Investment: To achieve consistent, high-quality SEN support, there must be investment in the workforce through designing and delivering additional training for teachers working with CYA with complex needs as well as teaching assistants. Increased capacity in therapy teams to be able to offer targeted and sometimes intensive support through evidenced based therapeutic approaches such as hydrotherapy, Sensory Integration, rebound therapy, Positive Behaviour Support and specialist Alternative and Augmentative Communication strategies.

MEASURING AND IMPROVING OUTCOMES FOR PEOPLE WITH COMPLEX NEEDS

Goal Framework: Seashell promotes and tracks progress against Education, Health and Care Plan (EHCP) objectives via long, medium, and short-term goals forming an individual education plan (IEP) for school students. IEPs are reviewed twice a year, with data broken down by overall progress and semester outcomes. Individual Learning Programmes (ILP) set termly, annual, and final destination targets in college, reflecting a broader view of success that includes preparation for adulthood beyond academics.

Destination Tracking: We monitor college students’ paths to independence and improved mental health.

Reducing Support: A key metric is decreasing staff assistance wherever possible, linking progress to greater independence and a life after school or college.

Person-Centred Reviews and Transition Planning: EHCP reviews include aspirations, barriers, and outcomes to ease transitions. The CYA voice is at the centre of the review, ensure the child’s voice guides their support, whilst also valuing the parent carer views

Holistic Focus: Beyond academics, we measure wellbeing, life skills, and skills in managing physical health e.g. involvement in medication administration or health monitoring where safe and appropriate.

PROMOTING OUTCOMES

Integrated Support Plans: Each learner has a personalised plan shaped by assessments, family input, and prior carer insights.

Multidisciplinary Approach: Teachers and multidisciplinary teams set baseline assessments, then define short term targets and conduct ongoing feedback sessions with students and families.

Total communication: All students have complex communication challenges and have a bespoke communication strategy to ensure a wide range of creative approaches are used to support understanding of language and ability to express themselves effectively, both to express needs but also build and maintain friendships.

Family support and advocacy: A dedicated support circle advocates for students with communication barriers, and communication with parents and carers is prioritised to ensure a consistent family support approach.

CHALLENGES AND IMPROVEMENTS OF EHCPS

Quality Variations: EHCP quality varies by authority; some plans are outdated, vague, or overly short-term and do not meet legal standards.

Timing & Accuracy: Authorities often fail to meet statutory deadlines and do not maintain accurate plans.

Impact of Non-Updated Plans: If local councils neglect to update EHCPs, schools are forced to operate on out-of-date information, which negatively effects education for complex needs children and young people.

Funding Disconnect: Since EHCPs inform funding, any lag in plan updates means services and budgets fail to meet a child’s current requirements.

Digitisation and Accountability: Moving EHCPs into a digital format can sharpen accountability, keep records current, and highlight the child’s voice at every transition point. They must be updated in a timely manner.

Individual Focus: EHCPs must be coproduced with families, and prioritise feasible, enforceable goals, alongside clear, accessible guidance for parents. Consistent, enhanced communication is crucial.

Systemic Underfunding: Widespread reliance on EHCPs to secure resources reflects the lack of adequate funding. Families often feel forced to fight for support because mainstream or maintained specialist settings schools aren’t sufficiently inclusive.

Readability and Length: EHCPs can exceed 60 pages, leading to confusion and inefficiency. Plans should be shorter, less jargon-heavy, and accessible. EHCPs should be written in plain, understandable language so that all stakeholders (including families and pupils) can easily comprehend them.

Practical and Useful: Concise, plain-language documents allow agency or temporary staff to understand and implement required support without ambiguity.

Updated Regularly: Plans should be updated during annual reviews, rather than languishing in local authority backlogs

IMPROVING OUTCOMES FOR FAMILIES

Lack of Support Leads to Crisis: Inadequate local SEN provision may push families into economic, physical and mental health crisis.

Central Role of Family Support: Meaningful assistance for families with complex-needs children is essential at every stage of education and care; Seashell has the expertise to model and deliver this support.

Providing Practical Support: Seashell does this through providing short breaks, free workshops, and integrated therapy which reduces stress and supports family mental health.

Universal Applicability: Strategies that work for families managing complex needs often prove beneficial to all families, improving inclusivity and consistency.

Training and Mediation: Providing mental health, IPSEA, and mediation training equips staff to better engage with families, fostering more productive relationships.

Interlinked Wellbeing: The mental health of a child is profoundly influenced by the wellbeing of their family, underscoring the importance of holistic, wraparound support.

Sharing Best Practice: By demonstrating a comprehensive family-centred approach, Seashell can guide other providers in adopting and sustaining similar models.

Economic Considerations: Effective family support reduces crisis interventions, thereby yielding clear economic benefits for both local authorities and families themselves.

Parents Can Work: Children in schools means that families are able to work who would have previously had to care for their SEND child.

WORKFORCE ISSUES AND TRAINING

Recruitment Challenges: Seashell and many other providers face difficulties recruiting and retaining staff largely due to sector wide low wages.

Sector Perception: Roles in specialist SEND settings are viewed as less prestigious and lack clear career pathways—leading many potential staff to view these positions as temporary rather than long-term commitments.

National Insurance Costs: Increased National Insurance costs add strain on charities, limiting the funds available for wage enhancements and thereby impacting workforce sustainability.

Professional Development: All staff across Seashell have to receive high levels of specialist training in addition to their professional qualification (e.g. teaching, SaLT, OT) and have to continue to have access to journals, conferences and specialist interest groups to maintain currency in knowledge.

Induction and Mentorship: New staff have to have opportunity to shadow experienced colleagues, receive mentorship, and undergo probation reviews following completion of a 2 week intensive induction training programme.

Mandatory Qualifications: Residential staff must complete the Level 3 Diploma in Residential Childcare; managers and support staff need relevant qualifications. Therapy staff require specific qualifications e.g. OTs require masters level Sensory Integration modules, SaLTs require post basic dysphagia training.

Communication and Behavioural Strategies: Staff are trained in tailored communication (e.g. signing, voice output communication aids) and supporting students with behaviours of distress through positive behaviour support

Emergency and Specialist Training: Comprehensive Emergency First Aid and training to deliver delegable health activities (e.g. administration of medication, tracheostomy support, gastrostomy, diabetes and epilepsy) to meet CYA health needs

ROLE OF SPECIALIST PROVIDERS AND NON MAINTAINED SPECIALIST SCHOOLS AND COLLEGES

Onsite Accredited Qualifications: Seashell now offers qualifications (e.g., in Multi-Sensory Impairment, validated by Liverpool John Moores University) to enhance staff development. Level 3 Autism training is also delivered in house to staff across the workforce.

Short-Term Placements: Seashell increasingly will offer staff training or host CYA on a limited schedule—such as a short placement or a few days per week—in order to address specific developmental or educational needs while the remainder of their programme will be delivered at their local maintained provider.

Financial Efficiency and Collaboration: Short-term placements would be cost-effective, reduce barriers between different educational providers, and facilitate knowledge-sharing.

Support for Emerging Resource Units: Seashell could assist in training personnel for newly established resource units, thereby enhancing local capacity.

Sharing Excellence: As a centre of excellence, we see our role as sharing our expertise to improve outcomes sector-wide.

CURRENT AND FUTURE SEND NEED

Medical Advances: More children with severe or life-limiting conditions now survive into adulthood, increasing demand for specialist schools and further education settings. Premature babies are now being resuscitated from 22 weeks gestation leading to more complex needs due to under development of essential systems.

Earlier identification: of autism, sensory processing disorders, and rare syndromes leads to more complex SEND profiles.

Resource Shortfalls: Local authorities often fall short in resource allocation for emerging needs.

Better Data Required: Currently there is no national data set relating to this population. NHS, education and social care all log different data sets using different terminology. Real-time data is needed to help the Department for Education plan effectively, along with regional data needed for LA commissioners and specialist providers.

4. CURRENT AND FUTURE MODEL OF SEND PROVISION

SEND VARIATION BETWEEN LOCAL AUTHORITIES

Inconsistent Support: SEN support quality varies widely—a “postcode lottery” for children.

Adherence to Law: Consistency requires adherence to SEND law and proper resourcing of local services.

JOINED UP WORKING

Multi-Agency Collaboration: Effective multi-agency collaboration across education, health, and social care is crucial for improving outcomes for children and young people with SEND.

The Role of the Charity Sector: Third sector providers can play a valued role and act as strategic partners with Integrated Care Boards and Local Authorities (a requirement on ICBs).

Integrated Approach: A system-wide focus on identifying and meeting needs at the earliest point through an integrated delivery model and collaborative approach to assessment and planning with families is essential.

Joint Commissioning: Better joint commissioning and clearer delegation of responsibilities is required between health, education, and social care. Alliance commissioning is supported as an approach to funding integrated services.

NHS Responsibilities: The legal obligations and capacity of NHS community paedatric teams needs to be addressed. Community Speech and Language Therapy, Occupational Therapy and Physiotherapy services are stretched beyond capacity and do not have the expertise or time to be able to deliver the support needed by this population. Paediatric audiology services do not have the specialist facilities or expertise to elicit successful hearing assessment results with CYA with complex communication challenges. Services such as Seashell present an opportunity to be able to commission specialist services to address complex needs across an ICB footprint making more prudent use of funds to benefit CYA across a wider georgraphical area (local services wouldn’t warrant recruiting full time positions with such high levels of specialism and therefore cost associated)

Clear Delegation: Clear delegation of responsibilities between health, education, and social care is necessary.

Barriers to Collaboration: There is a lack of communication and engagement with parents and carers, which fuels confusion about the educational path the child or young person is on.

Reducing Emergencies: Local authorities should have the ability to track children with complex needs throughout their lives and should be able to plan with education providers accordingly.

CURRICULUM

Individualised and Holistic Learning: The curriculum is tailored to each student’s EHCP, integrating education, therapy, and care.

Communication Development: Emphasis on developing communication skills using augmentative and Alternative Communication (AAC) strategies such as Objects of Reference, sign-supported communication like Makaton, British Sign Language (BSL) and multi-sensory methods.

Functional Skills and Independence: Practical skills (literacy, numeracy, money management, personal care, travel training) build independence.

Sensory and Therapeutic Integration: Sensory integration therapy and multi-sensory environments, alongside allied health support, enhance learning.

Community Engagement and Real-World Learning: Off-site visits and work placements provide real-world learning experiences.

Structured Routine and Predictability: A predictable schedule reduces anxiety and aids transitions.

Creative and Expressive Learning: Art, music, and drama foster sensory engagement and communication.

Physical Development and Well-Being: Regular physical activity and therapeutic interventions like hydrotherapy and rebound therapy, which contribute to both physical and emotional health.

Multi-Disciplinary Collaboration: Close teamwork among educators, therapists, and medical staff ensures aligned support.

Transition and Preparation for Adulthood: Supported internships, independent living skills, and transition planning ease the move to adulthood.

EXCESS PROFIT MAKING

Seashell is a Charity: Any modest surplus funds are reinvested in staff training, technology, campus upgrades, family support and community outreach.

Transparency and Accountability: The charity model prioritises financial transparency and accountability, ensuring that every pound is directed towards enhancing the quality of care and education rather than maximising returns for investors.

Outcome-Focused Approach: Without a profit motive, our focus is solely on achieving the best outcomes for children and young people.

Fundraising: Raising money through engaging donors, corporate partners, and local communities means Seashell is able to secure the resources necessary for our high levels of care and quality and capital developments.

Flexibility and Innovation: Free from commercial pressures, we can experiment with advanced assistive technologies and tailored interventions.

Enhanced Collaboration: Our charity model fosters strong partnerships with local authorities, families, and service providers, and enables a robust admissions process.

Long-Term Sustainability: Reinvesting in our workforce and services supports sustainable development.

Community and Stakeholder Engagement: Charities can engage meaningfully with communities through volunteerism, fundraising, and collaborative projects.

Acknowledge charities: It is crucial that any regulatory or policy measures aimed at curbing excess profit making do not inadvertently penalise charitable organisations.

5. FINANCE, FUNDING, AND CAPACITY OF SEND PROVISION

ACHIEVING FINANCIAL SUSTAINABILITY

Sector Underfunding & Financial Strain: The sector is underfunded by billions, compounded by inefficient reinvestment from private equity and financial strain caused by local authority lost tribunal spending.

Improved Funding Formula: An enhanced funding formula is essential to develop specialist local SEND, behaviour, and mental health support teams/hubs that work alongside schools and families.

Local Authority Financial Challenges & Fundraising: Local authorities face worsening financial situations that lead to fee increases, making fundraising increasingly crucial to underpin core services.

Protection of Legal Entitlements: Any measures to achieve financial sustainability should not erode legal protections and ultimately damage the lives of vulnerable young people and children.

National Insurance Rises: National Insurance Rises have created financial pressures on charities – charities should not have been included in the increase. This is having a £800,000 impact on Seashell.

Recognising Impact: The long-term financial and social benefits of effective SEND support should be recognised.

SAFETY VALVE AND DELIVERING BETTER VALUE

Avoiding Uplifts: Some local authorities have exploited these initiatives as a pretext to avoid providing necessary funding uplifts. Instead of funding the full spectrum of support required, some have asked for a basic educational package that does not meet the assessed additional support needs of the child.

Correct Levels of Support: The Safety Valve and Delivering Better Value initiatives within SEND programmes must ensure that children and young people receive the appropriate level of support—neither excessive nor insufficient—and are placed in the most suitable provision.

Collaborative Working: We have collaborated with a local authority that worked with us to ensure that appropriate placements were requested for the children requiring our specialist support. This proactive approach enabled the LA to accurately identify our small cohort of complex needs and secure the necessary funding to meet their requirements, rather than simply reducing placements or cutting funding.

Inconsistency of Support: Given that children with complex needs represent only a minor percentage of any LA’s SEND population, authorities should be well acquainted with these cases to ensure they are placed with specialist providers such as ourselves. However, the implementation of this programme has been inconsistent across local areas; in some regions, available funds have been inadequate.

CAPITAL INVESTMENT

Poor Data: How can decision-makers accurately determine capital investment requirements when the available data to project need is neither sufficiently detailed nor current?

6. FINANCE, FUNDING, AND CAPACITY OF SEND PROVISION

EFFECTIVENESS OF AREA SEND INSPECTIONS

Lack of In-Depth Evaluations: Despite repeated inspections since the implementation of the Children and Families Act in 2014, neither Ofsted nor the Care Quality Commission (CQC) has conducted in-depth evaluations that specifically address the needs of children with complex SEND profiles.

Too Much Focus on Mainstream: Current inspections predominantly focus on mainstream or maintained specialist provision, neglecting higher cost independent specialist providers.

Include Specialist Services: It is essential that inspections include assessments of these specialist services to ensure that local areas are meeting the needs of children in a timely manner and that the voices of children, young people, and their families are heard.

ENHANCING LOCAL AUTHORITY POWERS

Shift to Academies: The decentralisation of power through the proliferation of academies has diminished the control of local authorities.

Powers to Local Authorities: Restoring greater local authority powers would enable them to hold providers accountable for improvements, ensuring better outcomes for SEND pupils.

ENSURING ACCOUNTABILITY ACROSS ALL SCHOOLS

Comprehensive Inclusion Strategies: Local authorities should ensure that their SEND boards and decision-making processes include representatives from all schools—not solely maintained ones—to create a comprehensive inclusion strategy.

ROLE OF EXTERNAL ORGANISATIONS IN ACCOUNTABILITY

Accountability: External bodies must provide evidence of their accountability to the public.

Coproduction: Coproduction should be central to any reformed accountability approach, moving away from siloed working—a principle originally underpinned by the Children and Families Act but not yet fully implemented.

Better Outcomes: This approach would reduce costs, promote more effective working practices, and ensure that services meet the needs of children and young people.

Role of Department for Education: Furthermore, the Department for Education must hold Ofsted and the CQC accountable, particularly given recent concerns regarding their performance and public trust.