NPSA Submission to the National Council for Special Educational Needs (NCSE)

In asking for submissions the NCSE suggested that people answer a questionaire provided by them.  For that reason this submission is in a "question and answer" form.

GENERAL VIEWS

Note:
i.    The NPSA is an umbrella body for support groups with parents and siblings of people with an intellectual disability or autism.  Therefore, our answers to the questions below refer specifically to children with these disabilities.
ii.    We include much detail in our answers because we feel that it is important for the Council to be aware that the simple, or even simplistic, statements often found in legislation translate into very complex situations when efforts are made to implement them. 
iii.    In some of our answers we us the term “learning assistant” rather than SNA because we believe it is time to publicly acknowledge the fact that, in many schools, SNAs are not just carers but also work in a teaching capacity.  We believe it is appropriate for them to act as learning assistants and that the situation in terms of remuneration, qualifications and training should be regularised to take account of this reality.


Q.1 In relation to the key areas of the EPSEN Act, what, from your perspective, are the critical issues that need to be addressed?

The critical issue is that parents must feel a trust in the SENO and the Council.  In order to achieve this, the Council must be seen as a body that is objective and independent in its approach.  This will only happen when the relationship between the DES and the Council is clarified and when the Council is clear that it can make decisions as opposed to being merely an arm of the DES.
The issue of trust must be addressed immediately and must include a study of the following areas:
1.    Professional Support for the NCSE:  It is necessary for the NCSE staff in Trim and for the SENOs on the ground to be supported in their work by people who have an expertise in education and in special needs.  It is difficult to understand how people without access to such backup, no matter how well meaning, can hope to understand the needs of the families of people with special needs and also how to find solutions to the many issues.
2.    Training for SENOs:  It is necessary for SENOs to understand the issues many parents have and how to resolve these issues (see the response to question 8, below).
3.    Relationship between the DES and the NCSE:  There is a need to develop a good working relationship between the DES and the NCSE with regard to development of policy.  It has always been an issue with parents that the DES was too far removed from the reality on the ground and was, therefore, incapable of understanding their situation (this is a view shared by many in the teaching profession).  Unfortunately, the DES is now even further removed but is still charged with development of policy.  So, the only way for the current system to succeed is for the NCSE, who is closer to the problem, to have a large influence over the formulation of policy.


Q.2 What do you consider should be the priorities in the implementation phase?

The obvious priority is to provide appropriate assessment and a resulting education plan. 
This requires that
1.    The necessary professionals must be available to carry out assessments
2.    The SENOs be properly trained to carry out assessments or to coordinate the carrying out of assessments
3.    School staff are properly trained to
§    Assist with the preparation of the Plan
§    Implement it


Q.3 Give your views on the level of resources that may be needed to implement the Act and on how additional resources should be identified.



Q.4 Please identify any information or training needs that may be required in implementing the Act.

Staff Training.
It seems almost unnecessary to state that teachers and learning assistants working with children with special educational needs should have proper training.  However, experience indicates that in many situations staff are inadequately trained or are not trained at all.  This situation is unfair to the staff involved and is even moreunfair to the students under their care.
Therefore, teachers of children with special educational needs and learning assistants must be appropriately trained.  They must be given a thorough understanding of special educational needs.  They must be given an understanding of:
i.    The nature of intellectual disability and autism
ii.    The learning difficulties of children with special educational needs
iii.    The development of normal language acquisition.
iv.    Policies on the integration of pupils with special educational needs.
v.    How to work with parents and professionals
vi.    Therapeutic approaches which support children’s learning
vii.    They must be fully trained in behaviour management.
viii.    In the case of autism, they must understand:
a.    The specific language difficulties of children with autism and how their language learning differs from normal language acquisition
b.    The cognitive and psychological explanations of the autistic disorder
c.    The importance of directly aiming instructions at the student with autism, if this is needed by the student.
d.    The difficulties children with autism may have and the resulting influences on learning outcomes of the following:
·    Memory:  Children with autism very often have excellent memory skills.  It must be remembered that good recall is not the same as understanding.
·    Problem solving:  Children with autism very often have poor problem solving skills.
·    Perception:  Children with autism very often do not understand the subtleties of language but interpret in a very literal way.
·    Attention:  Many children with autism experience different levels of attentiveness.  With subjects in which they have a strong interest (obsession) their attention is excellent.  With other things they may suffer from severe deficits.
These difficulties will particularly affect someone taught in a subject-based curriculum.
·    They must be trained in the theory of the main interventions ABA, TEACCH, PECS, Precision Teaching, etc
·    They must be given practical experience (teaching practice) in using the above methods

In addition teachers must:
i.    Understand how to plan the learning environment and the curriculum
ii.    Understand how to how to assess pupils and write individual education plans.
iii.    Understand how to monitor and report the progress of special needs students.
iv.    Be aware that no assumptions can be made on what the student should or should not know.
v.    Be aware that pupils might not necessarily have a strong ability to generalise.  That is, training does not easily translate to other situations.  For example, the use of a fake shop in a classroom is often not obviously transferred to the real situation.
vi.    Be trained in the use of Learning Assistants
This training must involve a practical (teaching practice) element.


The Training of Other Staff Within the School
All teaching staff in a school should have a basic knowledge of children with special educational needs and ideally should have been involved with the development of the Whole School Policy and should support it.  Such training should be formal and should be aimed at imparting knowledge of special educational needs to the teacher and should also allow the teachers to talk through their concerns and reservations about such a venture.

General training for all teachers:
It is now a likelihood that most teachers, particularly at primary level, will teach children with special educational needs during their teaching career.  It is vital that training colleges acknowledge this fact by having compulsory and examinable modules on special educational needs on the trainee teachers’ course.
Equally, all teachers currently working in schools should be given the maximum amount of in-service and support possible in this whole area.

Training for Principals:
As the people driving the education process in schools it is vital that principals be given the necessary knowledge and understanding of special educational needs to be able to adequately plan, organise and employ staff.


VIEWS ON SPECIFIC ASPECTS OF THE EPSEN ACT, 2004

In addition to general comments about the Act, we would welcome any comment you might have in relation to the following specific areas: 


Q.5 What do you consider are the priorities in relation to identification and assessment of children with special educational needs?

For the child with special needs there are two forms of assessment, both of equal importance:

Formal Assessment of the Child’s Disability and Statement of Needs. 
Many principals and staff members will be involved with this assessment although in a large number of cases it will be done by a qualified professional.  Clearly, the primary need is for such professionals to be available when required.  This is a major issue as the assessments for the EPSEN Act will be kicking in at approximately the same time as the assessments for the Disability Act.  This is going to put a huge strain on already stretched resources and must be planned for immediately (in fact, the planning should already have taken place). 
It is difficult to establish priorities in this area as the need for assessment is as important for the fifteen-year-old who has been neglected over the years as it is for the three-year-old who needs early intervention.

School Based Assessment:
 
When we refer to school based assessments we mean the ongoing process of checking a child’s progress, which is part of the routine of any school structure.  For some children, these assessments would include State Exams, for others it might be purely at classroom level.  In all cases such assessments would also feed into the more formal multi-disciplinary assessments which are needed for long-term planning and for IEPs. Clearly, such assessments should always make allowances for the particular disabilities of each child.  Therefore:
a.    Assessments should take account of the following:
Personal Factors
i.    the child’s strengths and weakness
ii.    the child’s developmental level and any emerging skills
iii.    the child’s communications skills
iv.    the child’s independence skills
v.    the child’s personality

Social Factors
i.    How the child relates to peers and adults
ii.    If the child prefers be alone
iii.    How he/she manages in a group
iv.    How he/she responds to the learning environment
v.    How easily distracted is he/she

Behaviour
i.    What types of behaviour he/she displays
ii.    If the child has any aggressive or self-injurious behaviours
iii.    When and where the behaviours occur
iv.    The nature of obsessional interests
v.    His/her reaction to intervention

b.    Methods of Assessing the Child:
i.    Teacher record keeping
ii.    Consultation with parents
iii.    Video Records
iv.    Written tests which assess knowledge and performance.  In certain circumstances:
o    this might not include comprehension tests.
o    this might be done on computers (where writing is poor).
v.    Multiple choice tests.

c.    In Designing Tests:
i.    Care should be taken not to underestimate what the child knows.  Otherwise the outcomes may reflect the child’s lack of response to learning.
ii.    The questions must reflect the child’s capacity to absorb certain information as opposed to other information (for example with some children a test involving social interaction is not going to produce good results)
iii.    The tests should attempt to measure understanding as opposed to mimicking
iv.    Account must be taken of the fact that the child may know how to do something but does not have the ability to express the skills verbally or in certain social situations.


Q.6 What are your views about the preparation, monitoring and review of Individualised Education Plans?

a.    Elements to be included in the IEP:
i.    The nature of the child’s difficulties
ii.    Actions required:
·    the special education provision needed
·    the staff required, including frequency of support
·    specific programmes, activities, materials, equipment required
iii.    Help required from parents at home
iv.    Targets to be achieved in a given time.  These targets must be aimed at “stretching” the ability of the child.
v.    Any pastoral care or medical requirements
vi.    Monitoring and assessment arrangements
vii.    Other support agencies involved
viii.    Arrangements for review and the date it is to happen.
ix.    Issues affecting the child’s response to the learning environment (there must be suggested educational responses to these)
·    The child’s communication skills
·    The child’s cognitive skills
·    The child’s behaviour
·    Any additional difficulties that the child experiences such as epilepsy or physical disabilities.

b.    Information sources for the IEP:
i.    Assessments
ii.    Teacher observations
iii.    Reports from professionals involved with the child

c    Review of Plan
i.    It should be remembered that, for most children, the teaching content for any class is more or less governed by the official school curriculum.  Their progress is then measured against that curriculum in order to see if the child and the teacher are achieving.  This is not the case for a child with special needs.  In this case, the IEP should replace the official curriculum as a measuring tool.  Therefore, the targets in the IEP should be realistic, relevant and reachable.
ii.    While a formal review is obviously necessary, this must be fed by the result of in-school assessments as referred to in Q5 above.
iii.    It seems unnecessary to state but the issue of reviews once again raises the matter of teacher training and the vital need for same.




Q.7a Please comment on the support services that you feel should be available to children with special educational needs.

Professional Support for Mainstream Schools:

It is important to achieve the maximum degree of integration possible for each child with a disability, not only for the sake of children with a disability, but also for the rest of the population.  In a truly integrated society people with disabilities must be seen as an integral part of the community from the time they are born.  However, in moving towards the integration model it must be remembered that many professional supports for the child and also family supports such as counselling and information dissemination which were a common feature of the old system of having special segregated units for people with disability are often not available to the parents of children in mainstream schools.  Therefore, it is vital that such support structures be set up on a regional basis.  In relation to schools this would mean:
i.    Consultant Support:
To ensure that children with special needs receive the tailor-made programme that they require it would be necessary for the schools to have available to them:
·    Educational Psychologists:  It is important for even the best-trained teacher to be advised on the very specific needs of the child.  To ensure this, the school must have access as required to an appropriate educational consultant.
·    Behavioural  Consultants:  The issue of behaviour management is a major one when dealing with children with special educational needs.  Again, schools cannot be expected to provide an adequate service unless they receive support in this area.
NOTE:  All decisions made by consultants should be carefully explained to the teachers and the parents at appropriately convened meetings
ii.    Therapeutic Support:
Within the regional support teams there should also be Speech & Language Therapists and Occupational Therapists to service the schools.
iii.    Emergency Support:
To ensure the smooth running of the educational process it is vital that an emergency advice line be available to teachers to help resolve the kind of problems which arise from time to time.  In this way, rather than spending large amounts of energy in trying to resolve difficulties which have developed over a period, they would be dealt with before they reach crisis level.     
iv.    Other:
Where a student or students with special needs is/are assigned to a mainstream class, the numbers in that class should be reduced to allow for the extra work involved in catering for the child with special needs.


Q.7b In relation to these support services, what are your views on how the Education and Health sectors can work together most appropriately.

We have no suggestions in this areas except to say that, in the interests of the children, it is important for both departments to find a way to work together.
Also, it seems important that, if both departments are cooperating, then there should be a person or persons whose job it is to ensure such cooperation runs smoothly and that services are properly coordinated.


Q.8 What are your views on an appeals process and how it should be implemented?

It is our view that, while an appeals process is important, it is more important to achieve a situation where appeals are minimised.  What we mean by this is that the Council and its representatives must understand that resolving problems involves sitting down with all those involved and finding solutions that are acceptable to everyone.
In other words, the SENOs must realise, particularly in dealing with parents, that each issue must be approached with an open mind.  They must make an effort to discover the parents’ fears and their needs.  It is only in this way that parents will learn to trust the “establishment”.  They will then stop believing (as many do at present) that the purpose of the SENO is to persuade the parent that a particular solution is the only one.  In the short term this could involve “messy” solutions, but in the long term it will reduce the number of appeals and will encourage parents to trust the SENO and will eventually allow the SENO to confidently recommend “best” solutions.


Q.9 Other comments or views?

1.    PRE-SCHOOL/EARLY INTERVENTION.

It is important for many children with special needs to experience intervention at as early a stage as possible.  Such intervention must begin with an early assessment process followed by an IEP and finally an appropriate placement in a pre-school.

·    Pre-schools must be available to parents:
o    as a place where the process of early intervention begins
o    to prepare children with special needs for primary school.
·    There must be clear guidelines for pre-schools.  This should include a quality system, monitored properly by the authorities, for example, the Department of Education and Science (DES). 
·    Such pre-schools might be part of the service given by a special needs service provider, a mainstream school or a stand alone pre-school
·    The curriculum (for all pupils) should include appropriate social behaviour and communication skills.
·    Some children might need specialist “kick start” pre-schools.  These would “kick start” children with particular physical or behavioural difficulties and would be aimed at giving them particular assistance in helping them to catch up with their peers when they enter “big school”.
·    The period spent by special needs children in pre-schools should be dictated by the needs of the child as opposed to the child’s age.

2.    SECOND LEVEL

The nature of second level schools creates a particular difficulty for its students with special educational needs, no matter what level they function at.  The need many people with special needs have for a degree of predictability and consistency provides a challenge to the authorities of second level schools.  Below we look at the needs of students with special educational needs in this regard.

a.    Admission, Induction and Pastoral Care
i.    There should be a careful induction process for students with special educational needs.  This would include
·    School timetable
·    School layout
·    Support structures
ii.    The transition arrangements from primary to post primary should be in place long before the child is due to leave the primary.  Such issues as the child’s capacity to cope in different settings in the second level school and the age at which the child should move must be considered and taken into account . 
iii.    The issue of SNAs transferring with the child must also be decided at an early stage.  If the SNA is prepared to go then the decision should be based on parents’, teachers’ and professional advice and opinion.
iv.     It is important that the school facilitates friendships from primary school and aims at ensuring that the students with special educational needs have the company and support of such friends.
iv.    The school must be aware of the problems some people with special educational needs have with change.  Serious and regular efforts must be made to keep the student informed in a sensitive way of any changes which might occur.
v.    All aspects of the physical environment within the school should be taken into account.  For example, schools should ensure that drop-off points for transport of children with special educational needs should be safe
vi.    The ideal situation is that the student should attend a local school. 
vii.    There is a need to transfer information to the second level school.
viii.    Where the child is in a mainstream class one teacher should have responsibility for the child’s well being.
ix.    The child must be facilitated to take a reduced number of subjects.
x.    It might be necessary to consider increasing the time a special needs student is allowed to spend taking courses.
xi.    It is necessary to streamline and facilitate the process whereby a pupil is partly in a mainstream school and partly in a special school.

b    Staffing of Special Class:
The staffing arrangement in a special class, if one exists, must be flexible:
i.    For each permanent member of the class there must be one learning assistant.
ii.    The pupil-teacher ratio for a permanent class must be 3:1.
iii.    A part-time member of the class must have a personal learning assistant who moves with the student.
iv.    The special class should have one primary-trained teacher.

c.    Mainstream Class.
Where a student with special needs is in a mainstream class it is important that the needs of the student be taken into account.  Therefore:
i.    Where possible the class should have regular routines.
ii.    Careful consideration must be given to the amount of support provided and when it is provided so that the child does not feel singled out by having an adult with them or that he/she spends so much time with the learning assistant that there is little opportunity for them to work with others in the class.

d.    What is required of second level teachers:
All the characteristics given in the answer to question 4 particularly:
i.    An understanding of special educational needs and the needs of a child with special educational needs.
ii.    An understanding of parents’ concerns.

e.    Curriculum:
In a situation where the student might be considered capable of taking State Exams, part of the child’s IEP must give a clear indication as to what subjects he/she might take and in what way he/she may be capable of taking them.  The following examples of the strengths and weaknesses of children with autism illustrate the point:
i.    Subjects which may cause difficulty for students with ASD:
·    Subjects requiring peer interaction (e.g. group discussions in English and History).  Where such subjects cause difficulties alternative approaches may be needed.
·    Subjects which require an understanding of language and fiction such as English, History and Languages.  Certain students will have serious difficulty with these subjects.
·    Subjects which require group work such as Drama and PE.  Again certain students with ASD may have grave difficulties with these
ii.    Subjects which might be easier for students with ASD:
·    These include Mathematics, Art, Music, Computers, History, Geography, Home Economics.
·    Students should be able to pick subjects that they are good at.
·    The Students with ASD should not be placed in a class of low achievers because of a perceived need for additional supports.

g.    Accreditation
The latest figures from the Central Statistics Office show that 92% of people with disabilities who have gone through our education system have received no formal accreditation.    Assessment is at the heart of the process of learning.
Assessment for learning (formative assessment) plays a crucial role in progressing learning and in developing effective learners.
In Ireland and internationally, assessment of learning (summative assessment) is intrinsic to senior cycle education where the results of such assessment convert into certification, qualifications, a passport to Higher Education and becomes an important factor in the future work and life prospects of learners.
For this reason it is important that suitable assessment models be found for students with special educational needs.
The NPSA accepts that some people with special educational needs may never aspire to achieving success in the Junior and Leaving Certificate Exams as they are currently structured and in some cases could never hope to achieve any kind of formal state exam recognition.  Nevertheless we believe that State exams should attempt to cater more for people with all disabilities.  Even for those who cannot achieve such a level, there is no reason why their actual abilities should not be recognised.  Therefore, work should be undertaken on looking at an assessment process which is disability-friendly and which aims at presenting a positive view of the person’s talents and abilities.
The points below are made with that issue firmly in mind. 

Examples of methods which should be investigated and which are already being used:
i.    Formative Assessment as seen in the Transition Year.  This is characterised by a strong emphasis on assessment methods that inform, and are informed by, the teaching and learning process.
ii.    Stand-alone Qualifications: Many Transition Year programmes offer stand-alone qualifications, for example in the area of ICT.
iii.    The Link Modules of the LCVP have pioneered the use of prepared material and of video material within formal examination contexts.
iv.    The LCVP has also given rise to a growth in expertise within the system in the area of portfolio assessment.  The Leaving Certificate Applied has also pioneered new assessment approaches in the area of crediting module completion and in the assessment of project-based student tasks.
v.    The use of interview in which learners discuss their work has proved particularly successful as an assessment method.

Finally,
Q.10.  What is your interest in making this submission?

Our organisation, as stated above, represents parents of people with an intellectual disability and autism including children with these disabilities.  While dealing with our members we come across many issues relating to education provision.