Education, Health and Care Quality Assurance Framework
Consultation Summary and Responses to queries
4 November 2019
A. Overall approach and choice of domains
1. There was support for an Education, Health and Care (EHC) Quality Assurance Framework and for the proposed governance arrangements to make it happen.
B. Focus of the Quality Assurance Framework
2. There was support for the four proposed domains of the EHC Quality Assurance Framework: audit, voice, data and insights, and complaints and compliments. However, there were some points for clarification which are presented below in bold, followed by our response.
a. The EHC Quality Assurance Framework ‘doesn't seem to capture what might be available for over 16s, those in further or higher education, or up to the age of 25’.
The framework focusses on children and young people with an EHC Plan. This includes young people up to the age of 25. We have strengthened references to young people over 16 in the framework in consultation with the Connexions Service.
b. It also ‘doesn't seem to cover children younger than reception who are not in a primary school who may have an EHCP’.
As above, the framework will cover all children 0-25. We have strengthened references in the revised framework.
c. It also ‘doesn’t appear to cover any children who may be home schooled or those currently not in education, for example those who have been excluded, or are school refusers, or those where there is no provision to match their needs’.
The framework includes all children and young people (0-25) with an EHC plan.
The Council will continue to work with families and partners to identify appropriate provision for children and young people with EHCPs and address individual issues through assessment and review. Where we have a concern about specific groups (such as children who are at risk of permanent exclusion), we will target audit activity on their plans, provision and progress.
d. ‘Will there be any independent oversight of the Quality Assurance framework’?
We will have access to an independent SEND specialist who will work with the level 2 audit group and the Quality Assurance Group to moderate the framework and review processes and outcomes to ensure they are effective and appropriate.
They will review the framework at points throughout the year and provide feedback and challenge to the Quality Assurance Group.
C. Role of partners
3. Is this primarily a council Quality Assurance Framework? Would the work in the domains be carried out by the council?
No. This is a city (local area) EHC Quality Assurance Framework. All partners have a role to play in raising quality and sharing learning. However, because of our statutory responsibilities, the framework proposes that the Council and the Clinical Commissioning Group contribute across all four domains.
In implementing the framework, we will balance the benefits of wider partner skills, knowledge and experience with available capacity. For example, in the audit domain, where we are proposing a more structured approach, we will work through existing groups and seek to share resources.
In practical terms school-based level 1 audit activity will happen through the existing SENCO network. Through the network, SENCOs will be invited to participate in the level 2 multi agency audit group.
4. What role will Early Help services play in the EHC Quality Assurance Framework?
Early Help will be an important partner in the success of the framework. We propose to include learning from existing Early Help audits in the framework and to ensure that the scope of level 2 multi-agency audits include a child or young person with an Early Help plan. Representatives from Early Help services have also been invited to observe future SEND inclusion panels and level 2 multi-agency audits.
5. How should the framework include the experience of children, young people and their parents or carers who contact SEND IASS for support with issues relating to SEND?
SEND IASS plays an important role in supporting children, young people and their families. Learning from these experiences helps to raise quality across the city. In addition to their own processes, learning via SEND IASS will be an integral part of the Voice domain. As a result, it will be at the heart of local area learning via the proposed Quality Assurance Group.
D. The Audit domain
6. The EHC Quality Assurance Framework sets out an approach to audit in three levels: single agency (level 1), multi-agency (level 2) and system leader (level 3) case reviews.
7. Level 1 audit sets an expectation that ‘individual agencies [will] audit the quality of their own contributions to EHCPs’. Is this going to be informally, or will this take the form of prescriptive documents?
Level 1 audit is an important way that key stakeholders including schools and other education providers, social care and health all help to drive high quality EHC Plans. The framework proposes that these three groups work to an agreed template this will be developed jointly with the council’s APR service. Aggregate information from these level 1 audits will be shared with city stakeholders.
8. Will this mean that within MATs, SENCOs could meet once a year to audit EHCPs or does this mean that we will be tied to the LA's audit of vulnerable groups and timeframes?
At level 1: single agency audit, SENCOs via the SENCO network will meet termly to audit the quality of advice to plans. This will be facilitated by the council’s SEN Senior Adviser.
At level 2: multi agency audit, SENCOs will be invited to join the half termly Audit Group. This will be facilitated by the Council’s APR service. The multiagency audit is expected to last for approximately 3 hours. All documentation will be available to read during the meeting and attendees are not expected to contribute to the level 2 audit outside of this meeting. Different SENCOs will be invited throughout the year so that learning can be shared across the city.
9.‘It is good that [with consent] a child or young person or their parent and carer will be included in the level three review meetings. I wonder if this could be extended to any other audit or review meetings?’
We agree that this is important, and we know from other parts of the Council that this is valuable. We will fully embed and learn from level 3 audit. If successful, and with consent, we will extend to other forms of audit.
10. Clarity is required regarding the numbers of EHCPs being audited, audit criteria and areas of focus. There also needs to be further detail regarding the selection process of EHCPs and how audits will be coordinated.
Terms of Reference are being developed for each level of audit. They will describe how audits will be organised, collated and shared. These Terms of Reference will be developed collaboratively with colleagues to ensure that they are clearly understood and there is capacity to implement them. The process will be facilitated by the SEND APR Service.
E. Sharing learning
11. The EHC Quality Assurance Framework is designed to share learning. How will you do that?
The purpose of the framework is to drive local area (city) wide learning and improvement. We intend to do this by putting in place structured ways to draw together information across the four domains of audit, voice, data and insights, and complaints and compliments. The Quality Assurance Group, made up of partners from across the city, will lead on interpreting this information, agreeing improvement activity and sharing key information to the city (local area) workforce.
We will share information back to partners via the: SEND Executive Board, the Quality Assurance Group, existing networks (such as the city SENCO network), and through city events such as the Newcastle Inclusion Conference.
12. When will the EHC Quality Assurance Framework ‘go live’?
The framework draws on a lot of information that is already available such as city data and insights, organisations’ own approaches to complaints and compliments, and existing audit work. We will work with partners to put in place the governance and detail required so that t he EHC Quality Assurance Framework is in place from January 2020.
Should you have any further questions or queries about this matter please contact:
Noelani Hall, SEN Senior Practitioner
Tel: (0191) 2774637