DRAFT Special Educational Needs and Disabilities inspection, findings, and response Briefing paper for NHS Brent Chief Officer and Chief Operating Officer 24 Aug 17 This will form the basis of the paper for the Health and Wellbeing Board (with chronology removed/ reduced)
Purpose of the briefing This paper details the actions taken by NHS Brent Clinical Commissioning Group, and Brent Council, in responding to the May 2017 local area joint inspection of Special Educational Needs and Disabilities services in Brent undertaken by Ofsted and the Care Quality Commission. The commissioners have worked with London North West Healthcare NHS Trust, Central London Community Healthcare NHS Trust, Central and North West London NHS Foundation Trust and others involved in providing services for children with Special Educational Needs and Disabilities. This paper presents the local area governance to develop a joint Written Statement of Action, and to develop an underlying joint action plan with joint monitoring arrangements.
1. Background The Children and Families Act 2014 established duties for Clinical Commissioning Groups (CCGs) and Local Authorities (LAs) to improve the services for children with Special Educational Needs and Disabilities (SEND). Regulations were published in the 2015 Special educational needs and disability code of practice: 0 to 25 years. Local areas are required to have: a clear local offer of SEND support; arrangements for jointly commissioning SEND services; arrangements to introduce Education, Health, and Care Plans (EHCPs) to replace Statements of Special Educational Need, and to replace Learning Difficulty Assessments; and arrangement to support children with complex needs transition from child to adult services. For the purposes of the regulations, the local area is the geographical area of the local authority. Brent local area responsibilities are for children with SEND needs who are resident in Brent, even if they attend educational establishments in under a different LA boundary. The responsibilities of the Brent local area are held collectively by Brent Council (including public health and children s social care), NHS Brent CCG, NHS England, schools, early years settings, and other education providers. The Brent Children s Trust Board established a standing SEND subgroup to oversee a joint self-evaluation, collate evidence, and lead improvements to deliver the SEND reforms through a joint action plan. The unannounced inspection in May 2017 was joint between the Office for Standards in Education, Children s Services, and Skills (Ofsted) and the Care Quality Commission (CQC). The inspection evaluated the local area s implementation of the SEND Code of Practice to date, and identified areas for development.
2. Brent local area joint inspection by Ofted and CQC Communication with inspection team Inspectors made contact by phone on 08 May 2017 to alert the local area to an inspection beginning 15 May. Formal written confirmation was emailed later that day. During the inspection, the inspectors provided daily feedback, and gave verbal feedback on 19 May. The draft report dated 31 May was not provided directly to the CCG. A copy was sent to Brent Council in 14 June. The CCG did not identify any factual inaccuracies. The final report was not directly provided to the CCG. A copy was sent to Brent Council on 18 July. The Local Area has 70 days from the date of the final report to submit a written statement of action about the five areas of concern. Submission in due no later than 19 October. Ofsted & CQC Notification letter 08/05/17 20170508 CQC NOTIFICATION LETTE Ofsted & CQC Draft report sent 14/06/17, dated 31/05/17 Ofsted & CQC Final report 18/07/17, dated 13/07/17 Brent local area Draft written statement of action 23/08/17 LASEND Draft Report.pdf LASEND Draft Cover Letter.doc LASEND Letter Brent 10034547 PDF Final.pd 20170823 Brent 20170823 WSOA Childrens Trust WSOand CT Improvement The local area will sign off the Written Statement of Action through: Brent Children s Trust 12 September Sense-check with DfE and NHS England 25 September Brent Health and Wellbeing Board 05 October The local area s progress will be evaluated at the Community and Wellbeing Scrutiny Committee 22 November
3. Inspection findings In their report, the inspectors identified many strengths in the local area s provision for children and young people with special educational needs and disabilities. These included the strong commitment from senior leaders across Brent local authority in improving outcomes and services, how GPs offer annual health assessments to young people with a learning disability which strengthens the relationship between a young person and their GP practice, how children and young people achieved well academically because of the good partnership between schools and the LA, as well as the high quality of teaching they receive. It also noted that the Children s Trust Board ensures that improving education, health, and care outcomes for children and young people remains at the heart of its work. The report documented that children and young people who have special educational needs and/or disabilities are positive about the support they receive. Parents describe how their children s social skills and confidence are developed as a result of the local area s provision and that parents agree that professionals in Brent typically identify the needs of children and young people accurately and promptly. The excellent care provided by the Ade Adepitan Short Breaks Centre, which was recently rated Outstanding by Ofsted, was also commended in the report. Although some aspects of the inspection were very positive, a written statement of action has been requested. The LA, Brent CCG and health providers are working together to address these concerns and respond to them so that children in any setting can get the right health advice and treatment to support their education. The most challenging of these concerns to address is the waiting times issue that has arisen due to wider shortages of specialist NHS staff. Brent CCG is also appointing a specialist clinician to oversee and speed up the programme of health reforms. The Written Statement of Action addresses the following areas of concern. Area of concern strategic leadership of the CCG in implementing the SEN reforms the fragmented approach to joint commissioning causing gaps in services the lack of opportunity for therapists to respond to draft EHC plans before they are finalised Progress following the inspection CCG leadership fully sighted on strategic plans for SEND reforms. Designated Clinical Officer post created and recruited. Formal review of options with Brent Council on joint/ integrated commissioning. CCG paediatric therapy service specifications updated Joint monitoring with CCG and LA of LNW services Formal tender to deliver joint commissioning between CCG and LA Council for Disabled Children to facilitate 3 workshops to support joint commissioning Standard operating processes introduced Routine monitoring to be established poor access to services for some vulnerable groups; in particular, to audiology, OT and speech and language therapy limited opportunities for parental involvement when designing and commissioning services. LNW action plans for recruitment Weekly monitoring, support, and challenge ASD pathway redesign Audiology recruitment issue escalated to NHSE SEND national lead Parent-Care Forum re-launched Targeted engagement planned Health Partners Forum Oct 17
4. Chronology key dates and events Pre-inspection Mon Brent Children s Trust working on SEND reforms, including inspection preparation. Subgroup 13/03/17 led by Sandra Bingham (Head of Inclusion, Brent Council). Self-evaluation completed, with evidence stored (in Brent Council folders). Self-evaluation asked How effectively does Brent IDENTIFY the needs of SEND children (0-25years)? How effectively does Brent ASSESS & MEET the needs of SEND children (0-25years)? How effectively does Brent IMPROVE OUTCOMES of SEND children (0-25years)? SEND Joint Commissioning Strategy action plan included commissioning of paediatric therapy services for occupational therapy, physiotherapy, speech and language therapy, school nursing and Child and Adolescent Mental Health Services Hillingdon inspection noted to be good. 29/03/17 Community and Wellbeing Scrutiny Committee Report on SEND reforms from Gail Tolley (Strategic Director of Children and Young People).
Inspection notification and preparation Mon 10:30 - Phone call from Kay Goodfellow (CQC) to Diane Jones (Director of Quality and Safety, 08/05/17 Collaboration of Brent, Harrow, and Hillingdon CCGs) to say a joint Ofsted and CQC inspection of Brent local area SEND services would begin 15/05/17. Diane Jones was on leave for the week of the inspection. Email sent to Ethie Kong (NHS Brent CCG Chair), Rob Larkman (Chief Officer), Sarah Mansurali (Chief Operating Offier), Duncan Ambrose (Assistant Director for Mental Health, Learning Disabilities, Children, Maternity, Safeguarding), and Pippa Street (Interim Deputy Director for Quality and Safety). 10:45 Local officer for health identified as Dionne Greenaway (Senior Commissioning Manager for Child and Maternity Services, NHS Brent). Local officer for Brent Council was Sandra Bingham (Head of Inclusion). 11:00 Inspection team confirmed Gaynor Roberts HMI Roger Rickman, Ofsted inspector Kaye Goodfellow, CQC 11:00 Information requested by inspectors: SEND strategy Autism strategy Healthy child programme Neonatal screening programme School Nursing service 0-25years CAMHS service Speech & Language service OT service JSNA 2016 Draft timetable set by inspectors: Day 1: AM: meeting with strategic leads. PM: meeting with DMO / DCO, and LAC designated professionals Day 2: All day: meeting with HV, school nurses and community nursing teams (case records must be available to child s journey) Day 3: All day: meeting with CAMHS & AHP (case records must be available to child s journey) Day 4: All day: early years site visits Day 5: PM: feedback to strategic leads 11:15 Formal restricted notification of CQC inspection sent to: Mr Rob Larkman Accountable Officer at NHS Brent CCG Dr Etheldreda Kong Chair at NHS Brent CCG Ms Diane Jones Director of Quality and Safety at NHS Brent CCG Ms Sarah Mansuralli Chief Operating Officer at NHS Brent CCG 14:00 Notification to providers, with provisional dates and times for visits. 16:10 Brent Council sent notification to London North West Healthcare NHS Trust 09/05/17 10/05/17 11/05/17 Brent Children s Trust Board considered how to coordinate the inspection. CCG formally notified London North West Healthcare NHS Trust and arranged a teleconference for later in the week. 14:20 Brent Council 2013-16 SEND strategy circulated for reference. 15:45 CQC confirms additional inspection team members, and changes to the timetable Tahir Hussain (shadowing) Lea Pickerill (Quality Assurance) 17:20 CCG confirms two briefing sessions for providers. 10:00 CCG requested copy of SEND subgroup self-evaluation held by Brent Council. This was in the process of being updated and not available.
15:00 Additional documents (32) sent by CCG to CQC. 17:31 Duncan Ambrose circulates summary of teleconference with LNW, including clarification of gap around Designated Clinical Officer, and proposed action to introduce this. Current paediatrician Dr Al-Hadi s role pre-dates SEND reforms, and hence only partially covers the DCO responsibilities. 17:41 Self-evaluation circulated 17:57 Dr Hisham Al-Hadi clarifies his role as Community Paediatrician leading the SEN service, not as Designated Medical Officer. Fri 12/05/17 Sun 14/05/17 0930 LNW share example DCO job descriptions. 12:00 ASD waiting times noted to be 4 to 6 months. 21:50 Final timetable, self-evaluation, and scrutiny report circulated. 21:30 DCO proposal from LNW to introduce DCOs in place of current arrangements
Inspection week Morning updates from inspectors and requests for specific evidence Additional evidence sent to inspectors each day Mon Introductions, self-evaluation discussion, early years, LAC, vulnerable groups, transition to 15/05/17 adulthood, interview with DMO. Raising standards, assessing need, family nurse service, support, SEN panel, parent/carer 16/05/17 involvement, case audit, community children s nursing, joint commissioning, young people s participation School visit, social care short breaks, paediatric therapies, child development unit, CAMHS, 17/05/17 CCG leadership Visits 18/05/17 Fri Feedback from inspectors to Local Area 19/05/17
Actions following inspection Work to update CCG strategic plan for SEND following meeting with inspectors 17/05/17 Small business case for CCG funding Designated Clinical Officer, joining in with Hillingdon 23/05/17 recruitment. Interviews planned 09/06/17, then delayed to 16/06/17 to accommodate the one applicant. Decision on 05/06/17 to re-advertise as candidate unable to commit to the new interview date. Verbal update at Executive Committee 24/05/17 Mon Joint CCG and LA newsflash to those who took part in the inspection. 05/06/17 LA developing detailed action plan after the inspection 06/06/17 14/06/17 Revised DCO advert, with proposed interview date 26/07/17. Dates revised to 16/08/17. Subsequently revised again to 06/09/17. Mon 19/06/17 Mon 26/06/17 11/07/17 13/07/17 18/07/17 19/07/17 25/07/17 02/08/17 03/08/17 Mon 07/08/17 08/08/17 Fri 11/08/17 Mon 21/08/17 22/08/17 23/08/17 Brent Council received draft report from Ofsted and CQC, marked as copied the Sarah Mansuralli, but not received. 10 days to challenge any factual inaccuracy, with submission only via Gail Tolley. Brent Council forward draft report from Ofsted and CQC to CCG. CCG confirms no challenge to factual accuracy of the inspection report. Draft CCG SEND strategic plan discussed at SMT CCG strategic plan and LA action plan discussed by Children s Trust. Duncan Ambrose and Brian Grady tasked with drafting joint response as Written Statement of Action. SEND inspection implications discussed at LNW CQRG. Updated paediatric therapy service specifications recirculated. Final inspection report sent to Brent Council, but not Brent CCG. 70 days for local area to respond with Written Statement of Action (19 Oct). CCG strategic plan for SEND agreed at Exec Committee, with discussion of Chair, Accountable Officer, COO, Clinical Directors. Meeting with Elaine Baulcombe (DfE) and Elaine Ruddy (NHSE). Discussion of support in developing WSoA. Follow up meeting planned 26/09/17. Standard Operating Processes agreed with LNW for draft EHC plan review by therapists. Reflects OT, SLT, PT. Also need to pick up and other complex health needs. LNW CQRG. Following up actions to reduce paediatric therapy waiting lists. Rob Larkman, Sheik Auladin, Carolyn Downs, Gail Tolley meeting to discuss strategic next steps following SEND inspection, and to agree scope and appetite for joint commissioning option appraisal. Options defined by end of Oct with implementation immediately after. Weekly teleconference with LNW regarding SEND actions to reduce waiting times Duncan Ambrose and Elaine Ruddy discussion of progress. Link made to Council for Disabled Children, and to Greenwich CCG. Advice also given on OT recruitment ideas for LNW. Duncan Ambrose discussed support from Council for Disabled Children. Workshop mid-late Sep. Sheik Auladin, Duncan Ambrose and Elaine Ruddy discussion of progress. Escalated concerns around shortage of audiologists. Elaine supported the proposed changes to the ASD pathway. Sarah Basham, Gail Tolley, Brian Grady, Duncan Ambrose review of draft WSoA. Good progress. Gail to give comments.
Next steps 24/08/17 Fri 25/08/17 Fri 01/09/17 Mon 11/09/17 12/09/17 26/09/17 05/10/17 19/10/17 25/10/17 22/11/17 Draft WSoA to Rob Larkman and Sheik Auladin for comment. Draft WSoA to Elaine Ruddy for comment. Gail Tolley to review amendments. Targeted engagement with service users and schools begins Children s Trust to review draft WSoA and comment Meeting Elaine Baulcombe (DfE) and Elaine Ruddy (NHSE) for update and comments. Health and Wellbeing Board to endorse and comment Last day for WSoA submission Health Partners Forum Review of engagement on SEND, CAMHS, parental mental health Community and Wellbeing Scrutiny Committee Update repot on progress