Issue details

24/00026 - The Locality Model for Special Educational Needs Inclusion

Proposed decision


The Cabinet Member for Education and Skills to approve the adoption and implementation of the Locality Model for Special Educational Needs Inclusion in Kent


Reason for the decision


-     Adopting the Locality Model for Special Education Needs (SEN) Inclusion would be a step forwards in Kent County Council’s (KCC) commitment to delivering the priorities of the Countywide Approach to Inclusive Education (CATIE) Strategy. The CATIE Strategy is one of KCC’s responsibilities to implement the Designated Schools Grant management plan, as outlined in the Department for Education’s (DfE) Safety Valve Agreement with Kent.


-      Implementing the Locality Model will support increased inclusion in mainstream schools for children and young people with SEN. The Locality Model will be the framework that ensures KCC can deliver the most effective and appropriate High Needs Funding (HNF) allocations to local areas in Kent. The Locality Model will align with a new Kent SEN continuum being developed to span mainstream, specialist resource, and special school provisions, ensuring system-wide cohesion.




-      In May 2023, at KCC’s Children Young People and Education (CYPE) Cabinet Committee, the CATIE was set out as KCC’s strategy for 2023-28. The CATIE established KCC’s collective ambitions for children, young people, and their families in Kent. Professionals working together in a collaborative, sustainable system to ensure equity of education, meaning children feel they belong, are respected, and valued as individuals, and are fully supported to achieve their best.    


-      The CATIE, signposted within the DfE’s Safety Valve Agreement with Kent, states it will “develop a school/area-led approach to […] SEN support services (Locality Based Resources), to better respond to the needs of children and young people with Special Educational Needs and Disability (SEND)”.


-       CATIE’s Priority Two aims to develop community working and implement structures that support children and young people with SEND in Kent to have their needs met within their own locality, wherever possible.


-      As part of KCC’s work towards delivering on CATIE priorities a Locality Model has been developed, with the aim of improving the outcomes for children and young people with SEND in Kent. This proposal went out to public consultation between November 2023 and January 2024.


Options (other options considered but discounted)


-      The process for developing the Locality Model was iterative and alternative options were considered within the development process, to ensure the direction proposed is the right one for Kent. The group involved in developing and defining our options consisted of KCC staff from education, finance, and SEN, alongside leaders of education from KCC mainstream primary and secondary schools (selective and non-selective), single and multi-Academy Trusts, special schools, and free schools.


-      Three main options were considered:

1)    to maintain the current system

2)    to implement a Tariff system

3)    to implement a Locality Model


-       Option one was discounted as an impracticable solution; it is not currently performing well in Kent, there iscurrent inconsistency in mainstream SEN inclusion and provision, along with a lack of effective monitoring systems and accountability. Ofsted have stated, poor standards are achieved, and progress made, by too many pupils with SEN under the current system.


-       Option two could have been viable but was discounted due to its identified limitations. A tariff system[1] for mainstream would provide clear and transparent arrangements with a prescriptive allocation of resources but tends to be used in conjunction with individual funding allocations for children with EHCPs, rather than for wider operations and funding of SEN Support Services. The elements of inflexibility it would bring were also considered too restrictive for SEN support services, and unsupportive of innovative use of resources for mainstream if used on its own.


-       Option three was viewed as the best path for KCC to explore and define further with partners. Research finds that more consistent and effective support in mainstream schools lead to positive outcomes for children and young people. Local authorities who make substantial use of peer moderation and mainstream collaboration have found that doing so improves consistency and is a useful source of advice and support. The Locality Model is designed to improve the quality of the mainstream education offer in Kent, through early and accurate identification of need, high quality teaching of a knowledge-rich curriculum, and timely access to specialist health and care support, and via alternative provision placements where they are needed.


-      Proposals for the Locality Model were agreed following intensive collaboration with schools, settings, and other key stakeholders, and then put out to consultation with parent/carers, young people, all professional stakeholders, and all members of the public.


-  Following consultation, subsequent analysis of feedback, and defining KCC’s response to consultation feedback, the Locality Model will be   presented to the CYPE Cabinet Committee.


How the proposed decision supports Securing Kent’s Future andFraming Kent's Future - Our Council Strategy 2022-2026


-      The Locality Model directly aligns with KCC’s strategic vison for children, young people, and families, as set out in ‘Framing Kent’s Future’. Priority 1: Levelling up Kent explains that: ‘We will maintain improvement support services for all Kent schools, including maintained schools and academies, to maintain Kent’s high-quality education system’. The Locality Model will implement structures that will increase the inclusion of children and young people with SEN in mainstream schools, so they can be educated with, and are able to access the same opportunities to education as their peers wherever possible. The aim is children and young people with SEN in Kent receive early and timely support. That greater numbers of children and young people are able to have their needs met within mainstream settings, or should they need specialist provision, that wherever possible they can access this locally, close to where they live.


-      Under the Locality Model structure, available resources will be discussed by groups of schools and other SEN, education, or healthcare professionals in the local area, to determine where resource and HNF allocations would be best directed. The final decision to allocate HNF will remain with KCC, but by discussions occurring locally KCC aim to make better use of resources. This activity is expected to support KCC with its Safety Valve aims to achieve financial sustainability in the longer term. This would align with priorities set out in Securing Kent’s Future, the next step on from Framing Kent’s Future, agreed at Cabinet in October 2023.


Financial Implications


-      Kent currently spends approximately £45m on specific high needs allocations to schools per annum. Approximately 40% of this are for SEN support services for individual children and the remainder to children with an EHCP. This is funded from the High Needs Block of the Dedicated Schools Grant (DSG), a specific ring-fenced education grant from the Department of Education. The council is one of a number of local authorities which are part of the DfE Safety Valve Programme to support those councils with the highest overspends on SEN services to achieve a financially sustainable longer term position. The Kent’s Safety Valve agreement with the DfE states:


“The authority agrees to implement the DSG[2] management plan that it has set out. This includes action to:


3.1. Implement a countywide approach to ‘Inclusion Education’, to further build capacity in mainstream schools to support children and young people with Special Educational Needs and Disabilities (SEND), thus increasing the proportion of children successfully supported in mainstream education and reducing dependence on specialist provision


3.7. Ensure there is sufficient and consistent capacity across the county to support children with severe and complex needs in their local area where possible


3.8. Develop a school/area-led approach to commissioning of SEN support services (Locality Based Resources), to better respond to the needs of children and young people with SEND”

(page 2 and 3  DfE DSG ‘Safety Valve’ Agreement: Kent)


-      Kent must implement a sustainable approach to HNF to meet the DfE Safety Valve agreement and to ensure financial sustainability in this area moving forwards; the Locality Model will build the robust governance and monitoring processes required to implement the necessary new approach.




[2] Dedicated Schools Grant

Decision type: Key

Reason Key: Expenditure or savings of more than £1m;

Decision status: For Determination

Division affected: (All Division);

Notice of proposed decision first published: 23/04/2024

Decision due: Not before 22nd May 2024 by Cabinet Member for Education and Skills
Reason: To allow 28 day notice period required under Exeuctive Decision regulations

Lead member: Cabinet Member for Education and Skills

Lead director: Christine McInnes

Department: Education & Young People's Services

Contact: Roger Silk, Gifted & Talented Adviser Email: Email: Tel: 01233 898693.

Consultation process

The decision was considered and endorsed by the Children’s and Young People Cabinet Committee on 16 May 2024.


A public consultation on The Locality Model for SEN Inclusion ran from 29 November 2023 to 24 January 2024.


·   4 hybrid parent/carer briefings were attended by around 250 people during the consultation (exact numbers are not available due to some schools hosting parents and carers at their schools and joining virtually therefore only counted as 1 attendee)


·   1 Kent Youth Voice session was held, inviting young people to review the Easy Read Version of the consultation and questionnaire, with the response included in the analysis


  • 2 SEND Information, Advice and Guidance Roadshows were held with information provided on the consultation, with around 130 families attending


  • Various KCC and partner meetings received presentations and information from the Assistant Director of School Inclusion on the consultation with direct encouragement to complete questionnaires


·   832 questionnaire responses were received


·   50 email/postal queries were received and responded to



Cabinet Committee consultation planned: 

The proposed decision was considered and endorsed by the Children’s, Young People and Education Cabinet Committee on 16 May 2024


Financial implications: Please see details above

Legal implications: Under the Children and Families Act 2014 KCC has a duty to ‘to support the child and his or her parent, or the young person, in order to facilitate the development of the child or young person and to help him or her achieve the best possible educational and other outcomes’ and by doing this we are delivering on our obligation in accordance with this legislation. Local authorities must follow government guidance on distribution of their HNF Block and work under the SEND Code of Practice 2015, these guidance documents were used in the development of the Locality Model proposed. Links are provided below in the ‘Supporting Documents’ section.

Equalities implications: Equalities implications: An equality impact assessment (EqIA) was provided within the public consultation and has been updated following 160 items of feedback. The updated EqIA is linked in the ‘Supporting Documents’ section. The Locality Model EqIA will regularly be reviewed if the model is adopted and will be kept under review as implementation progresses. Data Protection implications: The project does not involve the processing of any personal data.