ALNCo task and finish group: report to the Minister for Education and Welsh Language

We would like to take this opportunity to thank all those involved in providing both oral and written evidence to the Task and Finish Group. The information received has been extremely valuable in terms of assessing the current arrangements for pay and non-contact time of ALNCos and the issues affecting the introduction of a consistent national approach. A list of contributors is attached at Annex 1.

This report has been prepared in response to a specific challenge within the transforming education system in Wales. Since the introduction of the Additional Learning Needs Code for Wales 2021 (ALN Code), the role of the Additional Learning Needs Coordinator (ALNCo) has been part of this transformational change. The report refers specifically to the impact from changes introduced by the Additional Learning Needs and Education Tribunal (Wales) Act 2018 (ALNET). 

The move from Special Educational Needs (SEN) to Additional Learning Needs (ALN) has positioned the ALNCo into one of the most demanding and complex roles in educational settings. It involves extensive tasks of leadership, collaboration, a significant amount of specialist knowledge and understanding of needs, embedded in a statutory responsibility. The challenges highlighted in this document are drawn from practitioner evidence. 

ALNCos have seen considerable change to their role, in relation to their workload and additionally in relation to their responsibility. Discussions with Local Authority (LA) representatives highlighted this increased workload for the ALNCo. Many ALNCos have other leadership and/or teaching roles within their school. This reduces the time that they can devote to overseeing the quality of provision and support for pupils with ALN. Many participating ALNCos felt they do not have sufficient time to carry out their role as effectively as they would like.

It is important to note that time to undertake the ALNCo role cannot be prescribed. The ALNCo should be supported, and their time safeguarded, in order for them to fulfil their duties, respond to and meet needs arising in real time situations in a person-centred way.

The term ‘non-contact’ is used interchangeably with ‘designated’, ‘dedicated’ or ‘protected’ time.

The ALNCo Task and Finish Group was established in response to recommendation 6 of the Independent Welsh Pay Review Body. Their fourth report notes that: 

We do not believe that a short-term amendment to the STPC(W)D is feasible or desirable, owing to the initial stages of implementation and the learning that needs to be collated and analysed in its wake. The ALNET (Wales) Act has wide ranging implications across schoolteachers’ pay and conditions, including the determination of a school’s headteacher group.

The recommendation was that a task group be established to undertake a review into the non-contact time and remuneration of the ALNCos, specifically to consider:

1. Whether the current remuneration process for ALNCo is appropriate and consistent.
2. What aspects of the current process or guidance could be improved to reflect the new ALNCo role and remuneration.
3. What changes may be required to the current salary requirements on reimbursement for ALNCos, particularly within the STPC(W)D.

The Task and Finish Group was given clear guidance to take this review forward with the following objectives:

• Undertake an independent review to examine the current non-contact allocation and remuneration of ALNCos, based on evidence and data.
• Provide an opportunity to recommend how ALNCos are remunerated going forward.
• Engage and consult, through existing social partnerships working on any issues identified.
• Provide an opportunity for the Minister for Education and Welsh Language to formally consider a report as part of wider consideration of Teachers’ Pay and Conditions.

Whilst the Group has focused on the objectives set above, it is anticipated that the further considerations following the main recommendations will be fully taken into account.

The Task and Finish Group listened to the voice of practice from a range of practitioners at various levels in the system. Evidence has been drawn from various sources, including representatives on the Task and Finish Group (Annex 1) and from discussions with LA representatives and Headteachers. 

The evidence was collected from June to October 2023 and highlights specific challenges in terms of the changes generated since implementation of the ALN reform began.

The group also considered a range of evidence drawn from published data. The recent Estyn report highlights challenges in the education system since this reform. 

A commissioned report from the National Academy for Educational Leadership (NAEL) identifies that a potential 37% of ALNCos are unlikely to remain in their current post in view of the challenges they now face. 

Whilst differentiated learning in educational settings is the responsibility of all teachers and staff to make learning and the learning environment as accessible and inclusive as possible, it is the role of the ALNCo to ensure that all learners with ALN have their needs met. The Task and Finish Group has clarified specific areas where the role of the ALNCo has been transformed since implementation of the ALN system in 2021. These include:

1. Individual Development Plans (IDPs)

• Preparation
• Review
• Maintenance

2. Managing others

• Information sharing
• Professional learning advice

3. Liaison with others

• Internal
• External

4. Statutory responsibilities

• IDPs
• Links with Senior Management Team
• LA collaboration

5. Other

• Contribute to Governing Body on ALN information
• Collaborate regarding release of staff for IDP completion
• Communicate with parent, families, carers for all issues of ALN
• Address challenges in service requests, for example, Speech Therapy, Mental Healt

This list is not exhaustive and, it should be noted, that different challenges exist depending on the setting and the position of the designated ALNCo. Challenges can be identified in terms of short, medium and long-term issues (Annex 2). As set out in the ALN Code:

 all staff who work with children and young people with ALN have a responsibility for ensuring that their learners’ needs are identified and provided for

However, it is the ALNCo who, at a strategic level, ensures the needs of all learners with ALN within the education setting are met. Having statutory responsibilities, the Code notes that the ALNCo should either form part of the senior leadership team or have a clear line of communication to that team. 

This report throughout refers to specific documents, in particular the Additional Learning Needs Code for Wales 2021, however, for ease of reporting, it will not reference all individual points.

Objective 1: undertake an independent review to examine the current non-contact allocation and remuneration of ALNCos, based on evidence and data

The current non-contact allocation and remuneration of ALNCos, based on evidence and data

Since the introduction of the ALN Code, the non-contact time has increased significantly to encompass the duties for which the ALNCo is now responsible. ‘Current’ relates to the present position in educational settings, however the Task and Finish Group have been able to identify changes made to the role of the ALNCo, many of which incur additional time for non-contact activities. 

The ALNCo is now involved in the strategic co-ordination of ALN resources, including deploying and supporting staff and working with colleagues on the senior leadership team to plan and decide on the appropriate resources to support staff within the setting. 

The Code specifies that it is vital that the ALNCo has sufficient time and resource to undertake their responsibilities effectively, including dedicated time away from teaching. ALNCos are most often a classroom teacher, a deputy headteacher or a headteacher who carry out the role in addition to their usual duties. Evidence shows that this non-contact/dedicated time has significantly increased to the point that many ALNCos are challenged to find time to undertake every task necessary within the working week.

Providing sufficient time and resource for the ALNCo to undertake their responsibilities effectively, as stated clearly in the ALN Code, would include dedicated non-contact time away from teaching. Since the introduction of the ALN Code, the non-contact time has increased significantly to encompass the duties for which the ALNCo is now responsible. ‘Current’ relates to the present position in educational settings, however the Task and Finish Group have been able to identify changes made to the role of the ALNCo, many of which incur additional time for non-contact activities. 

The Explanatory Memorandum to the Draft Additional Learning Needs Co-ordinator (Wales) Regulations 2020 was clear in its note that allowances paid to the ALNCo will need to be discussed as part of the annual teacher review process. The memorandum references the Regulatory Impact Assessment (RIA) for the Additional Learning Needs and Education Tribunal (Wales) Act 2018, which notes the previous SENCo role had been implemented in diverse ways in schools, with a variation in designation, so at that time it was not possible to determine the precise national salary cost. The memorandum was clear in the benefit that: 

The ALNCO Regulations set out tasks associated with the policy intention to create a strategic role that will help foster a whole school/college approach to ALN.

The ALN Code has introduced the IDP^{[Footnote 1]}, which is a legal document describing a pupil’s additional learning need/s, the support they need and the outcomes they would like to achieve. The IDP will replace all the plans which existed previously, including:

• Statement of Special Educational Needs (SEN)
• Individual Education Plans (IEPs) for learners who were supported through Early Years Action/School Action or Early Years Action Plus/School Action Plus
• Learning and Skills Plans (for learners over the age of 16)

In terms of time outside the classroom, the completion of the IDP requires the ALNCo to liaise with others, both internally and outside the educational setting, prepare a complex needs form, create a map and timeline, review initial preparation within one month, and subsequently review annually. Whilst managing existing Statements, the introduction of the IDP has created a shorter-term challenge in additional non-contact time for the ALNCo in the transition timetable of SEN to ALN. 

ALNCos have noted the additional time needed for discussion and re-submission of the IDP in the event of an ALNCo not securing LA support for provision. This appears to create a complex and repetitive process where six reports are required to support the IDP. All reports and information are gathered for collation by the ALNCo. As previously stated, the ALN Code is clear that the ALNCo must have sufficient time and resource to undertake their responsibilities effectively, including dedicated time away from teaching.

Protected time should be a major consideration for senior leaders in order to enable ALNCos to fulfil all the requirements of their role effectively.

It is not possible to quantify ‘sufficient time’ for non-contact activities. Person-centred-practice is central to the ALN system, therefore, a one-size fits all formula cannot be adopted to determine the amount of non-contact time an ALNCo requires to identify, support and champion the needs of each individual learner.

Responsibilities include

• Ensuring on-going communication with senior managers regarding the release of staff to contribute to the completion of the IDP.
• Identifying the training needs of all staff, including support with resources needed to deliver increased differentiation in the classroom, which should be available to all children and young people so they can thrive in their setting. The Code specifies that the ALNCo must advise teachers about differentiated teaching methods appropriate for individual learners.
• Contributing to in-service training for teachers to assist the ALNCo in carrying out the tasks set out in the Code (8.11 to 8.17), and to advise and contribute to the broader support provided within the setting, as well as the professional learning for other staff members.
• Supervising and arranging the training of learning support workers who work with pupils with ALN.
• Facilitating Multi-Disciplinary Team (MDT) meetings on health and education provision and to make service requests for support.
• Attending LA and cluster ALNCo forums where case and process issues are raised. These are a key element of the knowledge sharing process across Wales.
• The ALNCo should act as key point of contact with the Local Authority’s inclusion and support services in addition to external agencies, independent or voluntary organisation, health and social care professionals, educational psychologists and others where needed.

Estyn notes that one of the ambitions of the ALN Act and reform is improved collaboration and information sharing between agencies and identifies that this is currently too variable.

Recommendation 1

The Additional Learning Needs Coordinator should be appointed as part of the Senior Leadership Team of the setting in order to effectively meet their required responsibilities.

Objective 2: provide an opportunity to recommend how ALNCos are remunerated going forward

Recommendations on how ALNCos are remunerated going forward

There are specific areas of the ALNCo role that fall within senior management positions and statutory responsibility. Currently, there is no fixed pay scale or remuneration of the ALNCo role to reflect the seniority of the role, leading to variation across schools and other settings. 

1. The Code specifies that the ALNCo should either form part of the senior leadership team or have a clear line of communication to the senior leadership team.
2. The ALNCo needs to be involved in decisions around budgets and resources to help plan and allocate appropriate provision.
3. The ALNCo must secure relevant services to support a pupil’s Additional Learning Provision (ALP) as required.
4. The ALNCo must monitor the effectiveness of any ALP, monitoring the impact of interventions and progress against planned outcomes for all learners with ALN.

Recommendation 2

The Additional Learning Needs Coordinator should be remunerated in line with appointment to the Senior Management Team of the setting in order to reflect the managerial responsibilities of the role.

Objective 3: engage and consult, through existing social partnerships working on any issues identified

Issues identified through engagement and consultation with existing social partnerships

Many issues raised are specific to the setting, however, the responsibilities remain similar. There are some models of good practice in many Local Authorities. The issue of professional learning should be a key element for LA and governing body consideration in terms of non-contact time, alongside support and cover for this activity.

1. The ALNCo should be a source of expertise on ALN by developing specialist skills and knowledge.
2. ALNCos must advise teachers at the school or Further Education Institution about differentiated teaching methods appropriate for individual pupils or students with ALN.
3. The ALNCo will help increase awareness and knowledge of ALN among staff which will help raise standards among the education workforce in providing support to all learners with ALN.
4. The package of training and development that will be available to all ALNCos will help enable the ALNCo to effectively fulfil the responsibilities set out in the Regulations and supporting guidance, including the training and support of other staff.
5. Estyn reports that schools should ensure that ALNCos have sufficient time and resource to carry out their duties and that the professional learning of school staff has a sufficient focus on high quality teaching for pupils with ALN.

Recommendation 3

The Additional Learning Needs Coordinator should be offered a professional learning package appropriate to their role, experience and needs, and should be allocated non-contact time to undertake this

Objective 4: provide an opportunity for the Minister for Education and Welsh Language to formally consider a report as part of wider consideration of teachers’ pay and conditions

Recommendations for the Minister for Education and Welsh Language to formally consider a report as part of wider consideration of teachers’ pay and conditions.

The ALN transformation programme aimed to create a unified system for supporting learners from 0 to 25 with ALN by transforming the separate systems for special educational needs (SEN) in schools and learning difficulties and/or disabilities (LDD) in further education settings. 

1. Under the previous system, the SENCo did not hold a statutory role. The ALNCo now has a statutory role within the ALN system.
2. Governing bodies of all settings are required to ensure that ALNCos have prescribed qualifications and/or experience. This may allow some flexibility in the design of the role thus may have a negative impact should the governing body not be fully informed.
3. There is a range of structures in place at education setting and local authorities in the use of the additional budgets awarded for ALN transformation.
4. Whilst all staff in all education settings should now have at least a basic knowledge and understanding of the ALN system, it is the ALNCo who at, at a strategic level, ensures the needs of all leaners with ALN are being met.
5. There are significant demands on the time of the ALNCo which were not all foreseen before the transformation.

Recommendation 4

Consideration should be given to identifying a level which reflects the role designated to the ALNCo. This should be at Senior Management level in the setting and should draw remuneration commensurate with the role.

1. The Additional Learning Needs Coordinator should be appointed as part of the Senior Leadership Team of the setting in order to effectively meet their required responsibilities.
2. The Additional Learning Needs Coordinator should be remunerated in line with appointment to the Senior Management Team of the setting in order to reflect the managerial responsibilities of the role.
3. The Additional Learning Needs Coordinator should be offered a Professional Learning package appropriate to their role, experience and needs, and should be allocated non-contact time to undertake this.
4. Consideration should be given to identifying a level which reflects the role designated to the ALNCo. This should be at Senior Management level in the setting and should draw remuneration commensurate with the role.

Whilst the role of the Task and Finish Group was to inform on the non-contact time and remuneration for ALNCos, further challenges were highlighted which may need consideration.

1. There are inconsistencies across local authorities to school relationships and collaborative working. There are some models of good practice which could be shared across Wales.
2. Complete education reform has generated significant budgetary constraints, particularly in relation to Teaching Assistants (TAs). Inconsistencies in ALN budget allocation between LAs impacts schools’ ability to recruit TAs and deploy them to support all learners, including those with ALN.
3. Funding and budget allocations for ALN are not always clear and transparent. Whilst it is the ALNCo who draws up the documents and advises support staff regarding the programmes they should implement for each pupil, because budgets are very tight, cuts made have been made in that some Level 1 TAs are expected to carry out these programmes when they are not trained, contracted or remunerated to do so. This is also the case when TAs are expected to input and feedback onto IDPs. 
4. Understanding of ALN is not always comprehensive across the system. The creation of a ‘pyramid of knowledge’ would meet the needs of all involved, including ALNCos, Headteachers, Support Staff, Teaching Staff, Governors etc, where the ALNCo would be at the top of the pyramid with the greatest depth and understanding of ALN.
5. Many ALNCos are experiencing stress which leads to absence from work due to illness. This creates a major challenge for many schools.
6. It has not been within the capability of this group to garner fine and detailed data in relation to the hours ALNCos currently commit to their role. It would be the advice of this group that further specific research be undertaken across Wales to consider this aspect of the ALNCo role. 
7. Time to undertake the ALNCo role cannot be prescribed. Supporting the ALNCo and safeguarding their time in order for them to fulfil their duties, respond to and meet needs arising in real time situations, in a person-centred way, must be led by the most senior leaders within a setting. 
8. Protected, designated or non-contact time should be a major consideration for senior leaders in order to enable the ALNCo to fulfil all the requirements of their role effectively. 

ALNCo Task and Finish Group membership

Chair

• Dr Sue Davies, Independent Chair

Members

• Urtha Felda, NASUWT
• Laura Doel, NAHT
• Liz McLean, NEU
• Sara Allen, UNISON
• Cei Pryderi, UCAC
• Suzanne Hamer, NAHT Cymru
• Ffion Davies, Ysgol Henry Richard
• Gaynor Davies, Rhondda Cynon Taf County Borough Council

Additional oral or written evidence to the ALNCo Task and Finish Group

• Professor John Gardner - Former Chair of TRAAB (Teacher Recruitment and Retention Advisory Board)

Local authorities

• Ceredigion 
• Flintshire 
• Rhondda Cynon Taf County Borough Council
• Torfaen

Welsh Government

• Additional Learning Needs Branch, Support for Learners Division
• School Workforce Statistics, Education Directorate
• Pedagogy, Leadership and Professional Learning Division

Stakeholders

• National Academy for Educational Leadership

Ongoing

• Coordinating multi-disciplinary team to complete annual review of IDPs.
• Handling after LA refusal to award the level of resource asked for.
• Accessing support services.

Short term

Temporary, during implementation phase.

• Training education staff on identifying ALN.

Medium term

Permanent aspects of the role, augmented during implementation period.

• Managing enquiries from interested parents in response to increased promotion of ALN.
• Access to user-friendly online IDP systems. 

Long term

• Professional ALNCo qualification.

[1] IDPs differ considerably from their closest equivalents (IEPs) under the previous system (SEN). The time taken to prepare, create, maintain, review and revise an IDP has placed increasing demands on ALNCos. The previous IEPs identified only immediate targets, were brief and took limited time to construct. There is now a different, far more meaningful approach with IDPs which aims to develop independence for learners in reaching long-term aspirations. This requires additional planning and increased collaboration with parents or carers and also with wider agencies. The duty for the ALNCO to co-ordinate the making of Additional Learning Provision, however, had already existed in the SEN Code, therefore there was no expectation that this aspect would incur additional costs.