BABCP response to SEND reform: Putting children and young people first
The British Association for Behavioural and Cognitive Psychotherapies (BABCP) is the lead organisation for Cognitive Behavioural Therapy (CBT) in the UK and Ireland. Our mission is to support the development of CBT, and those who deliver it, to improve the mental health of people across the UK and Ireland.
As the leading organisation for CBT in the UK and Ireland with over 26,000 members, we are committed to promoting the highest standards of CBT practice, training, and supervision. We hold all our members to the highest professional standards, which they commit to by adhering to our Standards of Conduct, Performance, and Ethics. Alongside the Association for Rational Emotive Behaviour Therapy (AREBT) we keep the CBT Register UK and Ireland. This is the only officially recognised register of BABCP and AREBT accredited CBT therapists, supervisors and trainers, and evidence-based Parent Trainers. The CBT Register is a Professional Standards Authority (PSA) Accredited register. BABCP also provides individual registration schemes for Psychological Wellbeing Practitioners (PWPs), Children’s Wellbeing Practitioners (CWPs), Mental Health Wellbeing Practitioners (MHWPs), Education Mental Health Practitioners (EMHPs); and Evidence Based Parent Trainers (EBPTs) Accreditation. These registration schemes are approved by NHS England.
Our role in accrediting and registering CBT therapists, PWPs and, of relevance to this inquiry, CWPs and EMHPs provide us with a privileged overview of the people that our members work with, including children and young people in community, healthcare and education settings.
Details of the consultation process can be found here.
Our responses are noted below – click the ‘+‘ to see our response to each question:
1. We want children, young people and their families to be involved in making better, evidence‑based decisions about SEND, both in their local area and across the country. How can we make sure children, young people and their families have a genuine say in these decisions?
BABCP strongly supports an approach shaped alongside those with lived experience of SEND and their families and surrounding settings. Some of the ways in which the Government can ensure engagement with young people, children and their families is by setting up engagement sessions – such as physically setting meetings in school where parents and young people can attend and give feedback instead of relying solely on written feedback. When completing audits for schools, some of our members have noticed that engagement from parents could be challenging due to accessibility issues – some people may not be able to read or write – so it is preferable to go physically into the school, set up a table and listen to the feedback in that manner. Such engagement opportunities encourage co-design and co-production in partnership with stakeholders like the young people and families with SEND lived experience. This is important to be confident in services and policies and for them to feel able to influence the care they receive.
It will also be important to get the views from neutral people – e.g. neither teachers nor parents – such as Education Mental Health Practitioners (EMHPs). Often parents and teachers can have different opinions of a child’s needs – for example, parents may observe a behaviour at home that is not reflected at school or vice versa. If parents and teachers are not on the same page it is harder for children to access the support they need so it is important to consider the view of mental health professionals. Especially in cases where cultural context may shape how the parents and/or teachers understand behaviours, expertise and partnership working with others such as EMHPs can be essential in ensuring adequate support is provided.
2. How can we make sure that high-quality evidence and best practice inform decisions about SEND? Please share examples.
High-quality evidence and best practice can be embedded in SEND decision-making by ensuring that statutory processes consistently draw on recognised clinical guidelines, professional competency frameworks, and routinely updated evidence bases, and that these are applied consistently across education, health and care settings.
NICE guidelines provide robust, evidence-based recommendations for assessment and intervention across a range of conditions commonly associated with SEND needs and it could pose some benefit for particular, SEND-related decision-making explicitly using guidelines such as NG87 (Attention Deficit Hyperactivity Disorder), NG134 (Autism spectrum disorder in under 19s), NG11 (Challenging behaviour and learning disabilities), to support consistent, evidence-based approaches to identification, support planning, and mental health intervention.
BABCP Good Practice Guide for Working with Children, Young People and Families guidance could also inform SEND services as it sets out standards for evidence-based psychological interventions, including competency frameworks, supervision requirements, and adaptation of CBT for children and young people with additional needs particularly stating that interventions for children and young people must be developmentally appropriate, adapted for neurodevelopmental needs, and delivered by practitioners with specific training, supervision, and continuing professional development in CYP practice.
Part One: Putting children and young people first
3. How can we ensure that children are best supported by the Universal offer?
No comment
4. How can we ensure that children in the Targeted layer are best supported?
No comment
5. How can we ensure that children in the Targeted Plus layer are best supported?
No comment
6. How can we ensure that children in the Specialist layer are best supported?
No comment
7. How do you think early years settings, schools, and colleges can best support the mental health and wellbeing of children and young people?
The roll out Mental Health Support Teams (MHSTs) to 100% of schools will be a good step in supporting the mental health and wellbeing of young people. However, MHSTs are limited in their offer – low intensity CBT, mild moderate 6-8 sessions – which may not cover the needs of some children and young people who may require specialist support for eating disorders, bereavement support or access to high-intensity CBT. The only option available is often a CAMHS referral which can have a waiting list of 18 months to access support.
A key way for early years settings, schools and colleges to support the mental health of children and young people is to improve joint working and sharing information between these settings and Local Authorities and the NHS. Often, Local Authorities become aware of some issues that are related to mental health but due to not meeting the threshold for CAMHS it may end up with the local authority even if not the most appropriate. Other times, the matter may be a safeguarding issue for the Local Authority but it ends up in CAMHS due to lack of capacity or knowledge. Ensuring better joined up work between education settings, CAMHs and Local Authorities is crucial.
Currently, the Department of Education has Partnerships for Neurodiversity in Schools (PINS) that focuses on cross-sector partnership working between health, education specialists and parent/carer forums. So far it has helped improve teacher confidence, better collaboration and improved school environments. Consideration should be given to a nationwide implementation of such strategy to ensure health specialists are working closely with teachers etc.
Another key point for the Government to consider when aiming to improve the mental health of children is to consider the current format and requirements of primary school and the purpose and role of education as it stands. Children in the UK start primary school the September after their fourth birthday, when sitting down for one hour may not be the most developmentally appropriate behaviour. There are many studies identifying the importance of physical activity to be embedded in classrooms in early childhood. Other countries, such as Finland, don’t start primary school until children are seven years old.
Regarding the purpose of education, it is important for the Government to consider what is the priority in current education, for pupils to obtain the best possible grades or to gain good mental health and wellbeing, as these may not always be able to coexist; and to ensure the workforce is trained accordingly and to have access to the necessary support.
8. Do you agree that the refreshed ‘areas of development’ will support educators to understand and address barriers to learning and participation? Please explain your answer.
No comment
9. What arrangements would best support effective joint working between early years providers, Best Start Family Hubs, health, local authorities, and parents for children with SEND in the early years?
The Government has increased the provision of mental health in the community and education settings as demonstrated by these initiatives as well as the Whole School approach and the inclusion of MHSTs. However, in order to support effective joint working, it is crucial that these initiatives are appropriately resourced. The 2025 version of the MHST Operating Manual specifies that MHSTs are expected to work with more people but will not receive greater resources. Providing more funding for senior posts within MHSTs would allow for more of a tiered system within MHSTs. The Government should also consider an increase in supervisors which would free up more of the more senior clinicians to add more value.
There may also be opportunities to strengthen links between community-based support provided by Children’s Wellbeing Practitioners (CWPs) and school-based support delivered by Education Mental Health Practitioners (EMHPs). While CWPs may work within MHST or school-linked systems, they continue to practice within the scope of the CWP role and training pathway. CWPs and EMHPs currently operate as distinct roles within different service models, however stronger integration and clearer pathways between community and education-based provision could improve continuity of care and earlier intervention for children and young people with SEND [1].
10. How can the early years foundation stage (EYFS) two-year old progress check and the Healthy Child Programme development review be improved so that children’s needs are identified and supported more quickly? Please share examples.
No comment
11. What should the top three priority areas be for building and sharing evidence within the National Inclusion Standards?
No comment
12. What are the most important issues for national training to cover, to help support children and young people with SEND?
No comment
13. What practical actions can help teachers, educators and leaders manage workload whilst implementing these changes?
Teachers and leaders play a big role in children’s mental health. However, the ownership of implementing these changes should not solely rely on teachers and educators who are already stretched. They would need to be supported by an increase in resource. For teachers to be able to have time to improve mental health provision working with EMHPs as part of MHSTs there would need to be an increase in resource and a shift in priorities – e.g. currently teachers may be expected to focus on teaching the curriculum and marking and not on other areas of development.
14. How should the Special Educational Needs Coordinator (SENCO) role evolve to better meet the needs of children and young people with SEND?
No comment
15. What would provide assurance for families that an Individual Support Plan (ISP) is high quality and contains the essential information?
No comment
16. How can we ensure Individual Support Plans are clear, concise and practical for professionals to use?
No comment
17. How can we best support transition for young people with SEND, so that they are well supported into post-16 provision and further education, training or employment?
The Government should consider investing in EMHPs and CWPs as these roles can be a crucial part of the transition for young people, since they are able to work with ages up to 25-years-old within specialist provisions, and as part of CYPMHS or integrated services with the aim to improve transition into adult services. There are also new parts within the MHST Operating Manual on enhanced transition that EMHPs should be feeding into.
Part Two: New Targeted and Targeted Plus support that is written into law
18. How can we make sure that every area can meet the full range of the needs of children and young people through Inclusion Bases?
No comment
19. How can we make sure that Inclusion Bases help children and young people succeed in mainstream settings?
Increasing the available resources and funding in mainstream settings is crucial to the success of children and young people; as well as education on how best to use resources and funding. This includes ensuring there is an expansion of specialists, including education psychologists, occupational therapists and EMHPs that can assist, as teachers may not always have the necessary skills.
There is also a need for more education and training for current staff on key areas as well as increased supervision for teaching staff to be able to discuss SEND needs with those that have clinical experience.
Lastly, there is a need for better links with step up services with space to discuss referral.
20. Through the Experts at Hand offer, we want to ensure that mainstream settings can get quick specialist support for children and young people. What arrangements are needed between local area partners (education, health, social care) to deliver this Experts at Hand offer effectively?
No comment
Part Three: Specialist support for those with complex needs
21. What needs to be in place so that children and young people with low incidence, highly complex needs can always access the right specialist placement?
There must be sufficient resources so that children and young people with highly complex needs can access the right specialist placement. There is a need to increase the available resources and training in identification of key areas, with increased funding and more time to carry out the assessment with specialist staff and highly tailored approaches
Currently, there is a gap between issues being observed by teachers, mental health professionals or parents and access to specialist services. SEND children have a higher prevalence of mental health problems – the Children’s Commissioner report on experiences of children with SEND states that nearly 40% of children with SEND had an overall wellbeing rating indicating possible depression, twice as many as those without SEND. It is therefore important for children to be able to access the support they need promptly to reduce the risk of exacerbating education or support needs and mental health issues.
Another good mechanism to ensure children and young people access the help they need is the Best Start Family Hubs which will have a dedicated SEND practitioner to allow families of children with SEND to access earlier support in their community. The Government aims to roll these out in every local authority, prioritising neighbourhoods where families face the greatest barriers to support. However, it may not be until 2028 where these is rolled out across all local authorities.
22. How can Specialist Provision Packages be designed to effectively support the main types of need we currently recognise?
No comment
23. We propose that EHCPs will guarantee educational provision set out in a Specialist Provision Package, with day-to-day provision captured in Individual Support Plans. What is needed to make these proposals work effectively?
The main consideration for these proposals to work is to have sufficient resources available across all regions so that lengthy travel and impact on school budgets are prevented when trying to meet a need with funds that may not be available.
It will also be important to involved EMHPs in the development of the Specialist Provision Package and the Individual Support Plans.
24. We propose creating a more direct route to Specialist Provision Packages and EHCP assessments for children under 5 with complex needs. How can we make sure this works in practice?
For the approach to work in practice, it would be important to be a holistic, multi-agency, with collaborative working, and there would need to be the right staff in place, the right trainings and a budget to cover this. As per our answers above, there is a need for sufficient resources to be able to identify the needs and carry out the necessary assessments. While these assessments can be required at any time by parents, early years providers or health professionals it is important that they take place without delay.
25. What would you expect to be considered as part of the needs assessment, for example evidence and expert or professional input?
Evidence and expert or professional input must be considered as part of the needs assessment as well as evidence from key workers and experts from multidisciplinary teams with expert knowledge on key aeras such as educational psychologists, CBT therapists, etc. It is important for the needs assessment to observe the child in different settings and circumstances, and gain reports from parents and school staff with evidence.
It is worth mentioning in this context that the current shortage of educational psychologists within local authorities can be an area for the Government to consider in order to improve the needs assessment.
26. What factors should LAs take into account in proposing to parents and young people a list of potential settings to name on a plan?
Local Authorities should consider the impact of extensive travel on young people and their family life, the impact that introducing new people into the care circle would have on young people, and availability of specialist resources within settings.
27. What information and support do parents need to make a decision about which setting will be best for their child?
When making a decision about which setting is best for the child some of the information that is needed includes the needs identified, evidence-based ways of meeting these needs, formulation of areas of difficulties, mapping out of impact of pathways and support identified. There should be a pros and cons analysis together with family and a neutral party to support this exercise so that the risk of need versus availability of resource is minimised.
28. What do you think is the right maximum length of time for a temporary placement in Alternative Provision (AP) schools? Please explain your rationale.
No comment
29. We have set out our plans to regulate Independent Special Schools (ISS) sector. Do you agree that these proposed changes will lead to suitable placements being available at a fair cost? Please explain why.
No comment
Part Four: Reforming the system to reward inclusion
30. How should settings be held accountable for how they spend their Inclusive Mainstream funding?
There must be a level of accountability as well as adequate education into key areas. Advisors and neutral parties should be able to analyse options and best outcomes from choices made to be able to balance budgeting costs with best practice options.
31. Do you agree that more SEND funding should sit directly within mainstream budgets? Please explain why.
No comment
32. In relation to pooled funding, we propose that every school becomes part of a local SEND group. Do you agree that this proposal aligns with our aim for all schools to be part of high-quality, community-based trusts?
Yes, we agree that the pooling of local resources would prevent long journeys to access resources and would prevent duplication of resources within a small area, which may not be the most efficient, allowing for specialist provision to be enhanced within areas rather than within individual schools.
33. How should disagreements about membership, provision, or funding in groups of schools for SEND be resolved?
No comment
34. How can we ensure the most effective use of these local partnership groups?
No comment
35. Which stakeholders are important for the success of local partnership groups, and why?
Important stakeholders for the success of local partnership groups include children and young people, parents, Local Authorities, NHS staff (including EMHPs and CWPs), schools, teaching staff and SEND leads, and engagement groups. Children and young people are crucial as they are the people at the receiving end and they must have a say. Their parents and carers are similarly involved in their care, and so are NHS staff. Furthermore, as explored earlier in the paper, often parents and educators or teachers have different observations based on the setting where they interact with children and young people so it is crucial to involve them all.
36. How can we build stronger collaboration and a culture of improvement through local SEND strategic plans?
No comment
37. What information, advice and guidance can best support children, young people and their families to ensure greater fairness across the system?
No comment
38. Do you agree that a SEND specialist (e.g. a SENCO) should sit on the school complaint panel, when the complaint relates to SEND support and provision? Please explain why.
No comment
39. This consultation outlines a series of measures intended to reform the SEND system. Some of these measures have already been finalised, and this is clearly indicated within the document. With this in mind, is there anything further you would like to contribute to help inform the remaining proposals that are still under consideration?
No comment
