1. The University and College Union (UCU Wales) represents almost 7,000 academics, lecturers, trainers, instructors, researchers, managers, administrators, computer staff, librarians, and postgraduates in universities, colleges, adult education and training organisations across Wales. 

2. UCU Wales is a politically autonomous but integral part of UCU, the largest post-school union in the world. It was formed on the 1st June 2006 by the amalgamation of two strong partners – the Association of University Teachers (AUT) and the National Association of Teachers in Further and Higher Education (NATFHE) – who shared a long history of defending and advancing educators’ employment and professional interests.

3. We welcome the opportunity to respond to the consultation on the Additional Learning Needs and Education Tribunal (Wales) Bill.

4. UCU Wales agree with the proposal to unify the existing systems for SEN and LDD, if it will improve the transition from school to post 16, for both students and staff. However, we have some concerns around the roles and responsibilities of teaching staff within the FEI’s, and their access to appropriate and meaningful professional development and support, which will enable them to implement the proposals within the ALNET Bill.

5. We welcome the commitment to provide the training of all teaching staff and ALNCO’s across schools clusters and specialist support services and note that the core skills will be linked to the Professional Learning Offer and Pioneer Programmes; however we seek clarification as to how teaching staff in FEI’s will access opportunities to develop ALN teaching skills and knowledge, as they as not part of the schools clusters or Pioneer Programmes.  The current development of the Professional Learning Offer is focussed on teachers in school settings.

6. Under the proposals of the ALNET Bill, lecturing staff in FEI’s will be required to take an active role in the identification and provision for ALN in the post 16 sector, particularly with the emphasis on the duty to choose mainstream provision wherever possible, to reduce the need for specialist services. It is envisaged that the day to day process of supporting students with ALN will be the responsibility of the class teacher. Lecturing staff in FEI’s cannot be expected to provide this crucial but additional role, without robust training and support.

7. One of the risks identified for option two is that FEI’s will have more students with statutory entitlement to provision.  Whilst we agree that this is right and it is better for young people and their families; it must be acknowledged that in order to deliver this professionally and in a way that appropriately benefits those needing support, it will create extra work for existing staff. This may be impacted further, as there is the potential to reduce out of county placements in order to make associated savings.

8. UCU Wales support the idea that the entire workforce should have the appropriate tools to develop ALN skills and knowledge to help identify those who may benefit from ALN support.  We note the intention to raise awareness of Autistic Spectrum Disorders, in the FEI’s in the coming year.  However we have concerns that simply ‘raising awareness’ will not equip staff with the necessary skills and knowledge required to support learners with the multitude of other additional Learning needs.  Although as identified in Holtam 20101, education staff are generally confident in their skills and knowledge in relation to SEN, levels of confidence in assessing or identifying learning needs amongst classroom teachers was only 21%; it should be noted that this study did not include staff in the FE sector.

1 http://gov.wales/docs/dcells/publications/150330-sen-en.pdf

9. Holtam et.al 2010 also reported that classroom teachers in school, were the least likely members of staff to receive SEN training, which suggests that this may be the reason that classroom staff are less confident in identifying ALN.  They also stated that staff confidence was an important factor when it came to including pupils with SEN; further that confidence was linked to training and experience.  We note the suggestion that ALN should form part of initial teacher training, as this will be crucial in preparing the future teaching workforce and would welcome the inclusion of this in FE teacher training.

10. Therefore we welcome the proposal to develop the skills of all staff,   but seek assurance that sufficient training is made available to enable them to perform the duties place upon them, in a confident and professional manner.  Further, we seek clarification as to how and when staff would be able to access such training and materials.  We are clear that sufficient time and support must be provided within contracted hours of work.

11. Currently FEI’s have LDD coordinators rather the SENCOs, as noted this may be a member of the teaching staff or a member of student support services.  We agree that it is appropriate for ALNCO’s to have teaching experience and therefore for the FE sector, ALNCO’s should have FE experience of working directly with young people in supporting their learning.  However, bearing in mind the diversity of skills, qualifications and experience held by staff in the FE sector, it may not be appropriate to expect prospective ALNCO’s in this sector to fall easily into traditional academic pigeon holes.  Thus when it comes to expecting all ALNCOs to reach a masters level qualification, the FE sector may find that it is starting from a different point.

12. UCU Wales have some concerns over the expected role and responsibilities of the ALNCO in FEI’s.  We acknowledge that it is not the intention that the ALNCO should be responsible for the support of individual students, as this would fall to learning support staff and lecturers; however the ALNCO would be responsible for training and supporting other members of staff, as well as providing information and support to parents and other agencies/institutions including DECLOs.  It is also proposed that the ALNCO will need to be in a senior role, as they will be responsible for direct input and influence to the FEI’s policies to ensure that they comply with the Act when it comes into force. In addition the ALNCO will be responsible for the advising, training and deploying of other staff; involved in strategic coordination of ALN resources and actively involved in budgets.  It is expected that the role should be seen “as significant as roles such as Headteachers, Principals, Deputy Headteachers etc. [and] should therefore form part of the senior leadership team.”

13. Taking into consideration all of the above, plus the list of roles and responsibilities on page 23 of the draft Code and bearing in mind the size and geographic spread of many of the FEI’s in Wales and that the costings are based on only 13 FE ALNCOs, we do not see that the role of the ALNCO in FE would be compatible with other teaching duties or non-teaching responsibilities.  “Dedicated time away from teaching” would not be appropriate or sufficient for the scale of the role within the FEI’s; we believe the ALNCO to be a full time role in its own right.  Further, an assumption is made in the explanatory memorandum that a current LDD co-ordinator will be on a comparable pay scale to SENCOs (circa £39,500 per year plus allowances in some cases.) and the salary for the ALNCO will be similar.  Although this is currently in excess of the lecturer’s pay scale and the support staff scale, it sits at the bottom of the management spine.  If the ALNCO is to be seen as a significant role as described in para 9 above, this disparity needs to be addressed. 

14. It is stated in the Explanatory memorandum that Welsh Government see no link between ALNCO role qualifications and remuneration. It is also assumed that that no extra cost will be incurred as existing SENCOs /LDD coordinators will become ALNCOs, however the ALNCO role carries with it, substantially more responsibility and requires a highly qualified member of staff with expertise in dealing with a broad spectrum of ALN.

15. Senior managers within the FE sector will not be on teaching contracts; a different system of leadership and management operates within the FE sector, one that is not directly comparable to that in schools. Bearing this in mind, careful consideration of the roles and responsibilities of the ALNCO within the FE sector, need to be taken into account, when moving forward with the job description for the ALNCO FE.  Is this an enhanced teaching role or is a senior management role?

16. UCU Wales agree with the level of responsibility placed on the role of the ALNCO, i.e. as a senior member of staff, however this is not compatible with a teaching workload. We agree that ALNCOs should have experience teaching ALN, however senior managers in FEIs are less commonly from teaching backgrounds, as they are in school.   Therefore we seek clarity on the expectations, knowledge, experience and qualifications needed to fulfil the ALNCO role.

17. We fully support the intention to improve the continuity of support for young people with ALN, as they transition from school to FE and would welcome the opportunity to work with Welsh Government develop a system, which enables teaching staff in the sector, to deliver the best support that they can to all students, in an effective and professional manner.