SEND Reforms Have Parents Asking: What Are ‘Complex Needs’?


Access to education, health and care plans (EHCPs) – which hundreds of thousands of children currently benefit from – is set to change, as part of the government’s overhaul of the special educational needs and disabilities (SEND) system.

An EHCP is a legally-binding document outlining the needs of a child and what support is required to meet those needs.

Currently, almost 640,000 children with SEND in England have one in place. But as part of the new plans, these documents will only be reserved for children with the most “complex” needs.

Understandably, parents who have fought hard to earn their children much-needed extra support through an EHCP are concerned by what this now means.

What happens to EHCPs now?

As part of the reforms, the government wants to put children with SEND into two main categories by 2035: Targeted, which is for those who are in mainstream schools and involves support from education, health and care professionals, where needed; or Specialist, which is for children with the most complex needs who are either attending a mainstream or specialist setting.

More than a million children with SEND will be legally entitled to a more “flexible” school-based support plan setting out a child’s day-to-day needs, this time called Individual Support Plans (ISPs).

Only those who come under the Specialist umbrella – meaning those with complex needs – will be entitled to ISPs and EHCPs, the latter of which the BBC noted is “the framework giving them legal entitlement to support”.

The government said the transition from EHCPs to ISPs for children without complex needs will begin from 2030. ISPs will be in place for children who are transitioning from an EHCP before they move to the new system, so there should be no break in support, it added.

The news has left parents with one key unanswered question, however. What constitutes ‘complex needs’?

In response to an Instagram post on the reform white paper, shared by @AutismDadcast, one parent said: “Big question – no definition or indication as to what complex needs looks like. Kept referring to it but who qualifies for complex needs and who’s deciding what that looks like?”

Another added: “How do they define children with the most complex needs?”

What does the government mean by complex needs?

We don’t yet have a full definition. HuffPost UK understands more detail on this will be set out following the government’s consultation and work with experts over the coming year.

Broadly, though, it’s likely to refer to children who need more support than can be accessed through their local mainstream school and through ‘experts at hand’ (a team of local professionals like speech and language therapists, educational psychologists, etc, which schools will be able to draw from as part of the new reforms).

The NHS suggests that if a child has been “diagnosed with an illness, disability or sensory impairment and needs a lot of additional support on a daily basis”, they’re described as having complex needs.

“A child might have complex needs from birth, or after an illness or injury,” the service adds.

There has been some concern that children with conditions that present on a spectrum, such as autism and ADHD, might lose out on specialist support.

The i Paper highlighted that ‘Specialist Provision Packages (SPP)’ will be the new gateway to an EHCP, however also noted “children and young people with underlying needs linked to a condition which presents on a spectrum (such as autism) may not necessarily be supported by the same Specialist Provision Package”.

When pressed on this, education secretary Bridget Phillipson said the system will be “needs-dependent, not diagnosis-dependent”.

She told the i Paper: “Some autistic children do need a [Specialist Provision Package]. Other children with autism – with the right level of support within mainstream [schools] – can thrive, can achieve.”

For now, parents are once again left to wait for more clarity.