It is hoped that, in the coming days, Will Quince, minister for children and families, will announce an extension to the consultation deadline for responses to the much-anticipated and thrice-delayed SEND Green Paper.

This is an effort to right the wrong of the Department for Education’s monumental own goal in not providing accessible versions of its Green Paper - which revealed a lack of proper thought about who the Green Paper is really for and the importance of a fully inclusive system.

It’s an issue that is inherent within the paper itself too.

More qualifications needed

Because, while the paper proposes a new National Professional Qualification for Sendcos and the promise of “a transformed professional development pathway for teachers”, there is no explicit mention of introducing bespoke qualifications for educators to work with pupils with severe learning difficulties (SLD) or profound and multiple learning difficulties (PMLD).

This seems like a major oversight when we consider that there already exist mandatory educational qualifications for teachers and professional advisers of specific disabilities: Qualified Teacher of the Visually Impaired; Qualified Teacher of the Deaf (QToD); National Award for Special Educational Needs Coordination, for example.

Within three years of working in specialist settings, an individual already accredited with qualified teacher status must undertake these additional master’s-level studies.

Typically, they are two-year courses requiring an in-depth study of legislation, statutory guidance and evidence-based research, accompanied by practical application tasks and case studies.

All of this recognises that teachers of students with specific special educational needs or disabilities must become experts, knowledgeable and skilled in medical and neurological research, as well as legislation and guidance.

A growing area of need

Yet, there is no such requirement for teachers of children with PMLD - which, given the number of pupils represented, seems very surprising.

For example, according to the most recent census figures for education, health and care plans (EHCPs), hearing impairment (HI) accounts for 6,148 and visual impairment (VI) for 3,601 plans.

PMLD is cited for 9,976 - more than the total for VI and HI combined. Yet there is no need for additional study for teachers in this area of special education beyond initial teacher training.

Those working in the sphere of specialist provision recognise that these figures are complex: comorbidities are frequent and primary need may depend on the interpretation of diagnoses, disability and required support.

A further 31,300 children and young people are recorded as having SLD, which is likely to be identified at birth or early childhood and for which defining presentations and educational needs may often be similar to PMLD.

Furthermore, children recorded in each of these categories are likely to require support in accessing and interpreting all areas of a highly personalised curriculum and with communicating their needs and desires, as well as understanding others in the world around them.

Language barriers that must be overcome

Children with sensory impairment, PMLD and SLD have barriers to language acquisition and expression, including both verbal and non-verbal communication.

Again, though, this reveals an unevenness in the approach that needs rectifying.

Teachers working with children with VI and QToD are required to attain a level of fluency in the additional languages of braille or British Sign Language. The complexity of each is bewildering but it is key to ensure communication can take place to aid their learning. 

Students with PMLD or SLD have additional languages too that teachers must learn to use - including, but not limited to: interpreting body language, gestures and facial expressions; low and no-tech communication boards; high-tech eye-gaze devices; communicative iPads; switches and accompanying software; delivering social and sensory stories; Signalong and Makaton.

Without suitably trained adults, these students may never reach their potential. Not reaching potential at school can result in the most devastating of consequences: never being able to be understood in life.

Yet, still, there is no official training or qualification when working with these pupils in this area. But if communication is severely limited, it is of even greater importance that its development is effectively supported.

This matters hugely - not least when we consider that a key proposal of the SEND Green Paper is to establish new local SEND partnerships to bring together health, education and social care professionals.

Giving everyone a voice

Nowhere is the necessity for this more evident than in the support required for children with PMLD or SLD.

A student’s annual review is likely to require reports or, ideally, attendance from multiple professionals: occupational therapists; speech and language therapists; educational psychologists; physiotherapists; nursing teams; social workers; mobility and wheelchair specialists; consultant teams; dieticians; teachers; and support staff.

No wonder parents have found the system adversarial, as is explicitly and repeatedly acknowledged.

The SEND Code of Practice 2015 has one mention of PMLD in its 287 pages. An insistence on aspirational outcomes, independence and success in adult life is inadequate or irrelevant when applied to learners with complex needs.

With consultation for the SEND Green Paper open until 1 July, or potentially longer, there is now a unique opportunity to insist on improvements for society’s most vulnerable and potentially excluded students.

To facilitate this will require respondents to request the introduction of a mandatory qualification for educators working with students with PMLD or SLD.

In this way, legislation may give a voice to those who otherwise have little opportunity to be heard and understood, in any language.

Deborah Hollingsworth is a Sendco and Resourced Provision Manager in East London. She tweets @debs_cares