Five things the government can do to ensure SEND reforms promote educational equity
The government has recently consulted on its plans for reform of the SEND system. This blog summarises the FEA’s response to those proposals.
The government’s ambition to reform the SEND system is welcome - especially its emphasis on early intervention, whole-school inclusion and better partnership with families. The system has become deeply strained, and the government rightly acknowledges that reform will require time and patience. There is a lot to support in the proposed changes and it’s our view that they will move the system closer to the model of whole-school inclusion we have been advocating for in our recent Report Cards and Vision Statement, jointly published with the Disabled Children’s Partnership.
There are though areas in which the proposals could go further to ensure that they actively promote educational equity and are given the best chance to work successfully in practice. We summarise the five things government can do now to get this right.
Make greater recognition of the relationship between SEND and poverty
Children with SEND from lower-income households already face a ‘double disadvantage’ - they wait longer for diagnosis and support, and experience worse outcomes than their peers. This has been evidenced by the Sutton Trust, among others, who found that pupils who are eligible for Free School Meals are more likely to have SEND, but less likely to get the support they need.
Yet, despite the strong evidence supporting the existence of double disadvantage, the reforms offer little recognition of this form of intersecting disadvantage. For instance, the term free school meals features just once in the full consultation document.
To correct for this, SEND reforms should ensure that consideration of intersectional disadvantage is a design-principle of the new system. This should include but not be limited to socio-economic disadvantage - for instance the different experiences of children from minority ethnic backgrounds, or gender differences in SEND prevalence and experience, are also important considerations. And to make this happen, all strands of reform should be subject to an ‘equity impact’ test to ensure that socio-economic disadvantage, alongside other forms of intersectional disadvantage, have been considered. This is not about pitting one group against another, but ensuring that all children have equal access to entitlements and quality support. The FEA would welcome the opportunity to work with the DfE to design and roll out such an approach.
Safeguard forms of SEND disproportionately seen in lower-income groups to ensure they are not deprioritised under the reforms
It’s welcome that the government wants to shift towards supporting children with SEND through a needs-led approach, as opposed to diagnosis-led one. The proposals for Universal, Targeted and Specialist levels could be transformative, putting in place timely, flexible support which prevents escalation.
However, the new proposals create a risk that needs which are over‑represented among lower‑income pupils – notably those related to Social, Emotional, Mental Health (SEMH), behavioural difficulties, moderate learning difficulties (MLD), and speech and language - could be under‑served by the adoption of ‘areas of development’ which remove some of these needs as distinct categories. Research by the Joseph Rowntree Trust (Menzies, 2016) found that such needs are over-represented among children from lower income households.
We recommend that at minimum, during transition, National Inclusion Standards should set clear, minimum expected provision for areas like social emotional and mental health, and speech and language, with reporting requirements that allow government to identify and address gaps.
Make the system navigable for families and young people by creating guaranteed opportunities for their voice to be heard
The government’s reforms will shift some responsibilities towards schools, giving them new roles in assessing need, allocating support and forming a partnership with parents. This will inevitably lead to new bureaucratic processes, and these can unintentionally disadvantage the families with fewer resources to advocate or navigate the system.
It’s welcome that the government wants parents, carers and young people to have a meaningful voice in the support they received. This will be an essential strand of successful adoption, but needs active support to ensure this happens in practice. The government should require every Individual Support Plan to include a dedicated pupil voice section, with accessible options for contribution. For parents, it should also provide plain-language explanations of entitlements - and make sure families can raise concerns without fear of consequences. These mechanisms should be co-created with families and young people with lived experience during the implementation period.
Ensure that the essential work needed in the early years is not hamstrung by government requirements
Much of the SEND reform is focused on schools, where there will continue to be significant work in managing SEND, but it is welcome that there is a recognition of the importance of the early years and links to the government’s Family Hubs programme as a means of reducing some forms of SEND prevalence. This will be crucial for the ability of professionals to put in place mechanisms for earlier identification and support before school starts.
However, Family Hubs need to be designed with local context in mind, and not hamstrung by onerous central government prescription. Research about the impact of Sure Start by the IFS (2024) found that the earlier Sure Start centres - which had more autonomy, were designed with greater community input and had higher funding - were much more effective in supporting early childhood development and future educational outcomes than those opened with a more uniform model. To enable Family Hubs to follow a similar path, there should be a more permissive approach allowed by Family Hub guidance, in particular on the set of interventions that can be commissioned with Family Hub funding. Longer-term funding commitments will also be essential to enable Family Hubs to take the strategic, sustained approach these reforms require.
Prevent “inclusion” from becoming internal exclusion: monitor Inclusion Bases and behaviour practice
Inclusion Bases could strengthen mainstream capacity and reduce escalation to specialist settings. The forthcoming guidance on Inclusion Bases from the DfE is welcome, and we hope it will take learning from the leading forms of Alternative Provision such as that based on The Difference’s work in this area. But without proper safeguards, there’s a real risk that Inclusion Bases could replicate historic patterns whereby disadvantaged pupils are overrepresented in exclusion units or Alternative Provision pathways - and it becomes a form of internal exclusion.
To mitigate this, the government should introduce routine, transparent monitoring of Inclusion Base use: who accesses them, for how long, and what outcomes follow - broken down by Pupil Premium eligibility and protected characteristics. SEND expertise should also be embedded in attendance and behaviour support infrastructure, and inspector training should consistently reflect the links between behaviour and SEND.
Equity needs capacity
Even the best-designed reforms can fail if schools and trusts lack the conditions to implement them - leadership capacity, protected time, infrastructure, and sustained support. If the government is serious about equity, resourcing implementation isn’t optional; it’s the foundation. SEND reform is a once-in-a-generation opportunity to build a truly inclusive education system. But it will only succeed if equity is built in from the start - and measured every step of the way.
Read our full response below – this was submitted on behalf of the Fair Education Alliance in May 2026.
