CandLE Position Statement on Proposed SEND reforms 16^th of October 2025

Case studies of students CandLE support

All these students were originally deemed to be unable to access conventional learning, and all rely on Augmentative and Alternative Communication (AAC) as an Assistive Technology (AT) solution to provide an adaptive learning environment to optimise their learning outcomes. These students have all been labelled as having severe (SLD) or Profound and Multiple Learning Disability (PMLD) and all have physical disabilities. According to controversial research[i] these students are often deemed as ‘unteachable’ and as such National Curriculum learning is widely disapplied for this cohort of student:

Student 1

This student has cerebral palsy and was deemed to have severe learning difficulties by her mainstream primary school despite showing clear understanding of language and passing IQ tests with average scores. It took CandLE teachers a year to convince the local mainstream secondary school that she had age-appropriate understanding. She went on to pass 4 GCSEs followed by A Levels in Psychology and Philosophy and is currently studying philosophy at a Cambridge university.

Student 2

This student is 11 years old and has cerebral palsy. Her dad believed that she could achieve more than her special school were teaching her. The curriculum available within her special school limited learning and curriculum at a Key Stage 1 ceiling level. When she was 9 years old, her dad persuaded the local authority to engage CandLE within the special school to teach her on a 1:1 basis for 9 hours a week and she was (after only a few months) exceeding the curriculum learning ceiling  that the school was offering . She is now working on Key Stage 2 National curriculum content and working on our ASDAN accredited courses which aim to plug the gaps for students who have not previously been able to access the National Curriculum. With the help of a specially adapted keyboard, called the CandLE Sound and Say Keyboard, which has sophisticated word prediction, she is now writing her answers to questions rather than relying on being given choices or having to rely on a limited vocabulary as was previously the case. She and her dad are now visiting local schools with a view to transferring from special school to a mainstream secondary school. She has an ambition to achieve GCSEs. CandLE is hoping to pilot and then provide this model of curriculum access to special schools throughout the UK.

Student 3

This student is in Year 10 in a mainstream secondary school but has significant gaps in his knowledge as he was in a special school, without access to the national curriculum until he was 11 years old. He has cerebral palsy and had been educated in a school which mainly catered for students who have Severe Learning Difficulties (SLD) or Profound and Multiple Learning Difficulties (PMLD). In this setting he was not offered access to literacy and maths learning.  CandLE assessed him in 2018 and found he had potential for learning literacy, but it took parents another 3 years to obtain a mainstream placement for him. With the expert specialised support from CandLE the student is now accessing age-appropriate national curriculum with his peers in a mainstream school and using CandLE’s Sound and Say Keyboard is now writing sophisticated sentences.

Student 4

This student is 16 years old, has cerebral palsy, and was failed by both mainstream Primary schools who could not meet his needs and by schools in the Special Education sector. He was never taught the alphabet nor was he exposed to reading. He was deemed to have little or no understanding of language and was labelled as having severe learning disabilities. Initial CandLE assessment showed potential and ability in Literacy. His mother eventually persuaded the Local Authority that he should receive a literacy program from CandLE, which commenced in 2020 during Lockdown. The local NHS AAC services recognised his potential, and he was given his own AAC device at the age of 11, having had no previous access to a communication aid. With CandLE’s support by 2022 he had learnt to read and spell. The named specialist educational setting maintained that they could offer access to GCSEs for this student and felt that they could meet his academic needs This was very quickly retracted by the specialist setting who were, in practice only able to offer Functional Skill English and Maths. His mother removed him from school, and the Local Authority are currently providing Education Otherwise Than at School (EOTAS), with CandLE support, whilst an appropriate school placement is sought.  In 2025 this student is working at a Year 5/6 National Curriculum level and is making progress towards Key Stage 3 outcomes. He loves history and hopes to achieve GCSEs and go on to further and/or higher education.

Student 5

This student has Cerebral Palsy and is 20 years old. He is currently continuing his education in a specialist setting for post 16 students having attended special schools throughout his education. When he was assessed by CandLE in early 2025 his spelling skills were restricted to single letter knowledge only and he could not read or spell words. Within less than a year he has achieved 3 letter (CVC) word spelling and is making good progress with vowel blends and consonant clusters. He is also using the CandLE Sound and Say keyboard to good effect and has progressed from single letters and reliance on the limitations of an AAC vocabulary to being able to produce his own sentences.

Student 6

This student has Cerebral Palsy and is labelled as having Severe Learning Difficulties, she is non-verbal. She entered a mainstream secondary school in Year 7. Despite initial struggles with emotional regulation and a perception that her challenging behaviours prevented academic progress, CandLE’s tailored intervention program revealed her remarkable potential for learning and communication. This case highlights the importance of believing in a student’s capacity to learn, looking beyond challenges and appearances, and providing targeted support to unlock their full potential. Now, she can use her communication device to not only select individual words but also to type full sentences. She can talk about her feelings, make requests, and offer comments. She exceeded every expectation.

Student 7

This student’s journey is evidence of the significant learning potential of students who have a label of Profound and Multiple Learning Disabilities (PMLD). He has Down’s Syndrome and is faced with a range of challenges, including limited speech, global developmental delay, hearing and vision impairments, and delayed motor skills. He attends and mainstream school. Initially, he struggled to communicate, and school staff had difficulty assessing his literacy skills. He had a communication book which he rarely used and was turned down an NHS assessment for a communication device. CandLE, was brought in when he was in Year 9. He adapted well to our resources and books, and his communication skills began to grow alongside his learning. By Year 11, his progress was remarkable: he could combine two to three words to form sentences and could memorize the characters and plots of stories. We were able to accurately assess his literacy and plan his learning direction, with our ASDAN-accredited courses proving to be an excellent fit; providing him with access to national curriculum at a pace that works for him. He has just received his first certificate of achievement.

Student 8

This student has been labelled as having PMLD. He is currently on a Local Authority EOTAS package after he was not showing any progress in his specialist setting. With appropriate intervention he is now reading, spelling and carrying out maths operations at a Year 1 National Curriculum level. The family continue to search for a school placement that will enable him to take his learning forward.

The SEND (Special Educational Needs and Disabilities) Reforms

As the case studies above demonstrate, often students with Physical Disabilities (especially those with Cerebral Palsy) and/or labels of PMLD can often make excellent academic progress when given access to appropriate AAC and or Assistive Technology alongside adaptive teaching instruction and pedagogy.

Whilst the current push in the government SEND reforms to invest in early intervention is welcomed, it must be recognised that the needs of students who rely on AAC are often identified at a much later stage in their education than most students who have SEND.

According to Hoyfield, Light and Preece (2025)[1]

“Individuals who rely on AAC face multiple external challenges that can restrict opportunities to learn and use language, including limited access to competent partners, restricted opportunities for interaction, and low expectations.”

In some cases, potential for learning is missed altogether with students being inappropriately labelled as having severe or profound learning difficulties and then being consigned to learning environments where no conventional learning takes place and their access to the national curriculum is removed. The Reading Framework 2023 and the Writing Framework 2025 both state that it may not be appropriate to begin teaching certain students to learn to read or write.

The Reading Framework states:

“A very few pupils with profound and multiple learning difficulties (PMLD) might not be able to access direct literacy instruction. For pupils who are working at Standard 1 in the pre-key stage 1 standards, it may not be appropriate to begin teaching them to read.”[2]

The Writing Framework states:

““A very few pupils with profound and multiple learning difficulties (PMLD) may not be able to access direct literacy instruction in the same way as their peers.”[3]

Nowhere in either document is there any guidance on how such students should be identified nor any caveat to ensure that there is a rigorous identification procedure to avoid misdiagnosis with the resultant, catastrophic consequences that some students who could be learning in mainstream classes are denied access to education and in practical access to literacy

Whilst the current SEND review would not have the remit to consider how appropriate identification of learning need is arrived at; any continuance of an education system that provides restricted access to mainstream curricula and learning runs the risk of discriminating against students who have the potential to access mainstream learning.

Students in all the SEND categories may have similar sensory, physical and communication difficulties but if a student who could learn but does not have access to the means to do so through adaptive teaching and appropriate Assistive Technology, is wrongly labelled, then the education system has failed them. Misdiagnosis is particularly prevalent in the population of students who rely on AAC. Despite 25% of students who have cerebral palsy requiring AAC to communicate only 12-15% have AAC to support them.[4] AAC need is highest in the cohort of students who have the most severe motor impairments.[5] Despite this, such students, in the UK, cannot gain access to AAC unless they can demonstrate prior understanding of the purpose of AAC and a clear ability to communicate.[6] This renders many students who could potentially go on to complete qualifications and have normal lives without the means to do so.

Dyskinetic Cerebral Palsy is not normally associated with global developmental delay indicating that the labels PMLD (Profound and Multiple Learning Difficulties) and SLD (Severe Learning Difficulties) would not apply to this cohort. Research suggests that this group tend to have normal verbal memory.[7] Further it has been found that ‘Children with CP attending mainstream school had significantly better progress in mathematics and reading than those attending a special school, despite identical verbal IQ’.[8] Individuals with dyskinetic CP have been found to have better auditory comprehension, visuospatial abilities and working verbal memory that students with a different type of CP.[9]

It is only too easy to misdiagnose a student who has average intelligence as one who has PMLD, with a supposed IQ level of under 20, as demonstrated by the following diagram:

The lack of expertise in AAC within the teaching profession and within psychological and speech and language therapy services mitigates against the government relying on these professionals being equipped to provide appropriate assessment or teaching to this group. Assessment of students who rely on, or should have access to, AAC, especially the use of tests that have been standardized on a nondisabled population, increases the risk that students will be misdiagnosed and offered inappropriate educational placements designed for those with severe or profound learning difficulties.[10] Those who do have severe or profound learning difficulties, as our case studies show, may have the potential to achieve more than the very basic and/or sensory learning opportunities which may be all that is available to them in specialist settings.

According to the written evidence gathered by the Education Committee SEND inquiry (2022):

“Special schools, except for a few where AAC is given a focus, lack expertise in the learning needs of students who rely on AAC and often undervalue their communicative competence.”[11]

There is evidence that most students who rely on AAC can develop literacy skills with appropriate instruction.[12] There has, however, been little or no research into the use of AAC as an AT solution. This often leaves students who rely on AAC, reliant on AT solutions that were created for a different cohort of students which do not necessarily provide optimum access to learning.

Delayed access to AAC and AT increases the learning gap experienced by this group of students for whom there is no statutory provision to enable the gap to be reduced by intensive intervention, results in many of them failing to obtain qualifications despite the potential to do so. The following diagram is taken from a small sample of students who CandLE support in mainstream and specialist settings. The yellow area shows the maximum curriculum level the student could achieve within their specialist provision (as outlined by the school’s curriculum framework), and the green area shows the level that they need to be at for their local mainstream schools to be able to support them. The pink area is the gap between the two, demonstrating that these students’ needs are not being met by either specialist or mainstream settings.

The SEND reforms need to ensure that specialist settings have clear progression through to age-appropriate, mainstream learning opportunities. There also needs to be provision for intensive intervention for older students who have missed early learning opportunities. The SEND reforms also need to acknowledge the need for an evidence base to support and optimise the learning outcomes for students who rely on AAC.

Post 16 provision

Despite many students who rely on AAC being able to achieve the same learning outcomes as their non-disabled peers they will need more time to accomplish this. The 2014 Code of Practice allow for this by enabling students to have EHPs until they are 25 years old.[13] However, Education placements lack the funding streams to support this. Mainstream schools are directed that students who are over 19 years move on to further education outside school, and post 16 provision is only available with government funding for 2 years leaving students forced to move from one provider to another usually without any continuity meaning that courses started in one placement cannot be completed in another.[14]

Whilst specialist provision may have more flexibility with time, most specialist providers do not offer a broad and balanced curriculum which includes a full national curriculum that provides a pathway to GCSEs and A levels or equivalent qualifications. Despite specialist providers often maintaining that they can offer GCSEs consultation of the school performance website shows that, in practice, very few students are offered this pathway.[15]

The general requirement for students to have obtained either Level 2 Maths and English Functional Skills or GCSE at Level 4 or above before they can be admitted to mainstream post-16 provision cuts off any possibility that students who rely on AAC to take the time that an EHP purports to provide for, until the age of 25, to obtain the desired qualifications.[16] This results in students who do have the potential to achieve GCSE’s being offered inappropriate provision in a specialist settings where pursuing a GCSE is not available. Yet in mainstream universities students who manage to achieve this level of education can have their university years doubled to enable them to complete their degree. This shows how uneven and totally inconsistent the current education system is for this cohort of students. It is also worth noting that there is no statutory extensive provision for university students who rely on AAC. All the students we have worked with have had to self-fund their extra support in university which is the provision that, under an EHCP they could have expected to receive, but EHCP’s do not extend to university education.

Most specialist provision has a narrow offering, normally restricted to entry level, Level I and at the most 2, Functional skills and independent living skills. Most of these qualifications assume that the student has speech and average motor skills. This often leaves students who are reliant on AAC dependent on hand over hand support or left on the sidelines observing students who can complete practical tasks or dictate to a scribe.

Under the 2010 equality Act, students with disabilities are entitled to reasonable adjustments.[17] However, there is a failure to apply this in relation to students who rely on AAC who attend specialist provision. This is because courses offered are either inaccessible or because exam boards fail to agree to the reasonable adjustment required.

Ironically, GCSE and A level exam boards have made the necessary adjustments to ensure that students who rely on AAC are not placed at a disadvantage compared to their nondisabled peers. However, most mainstream schools lack the expertise or understanding to carry out the negotiation needed for each, individual student.[18]

Unless there is a redressing of the balance in terms of curriculum offer which would enable students to seamlessly transfer-between specialist and mainstream provision many students who rely on AAC continue to be between a rock and a hard place with no education provision meeting their needs.

Unless government funding and expectation, in respect of post-16 provision in both schools and further education the extra years required for students who rely on AAC to complete their courses the provision for them to continue in education until the age of 25 in little more than rhetoric.

Ordinarily Available Provision

Ordinarily, available provision can be defined as the provision made for children whose special educational needs can be met from the resources generally available to the school or setting. Ordinarily Available guidance issued by Local Authorities across England sets out a common set of expectations about the provision and practice that is expected in all mainstream schools and post-16 providers for children and young people with SEND. It’s what a young person, parent carer or family can expect to be “normally” or “ordinarily” available to their child without the need for involving specialist support. This will apply to all children without an Education Health and Care Plan (EHCP), but children with an EHCP will also benefit from this type of provision in addition to the provision written in their plan.

Although CandLE welcomes pedagogical approaches that supports removing barriers to learners with SEND and supporting improved cognition and learning; as outlined in these guidance documents, specifically around the use of strategies that promote working memory; we have concerns around the following:

• The Ordinarily Available Provision guidance and documents vary drastically between each Local Authority across England. As such a ‘post code lottery’ of ordinarily available provision will undoubtedly emerge with students in some areas having access to a wider range of provisions and support than students in other areas. There is also some conflicting guidance across Local Authorities which can cause confusion.
• Guidance only applies to mainstream settings – what should students in SEND schools expect in terms of ‘ordinarily available provision’?
• Lack of funding available to schools to ensure the provision is made available
• Little or no mention of the use of AAC or Assistive Technology in the guidance – research shows that more than 1 in 200 use AAC in the UK[ii] – where are these student’s needs represented? How have non-verbal student’s access to these provisions been considered?
• Some Guidance documents make recommendations of outdated strategies, going against accepted best practice research e.g. referring to the use of ‘hand over hand’ support. [iii]
• Lack of training opportunities for staff to be able to deliver these recommendations effectively.
• A lack of recognition that students may need individualised support to meet their needs – guidance documents allude to mass application of recommendations and provisions in an overgeneralised manner which could be counterproductive for students who have specific health, sensory or learning needs e.g. recommending the use of objects of reference, wobbly cushions, PECs etc. If recommendations are taken on ‘face value’ this could be damaging for some students.
• Guidance is often assumptive and perspective; there is a focus on the ‘what’ and not enough guidance for teaching staff on the ‘how’ e.g. ‘Focus on reducing anxiety and thereby behaviours’ – how? ‘Support equipment’ – what sort of support equipment?
• Suggested support strategies/interventions are often described superficially – without recognition or mention of expert specialist support that is available that should be sought in addition to ordinarily available provisions e.g. specialised assistive technology, Specialist Exams Access Support etc. Without knowing that ‘more’ and ‘better’ is available – how can settings actively advocate for further expert support and interventions for their students?
• Guidance does not consider ‘how’ a student may access these provisions if they have a physical disability e.g. stating that manipulatives must be used to support learning in maths – how can this be achieved for a student with motor/physical difficulties? There are AT alternatives and these are not noted.

Ordinarily Available provision and the Graduated Response

Without ring fenced funding, training and specialist support many students may not get appropriate or equitable access to these ‘ordinarily available provisions’ e.g. if a student has a physical disability; as such they may not be accessing quality first teaching which would be considered the foundational level of support as part of a ‘graduated response’[iv].  Furthermore, how will Local Authorities ensure that students get access to the support they need should they require specialist interventions or provisions that go beyond what would be considered as ‘ordinarily available’? Currently this provision is outlined within a student’s EHCP and students have a legal right to provision as outlined in their EHCP; this forms a part of a ‘graduated response’ – but if gaps in provision are happening at the most ‘basic’ universal, ordinarily available level how can the student’s needs be appropriately assessed and met? E.g. a student needs access to AAC software for communication but is unable to access this due to funding constraints. Without an EHCP how can families, children and young people secure support and provisions, especially if expert targeted support is needed?

Proposed SEND Reforms

CandLE have 5 main areas of concern in relation to the ongoing government SEND reforms-

1. Curriculum equity – the National Curriculum continues to be disapplied to increasing numbers of students, especially those categorised as having SLD and PMLD, giving unequal access to national curriculum learning for students with SEND. This is discriminatory. Many students are having access to the national curriculum automatically disapplied due to educational placement (most students in Special Education Schools), medical diagnosis and inaccurate labelling of special need. This is not providing students with SEND opportunities for academic inclusion.
2. There is little consideration of students with physical disabilities who are cognitively able and may benefit from or rely on AAC and or Assistive technology (as per our students in our case studies). Many SEND students are still not provided with the means, opportunities and access to support, technology and provisions that would allow them to demonstrate their cognitive ability and potential, as such these students are being assigned low academic expectations without fair and equal access to learning within the national curriculum and are being wrongly labelled and wrongly placed within the current education system.
3. There continues to be a lack of transparency and poor communication around SEND reforms, fuelling a distrust of policy makers and rumours – all of which are damaging to children and young people with SEND, their families and the professionals supporting them. The government continues to liaise with select organisations and for-profit businesses who appear to have a ‘carte blanche’ on embedding their products and viewpoints into statutory guidance giving them unfair commercial advantage without a strong research base[v]
4. Removing EHCPS would amount to removing Individualized, ring-fenced funding for students with SEND and would deprive them of their legal rights to specialist expert support and provisions. Focussing EHCPs in the specialist sector makes no sense at all. It is in the mainstream that this kind of protection needs to be focussed so that students stand a chance of access to the same educational opportunities as their non-disabled peers.
5. There is currently a binary system within education – there needs to be a more fluid continuum between mainstream and special education so that students are not ‘trapped’ within a system that does not meet their needs.

Recommendations

The SEND review should ensure that:

1. All students will have access to a broad and balanced curriculum including the full National Curriculum (adapted as appropriate) irrespective of the labels that have been assigned to them or the diagnosis they have been given.
2. Specialist and mainstream settings should be redesigned so that there is the possibility of seamless transition between settings.
3. Provision should be made for students who have experienced a learning gap to receive intensive intervention so that they can catch up on missed learning at any stage of their educational experience.
4. Funding for schools and further education colleges needs to consider the needs of students who rely on AAC to be able to take longer than their nondisabled peers to complete courses and gain mainstream qualifications.
5. Students who rely on AAC should have access to appropriate courses and qualifications that they can access
6. Reasonable adjustments should be made in all courses and qualifications that students who rely on AAC access so that they are not given an unfair disadvantage.
7. Genuine placements in educational settings with continuity between settings need to be available to students who rely on AAC up to the age of 25 in all Local Authorities.
8. SEND training for teachers, teaching assistants, educational psychologists, speech and language therapists and other therapists should include the use of AAC as an AT solution.
9. The rights of students to receive the support they need must be enshrined in law with a clear appeals process and ring-fenced funding.
10. University education should be included in the process that protects the educational rights of disabled students.

Marion Stanton, Head of Education  

MA, PGCE, Adv. Dip. Ed. Special, AAC Level 7, MCCT

Annamaria Madera, Deputy Head of Education

BSc PGCE

[1] Holyfield, C., Light, J., Nieder, D. & Preece, J. (2025) ‘External challenges for individuals who need or use AAC who are learning language: lived experiences, key research findings, and future directions’, Augmentative and Alternative Communication, 41(3), pp. 267–279. doi:10.1080/07434618.2025.2508485

[2] Department for Education (DfE). (2023) The Reading Framework: Teaching the Foundations of Literacy. London: Department for Education, p. 115

[3] Department for Education (DfE). (2025) The Writing Framework. London: Department for Education, p. 80.

[4] Stadskleiv, K. (2020) ‘Cognitive functioning in children with cerebral palsy’, Developmental Medicine & Child Neurology, 62(12), pp. 1354–1362.

[5] Lorentzen, L.E., Mæhle, M., Strand, K.M., Andersen, G.L. and Stadskleiv, K. (2025) ‘Cognitive assessment practices of children with cerebral palsy: a national cohort study’, Neuropsychological Rehabilitation. Advance online publication

[6] Eligibility Criteria – NHS England Specialised AAC Services (2025) Eligibility Criteria for NHSE Specialised AAC Services. ACE Centre & NHS England.

[7] Ballester-Plané, J., Laporta-Hoyos, O., Macaya, A., Póo, P., Meléndez-Plumed, M., Toro-Tamargo, E., Gimeno, F., Narberhaus, A., Segarra, D., Pueyo, R., & Júlia Ballester-Plané, §. (n.d.). Cognitive functioning in dyskinetic cerebral palsy: its relation to motor function, communication and epilepsy. Authors’ institutional affiliations.

[8] Stadskleiv, K. (2020). Cognitive functioning in children with cerebral palsy. Developmental Medicine and Child Neurology, 62(3), 283–289. https://doi.org/10.1111/dmcn.14463

[9] Pueyo, R., Junque, C., & Vendrell, P. (2003). Neuropsychologic differences between bilateral dyskinetic and spastic cerebral palsy. Journal of Child Neurology, 18(12), 845–850. https://doi.org/10.1177/088307380301801204

[10] https://praacticalaac.org/praactical/aac-assessment-corner-with-vicki-clarke-standardized-tests-for-aac-users/?utm_source=chatgpt.com [accessed 28.9.25]

[11] Communication Matters. (2022) Written evidence submitted to the Education Committee inquiry on children and young people with special educational needs and disabilities (SEND) [CMH0023]. London: UK Parliament. Available at: https://committees.parliament.uk/writtenevidence/14184/default/ (Accessed: 28 September 2025).

[12] Erickson, K.A. and Koppenhaver, D.A. (2020) Comprehensive Literacy for All: Teaching Students with Significant Disabilities to Read and Write. Baltimore: Brookes Publishing.

[13] Department for Education & Department of Health and Social Care. (2014) Special Educational Needs and Disability Code of Practice: 0 to 25 years. London: Department for Education.

[14] House of Commons Education Committee. (2025) Solving the SEND crisis: Fifth Report of Session 2024-25 (HC 492). London: House of Commons. P86

[15] Search for schools, colleges and multi-academy trusts – Compare school and college performance data in England – GOV.UK

[16] House of Commons Education Committee. (2025) Solving the SEND crisis: Fifth Report of Session 2024-25 (HC 492). London: House of Commons. p84

[17] United Kingdom. (2010) Equality Act 2010. London: The Stationery Office.

[18] AAC_Exams_Access_Guidance_KS34FS_2024-2025.pdf

[i] https://nasenjournals.onlinelibrary.wiley.com/doi/10.1111/1467-9604.12438

[ii] Examining the Need for and Provision of AAC Methods in the UK | ACNR

[iii] Ordinarily Available Provision – Leicestershire SEND

[iv] SEND – Graduated Response

[v] https://educationuncovered.co.uk/news/ruth-miskin-announces-new-handwriting-programme-for-schools-days-after-government-reveals-new-focus-on-handwriting-following-her-advice