Four strategic themes and three practical improvements emerging from the feedback local authorities are receiving on the data modelling in their draft plans.
As part of our work supporting 20 local authorities with their SEND local reform plans, we have been reviewing DfE feedback and helping authorities respond. While every area has a local flavour, several common themes are emerging. The feedback is less about changing strategic direction and more about strengthening the evidence, assumptions and analysis that supports the delivery plan.
The plans submitted across the country represent a significant amount of work. They have been developed against a backdrop of rising need, financial pressure, evolving policy expectations and tight timeframes. The themes emerging from feedback provide a useful indication of where authorities may want to focus their attention as plans are refined and developed.
1. Make sure the data supports the narrative
One of the most common themes is the relationship between the written narrative and the evidence underpinning it.
Many plans contain a clear vision for improving inclusion, outcomes and reforming services. The challenge is demonstrating, through the data modelling, that the proposed actions are realistic, achievable and grounded in local evidence.
The strongest plans show a clear line between the challenges identified, the evidence supporting those conclusions and the actions proposed in response. Moreover, they then demonstrate how the actions outlined in the plan have impacted the data.
Where that connection is less clear, DfE feedback often asks for additional evidence or a stronger explanation of how conclusions have been reached.
2. Demonstrate the expected impact of mitigation
Another common theme is the need to show the difference proposed interventions will make.
Many plans describe actions that will be taken, but DfE feedback often asks authorities to demonstrate how those actions will change future cohort growth, the need for specialist provision and financial pressures.
What would happen if nothing changed? How would need, provision and expenditure evolve under current conditions? What difference would a proposed intervention make? How much improvement is realistic, and over what timeframe?
These questions are important because they help demonstrate that a plan is capable of influencing future pressures rather than simply describing current activity.
This was also a topic discussed during Mime’s recent webinar on SEND reform planning, where local authority leaders shared practical experience of balancing ambition with deliverability. Peter Nathan, Director of Education at Enfield Council, highlighted the importance of being realistic about the pace of change. In some circumstances, slowing the rate of growth or improving outcomes incrementally can represent meaningful progress. Plans do not always need to show dramatic shifts. They need to show credible, evidence-based improvement.
Being explicit about the expected impact of mitigation helps strengthen the case for investment and provides a clearer basis for your modelling.
3. Include meaningful measures of progress
Plans should make it easy to track whether change is happening over time.
Including clear baselines, relevant benchmarks and measurable indicators can help demonstrate progress and support future decision-making – and these should go well beyond the metrics covered by the quarterly returns in the DfE template. Strong performance measures also provide a clearer link between the actions in a plan and the outcomes they are intended to achieve. Developing a theory of change, with input, outputs and outcomes, can help to articulate this neatly in a visual form.
4. Look beyond 2030
Many plans understandably focus on the period covered by data template requirements. In several cases, DfE feedback encourages authorities to look beyond the immediate reform period and consider longer-term impacts on need, provision and finances.
The changes the reforms aim for will take time. Cultural attitudes, patterns of need, provision sufficiency and workforce challenges can develop over many years.
Looking five to ten years ahead can provide a stronger foundation for decision-making and help avoid solutions that address short-term pressures without considering longer-term consequences.
The future remains uncertain, particularly given the outstanding questions surrounding legislative reform, national standards, and pending DfE guidance. However, authorities that model longer-term scenarios are often better placed to understand future risks, opportunities and investment requirements.
Three practical checks for your data tables
Alongside these broader themes, there are some practical areas that authorities may wish to review.
a. Make assumptions clear and sufficiently detailed
DfE feedback frequently asks for more detail on assumptions within data models and forecasts.
Reviewers should be able to understand what assumptions have been made, why they have been selected and how sensitive projections are to changes in those assumptions.
In particular, where unit costs by provision are not simply calculated as total spend divided by the projected number of pupils, the rationale and calculation method should be clearly explained.
b. Check for gaps
Data tables should be complete
Missing figures or unexplained gaps in tables are problematic for the DfE and can create questions that distract from the wider strategic case being made.
c. Keep tables consistent
Inconsistencies between tables are also problematic both for the DfE and those internally responsible for delivering, monitoring, and evaluating the plan.
Turning feedback into stronger plans
The first wave of comments suggests that the DfE feedback is less on dramatically changing strategic direction and more on clarifying the evidence, assumptions and long-term thinking that sit behind plans.
Local authorities that respond most effectively are likely to be those that treat feedback as an opportunity to strengthen the link between evidence and decision-making, creating plans that remain useful long after submission.
If you are reviewing feedback on your SEND local reform plan and would value a second perspective on the data, assumptions or modelling, we would be happy to have a conversation.
Written by Joe Miller
