Just as many of us were contemplating the great educational challenges of the summer holidays - how many out-of-office replies constitute a meaningful break, whether anyone will ever find the lost PE kit from July 2024, and how long it takes for policy announcements to become urgent matters in September - the Department for Education has released a consultation that could fundamentally reshape how SEND funding operates in England. It is, in short, a significant proposal.
At first glance, the proposal sounds positive enough. The government wants mainstream schools to receive more SEND funding upfront, rather than having to bid or apply for additional funding from local authorities after needs emerge. The stated aim is to enable schools to intervene earlier, reduce bureaucracy and respond more flexibly to pupils’ changing needs. Few would disagree with that ambition, but, as ever with SEND reform, the detail matters.
Once considered in detail, the proposal looks less like a straightforward investment in inclusion and more like a significant redistribution of responsibility and risk within the system.
The headline
The consultation proposes allowing local authorities to increase the £6,000 threshold of additional SEND costs that mainstream schools are expected to meet from their own budgets. In return, more funding would be transferred from high needs budgets into mainstream school budgets upfront. In plain English, schools would receive more money, but they would also be expected to meet more of the cost of support before additional funding becomes available.
That is why many people looking at the proposal have reached the same initial conclusion: this feels like giving with one hand while taking with the other. The government frames these changes as a way to increase flexibility and enable earlier intervention, with schools receiving larger core budgets and making decisions without navigating complex funding applications. The key question is whether that flexibility is matched by sufficient resource to meet the expectations being placed upon schools.
The inclusion question
The wider SEND reforms are built around a central proposition: mainstream schools should be able to meet more needs earlier and more effectively. In principle, NASS has consistently supported stronger inclusion in mainstream schools. Most children and young people should be able to access excellent support without needing to navigate a lengthy statutory process simply to get help. The challenge, however, is that inclusion is not achieved through aspiration alone.
Inclusion requires people, expertise, training, specialist advice, staffing and sustained funding. One of the risks in the current debate is that inclusion becomes shorthand for expecting mainstream schools to do more, without an equivalent conversation about the additional capacity they need in order to succeed.
Why special schools should pay close attention
At this point, some special school leaders may reasonably be asking: why is NASS paying such close attention to a policy aimed at mainstream schools?
The answer is simple: changes in mainstream provision inevitably affect special schools. If mainstream schools are properly funded and supported to identify and meet need earlier, fewer children may reach crisis point or require specialist placements, which would be a positive outcome. But if expectations rise faster than capacity, more children may arrive later in the system with greater complexity and higher support needs. Special school leaders know better than most that when early intervention does not materialise in practice, need does not disappear but often increase and become more complex.
The government's case
The government argues that the current funding system can encourage schools to seek additional funding only once needs have become significant enough to trigger formal processes. Funding applications take time, local authorities face administrative burdens, and support can be delayed. On that basis, there is a reasonable case for giving schools greater certainty over resources upfront, enabling them to respond earlier and with more flexibility.
Many school leaders would welcome that certainty, alongside fewer forms, fewer funding hurdles and, perhaps, fewer meetings—although we should be careful not to make promises that maybe cannot realistically be kept. The issue is therefore not whether early intervention is desirable, but whether the mechanism proposed will actually deliver it in practice.
Where the concern lies
The central concern is that the consultation appears to focus heavily on funding distribution rather than funding sufficiency. Changing where money sits within the system is not the same as adding new money to the system, and a school receiving additional funding upfront may still face difficult decisions if the costs of meeting need continue to rise.
This challenge is particularly acute in the broader context of rising demand. Demand for SEND support continues to increase, the number of children with Education, Health and Care Plans (EHCPs) has grown substantially in recent years, and local authorities continue to face significant pressure on their High Needs budgets.
Against that backdrop, transferring responsibility without ensuring adequacy of resource carries obvious risks. Schools may gain more flexibility, but they may also have greater exposure.
The £6,000 question
One of the most significant elements is the proposal to increase the threshold that schools are expected to fund themselves before accessing additional support funding. This matters because the threshold is not merely an accounting mechanism, it reflects an underlying assumption about what a school should reasonably be able to provide from its delegated budget.
Raising that threshold effectively changes the balance of responsibility between schools and the wider system. The consultation asks whether schools should receive more resource upfront. The key issue here is whether giving schools more money upfront results in children with SEND receiving quicker identification and support and securing better outcomes. As every school leader knows, theoretical funding models and children’s actual needs rarely align quite as neatly as spreadsheets would suggest.
What about EHCPs?
The government is keen to reassure families that legal rights attached to EHCPs will remain unchanged. Local authorities would still retain duties under the Children and Families Act, and schools would still be required to use their "best endeavours" to secure appropriate provision.
That reassurance is important. However, maintaining legal duties does not automatically resolve practical questions about implementation. A system can preserve rights on paper while still creating uncertainty around how those rights are delivered in practice. This is one reason why the sector will need to examine the proposals carefully rather than simply accepting the headlines.
Our view
At NASS, we support the ambition of earlier intervention, reducing unnecessary bureaucracy, improving inclusion. But we should be cautious about assuming that moving money around the system, by itself, creates greater inclusion.
Inclusion is built through workforce development, specialist expertise, capacity, leadership and sustained investment. The consultation opens an important conversation about how SEND funding reaches mainstream schools, and that conversation is worth having. However, it also raises an equally important question about who ultimately carries responsibility when demand continues to rise faster than resources.
That is the issue many school leaders will recognise immediately beneath the surface of these proposals.
Final thoughts
Perhaps the most telling aspect of this consultation is that it arrives not as a minor funding adjustment but as part of a much bigger attempt to reshape the SEND landscape. The government's own documentation positions it as a first step towards rebalancing high needs and school budgets and testing a fundamentally different approach to funding inclusion. We are also concerned that this is a system changing before we have had the Government’s response to the SEND consultation and under an existing legal system that must be upheld.
That is why this matters. This is not simply a consultation about moving numbers between funding lines, it is a consultation about changing assumptions about who provides support, who holds risk, where accountability sits and how inclusion is funded in practice.
The implementation will be everything. As ever in SEND policy the devil is in the detail, and launching such and important consultation right before the holidays and with a closing date very close to the start of term is an interesting choice by DfE.
The consultation remains open until 18th September 2026 and can be found here: Upfront funding for mainstream schools: creating a ‘local SEND inclusion formula’ – what parents and carers of children and young people need to know - GOV.UK