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Agenda item

DfE Consultation Update - HNB Funding

The report of Marie Taylor (Head of Finance – Children and  Education) seeks to present the DfE consultation on the HNB funding formula for 22-23 and beyond, to share the local authority response and to seek Schools Forum views on the consultation questions.

Minutes:

Marie Taylor (Head of Finance – Children and Education) referred to the report which sought to present the DfE consultation on the review of NFF for allocations of high needs funding to local authorities: changes for 2022-23 which was launched on 10 February to run until 24 March 2021.  Marie highlighted the following:

 

·         This was a previously unannounced consultation asking 5 questions with a finance focus being issued prior to the SEN review which had been promised for later this year;

 

Proposal 1. The current formula has 50% lump sum comprising LA planned spend in 2017/18.  The first proposal is to use actual 2017/18 expenditure opposed to 2017/18 budget as a baseline to allocate the historical element.  Proposed 2022/23 onwards.

 

·         This proposal would mean a reduction in funding of £1.2 million for Wiltshire potentially, for one year only.  Having a formula that changes just for one year would have a nasty impact on Wiltshire, however 95 local authorities would gain under this proposal, so this was of concern.  For Wiltshire the 2017/18 actual spend was less than planned and there was a big jump from 2016 onwards so this proposal was not something that Wiltshire would support.  A response for this had been drafted and it was hoped that schools would use this for their own responses to support the view.

 

Proposal 2.  Increase the proportion of actual expenditure in 1 above (the historical lump sum) to 60%

 

         This proposal would mean a reduction funding, estimated to be in excess of £1.5 million for one year only.  The DfE wrote directly to us after this consultation was issued to inform us that they had made a mistake in the 2017/18 figures and had understated our place  values by 17 places.  Whilst the true value of the decrease was not known, it would still be significant and again Schools Forum members were encouraged to respond to the consultation to state their strong disagreement to this proposal.

 

Proposal 3.  Alternative to the historic spend factor (Proposed 2023-24 onwards)

 

       The DfE have confirmed they would prefer to replace the historic spend factor with alternative factor(s) longer term that better reflect local issues and are able to be kept up to date but that avoid perverse incentives such as numbers of EHCPs.  The DfE say that the earliest alternative factors could be introduced is 2023-24 following the SEN Review.

 

       Officers agree that moving away from an outdated formula and towards a suite of easy to update drivers to reflect the needs of young people and take into account local variables including rurality would be fair, transparent and a positive move for Wiltshire, however it was not accepted that using numbers of EHCPs is inappropriate and believe it should be a major factor in the new formula. This would be quite contentious to feed back to the DfE but in nationally an assessment for an EHCP is how we assess and support the children’s needs.  A way to avoid EHCPS being a perverse incentive to funding could be including a cap on average national growth of it as a measure.

 

Question 4 -  Attainment data as a funding driver – views on pandemic impact (Proposed 2022-23 & 2023-24)

 

         For 2022-23 there would be no attainment data due to the disruption to tests and exams in 2020 and this was likely to be repeated for 2021.  The DfE are proposing that 2016,2017,2018,2019 and 2019 (2019 used twice) is used for both 2022-23 and 2023-24 years.  This was discussed at the School Funding Working Group (SFWG) meeting and it was agreed that a consistent approach is preferable, however it was felt that modelling should be carried out across more options as this approach carries a level of risk as the cohort of young people is so small for some it could be disproportionate.

 

Question 5 - Effective proxies for SEND & AP in the formula

 

           For this factor the DfE currently take into account the local population of C&YP, two health & disability measures (bad health* & DLA) and two deprivation factors (FSM and local area deprivation measure.)

 

         The DfE welcome views on how proxy factors can be improved, confirming, numbers of EHCPS are not a suitable measure.

 

         This was again discussed at the SFWG and it was felt that a wide range of factors should be incorporated, and they should absolutely include numbers of EHCPS or numbers of assessments.  Wiltshire also wanted to feedback that their rates had not been uplifted for some time.

 

Marie highlighted the importance of a high number of responses from Wiltshire bearing in mind that 95 other local authorities would benefit from proposal one.  It had been agreed at the SFWG meeting that Neil Baker and Lisa Percy would prepare a joint letter and invite all Headteachers to join in with that response.

 

A Councillor representative asked if the 95 local authorities mentioned were non rural county local authorities and if there were any other factors?  Marie Taylor reported that previously when there were “statements” (before EHCPs) Wiltshire did not have as many as perhaps others in other local authorities and we have been playing catch up since then, However those that got there earlier would reap benefits from this proposal as in 2017 some local authorities were spending more than us. Rurality of authority did not come into it – it would be the level of spend in 2017.

 

The Chair confirmed that he and Lisa Percy (Vice Chair) had prepared a response based on the views of the Wiltshire Officers and as schools are currently very busy with Covid and children returning they had made it as easy as possible for schools to respond to the consultation.  This had been shared with WASSH and PHF to ask the to share with schools and request that they send in individual school responses.

It was confirmed that the Wiltshire Parent Carer Council would also prepare a response based on the Officer views and views of Schools Forum.

 

Resolved that Schools Forum:

 

1.    Note the DfE consultation and proposed Local Authority responses.

 

2.    Promote the completion of the consultation document within their school communities.

Supporting documents: