The scale of proposed SEND reforms alongside other policy changes risks 鈥渟mothering鈥 the school system, the government has been warned. School leaders鈥 union NAHT, the Association of School and College Leaders (ASCL) and the Confederation of School Trusts (CST), as well as teaching unions NASUWT and the NEU have published responses to the which closed on 18 May. All responses welcomed the move to create more inclusive environments with early intervention. But they also warned that funding and resources may not match up to expectations. Here鈥檚 everything you need to know. 1. 鈥楽ystem-level smothering鈥 Leadership unions have warned that the SEND reforms 鈥 alongside changes to curriculum, enrichment and suspensions guidance 鈥 will be overwhelming for schools. The NAHT and CST both said implementing everything at once represented a 鈥渃umulative burden鈥, while ASCL said it had 鈥渟erious concerns about the scale of expectations being placed on schools鈥. CST described this as 鈥渟ystem-level smothering鈥, while the NEU said reform was 鈥渦nsustainable before it has got off the ground鈥 without protected and funded time, and argued the proposals were dependent on staff who 鈥渄idn鈥檛 exist yet鈥. Clearer alignment is needed across education, health and social care, otherwise there is a 鈥渞isk that expectations continue to fall disproportionately on schools and trusts鈥, the union added. The NASUWT said it did not believe the timeline for reform is realistic, and suggested reforms should be piloted and independently evaluated before wider implementation. 2. Funding 鈥榞aps鈥 will remain Funding for the reforms include 拢3.5 billion in extra high needs funding by 2028-29, a 拢1.6 billion inclusive mainstream fund, 拢1.8 billion 鈥渆xperts at hand鈥 service and 拢200m in teacher training. ASCL and the NEU said it was not clear whether funding will be enough to implement the reforms. The teacher training funding in particular is a 鈥渄rop in the ocean鈥, according to ASCL. CST also warned that current gaps in funding 鈥渨ill remain鈥. It proposed a two-layer model that creates separate funding for commissioned provision and meeting individual needs through the universal offer. 3. 鈥楥onfusion鈥 on experts at hand Unions have also welcomed the experts at hand service, which aims to make more external professionals including educational psychologists and occupational therapists available to support schools. The NAHT said clear, nationally consistent response times must be set, with clear protocols on how to escalate concerns when response times are missed. CST said there was 鈥減otential鈥 in the model, but also 鈥渟ignificant confusion鈥 in the system about how it will operate in practice. 4. Inclusion bases One of the main proposals in the white paper is for all secondary schools to have an inclusion base to support pupils with additional needs. ASCL said it supported this in principle, but warned such bases are 鈥渘ot a silver bullet鈥, and inclusion must be system-wide. The union also said inclusion bases 鈥渟hould not become holding pens, standalone units or exclusion by any other name鈥, but welcomed the attempt to simplify the language used for the bases. At present they can be called SEN units or resourced provision. While the NAHT said inclusion bases had a critical role to play, it 鈥渇undamentally challenges the assumption that inclusion bases can meet the full range of SEND鈥. CST said guidance must clearly differentiate between support bases commissioned by schools, and those commissioned by councils. 5. 鈥楲ight鈥 EHCPs? Reforms will require schools produce an individual support plan (ISP) for every pupil with additional needs, including those with an education, health and care plan (EHCP). While an EHCP would be secured for pupils with the 鈥渕ost complex needs鈥, this would be through a nationally defined specialist support package. But the NAHT raised concerns ISPs risk becoming a 鈥渓ight EHCP鈥, adding complexity rather than reducing bureaucracy. As ISPs will be looked at during Ofsted inspections, the union also outlined concerns the plans will evolve into accountability tools, rather than supporting provision. CST said the relationship between ISPs, EHCPs and new specialist support packages 鈥渞equires much greater clarity鈥, as it is not clear how they will interact. The NASUWT said reducing EHCPs 鈥渋s likely to compound the problem of schools being accountable when things are outside of their control鈥. ASCL warned that an average secondary school may have around 200 ISPs. 6. Complaints process Government has said parents will have to appeal decisions on ISPs through their school鈥檚 complaints process. But CST said this risks an 鈥渆xponential rise鈥 in complaints, which could 鈥渙verwhelm鈥 schools. ASCL said school complaints should be independent, put through the local government ombudsman. The leadership union also did not agree that a SEND specialist should sit on the complaints panel, warning the 鈥渇ocus on schools and colleges to self-monitor is unfair for them and for families鈥. 7. Health 鈥榤ust play more active role’ The NASUWT said the health and social care sectors 鈥渕ust play a more active role鈥 in delivering and resourcing support for SEND. 鈥淭he extent of [Department of Health and Social Care] involvement with, and ownership of the reforms, is unclear,鈥 its consultation response said. CST agreed there should be more clarity on the role of health services, ICBs and local authorities in the reforms system. 8. More resource needed for SENCO aims Ministers want to make the role of special educational needs coordinators (SENCOs) more strategic under the new system. The NAHT said this would only work if schools had more resources and staff members, while ASCL said guidance and examples of how SEND responsibility can be spread throughout school leadership should be shared.