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Planning to Improve Access to Education for Pupils with Disabilities
Guidance on Preparing Accessibility Strategies

Chapter 3 - Procedures for Local Authorities

Form in which the accessibility strategy should be produced

68. Local authorities already have considerable experience of strategic planning for pupils with special educational needs and disabilities. For example, they plan in advance capital spending on improvements in schools and they prepare plans to demonstrate how they will spend funding under the Inclusion Programme, which forms part of the Scottish Executive National Priorities Action Fund.

69. In addition to this, two larger planning programmes include planning for children with disabilities: Improvement Plans under the National Priorities in education, and Children's Services Plans.

70. The National Priorities specify as a priority the need to " promote equality and help every pupil benefit from education, with particular regard paid to pupils with disabilities and special educational needs, and to Gaelic and other lesser used languages" ¹³. Under section 5 of the Standards in Scotland's Schools etc. Act 2000, local authorities should prepare an 'annual statement of improvement objectives' - known as an Improvement Plan or a Progress Report on the Improvement Plan - which shows what they have achieved and how they intend to make further progress in meeting the National Priorities.

71. Local authorities should document their accessibility strategies where they feel it is most appropriate to do so, and they are encouraged to dovetail and cross-refer to their accessibility strategy in other related plans. All these plans should form a clear part of the Community Planning framework. It is expected that local authorities' strategies should form part of their Improvement Plans under National Priorities. This will expand and build on the work that local authorities have already started carrying out through their Improvement Plans.

72. As a result, school development plans (under section 6 of the 2000 Act), should take account of the local authorities' accessibility strategies and how they will affect individual schools. Individual schools will not be required to have their own accessibility strategies, but staff should clearly be involved in the preparation and implementation of the authority's strategy.

73. The authority may also choose to include their accessibility strategy within their Children's Services Plan, which must be prepared every three years. The ¹⁴Children's Services Plan should demonstrate how the authority is improving its children's services in general and must include information about how it is promoting equal opportunities for children. There should at least be a cross-reference in the Children's Services Plan to the accessibility strategy.

74. As was stated in the Introduction, accessibility strategies should last for a period of three years. However, the regulations under the Education (Disability Strategies and Pupils' Educational Records) Act state that initial strategies should last for a period of 'up to' three years. This will allow those initial strategies to fit into the current National Priorities and/or Children's Services Plan planning cycles.

Process - How to prepare and implement an accessibility strategy

75. The suggested cycle for auditing, planning, implementing and reviewing strategies is as follows:

Getting started

76. A local authority's accessibility strategy should not be prepared by one person alone unless similar extensive planning for pupils with disabilities has recently been carried out. Although one person may be given the lead in taking the strategy forward, the authority should set up a small planning group to devise the strategy, arrange consultation and ensure that the strategy is implemented and reviewed.

77. The planning group should not just involve education officials, although of course they are likely to take the lead in developing the strategy. It is up to each local authority to decide who is likely to be able to make a valuable input as part of the planning group. This might include or involve: access officers/officers in charge of disability access across the authority, inclusion coordinators, pre-school co-ordinators, educational psychologists, officials from the buildings/capital investment department, social work services, head teachers and others from outwith the authority, such as: local health professionals/therapists, design professionals, parents' group/forum representatives, voluntary organisations or pupils with disabilities.

78. The planning group should meet regularly during the period when the strategy is being prepared. Once the strategy is in place, the group should probably continue to meet at least two or three times each year to take forward implementation and review progress.

Access audit and review of accessibility

79. A local authority cannot determine its priorities and prepare an accessibility strategy without knowing what progress it has already achieved and identifying areas where improvements are needed. Many local authorities have carried out audits of existing facilities over recent years, though these may need to be updated. Those who have not, or whose audits have been restricted to physical access, for example, should consider how they will assess the current accessibility of their schools (and also of course nursery classes and any education provided on Gypsy/Traveller sites). If a planning group wants to audit all its schools, but feels it does not have time, it could plan a programme to audit a certain number of schools each year (one in each cluster perhaps). Any issues could then be fed in when the strategy is reviewed.

80. If the authority chooses not to carry out a formal audit (either using its own staff or by contracting occupational therapists or other experts/ organisations to do this), it must be satisfied that it has accurate and up to date information it can use to inform the preparation of the strategy. Local authorities may find it helpful to refer to the Department for Education and Skills Building Bulletin 94 - Inclusive School Design¹⁵ which provides useful guidance on carrying out accessibility audits of schools and improving accessibility.

81. Any audit or information gathering exercise carried out should not just use checklists to consider physical access. It should also look at wider considerations: the need for staff training, the need for additional space/ rooms for pupils with disabilities, the availability of teaching materials in alternative formats, the use of inclusive teaching methods and schools' experiences of and attitudes towards pupils with disabilities and inclusion. Self-assessment tools like How good is our school?¹⁶ are useful in carrying out these audits.

Initial Consultation

82. How widely a local authority consults before drafting its strategy will depend to a large extent on how much experience the authority, and those on the planning group, already have in accessibility matters and determining where improvements will be needed. The planning group may need to seek advice on improvements for pupils with certain disabilities from those with relevant expertise, such as voluntary organisations and design professionals. They may also wish to develop links with other local authorities to share good practice. Head teachers and/or school boards and managers in local authority centres which have pre-school classes (as well as local parents' groups and, if possible, children) should be contacted at this early stage (if this has not already been done as part of an audit) and asked to identify priorities for change in their school.

Shared Premises

83. In planning for improvements on premises which may be shared with local authority departments, other than education (e.g. leisure services, Social Work Services, etc.), or other agencies (e.g. health services), the planning group should ensure that they consult people from these services early on to encourage joint improvements.

84. For example, nursery classes provided by a local authority outwith schools may be held in a building, such as a community centre. The centre is likely to be used for a range of purposes and it may be necessary to consider whether any physical alterations are required in other parts of the building where others may require access. The aim should be to ensure a co-ordinated approach, and that, where appropriate, any physical alterations take account of the wider range of users, rather than just the pre-school pupils.

85. By October 2004, under Part III of the DDA, service providers in such centres, will have to take reasonable steps to remove, alter or provide means of avaoiding physical features of a building which continue to make access impossible of unreasonably difficult for people with disabilities. Therefore, planning to make improvements to the physical environment in such non-school centres should already be underway.

86. So other agencies/services will wish to ensure that any proposals will also take account of their obligations and, in some cases, the cost of alterations might be shared between the different services. This approach should also apply to new community schools and to any education provided by the local authority on Gypsy/Traveller sites. Although it is not a requirement of the legislation, local authorities may want to include planning for any education they provide in hospitals or in a child's home, where the child is too ill to attend school. Here, plans could be made to improve access to the curriculum and improve communication with pupils. Guidance on 'children too ill to attend school' provides further advice on this ¹⁷.

87. Local authorities may also want to work with local Further Education colleges to improve pupils' access to the curriculum while they are on link placements at a college.

88. Planning groups will also want to consider how the accessibility strategy is addressing access for children with disabilities to services provided in schools by other groups, such as parents' groups providing out of school care on a voluntary basis.

Drafting the accessibility strategy

89. Annex C includes a template of suggested headings which could be included in an accessibility strategy. Quality is more important than quantity in drafting an accessibility strategy and the focus should be on what will be improved as a result of the strategy, rather than producing a lengthy document. When they start to draft the strategy, the planning group should have information about all the barriers or potential barriers to participation for pupils with disabilities. These may be barriers in individual schools or pre-school provision or to education provided to children on Gypsy/Traveller sites, or they may be common needs for improvement in all or most of the schools in the authority's area, such as staff training needs.

90. Local authority accessibility strategies do not need to cover pre-school education provided by private or voluntary sector providers operating in partnership with a local authority. The majority of these providers are small companies or voluntary groups, who may be operating in premises which they do not own. Therefore, it would be too burdensome to require such providers to prepare and implement formal strategies when they are already subject to the duties to improve the physical environment under Part III of the DDA (Access to Goods and Services). Instead, local authorities should use their negotiations for contracts with these providers to ensure commitment to improving over time access to all aspects of education for children with disabilities.

91. In drafting the accessibility strategy, the group should make sure that it considers and tackles barriers to participation for pupils with all kinds of disabilities, not just one or two. However, this does not mean that a strategy cannot place a focus on one disability if the group feels that there are particular weaknesses here which need to be addressed before other improvements are carried out. In preparing the strategy, the group should also make sure that any proposals for change fully take into account issues of pupils' gender, race/ethnicity, religion, sexual orientation or any other characteristic.

92. The planning group should also look to improve access to education which the local authority provides in portacabins or other temporary accommodation on Gypsy/Traveller sites. Currently, at least three local authorities provide education in this way. Although such education will normally be provided, along with health and other community services, on a temporary basis, the local authority should be aiming to ensure that all Gypsy/Traveller children with disabilities are able to access education. Any initiatives which are taken across the authority to improve the accessibility of the curriculum and school information should clearly be extended to education provided on Gypsy/Traveller sites.

93. The group may find it easiest to list the barriers under each of the three aspects of access which they must consider: the curriculum, the school environment and school information. Each of these aspects is considered in detail in Chapter 2. There may also be an extra category for barriers or needs which either do not fit into the three specified categories or span all three. For example, the authority may recognise that it needs to improve awareness amongst staff and pupils about disability and promote positive attitudes towards inclusion.

94. In considering the list of barriers and suggested improvements, the group should rank these in broad terms as short, medium and long-term priorities. This will probably include some improvements which have been already planned or are underway, but have not been completed, such as an ongoing rolling programme of improvements to schools. There may also be a category for improvements which are not thought to be a priority at that time or where the cost would exceed the long-term benefit.

95. The group should then decide which of these priorities it can realistically tackle over the period of the strategy. The strategy should look to address at least all of the short-term priorities (i.e. the most immediate needs), probably within the first year. Most or all of the medium-term priorities would also be expected to be addressed or to start to be addressed during the period covered by the first accessibility strategy. Some long-term priorities should also start to be addressed during the first period, such as rolling programmes of training for all staff or the roll out of new teaching methods. However, it is recognised that a key objective during the first strategy period may be establishing baseline details for the next strategy and, therefore, that many longer-term priorities may not start to be addressed until the second strategy. Preparation of strategies should be seen as an ongoing process, rather than the production of documents in isolation.

Resources

96. Local authorities are required by the Act to resource adequately their accessibility strategies. This means that the authority must recognise this as legitimate expenditure and include it within its budget, and should ensure that funding provided for accessibility or inclusion is used for these purposes. Therefore, the planning group will need to involve someone from the finance team or with control over budgets to ensure that funding is set aside for the improvements that the authority commits itself to in its strategy. At the same time, the planning group will clearly need to bear in mind in prioritising proposed improvements, that the resources available will not be unlimited. This means that they will need to plan the implementation of improvements, particularly more expensive measures, such as major one-off physical alterations to school buildings (for example, installation of lifts), over time.

97. In making its plans, the group will need to consider the demand or future demand in order to analyse the benefits against the cost of an improvement. In looking at future demand, especially in considering medium and long-term priorities, the planning group may need to forecast how need will change in future and plan for the necessary adaptations, even though some of these may not be carried out within the period of the first strategy. Health professionals and Social Work Services may be able to help here by providing, for example, information/data from any local register of children with disabilities or passing information about pupils with disabilities on to education professionals in the pre-school joint assessment team (PRESCAT).

98. In looking at how to resource the strategy, the planning group should consider all the potential sources of funding available to them to implement the strategy.

99. It is expected that account would be taken of the following:

• Additional funds that are being made available nationally in general grant (grant-aided expenditure) specifically to assist in implementation of accessibility strategies;
• Inclusion Programme funding, which should be used to promote equality and inclusion in Scottish schools;
• Existing local authority revenue expenditure on education services including resources identified specifically against SEN;
• The SEN Specific Grant for in service training, which is available to provide training for teaching, learning support, auxiliary and other staff to enable them to support and teach effectively children with a variety of special educational needs and disabilities;
• Capital investment in schools from local authorities' single capital allocations for non-housing services.
• Other funding sources, such as funding from other agencies for joint initiatives.

Public/Private Partnerships (PPPs)

100. Some authorities have also received revenue support, which is currently helping to fund new school building and refurbishment work in schools, with a capital value of around 500 million. A further tranche of revenue support is now available and will lead to significant further investment in schools through PPPs. This offers an excellent opportunity for local authorities to make improvements to the physical environment of their whole school estate, including outside areas, such as playgrounds.

101. Local authorities should ensure that accessibility is fully addressed in negotiating future PPP contracts. Authorities should not just assume that private partners will automatically consider all the necessary accessibility requirements when building or refurbishing schools. This will be especially important when negotiating building specifications and contracts for new builds - long-term future requirements for space, access, lighting, colour contrasting and signage to make it easy for pupils to find their way around, etc. should be incorporated into the initial design.

Setting goals and targets

102. Once the planning group has decided what changes and improvements should be included in the accessibility strategy, they should set goals and targets to demonstrate exactly what they wish to achieve. Where possible, they should use SMART (Specific, Measurable, Achievable, Relevant and Timed) targets to specify what outcomes will be achieved and by what date. However, there are some improvements for which the outcomes may be difficult to quantify or where it is difficult to specify dates by which they will be achieved. For example, strategies should, as they are implemented, lead to improvements in the following areas:

• in changing positively the ethos of schools and attitudes amongst pupils towards pupils with disabilities;
• in increasing the confidence of school staff in supporting pupils with disabilities and special educational needs;
• in visibly increasing the opportunity for involvement of pupils with disabilities in extra curricular activities, school trips, sports and wider school life in general.

Further consultation

103. Local authorities should consult as widely as possible on their draft strategies, especially if they have carried out a limited initial consultation. Information about reasons why certain improvements have been made a priority and why other proposals may have not been included should be outlined in the accessibility strategy. This will assist those who are being consulted (or who may be reading the strategy after it has been finalised) in understanding why certain proposals have been prioritised above others.

104. Interested groups and individuals should be consulted either directly or indirectly. The authority should ask some or all head teachers or school boards to consult groups of pupils, parents and school staff directly. Schools should consult as widely as possible. The local authority should ensure that head teachers and school boards are clear about the legislation, what the strategy is for and what it can and cannot do before they consult their staff, pupils, parents and others. This is important as parents naturally may have high expectations and are likely to want what is best for their own child. Head teachers and school boards and the planning group need to ensure that parents and others are aware that the accessibility strategy will not necessarily bring forward major changes overnight, but instead will lead to a gradual programme of longer-term improvements.

105. Schools should involve all their staff, not just teaching staff, and should remember to consult a wide range of pupils. This should not only be pupils with disabilities - those who do not have a disability may also have views and relevant ideas to contribute. Similarly, the school should seek to involve a wide range of parents and carers, not only those who have children with disabilities or those who are always involved in school activities.

106. It is important that staff are not just told about the strategy, but that they are able to give their views at this stage. This should ensure that everyone 'buys into' the strategy, which is vital in the case of school staff who will have to implement many of the changes and ensure that these are effective. The planning group must be prepared to revise the draft strategy in light of the consultation exercise.

107. Consultation might be in the form of an open meeting or meetings/ seminars to discuss the strategy, focus groups, a written or web consultation asking for comments on the strategy or ad hoc telephone calls and small discussions, asking for advice on particular points, etc. The group should ensure that any consultation is accessible to everyone with an interest, including pupils or parents with disabilities or those from minority ethnic backgrounds, where, for example, English is not their first language. Therefore, special arrangements should be in place to support those pupils or parents who may otherwise find it difficult to give their views.

108. Planning groups should involve or consult the following groups, either formally or informally:

• schools and nursery schools, their staff and parents/carers;
• a sample of pupils;
• specialist teachers and inclusion co-ordinators/network support;
• school boards;
• local parents groups;
• local Councillors - the Council's Education/Children's Services Committee;
• local childcare partnerships and pre-school joint assessment teams;
• NHS Boards/Trusts: health professionals - therapists, doctors, school nurses;
• Social Work Services;
• Local authority ICTSLS (ICT Support for Learning in Scotland) group members;
• relevant national and local voluntary organisations (see Annex B) and equality groups (e.g. local Gypsy/Traveller groups) as necessary; architects and/or other design professionals;
• out of school clubs and others who use school premises;
• any other relevant bodies, such as the SQA, sportscotland, Learning and

Teaching Scotland and any relevant trade unions.

Implementation and Publicising the Strategy

109. Once the strategy has been prepared and revised as necessary following consultation, it then needs to be implemented. Either the whole planning group should be jointly responsible for ensuring that the strategy is implemented or an individual within the local authority should be given responsibility for driving forward implementation. They should liaise with school staff and those who will be carrying out any improvements.

110. Local authorities must make a copy of their strategy available in electronic format or hard print copy to anyone who asks to see it. The strategy should wherever possible be made available within a few working days of the request. However, if someone requests a copy of the strategy in an alternative form, this may take longer to prepare. For example, someone with a visual or hearing impairment might request a copy of the strategy: in Braille, in large print, on CD Rom, on audio tape or through video signing/subtitled videos. Such requests should be complied with as soon as possible. In addition, wherever possible, local authorities should make their accessibility strategy or a summary of the strategy available in any other alternative form or in community languages or Gaelic, taking account of the needs of local communities.

111. Those responsible for implementation should ensure that the finalised strategy is publicised and relevant and interested groups are aware of how it will affect them. They should make every effort to provide a summary of the strategy to all those who may have an interest. (This might, for example, be as part of the Children's Services Plan.) All those consulted during the preparation of the strategy should be at least made aware of how the strategy has been finalised. School staff especially should be aware of how the strategy will impact upon them and should make staff, pupils and parents aware of this. The authority may consider organising awareness raising events for school staff and pupils or linking information about the accessibility strategy to staff training sessions. Copies of the whole strategy might also be sent to relevant groups or organisations (in alternative forms where necessary) and posted on a relevant website.

112. The local authority and its schools should ensure that relevant improvements and commitments to change within the accessibility strategy are fed into ¹⁸School Development Plans when they are reviewed. Summaries of the School Development Plan should include reference to the accessibility strategy to ensure that all parents are aware of it and know that they can ask to see the strategy if they wish to. Similarly, head teachers should consider including a summary of how the strategy applies to their school in the School Handbook.

Monitoring, Review and Evaluation

113. The planning group will need to review the strategy at regular intervals during its lifespan. At a minimum, the planning group should meet formally once every year to review progress in implementing the strategy. In most cases, the group would probably wish to meet two to four times each year to consider progress. The group should also review the strategy if individuals or organisations complain to the local authority that the accessibility strategy does not include certain important improvements which may be necessary or that the strategy has not been properly implemented.

114. The group should consider how they will aim to resolve disputes or reach a compromise with anyone who has a complaint. The authority's complaints procedures should be used to deal effectively with complaints related to the accessibility strategy and these procedures should be well publicised (and accessible to those with disabilities). Any parent support or mediation services relating to education that the authority has in place should be able to consider disputes relating to the accessibility strategy.

115. If necessary, the accessibility strategy may need to be revised following a review. Revisions may be needed, for example, if certain expected improvements are found not to have been successful and a different approach is needed, or where changing circumstances mean that a new priority emerges, which had not been anticipated (or which was not previously such a high priority). If the group wishes to make large or significant changes to the strategy, they should consult relevant people before doing so and ensure that they make schools and other interested groups aware of the changes that have been made.

116. Towards the end of the three year period (or the period covered by the strategy if the first strategy is shorter than this), the group will want to evaluate how successful the strategy has been. The evaluation should include an assessment of whether the goals and targets have been met and also whether there has been a qualitative improvement in access to education for pupils with disabilities. The group should also ask stakeholders, such as school staff, pupils and parents to evaluate progress which has been made.

117. This evaluation should give the local authority a clear picture of what has worked well, what has not worked well and where further improvements are needed. This information should then form the basis of the development of the accessibility strategy for the following three year period. The local authority should then go through a similar process of consultation in developing the next strategy. The next strategy should start immediately the previous one ends.

118. A brief evaluation of what has been achieved (and what was not achieved) during the period of the strategy should be included in the introduction to the following strategy and should help explain why certain priorities have been chosen for the next strategy over others.

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