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

Chapter 4 - Procedures for Independent, Grant-Aided and Self-Governing Schools

119. Procedures for those bodies responsible for independent, self-governing and grant-aided schools will be similar to those for local authorities, although clearly the planning is likely to be on a much smaller scale as the strategy will normally only cover one or two schools.

Form in which the accessibility strategy should be produced

120. Many of those responsible for these schools already have experience of strategic planning for pupils with special educational needs and disabilities. For example, they plan in advance for capital spending on improvements in the school and they plan for learning support and other support for pupils with disabilities as part of their existing business planning.

121. Responsible bodies are free to prepare their accessibility strategy as a free-standing strategy or to integrate it within existing frameworks, such as school development planning, if they prefer. As was stated in the Introduction, accessibility strategies should cover 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 current planning cycles.

Process - How to prepare and implement an accessibility strategy

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

Getting started

122. Although one person, such as the head teacher or head of learning support, may be given the lead in taking the strategy forward, depending on the size of the school, the responsible body may wish to consider setting up a small planning group to devise the strategy, arrange consultation and ensure that the strategy is implemented and reviewed.

123. It is up to the individual school to decide who might have a role to play in the planning group. The planning group might, for example, involve a teacher, someone involved in learning support, the head teacher/principal, a member of the board of management, the bursar/finance manager or someone with responsibility for the school estate. The group may also include representative parents, health bodies or voluntary sector organisations.

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

Access audit and review of accessibility of the school

125. A planning group cannot determine its priorities and prepare an accessibility strategy without knowing what progress it has already achieved and without identifying areas where improvements are needed. Some schools may already have carried out an audit of existing facilities over recent years, though it may need to be updated. Where this has not been done or where audits have been restricted to physical access, for example, the planning group should consider how they will assess the accessibility of the school (or schools). If a planning group wants to carry out a detailed audit, but feels it does not have time, it could initially do a simpler audit using a checklist or indicators and carry out a detailed audit during the strategy period. Any issues raised by the detailed audit could then be considered when the strategy is reviewed.

126. If they do not choose to carry out a formal audit, they must be satisfied that they have accurate and up-to-date information they can use to inform the preparation of the strategy. The lead person or planning group may find it helpful to refer to the Department for Education and Skills Building Bulletin 94 - Inclusive School Design¹⁹, which provides useful guidance on carrying out accessibility audits of schools and improving accessibility.

127. The planning group should also be clear from the start about what can and cannot be changed. For example, some of a school's buildings may have listed building status. Therefore, the scope for physical alterations may be limited and the group must make sure that they are aware of what alternative arrangements or alterations they can make to improve physical access.

128. Any audit carried out should not just consider physical access to the school. 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 forms, the use of inclusive teaching methods and the school's experiences of and attitudes towards pupils with disabilities and inclusion. Self-assessment tools like How good is our school?²⁰ can be useful in carrying out these audits. Although the focus of the strategy should be on access to education, if the school has boarding houses, then access to facilities in these should also be addressed.

Initial Consultation

129. How widely a group consults before drafting its strategy will depend to a large extent on how much knowledge and experience those on the planning group already have in determining where improvements will be needed. The planning group may need to go to those with relevant expertise, such as voluntary organisations and design professionals, to seek advice on improvements for pupils with certain disabilities. They may also wish to develop links with those in other schools or with their local authority to share good practice and get ideas from them.

Drafting the accessibility strategy

130. When they start to draft the strategy, the planning group should have information about all the barriers or potential barriers to participation. 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 long document.

131. 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 (or current demands) which need to be addressed before other improvements are carried out.

132. In deciding what disabilities should be covered by the accessibility strategy, the planning group should look at Appendix One of the Disability Rights Commission's Code of Practice for Schools (pages 117-122) for an explanation of which pupils are considered as disabled under the Disability Discrimination Act. Ultimately, in the case of a complaint under the DDA, it is for the Sheriff Court to decide whether or not a pupil is defined as disabled. Broadly speaking, pupils who might be planned for in the accessibility strategy include those in the following groups:

• Physical disabilities (pupils who use wheelchairs, those with other mobility difficulties (such as cerebral palsy), those who need help changing, toileting or eating and so on);
• Sensory impairments (pupils who are blind/have a visual impairment, deaf/ have a hearing impairment or deafblind);
• Learning difficulties (those with moderate, severe, complex or profound learning difficulties (these difficulties might be the result of a disability, such as Down's Syndrome), as well those with specific learning difficulties, such as dyslexia or dyspraxia;
• Autistic Spectrum Disorders (pupils with classic/childhood autism, Asperger's Syndrome or high functioning autism who will have problems with social interaction, communication and imagination);
• Language and communication disorders (such as pupils with a specific language impairment);
• ' Hidden' disabilities (pupils with epilepsy, diabetes, severe asthma or mental health problems (such as depression or eating disorders)).

However, clearly this list should be used with caution because there will be some pupils with these types of difficulties, who may not be considered as disabled under the DDA (although this does not mean that schools should not plan for them) and many other, less common, disabilities which are not on this list. Similarly, accessibility strategies are likely to focus more on certain groups of disabilities than others - depending on the circumstances of each school.

133. The group may find it helpful 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 and needs which either do not fit into the three specified categories or which span all three. For example, the group may recognise that there is a need to improve awareness amongst staff and pupils about disability and promote positive attitudes towards inclusion.

134. In considering the list of barriers and suggested improvements, the group should rank these in broad terms as short, medium and long-term priorities. These may include some improvements which have been already planned or are underway, but have not been completed, such as an ongoing programme of improvements or training. 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.

135. The group should then decide which of these priorities it can realistically tackle over the period of the strategy. The strategy should 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 start to be addressed in the first accessibility strategy. Some long-term priorities might start to be addressed in the first strategy, such as rolling programmes of training for 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

136. Bodies responsible for schools are required to resource adequately their accessibility strategies. This means that the body must recognise this as legitimate expenditure and include it within its budget. Therefore, the planning group will need to involve the bursar or finance manager to ensure that funding is set aside for the improvements that the school 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 may be limited. This means that some of the more expensive measures it wishes to take forward, such as physical alterations to school buildings (for example, installation of lifts) may need to be planned over a longer period to ensure that sufficient resources are available. The group will need to consider the demand or future demand in order to analyse the benefits against the cost of an improvement.

137. Scottish Ministers recognise that bodies responsible for independent sector schools will need to fund improvements themselves, either through existing budgets, through increases in fees or through fundraising and other sources. Ministers believe that all school education in Scotland should become more accessible and that pupils with disabilities should have equal rights to education in both the state and independent sector. However, at the same time, they clearly recognise the financial constraints on independent schools.

138. In their inspections, HMIE will take such constraints into account and recognise that large scale changes may take some time. Although accessibility strategies should be anticipatory and should cover prospective pupils, planning groups do not have to include large scale alterations (for example, to make the school accessible to pupils in wheelchairs) if there is not an apparent demand for this in the foreseeable future, and if there are other higher priority demands for improvements.

139. It is more likely that any significant physical alterations would be carried out either when existing buildings are being refurbished or when new buildings are being constructed. Contracts for the construction of new buildings should be informed by the accessibility strategy and long-term future requirements for space, lighting, physical access, colour contrasting and signage to make it easy for pupils to find their way around, etc. should be incorporated into any initial designs.

Setting goals and targets

140. 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 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 other 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 involvement of pupils with disabilities in extra curricular activities, school trips, sports and wider school life in general.

Further consultation

141. Schools should consult as widely as possible on their draft strategies, especially if they have not carried out much 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.

142. They 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. Consultation might take the form of a meeting or meetings to discuss the strategy, a written or web exercise asking for comments on the strategy or ad hoc telephone calls 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 who otherwise may find it difficult to give their views.

143. All school staff should be involved, not just teaching staff, and the group 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 good ideas to contribute. Similarly, the group 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. 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 as they will have to implement many of the changes and ensure that they are effective.

144. The planning group should consult with the following groups, either formally or informally, wherever relevant:

• pupils and parents/carers;
• the board of management;
• health professionals - therapists, doctors, school nurses, etc.;
• Social Work Services, where necessary;
• relevant national and local voluntary organisations (see Annex B) and equality groups as necessary;
• architects and other design professionals;
• other relevant bodies e.g. the SQA, sportscotland, etc.

Implementation and Publicising the Strategy

145. 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, such as the head teacher, should be given responsibility for driving forward implementation.

146. Schools must make a copy of their strategy available (within a reasonable time) 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 a form other than by e-mail or standard hard copy, 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. Such requests should be complied with as soon as is reasonably possible.

147. 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. All those consulted during the preparation of the strategy should be at least made aware of the final strategy. Staff, pupils and parents especially should be aware of how the strategy will impact upon them. Copies of the strategy might also be sent to relevant organisations and posted on the school's website.

Monitoring, Review and Evaluation

148. The planning group or individual responsible for implementation will need to review the strategy at regular intervals during its lifespan and beyond in the cycle, into the next strategy period. The planning group, if there is one, should meet formally at least once every year to review progress in implementing the strategy. The group should also review the strategy if individuals or organisations make a complaint that the accessibility strategy does not include certain important improvements which may be necessary or that the strategy has not been properly implemented.

149. The planning group should consider how they will aim to resolve disputes or reach a compromise with anyone who has a complaint. They should make sure that the school's complaints procedure can be used to deal effectively with complaints related to the accessibility strategy and that these procedures are well publicised.

150. If necessary, the accessibility strategy may need to be revised following a review. Revisions may be needed, for example, if certain changes 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 was not previously such a high priority). If the group wishes to make large or significant changes to the strategy, they should consult any relevant people before doing so and ensure that they make interested groups aware of the changes that have been made.

151. Towards the end of the three year period (or the period of the strategy if it 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 was been made.

152. This evaluation should give the planning group 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 planning group should then go through a similar process of consultation in developing the next strategy. The next strategy should start immediately the previous one ends.

153. 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 next strategy over others.

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