SEND Reform: Putting Children and Young People First

Opening statement

Aphantasia Academy Ltd welcomes the ambition behind these reforms. We support the move towards earlier support, clearer inclusion expectations, stronger accountability, better use of evidence, and a more coherent system of support across education phases.

This response focuses on an important gap in the current SEND landscape: invisible cognitive differences that can significantly affect learning, participation, emotional wellbeing, and engagement, but are often missed because they do not fit neatly within established categories. We ask the Department for Education to consider children and young people with aphantasia, anendophasia, and severely deficient autobiographical memory, whether or not those differences sit alongside a recognised SEND profile.

Our central submission is this: inclusion cannot be judged only by what a child can do outwardly. It must also consider what schools assume a child can do inwardly. If support depends on mental imagery, inner speech, vivid autobiographical recall, or easy access to internal emotional states, some learners will be excluded by design even where good intentions are present.

Q1. How can we make sure children, young people and their families have a genuine say in these decisions?

Children, young people and families should be involved not only in strategic consultation but in the design of support, guidance, training materials, and examples of practice. For groups whose needs are often invisible or poorly understood, co-production is especially important.

• Require consultation and co-production to include children and families whose barriers are often masked or misread, not only those attached to well-recognised labels.
• Build parent and young person voice into ISP review processes in a structured way.
• Encourage settings to ask not just what is hard, but what school assumes a child can do in their mind that may not be available to them.
• Use lived-experience panels when developing National Inclusion Standards, training content, and reasonable-adjustment guidance.

Q2. How can we make sure that high-quality evidence and best practice inform decisions about SEND?

We support the emphasis on evidence-based practice but recommend a broad interpretation of evidence that includes practitioner expertise, lived experience, case-based learning, and emerging research, especially in under-recognised areas.

• Create a process for identifying under-recognised barriers that are repeatedly surfacing in practice, even where the formal evidence base is still developing.
• Update National Inclusion Standards regularly as emerging evidence develops.
• Develop case-study libraries showing how barriers present in day-to-day educational practice.
• Support research partnerships between universities, schools, and specialist organisations to evaluate practical adaptations.
• Distinguish clearly between unvalidated screening claims and low-risk, barrier-based adjustments that improve access regardless of diagnosis.

Q3. How can we ensure that children are best supported by the Universal offer?

The Universal offer will work best when it explicitly challenges hidden assumptions in mainstream teaching and wellbeing practice. Many children do not need specialist input first. They need mainstream practice to stop asking them to do inaccessible things.

• Include teaching materials that do not assume all pupils can visualise, mentally rehearse, or reflect through vivid recall.
• Provide multiple access routes for core tasks, including verbal, written, sensory, concrete, and externally scaffolded alternatives.
• Offer guidance for staff on phrases and activities that may unintentionally exclude, such as picture this, replay what happened, listen to your inner voice, or imagine your calm place.
• Include non-visual and non-memory-dependent curriculum adaptation examples.
• Ensure universal pastoral and mental health support does not assume vivid internal imagery or autobiographical reliving.

Q4 to Q6. Targeted, Targeted Plus, and Specialist support

Across all three layers, support should begin with a careful description of the barrier, not simply a description of the symptom. A child may look disengaged, resistant, emotionally avoidant, or forgetful when the true issue is that the strategy being used depends on internal capacities they do not have in the assumed way.

• Use barrier-based formulation that records what the child finds inaccessible and in which contexts.
• Build short-cycle review into plans to test whether the support method itself is cognitively accessible.
• Train staff to recognise when non-response may reflect mismatch rather than unwillingness.
• Prompt ISPs to record barriers to learning in plain language.
• Preserve flexibility within Specialist Provision Packages for needs that cut across current categories.
• Ensure specialist placements and outreach services do not rely on inaccessible internal processes either.

Q7. Mental health and wellbeing support

Mental health and wellbeing support must itself be cognitively accessible. Many current approaches assume that children can picture calming scenes, replay past events, narrate or capture inner thoughts, or identify emotions through internal scanning. For some children, those routes are limited or absent.

• Prioritise concrete, externalised, relational, and body-based approaches rather than over-reliance on visualisation or introspection.
• Train staff on why some children appear to have low emotional insight when the issue may be the method used to access emotion.
• Offer alternatives to memory-heavy reflective work.
• Place stronger emphasis on felt safety, routine, relational attunement, and practical coping.

Q8. Refreshed areas of development

We partly agree that the refreshed areas of development will help educators understand and address barriers to learning and participation. However, they do not yet clearly capture invisible differences in imagery, inner speech, and autobiographical memory.

• Add supplementary guidance on invisible cognitive-access barriers.
• Include examples in the National Inclusion Standards showing how internal imagery, inner speech, and autobiographical recall affect learning and wellbeing.
• Help staff distinguish between behavioural presentation and underlying cognitive-access barriers.

Q9 & Q10. Early years

In the early years, effective joint working requires shared language about barriers rather than waiting for diagnostic certainty. Parent observations should be able to follow the child into nursery and school transition.

• Develop joint guidance for early years practitioners, health visitors, and SEND practitioners on signs that a child may process internally in a different way.
• Use progress checks and reviews to look at patterns in remembering, pretend play, communication, and engagement, without turning those observations into simplistic screening claims.
• Use observation, dialogue with parents, and practical support as the first response.

Q11 to Q14. Training, workload, and the SENCO role

National training should cover how to identify barriers rather than over-rely on labels, how hidden assumptions in teaching and support can exclude pupils, and how to interpret apparent disengagement, resistance, or low insight more carefully.

• Include case-based examples of aphantasia, anendophasia, and autobiographical memory difficulties in national training.
• Reduce workload through concise ISP templates, model wording, and integrated digital systems.
• Support SENCOs to lead staff understanding of hidden barriers and challenge inaccessible default practices.
• Ensure SENCO leadership connects with attendance, pastoral, and safeguarding interfaces where SEND issues may be misread.

Q15 to Q17. ISPs and transition

Families will trust Individual Support Plans if they are specific, understandable, co-produced, and clearly linked to real barriers and practical provision. For many children, the difference between access and failure lies precisely in the daily method.

• Describe the barrier in plain language.
• State clearly what staff will do differently.
• Explain what the child is not expected to do if that route is inaccessible.
• Include family insight and review whether the support worked.
• Ensure transition documents record how the young person learns, regulates, and accesses support, not only what provision they previously received.

Q18 to Q24. Inclusion Bases, Experts at Hand, Specialist Provision Packages, EHCPs

We support Inclusion Bases and the Experts at Hand model where they help children remain meaningfully connected to mainstream education and where they provide specialist input early enough to prevent escalation.

• Ensure Inclusion Bases do not simply provide more of the same inaccessible support in a smaller room.
• Include access to specialists who can advise on under-recognised barriers, not only established diagnostic profiles.
• Design Specialist Provision Packages around function and access as well as category.
• Treat day-to-day provision recorded in ISPs as critical rather than secondary.
• Ensure early years fast-track routes do not overlook children whose needs are significant but less obvious.

Q25 to Q31. Needs assessment, parental choice, AP, independent special schools, funding

Needs assessments should consider parent and family insight, professional observation across contexts, response to prior interventions, developmental history, and the evidence of what methods are and are not accessible.

Explicitly consider whether a child can access expected internal processes such as mental rehearsal, inner speech, autobiographical recall, and mental imagery where these are central to school demands.

• When naming settings, consider not only provision on paper but whether the setting can deliver cognitively accessible support.
• Ensure temporary placement decisions in alternative provision review whether unmet cognitive-access needs contributed to the placement.
• Do not let cost regulation reduce access to rare expertise for low-incidence or poorly recognised needs.
• Hold settings accountable for whether funding improves access, participation, attendance, belonging, and outcomes, not only for how it is itemised.

Q32 to Q39. Local partnership, family guidance, complaints, and final recommendations

We support stronger local partnership and strategic planning. However, local systems will only improve if they include voices able to speak to under-recognised needs, emerging evidence, and patterns of children being misunderstood in mainstream systems.

• Ensure local SEND groups include expertise on under-recognised barriers and hidden learner mismatch.
• Provide families with national plain-language guidance on hidden barriers to learning, reasonable adjustments, and what a good ISP contains.
• Include a SEND specialist on complaint panels where the complaint relates to SEND and equip panels to consider whether support was cognitively accessible.
• Use this reform process to ensure that children whose inner experience falls outside the norm are not left behind in a system designed to improve inclusion.

Closing statement

We would welcome further engagement with the Department for Education on how invisible cognitive differences can be better reflected within inclusive practice, staff training, support planning, and reasonable-adjustment guidance.

A genuinely inclusive system must recognise that some children cannot simply picture it, replay it, self-talk through it, or draw on a past experience in the way education often assumes. If these reforms are to succeed, they must include children whose inner experience falls outside the norm as well as those whose needs are already more visible to the system.

Key policy sources referenced

• Department for Education. Every Child Achieving and Thriving. Published 23 February 2026.
• Department for Education. SEND reform: putting children and young people first. Consultation document, including Appendix C consultation questions.
• Department for Education. Specialist Provision Packages consultation material.