As a network of non-school Alternative Provision (AP) providers, we welcome the ambition of the SEND reform to create a more inclusive, consistent and less adversarial system. The focus on earlier intervention, clearer standards, and improved accountability is both necessary and overdue.

However, there remains a critical question at the heart of these reforms:

What happens to the children who are not on a school roll?

This group includes some of the most vulnerable young people in our system, particularly children in care who may have been moved out of the area, are experiencing significant trauma, or are unable to access formal education due to exclusion, mental health crisis, or unmet need.

The Real Risk of Invisibility

The reform proposes stronger monitoring of pupil movement, particularly around off-rolling and exclusion. While this is a positive step, there is currently limited clarity on how these mechanisms apply to children who are not on any school roll at all.

Without a formal placement:

• A child’s needs may not trigger statutory SEND processes.
• Oversight becomes fragmented across services.
• Responsibility risks becoming unclear.

The result is a system where the most vulnerable children are at risk of becoming effectively invisible.

The Critical Role of Virtual Schools

For children in care, there is already a structure designed to prevent this invisibility – the Virtual School.

Virtual Schools have a statutory responsibility to:

• Promote the educational outcomes of children in care.
• Track attendance, attainment, and progress.
• Provide strategic oversight across placements and provisions.

However, within the context of SEND reform, their role becomes even more critical.

If a child is not recognised as being “on roll”, including on the roll of a Virtual School, they risk being excluded from the very mechanisms designed to support them.

This has significant implications:

• Access to Individual Support Plans (ISPs) and SEND processes is often triggered through educational placement.
• Funding, accountability, and oversight are typically tied to on-roll status.
• Multi-agency coordination is more effective when a child is formally recognised within an education system.

Why “On Roll” Status Matters

Under the reform, much of the proposed support including SEND planning, early intervention, access to specialist services, monitoring and accountability is built around the assumption that a child is on a school roll.

For children in care who are accessing non-school AP, receiving EOTAS packages and/or not yet ready for formal education, there is a real risk that they sit outside these systems, unless their educational status is clearly defined.

Recognising children as on roll with a Virtual School is therefore essential.

It ensures:

• They remain visible within the education system.
• Their needs can trigger SEND support processes.
• There is clear accountability for outcomes.
• They can access the same entitlements as their peers.

EHCPs, ISPs and the Question of Protection

Education, Health and Care Plans (EHCPs) will remain within the reformed system, but with changing thresholds and the introduction of Individual Support Plans (ISPs), the landscape is shifting.

For children not on a school roll:

• Lack of an EHCP or movement away from EHCP entitlement may mean reduced legal protection and funding certainty.
• ISPs, while broader in reach, may rely on school-based systems and internal complaint processes.

This raises an important concern:

• What safeguards exist for children who are not in a school setting to access or challenge provision?
• For traumatised children in care, who may already experience delays in assessment or disrupted engagement with services, the risk of missing or losing statutory protection is significant.

A System Built Around Schools

A central strength of the reform is its emphasis on:

• Early identification
• Evidence-based intervention
• Expansion of specialist services

However, these developments are predominantly school-based or school-linked.

For children who are unable to access school due to trauma:

• The expectation of engagement within a formal setting is likely to be unrealistic
• Access to support is likely to be delayed until a placement is secured
• Opportunities for early intervention may be missed entirely

This highlights a key gap:

The system assumes readiness for education, rather than recognising that for some children, readiness must be built first.

The Reality for Children in Care

Children in care are disproportionately affected by:

• Disrupted education
• Exclusion and poor attendance
• Trauma, attachment difficulties, and mental health needs

These are not new challenges but within the context of reform, they present heightened risk.

If a child is off roll, out of area and/or not yet engaged in an education setting they are significantly less likely to benefit from:

• Structured SEND planning (ISPs)
• Specialist provision pathways
• Consistent oversight and accountability

EOTAS and the Need for Clarity

Education Other Than at School (EOTAS) remains a crucial but under-defined element within the reform landscape.

There is an urgent need for:

• Clear statutory guidance on EOTAS
• Recognition of non-school and community-based provision
• Defined pathways for children who are not yet able to access formal education

Without this, there is a real risk that children accessing term-time off-site provision, therapeutic education and remote or bespoke packages will fall between policy frameworks.

Balancing Opportunity and Risk

The SEND reform does offer important opportunities.

Potential Benefits:

• A statutory Individual Support Plan for all children with SEND.
• Increased investment in specialist services.
• Greater scrutiny of pupil movement and off-rolling.

However, key risks remain:

• Children without a school roll may remain outside the system’s core mechanisms.
• Reduced reliance on EHCPs may weaken legal protections for the most complex cases.
• Internal complaint processes linked to ISPs may lack the independence of tribunal routes.
• Expansion of services may not yet reach community-based, trauma-informed provision.

The Role of Non-School AP

Non-school AP providers are uniquely positioned within this landscape.

We effectively:

• Engage children before they are ready for school.
• Provide therapeutic, relationship-based environments.
• Act as a bridge between crisis and re-engagement.

For many children, particularly those with complex trauma:

• Stability, trust, and regulation are not outcomes of education – they are the foundations that make education possible.

It is also important to also acknowledge that the new non-school AP standards reference a 12-week timeframe for placements. While this may support accountability and structured review, such a short period does not reflect the lived reality of children with complex trauma.

A 12-week timeframe is unlikely to provide sufficient opportunity for the therapeutic, relational work required to enable a child to feel safe, rebuild trust, and become ready to learn and is almost certain to result in a failed premature transition to an environment that is not yet ready to meet needs.

Moving Forward: A Call for Integration

If the SEND reform is to truly meet its ambition, it must:

• Recognise children not on a school roll as a distinct and priority group
• Provide clear statutory pathways for those accessing EOTAS and non-school provision
• Ensure SEND processes can be triggered and maintained outside of school settings
• Strengthen collaboration between education, care, and health systems
• Value non-school AP as a key partner in early intervention and recovery

Final Reflection

The intent of the SEND reform is clear: a more inclusive, equitable system for all children. But inclusion cannot depend on a child’s ability to access a school building.

For children experiencing trauma, the pathway into education is often indirect, relational, and long-term.

Recognising children in care as being on roll through Virtual Schools is not an administrative detail – it is a safeguarding and equity issue.

The implications of fixed timescales within trauma-informed practice is a critical issue in its own right and one that warrants further exploration. It is a conversation I’m sure we will return to in a future blog.

Without flexibility around timescales, and without explicit mechanisms to support those not on a school roll, there is a real risk that the children who need the system most will remain just beyond its reach.

As a network of non-school AP providers, we stand ready to be part of the solution, but we must first ensure these children are seen, recognised, and given the time they need to recover, rebuild, and re-engage with education.