Governors Response to the Consultation on the proposed new National Funding Formula, March 2017
Many of the questions are complex. We have answered in more detail where we felt we had clear concerns to voice about the possible impact on Anson.
Q1: In designing our national funding formula, we have taken careful steps to balance the principles of fairness and stability. Do you think we have struck the right balance?
No
The proposals do not provide enough financial stability for schools. All primary schools in our borough, Brent, stand to lose significant amounts of funding, at a time when we are all experiencing rising cost pressures, which amounts to a real terms cut.
The proposals will, we believe, result in cutbacks being made and we are worried we will not be able to manage the funding reductions whilst maintaining or improving performance levels.
We support the call by London Councils to allocate an additional £335 million to the national funding formula to prevent cash losses to individual schools.
At Anson Primary School:
Q2: Do you support our proposal to set the primary to secondary ratio in line with the current national average of 1:1.29, which means that pupils in the secondary phase are funded overall 29% higher than pupils in the primary phase?
No (ratio closer)
In Brent, analysis shows that the proposals result in the primary to secondary ratio moving from the desired 1:1.29 up to 1:1.34.
We ask that the Department for Education perform a regional analysis to ensure the proposals are not unintentionally moving funding from the primary to secondary phase in areas such as London.
We are concerned that the Universal Infant Free School Meal provision will have reduced applicants for Free School Meals in primary schools and that deprivation levels will be underreported.
At Anson Primary School, we are already helping children starting education with lower levels of ability to catch up by end of KS2, plus addressing EAL children arriving at atypical times, often with no prior educational record. These children are entitled to the educational chances available through secondary school, but restricting primary funding in favour of secondary is a false economy.
Q3: Do you support our proposal to maximise pupil-led funding, so that more funding is allocated to factors that relate directly to pupils and their characteristics?
Not answered
While we do not have an absolute position on this question, from our experiences at Anson Primary School, we would propose linking any pupil-led funding with a mobility funding factor.
Q4. Within the total pupil-led funding, do you support our proposal to increase the proportion allocated to the additional needs factors (deprivation, low prior attainment and English as an additional language)?
Yes. However we are concerned that the FSM measure is not accurately capturing deprivation levels in Brent.
Allocating more funding in the formula on additional needs factors highlights the inconsistency whereby Pupil Premium, also allocated on deprivation measures, is allocated at a flat rate across the country. Pupil Premium should therefore also be adjusted by an Area Cost Adjustment to ensure fairness in school funding.
Q5. Do you agree with the proposed weightings for each of the additional needs factors?
No Not clear which answer to select – 4 sections, each with 3 options!
We are concerned that the FSM measure underreports deprivation and would favour greater weighting to be made towards the IDACI measure.
We would support some rebalancing in the weighting between low prior attainment and English as an Additional Language. Children with EAL need additional support and resource from schools, so this factor should be increased.
In addition, children entering schools at atypical times frequently have EAL, and increasing this allocation would compensate for the lack of a mobility funding factor. It is not clear how children with no prior attainment scores, who again are likely to have EAL would be funded.
Q6. Do you have any suggestions about potential indicators and data sources we could use to allocate mobility funding in 2019-20 and beyond?
A mobility funding factor is strongly welcomed. Pupil mobility creates additional cost pressures for schools and additional needs for individual pupils.
We support London Councils’ call to investigate the use of the national pupil database to create a pupil mobility funding factor.
Q7. Do you agree with the proposed lump sum amount of £110,000 for all schools?
No (allocate a higher amount)?
No. Financial viability of small schools is not just a rural issue. Smaller schools such as those with one form of entry serve their community but cannot always expand in a place like London where land is so expensive. Smaller schools should receive additional funding.
Q8. Do you agree with the proposed amounts for sparsity funding of up to £25,000 for primary schools and up to £65,000 for secondary, middle and all-through schools?
Not answered
Q9. Do you agree that lagged pupil growth data would provide an effective basis for the growth factor in the longer term?
As school balances decline, local arrangements will be needed to fund year on year growth.
We are concerned that this lag could lead to cash-flow problems, and make budgeting harder.
Q10. Do you agree with the principle of a funding floor that would protect schools from large overall reductions as a result of this formula? This would be in addition to the minimum funding guarantee.
Yes
We agree with the principle of a funding floor, but this should be set at current funding levels rather than -3%. Funding protections should be enhanced with additional resources.
Q11. Do you support our proposal to set the floor at minus 3%, which will mean that no school will lose more than 3% of their current per-pupil funding level as a result of this formula?
No (floor should be higher)
There is no evidence that schools can manage a funding cut of 3% alongside other cost pressures without impacting on school standards.
At the very least current funding levels should be protected.
Q12. Do you agree that for new or growing schools the funding floor should be applied to the per-pupil funding they would have received if they were at full capacity?
No answer
Q13. Do you support our proposal to continue the minimum funding guarantee at minus 1.5% per pupil? This will mean that schools are protected against reductions of more than 1.5% per pupil per year.
No (funding guarantee should be higher)
We support the continued use of a Minimum Funding Guarantee to provide more financial certainty for schools’ medium term financial planning.
No school should lose any funding as a direct result of the implementation of the National Funding Formula. After its introduction, the process of refreshing the data behind the funding formula each year is likely to cause further turbulence for schools. It is therefore essential that sufficient investment is introduced into the funding system each year to protect against disruption.
Q14. Are there further considerations we should be taking into account about the proposed schools national funding formula?
The School National Funding Formula should be considered alongside the Pupil Premium funding. We believe that an area cost adjustment should also be applied to the Pupil Premium to ensure fairness across the funding system.
Our particular concerns at Anson Primary school are
we have to pay London weighting salaries, but do not qualify as an inner London school for funding
we have a tight site with very limited scope for expansion. Classrooms built for 20 pupils are already accommodating many more
we have a high proportion of children with very variable additional needs some of whom need bulky equipment or resources to support them which is further pressure on space as well as staff training
the school is already forced into resourceful and flexible solutions to support the spread of needs amongst the children attending which will be impossible on much tighter budgets
Chapter 5 – Central Schools Services Block
Q15. Do you agree that we should allocate 10% of funding through a deprivation factor in the central school services block?
Yes. Local authorities in more deprived areas are likely to incur higher costs.
Q16. Do you support our proposal to limit reductions on local authorities’ central school services block funding to 2.5% per pupil in 2018-19 and in 2019-20?
Yes. This will enable longer term planning, and avoid sudden disruption to services.
Q17. Are there further considerations we should be taking into account about the proposed central school services block formula?
Q18. Is there any evidence relating to the 8 protected characteristics identified in the Equality Act 2010 that is not included in the equalities impact assessment and that we should take into account?
Anson Governors also responded to Part 2: High Needs consultation:
Q1: In designing our national funding formula, we have taken careful steps to balance the principles of fairness and stability. Do you think we have struck the right balance?
No
The proposals will not produce the stability required by the High Needs education sector in Brent.
The proposals will not allow for the growth in demand for High Needs Provision, and do not adequately fund the mix of provision developed over time in our borough in response to the needs of local children.
As the proposals make it likely that no additional funding will be allocated to Brent in the medium term, this leaves the increase in demand and other school cost pressures effectively unfunded.
The pressure this puts on the High Needs block will impact on all types of provision, causing instability in the funding allocations for:
Early Years SEN provision
Special provision
Support for pupils in mainstream primary and secondary schools
19-25 in high needs education
SEN support services across the borough.
Q2: We are proposing a formula comprising a number of formula factors with different values and weightings. Do you agree with the following proposals?
• Historic spend factor – to allocate to each local authority a sum equal to 50% of its planned spending baseline
• Basic entitlement – to allocate to each local authority £4,000 per pupil
No (not clear which option to select – two sections, three options for each)
No. The proposals do not result in adequate funding to support High Needs provision in Brent.
Q3: We propose to use the following weightings for each of the formula factors listed below, adding up to 100%. Do you agree?
• Population – 50%
• Free school meals eligibility – 10%
• IDACI – 10%
• Key stage 2 low attainment – 7.5%
• Key stage 4 low attainment – 7.5%
• Children in bad health – 7.5%
• Disability living allowance – 7.5%
No (not clear which option to select – 7 sections, three options for each!)
It is not clear how these proxy measures actually relate to levels of High Need and the mix of required provision in any specific local authority area. Most of these measures are used elsewhere in the school funding system as a measure of low level special educational need. A stronger evidence base is needed to demonstrate how they relate to demand for actual High Needs provision.
We question how well these indicators will accurately measure the need or special provision required for Early Years children and young adults 19-25 years old. For example, Disability Living Allowances are unlikely to be in place for Early Years SEN children.
Pupil mobility is also a cost driver in High Needs provision and we feel this should be reflected in the funding formula.
Q4: Do you agree with the principle of protecting local authorities from reductions in funding as a result of this formula? This is referred to as a funding floor in this document.
Yes
Q5: Do you support our proposal to set the funding floor such that no local authority will see a reduction in funding, compared to their spending baseline?
Yes
Though this is qualified support for the proposal. Given the rising cost pressures on schools, a cash flat settlement is in effect a funding cut. Local Authority funded schools are already pressured financially without any real terms cut in funding.
At Anson we are already experiencing Local Authority cuts in Higher Needs support, leaving the school exposed and needing to directly fund services for children that they should be entitled to anyway. This has an impact on the funding available for overall provision for the school population.
Q6: Do you agree with our proposals to allow limited flexibility between schools and high needs budgets in 2018-19?
No
School forums should be empowered to make these decisions locally as this is an established and proven mechanism for making decisions in the interests of the entire local education community.
Whilst we feel there is value in enabling local school leaders to make decisions, this cannot compensate for adequate funding which keeps pace with rising costs across all funding blocks.
The planning and funding of Free Schools in the High Needs sector should also be reviewed when considering the role of local decision makers.
Q7: Do you have any suggestions about the level of flexibility we should allow between schools and high needs budgets in 2019-20 and beyond?
Defined limits are welcomed, but it remains important that each funding block is adequately funded.
Q8: Are there further considerations we should be taking into account about the proposed high needs national funding formula?
The proposed funding arrangements are not in line with the level of need and local provision established in Brent.
The needs of pupils are not reflected in the proposals. The number of EHCPs is not considered, nor the numbers of pupils requiring support as captured by council SEN banding systems.
A banding system may also help with dealing with the inequity between placement costs in the independent and state sectors. Currently independent sector charges are frequently much higher.
A cash flat settlement ignores the cost pressures experienced by all schools, but also the increased pressure felt by the High Needs education sector in the context of cuts elsewhere. National Health and social care budgets are being cut in real terms, with the result that special schools are picking up health costs in order to provide for the needs of individual children. Children funded in the High Needs block disproportionately access NHS services, and so are disproportionately affected by the funding pressures this service is under. This will be compounded by real term cuts to High Needs education funding.
At Anson Primary School we remain committed to accessing the proper entitlement for each child. However, the cost thresholds for the school on EHCPs and the withdrawal of higher needs funding if a child moves from the school in-year when staffing and other related costs cannot be recovered by the school in-year, is already leading us towards compromising our commitment. We need relief, not further pressure, for this Higher Needs funding.
Q9: Is there any evidence relating to the eight protected characteristics as identified in the Equality Act 2010 that is not included in the Equalities Analysis Impact Assessment and that we should take into account?
The proposals would mean that children with High Needs in Brent will be at risk of being disadvantaged which is the basis for equalities legal challenges.
A cash flat or real terms cut in funding will impact upon provision for disabled children. The local offer and support will be restricted resulting in less access and opportunity for disabled children.