The Disabled Children’s Partnership responds to consultation on Education Otherwise Than At School
The Disabled Children’s Partnership has responded to the Government’s consultation on the future of Education Otherwise Than At School (EOTAS).
EOTAS is currently used where a local authority determines that it would be inappropriate for a child or young person with an Education, Health and Care Plan (EHCP) to receive their special educational provision in a school or college. Provision might instead take place at home or through a combination of different providers.
The Government is considering changes to how EOTAS is commissioned, overseen and quality assured as part of its wider SEND reforms. This includes proposals for children receiving EOTAS to be connected to a named school or college responsible for managing their arrangements, alongside consideration of national quality standards and how EOTAS provision should be reviewed.
DCP supports the principle of improving consistency, quality and accountability. However, we have significant concerns about reforms that frame EOTAS primarily as a temporary route back into school.
For some children and young people, EOTAS is not a stepping stone back to school – it is the most appropriate, and sometimes the only feasible, way for them to access education.
Our response is informed by a DCP survey of 89 parents whose children currently have EOTAS packages. Their responses demonstrate just how complex and overlapping these children’s needs can be. Of those responding, 73% described autism, ADHD or other neurodevelopmental needs, 54% mental health or anxiety-related needs, 47% school trauma, autistic burnout or emotionally based school avoidance/non-attendance, and 42% sensory processing or sensory sensitivity.
Families also told us about the difference EOTAS can make when it works well – enabling children to recover from trauma, rebuild trust, improve their wellbeing and re-engage with education.
Our response highlights several areas that must be addressed as the Government considers its next steps:
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EOTAS must remain a protected educational pathway
For some children, even a significantly more inclusive school system will not be able to provide an environment in which they can safely access and benefit from education.
DCP is therefore calling for EOTAS to remain a statutory educational pathway within the existing Section 61 framework, with EOTAS provision included within a child’s EHCP and families retaining their right to appeal decisions at Tribunal. Decisions must be based on individual need rather than the availability of placements or eligibility thresholds.
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Returning to school should not automatically be the goal
While better inclusion in mainstream and specialist schools could reduce the number of children who need EOTAS, returning to school will not be appropriate for every child.
Our response warns against measuring the success of EOTAS primarily by whether a child returns to school. Instead, success should be based on meaningful outcomes including wellbeing, engagement with learning, confidence, relationships and progress.
Where returning to school is appropriate, it should happen gradually, with the child and family involved in the decision, support from professionals who know them and the flexibility to pause or reverse the transition if it is not working.
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Frequent reviews risk adding pressure rather than improving provision
DCP does not support proposed three-monthly reviews of EOTAS arrangements.
For children who may have experienced trauma and spent significant periods unable to access education, building relationships and trust can take considerable time. As our response highlights, it may take months simply to identify suitable provision and build a relationship with a new professional – and much longer before changes in wellbeing or educational outcomes become visible.
Reviews should therefore be triggered by evidence that EOTAS is no longer meeting a child’s needs, rather than by an arbitrary timetable.
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Commissioning must not make an already fragmented system more fragmented
We are concerned that making individual schools responsible for commissioning EOTAS could increase inconsistency and fragmentation.
Many children receiving EOTAS have complex, overlapping needs requiring input across education, health and care. The school named to oversee their package may also have no existing relationship with the child or understanding of their needs.
Instead, DCP proposes that local authorities retain responsibility for agreeing, funding and quality-assuring EOTAS, with an independent organisation coordinating provision and helping families navigate the system. Every child should have a named EOTAS coordinator, with national standards helping to ensure consistent, high-quality provision.
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Reform must be based on a better understanding of who needs EOTAS
Our survey suggests children receiving EOTAS have highly complex and overlapping profiles of need which are not always adequately reflected in national data.
For example, 34% of respondents described a Pathological Demand Avoidance (PDA) profile and 11% eating disorders or related needs. Our response argues that the interaction between neurodevelopmental, sensory and mental health needs needs to be better understood when considering whether a school environment can meet an individual child’s needs.
DCP is calling on the Department for Education to undertake further research, engagement and piloting to better understand the EOTAS population, including the specialist provision that would need to be expanded to enable more children to access school where that is right for them.
Getting EOTAS reform right
Families tell us that good EOTAS can be transformative. Personalised, flexible provision can give children who have been unable to access education the opportunity to recover, rebuild relationships and begin learning again.
But families also describe lengthy battles to secure support, inconsistent provision and poor accountability. Reform should address those problems rather than remove or weaken a pathway that some children fundamentally need.
Ultimately, a more inclusive school system should mean fewer children need EOTAS – but inclusion cannot mean requiring every child to learn in a school.
For those children whose needs cannot safely or effectively be met there, EOTAS must remain a legitimate, protected and properly funded route to an education they can actually access.