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News and Discussion Forum

This forum is for professionals working with pupils with learning difficulties and disabilities (PMLD, SLD and MLD). There are articles and news items from Peter Imray; our Director of Developments and from other EQUALS Trustees. You can also read about new and exciting developments from the EQUALS charity.

We also welcome contributions from members, so should you wish to contribute an entire post, please email your item to  our Strategic Development Officer; Paul Buskin at


posted by Peter Imray on the 10th January 2020


The delivery of Relationships and Sexual Education (RSE) will become compulsory in English schools from September 2020. This has always been a necessary, though challenging subject to teach to pupils and students with profound and multiple learning difficulties and severe learning difficulties (Stewart et al, 2015) with or without an additional autistic spectrum condition, because the very nature of relationships is naturally flexible, movable, contextual and therefore engages with numerous abstract constructs and situations. One of these concerns the nature of masturbation, particularly in relation to where and when one can do it. It is relatively easy to teach about private and public and though the lessons may for some, take a long time to learn, they are learnable by most.

However, a very small number of people, usually the most complex with the greatest degree of learning difficulty and the highest level of need, may well find extreme difficulty in deferring sexual release and indeed, in understanding the necessity to defer sexual release. It has therefore become fairly common practice for special schools particularly, not only to allow pupils who are obviously in need to use a locked cubicle in a school toilet to masturbate, but also to actively encourage those who are obviously in need to do so. That is, it has become an essential part of the curriculum and teaching process to encourage learners to take responsibility for self-regulation. They can only do this if they can have access to an immediate solution, such as using a locked cubicle in a school toilet.

Part of my responsibilities as Director of Developments at Equals (a UK Based not-for-profit charity working for the educational interests of people with SLD and PMLD and their families) is to develop curriculum materials. In order to discover the latest thinking in the area of RSE and learning difficulties, I attended a one day course recommended by the Sex Education Forum (SEF) run by two very experienced workers in the field namely, Mel Gadd and Claire Lightley. They advised in the strongest possible terms, that the strategies evolved by special schools over a number of years are illegal and therefore invite prosecution of both students and staff.

This short paper is written with a desire to find areas of agreement that can overcome an apparently intractable contradiction. That is, whilst the argument on the illegality of the act of masturbation in a school toilet (or indeed in any public toilet) whether in a locked cubicle or not, is certainly factually correct, I would suggest that the Sexual Offences Act 2003, does not mean that:

‘if you allow or enable a person with learning disabilities to masturbate in a public place or where other members (especially other children) of the public access, such as a school or college toilet, you are potentially enabling or/and committing a sexual offence and placing the young person and yourself at risk of prosecution.” (Gadd, 2018)

Indeed, I am arguing that such advice is

(i) positively harmful to the mental well-being of a number of young people and adults with severe learning difficulties (SLD) and profound and multiple learning difficulties (PMLD);
(ii) in direct contravention of the Equality Act 2010 and Article 14 of the European Convention on Human Rights;
(iii) potentially and unnecessarily placing in physical danger those who are supporting young people and adults with SLD and PMLD, as well as other members of the public, other students and indeed the persons themselves;
(iv) in direct contradiction to the process of maximising independence in learners, particularly with regard to maximising opportunities for all learners in all circumstances to take control of, and be responsible for, their own behaviours.

Let me expand on these one at a time.

1. Literal enaction of Sections 17 and 71 of the Sexual Offences Act 2003, may well be positively harmful to the mental well-being of a number of young people and adults with SLD and PMLD.

Gadd and Lightley are rightly insistent that masturbation is a natural, normal and pleasurable activity, and that:

…..every young person with learning disabilities receives programmes of education on growing up, sex and relationships tailored to age and developmental ability. (Gadd, 2018 p5)

There are however a small but growing number of children, young people and adults, presenting with very complex needs (Pinney, 2017) for whom Carpenter (2011) has described schools as being ‘pedagogically bereft’. That is, their needs are so severe, so different, so complex, they do not fit into any category for whom the current education system has an answer. One thing is certainly clear; it is not possible to instruct these young people to do anything they don’t want to do and have any reasonable expectation that they will concur (Imray, 2018; Imray et al 2017).

Interestingly, two of the examples used (Gadd, 2018 p5 and Gadd, 2019 p7) talk of a young man with the developmental age of a six year old, and advises that he should wait until he gets home. In severe learning difficulties (SLD) terms, this is the equivalent of a very high functioning learner who is possibly able to defer gratification and fully understand the concept of waiting until he gets home. There are however, many with SLD, particularly those functioning consistently and over time within the lower levels of the P Scales, that is, well below the developmental age of six, and all with PMLD, who do not, and by definition, cannot, have this level of understanding. One might as well expect a 12 month old to stop crying on demand because this is not an appropriate place to cry.

Further, even the young man with the developmental age of 6 is unlikely to be able to do what other neuro-typical, conventionally developing teenagers in school can do and often do do; that is, ask to go the toilet when he wants to masturbate. As long as the neuro-typical, conventionally developing teenager doesn’t advertise the reason for going to the toilet, no-one is going to deny him. The neuro-typical teenager probably knows that it’s perfectly normal and natural to masturbate, works out that the only way he can concentrate on his school work is to relieve himself, and takes himself off, making sure to lock the cubicle door and not draw attention to himself. If someone with SLD, even a high functioning person with SLD, is to have the same right, we will have to teach him that it’s a positive thing to do. It is highly unlikely that he will be able to work this out for himself because this is generalising understanding and if he found this level of generalising easy, he wouldn’t have SLD.

We therefore have to spend a considerable amount of time positively teaching him that it is a good thing to go to the toilet to relieve himself when he is not able to suppress his sexual excitement, providing he follows certain basic rules, such as locking cubicle doors. It is, I would suggest, contradictory to argue that masturbation is normal, natural and good, but masturbating when one really needs to, is bad. Such a stance can only lead to confusion and misunderstanding and will quite possibly be extremely deleterious to his good mental health. We would not consider denying other natural desires; we accept that ensuring sufficient food, water, exercise, warmth, kindness, love etc is good for one’s mental health. If a learner desires food and water now, it would be perverse and even abusive to demand that the learner defers this desire for several hours; why should we do this for masturbation?

Given these conditions, it seems reasonable that we teach all those with learning difficulties, whether high functioning or not, a certain clear, basic principle. That is,

any form of sexual activity needs to take place in private, this means in places where other people are not and I can be by myself (Gadd, 2019).

This phrase is taken from the handout given on the day of the course. My argument is that a toilet with a locked door (wherever the toilet is) is a place where ‘other people are not and I can be by myself’.

Secondly, it can be argued that the Gadd and Lightley advice is in direct contravention of the Equality Act 2010 and Article 14 of the European Convention on Human Rights.

The nature of the law is that by and large, it operates under the principle of reasonableness. One can see this in the recent judgement of Judge Rowley (Sellgren, 2019).

Judge Rowley questioned whether the law as it stands within the Equality Act discriminates against children who habitually express challenging behaviour, which is itself part (and sometimes a very central part) of their SEND. The key lies in recognising that “aggressive behaviour is not a choice for children with autism”. In making this statement Judge Rowley held that:

“In my judgment the Secretary of State has failed to justify maintaining in force a provision which excludes from the ambit of the protection of the Equality Act children whose behaviour in school is a manifestation of the very condition which calls for special educational provision to be made for them. In that context, to my mind it is repugnant to define as ‘criminal or anti-social’ the effect of the behaviour of children whose condition (through no fault of their own) manifests itself in particular ways so as to justify treating them differently from children whose condition has other manifestations.”

We know, do we not, that expressed and overt challenging behaviour is a common feature of a number of conditions that fall within the SEND umbrella. Autism is certainly one, but it is also fairly common in those with severe learning difficulties, moderate learning difficulties and profound and multiple learning difficulties, and when these conditions are mixed, that is ASD plus SLD for example, it is even more likely (Emerson et al, 2014 for example). Indeed, challenging behaviour has long been regarded as being ‘normal’ for those with learning difficulties (Hewett, 1998). We know also that the nature of challenging behaviour is enormously disabling for those who are stuck in the cycle (O’Brien, 2016; Ashton, 2015 for example) and that challenging behaviour is defined by us.

‘Challenging behaviour’ is a socially determined construct. Reiteration of this construct and its accepted definition is necessary to focus assessment, formulation and interventions on the relationship between the individual and their environment, rather than on the elimination of behaviours. (Learning Disabilities Professional Senate, 2016, p4)

Imray (2018) argues that recognition of this has profound implications for how we, as educators, carers, advisors, supporters etc respond.

Let’s just deconstruct this statement, because this is very, very important. Challenging Behaviour, with capital letters and as a ‘category’ or as a label which we might assign to a child, young person or adult is not the same as severe learning difficulties or profound and multiple learning difficulties or autism. These are also categories or labels, but it is not possible to change them. A child who has SLD will grow into an adult with SLD and there is nothing anyone can do about this. It is not because of bad teaching, or bad schooling, or bad parenting; it is what it is. It might be considered to be an impairment, in the same way as having no right arm is, though it is not necessarily disabling, if we as a society choose not to make it so. (Imray, 2018 p7)

We can however, decide the opposite course and actively choose to make the impairment disabling. That is, we can (and often do) choose to disable, by for example, insisting that all children conform to our rules, do things our way, cope with situations and stresses that we can cope with, communicate in ways in which we communicate, are interested in things which we find interesting, obey rules which we are able to conform to, are conversant with and apply social rules which we have put in place etc, etc, etc. We do all of these things even when we know that children will have difficulties in doing so, and all of their behaviours are telling us that they have no interest in doing so. In such situations we should not be surprised when some children raise objections. And this is very much the point, the objections are highly likely to be physical expressions of challenging behaviour, often violent, often painful, because those who are expressing them have no other way because of their SEND. Children who express habitual challenging behaviours do not do so out of choice, they do so because they have no other way (Imray and Hewett, 2015).

Article 14 of the European Convention on Human Rights obliges us to reach decisions which do not involve us acting irrationally, given the information we have before us. It requires that all of the rights and freedoms set out in the Act must be protected and applied without discrimination. Discrimination occurs when one is treated less favourably than another person in a similar situation and this treatment cannot be objectively and reasonably justified.

Similarly, the spirit of the Equality Act is to state very clearly and plainly that we cannot use a person’s impairment as a reason to disable them. We would I’m sure regard it as ‘repugnant’ to suggest that someone without physical mobility should be excluded because they can’t get to their next classroom under their own volition. The issue relating to challenging behaviour, and indeed masturbation, is no different. Judge Rowley has (rightly) argued that the law must not be interpreted in a way that disadvantages those with SEND. Not offering a person an opportunity to sexually relieve him or herself in the same way that is open to those without a learning difficulty (by for example, innocently asking to go to the toilet) is effectively discriminating against that individual because of his/her learning difficulty.

3. The advice potentially and unnecessarily places in physical danger those who are supporting young people and adults with SLD and PMLD, as well as other members of the public, other pupils and indeed the persons themselves.

I don’t think I need to overly expand on this, because the arguments have already been made. Most with learning difficulties may be able to defer sexual relief, some will not. Those ‘some’ may well react in a negative manner, which may be physically violent in nature, and to be honest, who would blame them.

If a learner has communicated a basic request – I am hungry and need food, I am thirsty and need drink, I am cold and need warmth, I am frightened and need comfort, I am sexually frustrated and need relief – but this is being refused, it is not unreasonable that the person being refused gets annoyed. Why would they not? Clearly the level of that annoyance will vary from person to person, but those who are doing the refusing have to expect challenging behaviour, and no amount of admonitions, strong/strict voices, clear instructions etc. will overcome this crisis. The point is here that this is entirely unnecessary. All learners can be taught to take control of their own behaviour, providing they are given control over the resolution. If we are not willing or able to give them control, we mustn’t be surprised at the behaviour.

4. Lastly, and following on from the points above, the advice is in direct contradiction to the process of maximising independence in learners, particularly with regard to ensuring wherever possible, that all learners in all circumstances take control of, are responsible for, and crucially, are able to self-regulate their own behaviours.

We can, through repetition and constant over-learning, ensure that all learners with SLD at least understand

  • which parts of the body are universally private
  • that permission is central to touching others and being touched by others, especially on private parts of the body
  • that sexual acts such as masturbation must be conducted in a private space
  • that a private space means somewhere where I can lock the door, where other people are not and where I can be by myself
  • that I will be taught the exact geographical location of private spaces and public spaces in the environments that I normally inhabit such as school, home, out in my local community etc.

If we are reliant on members of staff telling learners what they are not allowed to do, and ensuring that they do not do what they are not allowed to do, the individual with learning difficulties will always be reliant on such people making the decision. Any notion of independence will be a sham since we are fostering a paternalistic relationship where those without learning difficulties always know best and will always be directive.

Peter Imray
9th January 2020


Ashton B (2015) Promoting Positive Behaviour in S Martin-Denham (ed) Teaching Children and Young People with Special Educational Needs and Disabilities. London. Sage.

Carpenter, B. (2011) Pedagogically Bereft!: Improving learning outcomes for children with foetal alcohol spectrum disorders. British Journal of Special Education 38 (1): 38–43.

Emerson, E., Blacher, J., Einfeld, S., Hatton, C., Robertson, J., & Stancliffe, R.J. (2014). Environmental risk factors associated with the persistence of conduct difficulties in children with intellectual disabilities and autistic spectrum disorders. Research in Developmental Disabilities, 35, 3508–3517.

Gadd M (2108) Common concerns and suggested solutions: Guidance document 2017. FPA Project Jiwsi.

Gadd M (2019) Masturbation: Working with people with learning disabilities. Lightly Consulting/Cwmni Addysg Rhyw/Sex Education Company.

Hewett D (1998). Challenging Behaviour is Normal in P Lacey and C Ouvry (eds) People with Profound and Multiple Learning Difficulties. London. David Fulton.

Imray P (2018) Turning the Tables on Challenging Behaviour (2nd ed). London. Routledge.

Imray P, Colley A, Holdsworth T, Carver G and Savory P (2017) Listening to Behaviours: adopting a Capabilities Approach to education. The SLD Experience. 76: 3-9.

Imray P and Hewett D (2015) Challenging Behaviour and the curriculum in P Lacey, R Ashdown, P Jones, H Lawson and M Pipe (eds) The Routledge Companion to Severe, Profound and Multiple Learning Difficulties. London. Routledge.

Learning Disabilities Professional Senate (2016) Challenging Behaviour: A Unified Approach. London. The Royal College of Psychiatrists.

O’Brien, J. (2016) Don’t Send Him in Tomorrow: Shining a Light on the Marginalised, Disenfranchised and Forgotten Children of Today’s Schools. Carmarthen. Independent Thinking Press.

Pinney A (2017) Understanding the needs of disabled children with complex needs or life limiting conditions. London. Council for Disabled Children/True Colours Trust.

Sellgren K (2019) School exclusion of autistic boy unlawful, judge rules. Katherine Sellgren, BBC News education report; accessed at on 19th October 2019.

Stewart D S, Mallett A and Hall T (2015) Sex and Relationships Education in P Lacey, R Ashdown, P Jones, H Lawson and M Pipe (eds) The Routledge Companion to Severe, Profound and Multiple Learning Difficulties. London. Routledge.

Local Training Courses for PMLD – SLD – MLD

High Quality Local Training from only £19

For Teachers working with pupils with PMLD, SLD and MLD.

The EQUALS charity is committed to offering high quality local training at prices that schools can afford. At this time schools are struggling with reduced budgets and many teachers are finding it more difficult to access training which is essential to carry out their roles.

With the support of EQUALS Members, we are using local schools to deliver a selection of twilight training workshops. These are scheduled to start at 4pm (after pupils have left, and when there is more capacity in school car parks) and finish at 6:30pm.

Over the past two years EQUALS has been very busy developing a new Semi-formal SLD/MLD Curriculum. This contains a dozen schemes of work. As from 1st September 2019, Ofsted introduced a new school inspection framework and their inspectors will now be looking to see whether the children are being offered a “broad, rich curriculum and real learning. Ofsted will also be looking at how teachers are managing pupil behaviour. Does your school provide a broad and balanced curriculum for PMLD, SLD and MLD? Or is it teaching to assessment?

With this in mind, EQUALS has been delivering a series of twilights by Peter Imray for Semi-formal SLD/MLD Curriculum.

More topics will be covered during 2020, which could include:

    • MAPP – Mapping & Assessing Personal Progress
    • S&R Education – following new government guidance that is due to come out during 2020
    • New Ofsted Framework – A new Ofsted inspection framework started from 1st September 2019
    • Formal Subject specific Curriculum – a new pack will be published by EQUALS during 2020
    • Sensory Issues and Awareness for Complex Learning
    • Story Telling – Narrative
    • Call and Response

If your school is interested in a twilight for Semi-formal SLD/MLD Curriculum, there is some additional information below, and a link to place a booking. Should your school be interested in any of the further topics listed above please let us know. Is your school interested in hosting a twilight workshop in your own school?

Please contact for further information and to register any interest.


Semi-Formal (SLD/MLD) Curriculum by Peter Imray


Venue: Blossom House School, Station Road, London, KT3 6JJ.
Date: 23rd January 2020.

Costs: Only £19+VAT for EQUALS Members and £59+VAT for non-members

EQUALS Membership costs only £120+VAT for 12 months. Join today and you could benefit from some new members offers.

click here to find out how join the EQUALS Charity

Course Profile

With the Rochford Review confirming that ‘schools already have the freedom to use any curriculum they feel is appropriate for the needs and requirements of…… pupils’ who are not engaged in ‘subject specific learning’, we seek to explore

    • What does subject specific learning mean?
    • Who might be involved in subject specific learning and who might not?
    • What kind of curriculum makes sense for learners with SLD who will only ever be able to succeed (at the very best) up to the very beginnings of the National Curriculum?
    • What kind of curriculum model can enable those with SLD to be the very best that they can be and to do the very best that they can do, irrespective of their level of learning difficulty?

We seem to be in a position of much greater flexibility than we have been for a very long time which makes for extremely exciting and interesting times in curriculum development!

Below is a short video of just over 11 mins by Peter Imray; our Director of Developments.
Peter Imray talks about our brand new Semi-Formal (SLD) Curriculum.

To learn more please click here
Or contact Paul Buskin at the EQUALS office on 0191 272 1222
or email


Over the past 18 months, EQUALS has successfully delivered twilight workshops at:

  • Bennerley Fields School in Derbyshire.
  • Birchwood School, Leicester.
  • Broomlea Primary School, Glasgow.
  • Hadrian School in Newcastle upon Tyne.
  • John F Kennedy School in London.
  • Kingsbury Primary School, Lancs
  • Melland High School in Manchester.
  • Oak Grove College in Worthing.
  • Palmerston School, Liverpool
  • Priory Woods School in Middlesbrough.
  • St Nicholas School, Kent.
  • St Ann’s School in London.
  • Swiss Cottage School in London.
  • Threeeways School in Bath.
  • Wilson Stuart School in Birmingham.


December 2020

‘Former EQUALS trustee Andrew Colley, in association with the University of Cambridge Faculty of Education, is launching a major survey of special schools who teach young people aged 14 – 19 with PMLD. The ‘Lives Lived Well’ questionnaire aims to shed light on all the good practice in UK schools with respect to independence, community participation and wellbeing for this group of learners.
The questionnaire itself and full details about its aims and objectives can be accessed using the online link below. It should only take about 15 minutes to complete.

Many thanks’

1. OFSTED Lead for SEND Nick Whittaker

Background – Nick Whittaker – 5 years MHI SEND lead one year – Headteacher Special School
Inspections – Local area inspections – OFSTED schools and ITT University
Local area inspections – 5 year strategy force for improvement – intelligent, responsible and focussed (impact)

Local area inspections 151 areas over five yrs – 100 to date in about 50% areas of specific weaknesses. Important to note that systemic weaknesses but also examples of where arrangements are working well.
Where there is a statement of written action there are re-visits to ensure that the local areas testing the progress in addressing the areas of weakness within the statement. Acknowledge in area with no written statement of action still areas for development – if no improvement is made then a statutory notice of action.
The future when local area inspections ends 2021 dialogue is now taking place with stakeholders.
The lack of some clinical medical officers was noted as a difficulty within local authority inspections related to EHCPs
A common areas of weakness effectiveness of joint commissioning SLCN , Physiotherapy etc..Where it is working more effectively it is more responsive – they have a clear picture of the needs of pupils and they evidence the impact and outcomes.

Next report Local area inspections within the chief inspectors annual report
Note SEND report and chief HMI reports coming out – SEND reform

Add handbook section 5 and annex materials – guidance para 314
Links to preparation for life after school education, employment and training.

The quality of the curriculum – intent (ambition translated into a framework)

Education Inspection Framework -(EIF)– takes a strong stance on inclusion –Leadership and Management – Quality of education

Move towards real focus on the substance of education and how leaders assess pupils learning and preparing them for what is come next after school.
Access to a rich and broad curriculum with a depth of knowledge and skills.

Intent – Implementation and Impact –
Intent – framework of aims skills and knowledge – building towards something that is ambitious
Implementation – How translated into practice thorough teaching – expert knowledge and key concepts – checking understanding gaps in knowledge etc..
use and apply knowledge fluency – automaticity – Curriculum sequenced overtime with assessment opportunities and what does it tell us leading to difference s in teaching
Impact – are they building towards something ambitious?

Inspection methodology – Not looking at internal school data but evidence of learning – annotation – video/photos – work scrutiny

Inspecting the curriculum May 2019 document sequence of inspection activities
How decisions are made by curriculum leaders – what this looks like and is offered in your school
Deep dive needs a unit of progression i.e. a subject
Aims and content – how implemented and what does this look like – for PMLD unit of progression might be building towards a different set of outcomes – e.g. communication, social or physical development etc..

OFSTED expect a written statement of intent for distinct group of pupils including decisions about what curriculum is building towards a model of progression.
Leaders to have a dialogue with OFSTED – Deep dives might be areas of subject that are strong or viewed as needing development.
Inspectors will talk about what you are assessing and how but not look at or validate internal data. They will look at progression from EYs through key stages – Post 16 how have they built up over the years and prepare for life after school and adulthood.

Parent/Carers – changes to the online questionnaire – Inspectors might follow up with SENCO conversations with parents and carers – needs identified – involved in decision making in terms of support and how it is working. Feature more prominently within the inspection report.

2. Policy and DFE updates

Major review pupils with SEND released

National audit office report SENDS

Engagement model out in middle of November 2019 – video to support the launch and a training programme

Not going to plan EHCP two years on – Document Link

3. Issues related to Brexit –which may impact upon special schools

  • Availability of staff teaching and support staff
  • Safeguarding of families – increase in hate crimes
  • Benefits delivered on time
  • Resources and equipment
  • Mental health of young people
    School meals etc..

These are notes taken from the meeting so accuracy might vary – the actual minutes will be available on

In October 2019, DfE launched a public consultation seeking views on changes to the statutory framework for the Early Years Foundation Stage (EYFS). The consultation includes proposed changes to the educational programmes, the early learning goals and the EYFS profile assessment.

DfE consultation document

The consultation will run from 24 October 2019 to 31 January 2020

EQUALS would like to encourage specialist schools to take part in this consultation….

For further information please refer to the Consultation Summary …

Click here to download the Consultation Summary

The full consultation can be found at:


NCVO – Central London – 26th June 2020

14-25 Education
What does independence mean for young
people with PMLD, SLD and MLD

Practical Solutions and Possibilities

Our last four conferences have been 100% full and over subscribed so early booking is recommended.

Members places are only £149+VAT. Early booking is recommended as our last four conferences were oversubscribed.

click here to book your place today.

For more information please contact


University of Manchester

Curriculum at the Heart of Learning for
all Learners with PMLD, SLD and MLD

Our summer Conference this year was related to ‘Curriculum at the Heart of Learning for Learners of all ages with PMLD, SLD and MLD’.  This event was an amazing success and was so popular, we have opted to run this again further north at the ‘University of Manchester’ on the 20th March 2020. Members places are only £149+VAT. Early booking is recommended as our last four conferences were oversubscribed.

click here to book your place today.

Our last four conferences were oversubscribed so early booking is recommended.
For more information please contact


Please see the National SEND Forum website the link is

The website contains information about the group and which organisations currently attend – this includes events and the National SEND Forum minutes.

The meeting in May 2019 focussed upon the Timpson review and the review of the SEN COP which will be revised by 2020 although this is likely to be minor revisions and the group plan to complete a list of ideas at the next meeting in July 2019.

Please see the SEND and AP provision consultation which is open until the 31st July 2019 the link is attached

The next focus was on whole school SEND its structure and function – please see the link to whole school SEND

The group will be meeting with Lorraine Mulroney (NHS SEND) and formulated questions to be asked when she attends the group at the July 2019 meeting.

The full agreed minutes will be available on the National SEND Forum website shortly

Steve Cullingford-Agnew

A group of like-minded advocates for people with profound and multiple learning disabilities came together several times in 2016, in order to identify a means of ensuring a stronger voice for people, at a national level, and to aim to ensure that people received good quality service and support regardless of where they lived and who was providing their support. ‘Supporting people with profound and multiple learning disabilities’ CORE & ESSENTIAL SERVICE STANDARDS is an excellent resource in order to ensure that people with profound and multiple learning disabilities have access to consistent high-quality support throughout their lives, when supported by any service provider.

For more resources and information to support people with profound and multiple learning disabilities also look at PMLD Link

Steve Cullingford-Agnew

Thoughts on Curriculum and Assessment by Peter Imray – January 2019


Over the last five years or so there has been increasing interest in curriculum development which has recognised the problems of target driven models. Amanda Spielman, Her Majesty’s Chief Inspector at Ofsted, has stated that

The curriculum is the yardstick for what school leaders want their pupils to know and to be able to do by the time they leave school. It is therefore imperative that the new inspection framework has curriculum as a central focus.’ HMCI (2018)

The resultant new (2019) Ofsted framework which highlights the centrality of the 3 I’s of ‘intention, implementation and impact’ fits perfectly with Equals’ stated ambition within its Semi-Formal Curriculum, for all teachers to ask key questions of their daily work, namely (i) why am I teaching what I’m teaching (ii) what am I trying to achieve and (iii) am I making a difference.
For schools teaching pupils and students with SLD and PMLD, this view also mirrors and moves forward with the points expressed in the Rochford Review, which noted that

schools already have the freedom to use any curriculum they feel is appropriate for the needs and requirements of …… pupils (not engaged in subject specific learning)’ (Rochford Review, 2016, p20).

There is certainly a case to answer that the National Curriculum is an entirely inappropriate model if learners are never (by definition) ever going to get beyond its very earliest levels, and where most never even reach the start. It has been argued that

‘…children, young people and adults with severe or profound learning difficulties will not succeed in the National Curriculum, or indeed, in any curriculum model designed for neuro-typical conventionally developing learners. They will not succeed because they have severe or profound learning difficulties. It is not possible for them to succeed. If they could succeed, they wouldn’t have severe or profound learning difficulties’ (Imray and Colley, 2017, p58).

Such sentiments echo previous suggestions that a curriculum geared to the norm cannot be an appropriate model for those 70,000 or so learners with PMLD and SLD who make up less than 0.8% of the whole school population in England and Wales (Pinney, 2017) yet have the greatest complexity of need.

By definition, exceptional students require an extraordinary response from educators – something different from the ordinary, even if the ordinary is good………Failure to create these explicit structures to accommodate students at the extremes of performance distribution inevitably results in their neglect. They are forgotten. They don’t just fail a little. They fail a lot, and their noses are rubbed in their failures.’ (Kauffman, 2002, p259).

This school acknowledges that there is a growing interest in the concept of a multi- tiered curriculum approach which sees Pre-Formal and Semi-Formal curriculum models working in with the existing Formal model that is the National Curriculum. It is known that a number of Ofsted ‘outstanding’ schools such as Priory Woods School in Middlesborough, Melland High School in Manchester, John F Kennedy School in Stratford east London, Three Bridges School in Bath, St Ann’s School in Hanwell, west London, Columbus Grange School in Sunderland and The Russett School in Chester, just to give a few examples, have already, or are in the process of, adopting this approach.

All of these schools run the Equals Semi-Formal Curriculum (Equals, 2018) and we feel that this model, which Equals regards as the only curriculum in the world written specifically for children, young people and adults with severe learning difficulties, gives us a solid base on which to move forward.

In the model above, it is neither necessary nor advisable to adopt a hard line on which curriculum might be appropriate for each learner as it is evident that learners on the edges of a learning difficulties spectrum, such as are described by the terms PMLD, SLD or MLD, may benefit from some involvement in the adjacent curricula. That is, those assessed as P3 (i) and (ii) may benefit from some elements of a semi-formal curriculum; those on P4 or P5 from elements of an informal curriculum; learners working at P8 or L1 may well cover some elements of a formal curriculum. Similarly, learners working consistently and over time at levels at or even above L2 may still benefit greatly from elements of a semi-formal curriculum, especially in for example, independence.

There is therefore a fluidity about this model which both allows for and encourages a personalised (or individualised) approach, whilst still recognising that core elements of each curriculum will broadly fit the learning needs of all learners within the PMLD and SLD spectrums. The logic behind this approach comes from the sure and certain knowledge that our learners can make progress within curricula specifically designed for them, but will struggle to do so within curricula that is not (Imray and Hinchcliffe, 2014).

We believe that the nature and extreme complexity of both the severe and profound and multiple learning difficulty spectrums, as well as the absolute necessity of extensive repetition being built in to the learning process mitigates against fulfilling one’s potential in both academic and alternative curriculum models. Such ‘dilemmas of difference’ (Norwich, 2008 and 2013) mean that choices have to be made, because not making such choices leaves insufficient time in the school life of the learner. For us, the argument is made by the fact that, by definition, the very best that can be achieved by the most able on the SLD spectrum within a National Curriculum model (that is, fulfilling their academic potential) is equivalent to the start of the academic model, and for most on the SLD spectrum and all on the PMLD spectrum, well below the start. It seems self-evident that to have one’s ambitions limited to the start of a curriculum indicates that it is the wrong curriculum.

This also opens up another debate about the relevance of neuro-typical (mainstream) time frames. There is some logic to seeing the validity of a curriculum framework as being in its ability to prepare the learner for the next stage, whatever that might be. In UK mainstream terms, there is a fairly seamless transition from 3 to 5 (early years), from 5 to 11 (primary), from 11 to 16 (secondary), from 16 to 18 (sixth-form), from 18 to 21 (university) and then on to work. Each curriculum model builds on and extends from the last.

These time frames however do not make sense and therefore cannot apply to those on the SLD or PMLD spectrums, because of the degree of repetition required, the difficulties with communication and cognition, and the naturally extended time required for progress to be established within independence, fluency, maintenance and generalisation (Sissons 2018) even within a specific SLD or PMLD curriculum model. For these learners the key ages are 2 or 3, when they enter the education system and 19 when they leave it. It is not an accident that the majority of UK special schools specifically for those with SLD and PMLD cater for the 2 to 19 age range, and see this as a perfectly normal and sensible arrangement. For learners on the SLD spectrum, there may be some logic in delivering a broadly academic framework, particularly within literacy and numeracy, until the age of 8 or so, because this would allow sufficient time (i) to assess the accuracy of a SLD or PMLD ‘diagnosis’ and (ii) to make a reasonable judgment on academic potential. A reasoned, informed, experienced and expert multi-disciplinary judgement can then be made, and if it is assessed that a non-academic route is more appropriate, still leave 10 or 11 years to concentrate on a specialised SLD or PMLD curriculum model.

Our conclusions on curriculum and curriculum design are therefore that the current school cohort (and indeed, cohorts for the foreseeable future) are not best served by the National Curriculum alone. Our experience, concurring with a number of outstanding special schools, has led us to adopt a much more flexible and personalised approach which sees the curricula on offer changing to meet the needs of the pupil rather than the other way round. The learner must be at the centre of curriculum design.


Returning to the Rochford Review and its primary function of determining on assessment for learners working consistently and over time below age related expectations, we believe that there are a number of other key statements.

As it is neither possible nor desirable to set national expectations for what these pupils should have learned at a particular age or by the end of a key stage, the members of the Rochford Review do not believe it is appropriate to apply a framework to statutory assessment that evaluates their attainment in that way. It would be neither fair to the child, nor to the school.’ (Rochford Review, 2016, p20)

As assessment for pupils with severe or profound and multiple learning difficulties should be suitable for each pupil’s individual needs, the review does not feel that it would be appropriate to prescribe any particular method for assessing them. (ibid, p6)

That is, schools should be responsible for determining the best way to assess the attainment of their particular pupils, and that this must be an ipsative judgement, rather than one which is comparative to other learners. This is an important statement, as it establishes that attempts to design assessment schemas by using estimations of ‘expected’ progress over a specific time period (such as was used with the P scales and other variations of this, notably Pivats and B Squared) are not effective and can often be counter-productive in their tendency towards assessment led teaching.

Assessment is a good master but a terrible servant……..Too often we start out with the idea of making the important measureable, and end up making the measurable important.’ (Williams, 2015).

Nevertheless, this school accepts the fundamental need for accountability and fully supports the notion that

schools must be able to provide evidence to support a dialogue with parents and carers, inspectors, regional schools commissioners, local authorities, school governors and those engaged in peer review to ensure robust and effective accountability.’ (Rochford Review, 2016, p7)

With this in mind we have adopted a wide ranging ‘basket of assessments’ after the approach mooted by Swiss Cottage School (2014) see Figure 2 below.

Our conclusions on assessment of pupil progress are therefore that

(i). accurate formative and summative information is vital, but that this cannot be achieved by a single measurement
(ii). the assessment schemas used must be able to show both lateral and linear progress, and reflect the real progress made by learners wherever and however that may be made
(iii). the assessment schemas used need to reflect the curricula on offer and the effectiveness of teaching, but must not drive either.


Equals (2018) The Equals Semi-Formal Curriculum. Newcastle. Equals.

HMCI (2018) HMCI commentary: curriculum and the new education inspection framework.  Available at ww  Accessed 10th October 2018.

Imray P and Colley A (2017) Inclusion is Dead: Long Live Inclusion. London. Routledge.

Imray P and Hinchcliffe V. (2014) Curricula for Teaching Children and Young People with Severe or Profound Learning Difficulties. London: Routledge.

Kauffman J M. (2002) Education Deform: Bright People Sometimes Say Stupid Things About Education . Laham, MD: Scarecrow Press.

Norwich B. (2008) Dilemmas of Difference, Inclusion and Disability: International Perspectives and Future Directions. Abingdon, Oxford: Routledge.

Norwich B. (2013) Addressing Tensions and Dilemmas in Inclusive Education. London: Routledge.

Rochford Review (2016) Final Report

Sissons M (2018) MAPP. Mapping and Assessing Personal Progress. Newcastle, Equals.

Swiss Cottage School (2014) Progression Planners. Meaningful Assessment for learners with Special Educational Needs and Disabilities. London. Swiss Cottage School Development and Research Centre.

William D (2015) Planning Assessment Without Levels. Available at   Accessed 23rd April 2018.


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by Peter Imray