Agenda Item 6

Cabinet
Report Title:

The Future of Specialist Provision in Suffolk

Meeting Date:

8 December 2015

Lead Councillor(s):

Councillor Gordon Jones, Cabinet Member for Childrens

Services, Education and Skills

Local Councillor(s): All Councillors

Director:
Assistant Director
or Head of Service:
Author:

Sue Cook, Corporate Director for Children and Young

Peoples Services
Nikki Edwards, Assistant Director for Children and Young
Peoples Services
Paul Senior, Consultant, Children and Young Peoples
Services

Brief summary of report

1. The Council as the Local Authority (LA) has a statutory responsibility to keep the
work of specialist provision under review to ensure that it is responsive to needs.
2. Following the recent review of specialist provision, there is now a need for a
formal consultation process to take place, with a focus on securing sustainable
and needs-led delivery models for the future work of:

Special support centres (SSCs)

Residential provision in our Moderate Learning Disability (MLD) Special
Schools
Special Schools
Post-16 specialist provision
Alternative Provision

3. The Council is responsible for ensuring geographical consistency across the

county so that a wide range of provision is available wherever a child or young
person lives in Suffolk.
4. It is a priority for the Council and its partners to close the gap between the
achievement of pupils with SEN and their peers without SEN.
5. The current range and location of specialist provision when mapped against the
need shows that there are considerable gaps and fails to effectively discharge
the LA duty to provide sufficiency of provision. The desired outcome for this
programme of work is that more learners with SEN are able to attend their local
school with appropriate levels of support, or local specialist provision in Suffolk,
17

in addition the achievement gap for this group of children and young people will
be closed, supporting us to the meet the Raising the Bar aspirations for all
Suffolk learners.
What is Cabinet being asked to decide?
6. The Cabinet is being asked to note that with a view to commissioning the most
appropriate future model of delivery in response to local needs, the consultation
will include:
i)

A formal consultation process on a range of options developed through

stakeholder engagement, for the most efficient and effective future use of
specialist support centre provision and allocated resources.

ii)

A formal consultation process with a focus on identifying options for the most
efficient and effective future use of alternative provision and allocated
resources.

iii)

The redesign or decommissioning of the residential provision in our

Moderate Learning Difficulty special schools.

iv)

A formal consultation programme with local special schools, with a view to

changing the current provision designations (such as moderate learning
disability and severe learning disability) in response to local needs.

v)

Through the work of the Raising Participation Board work should be

undertaken to map need and review the post-16 provision offer, to identify
gaps and inform future commissioning priorities.

Reason for recommendation

7. With regards to the current arrangements for the commissioning of specialist
provision, the status quo is not sustainable and a change in approach to meeting
the needs of vulnerable learners is urgently required.
8. Without intervention, the Council will be unable to effectively and efficiently meet
the educational needs of its most vulnerable learners.
9. A summary of the review findings can be found in Appendix A.
What are the key issues to consider?
10. LAs have a duty to ensure a sufficiency of provision for pupils with special
educational needs and /or disabilities. The Councils Children and Young
Peoples Services Directorate has completed a programme of work to undertake
a comprehensive assessment of need and map existing provision, to help
identify its provision gaps.

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11. The Council needs to make some changes in the way it commissions provision
for vulnerable learners in Suffolk to help progress its Raising the Bar
aspirations.
12. The Council aims to achieve geographical consistency of targeted and specialist
provision across the county, so that a suitable local offer is available wherever a
child or young person lives in Suffolk.
13. The Council is facing considerable financial pressures in meeting the demand for
educational inclusion provision, for the rising number of vulnerable learners
presenting with more severe and complex needs.
14. Given that the responsibility for this group of young people rests with both the
Children and Young People (CYP) and the Adults and Community Services
(ACS) Directorates, co production and joint working across both Directorates
will be important to progress this process.
15. Following the interface with Cabinet, work will be undertaken with the Equalities
Team to progress the Equality Impact Assessment (EIA) process for this
programme of work.
What are the resource and risk implications?
16. The Council currently invests 47m per annum in commissioning and providing
targeted services and provision in response to meeting the needs of children and
young people with additional needs.
What are the timescales associated with this decision?
17. The programme is envisaged to be completed by September 2016. The timeline
outlining milestones and timescales is attached at appendix B to this paper.
Alternative options
18. The planned consultation process will identify a number of alternative options to
be considered. These options will be carefully evaluated by all key stakeholders
and recommendations will be presented to Cabinet to make final decisions.
Who will be affected by this decision?
19. By making improved use of local specialist provision and resources this decision
has the potential to impact positively on reducing the number of vulnerable
learners needing to be placed in out of county specialist educational provision.
20. Local provision gaps in specialist provision currently mean that there are 258
vulnerable learners placed in out of county specialist educational placements.
Strengthening the local educational offer will ensure that it is only Suffolks
learners with the most highly complex levels of need that will require access to
out of county specialist educational provision.
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21. 17.8% of the local children and young people population have an additional need
and their needs are met in local provision. The range of provision includes
specialist provision such as pupil referral units, special schools, special support
centres and post-16 provision. It is the aim of this programme to provide access
to a local, broader and more flexible menu of provision in response to assessed
needs. This will replace the current offer which has a number of identified gaps
and in the main remains a historic model of delivery.
Sources of further information
a) The Children and Family Act 2014
b) The Taylor Review of Alternative Provision 2012 (DfE)
c) Specialist Provision Review report (appendix A)

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Appendix A: The Future of Specialist Provision in Suffolk - Review Report Summary

SUBJECT:

The Future of Specialist Provision in Suffolk - Review Report Summary

AUTHOR:

Paul Senior Consultant

DATE:

1 December 2015

1. SUMMARY OF MAIN POINTS:

1.1 Local Authorities have a duty to ensure a sufficiency of provision for pupils with special educational
needs and / or disabilities. We have commissioned a programme of work to undertake a comprehensive
assessment of need and map existing provision, to help identify our provision gaps.
1.2 During the 2014/15 academic year a review of provision for children and young people with additional
needs was undertaken across Suffolk. Phase one of the review process maintained a focus on alternative
provision and special schools, whilst phase two which took place in the 2015 summer term period looked
at targeted elements of SEN and specialist provision.
1.3 The LA aims to achieve geographical consistency of targeted and specialist provision across the
county, so that a suitable local offer is available wherever a child or young person lives in Suffolk.
1.4 The local authority is facing considerable financial and demographic pressures in meeting the demand
for educational provision for the rising number of children and young people presenting with more severe
and complex needs. Local evidence proves that the status quo is no longer sustainable or responsive to
local need, with regards to the current specialist provision programme that is commissioned by the local
authority.
1.5 This report presents a number of findings and recommendations for the range of commissioned
specialist provision for vulnerable learners, that came into scope for the review programme:
Special support centres (SSCs)
Moderate learning difficulties (MLD) Residential provision
Post 16 specialist provision
Continuum of provision
Alternative Provision and Pupil Referral Units
1.6 The report and associated recommendations have been developed with considerable support and
challenge from local school leaders, parents/ carers, partner agencies, school governors, LA officers and
provision providers (this includes PRU, Special School and SSC head teachers).
1.7 The local authority (LA) now plans to move to the next stage in the process, which will be the formal
consultation phase with a focus on the recommendations provided.
2. DETAILS
2.1 The review of specialist provision has been carried out in two phases. The 2015 summer
term review of specialist provision follows the work previously undertaken earlier in the
2014/15 academic year (phase one), with a focus on local PRUs/ alternative provision,
Special Schools and Support Services.
2.2 Outcomes to date:
Reduction in permanent exclusions in local schools;
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Increased Pupil referral units (PRU)/ Alternative provision (AP) capacity for earlier
intervention activity;
Reforms to the In year Fair Access Protocol and supporting arrangements;
Development of locality assessment centre programmes;
Strengthened locality ownership and oversight of vulnerable children;
Development of locality governance and quality assurance arrangements driven by
schools.

2.3 The phase two review process focused on other areas of specialist provision and
included the work of special support centres (SSCs).
2.4 Phase two review forecasted outcomes:
An increase in the number of post 16 offer places in Suffolk. There is a proposal to
commission provision at the Bridge School campus;
Less Suffolk children and young people needing to be educated in non- Suffolk
settings;
Continuum of provision model designed in response to need, rather than
convenience leading to better outcomes;
Through restructuring and redesign, our specialist provision is better positioned to
meet the needs of pupils with a higher level complexity of need. A natural
consequence from this will be that more pupils will be able to have their needs met in
their local school.
2.5 As part of the overall provision for children and young people with additional learning
needs, Suffolk County Council commissions provision for vulnerable learners in:
14 pupil referral units;
10 special schools;
7 specialist support centres (SSCs) in mainstream primary schools.
2.6 Whilst this report presents findings and recommendations across a number of SEN
settings, the main focus will be on areas not fully captured in the phase one Working
Together for Inclusion report and action plan:
Special support centres (SSCs)
MLD Residential provision (The Ashely and Priory Special Schools)
Post 16 specialist provision south Suffolk
Continuum of provision
Alternative Provision redesign (pupil referral units and education otherwise than at
school)
2.7 The work of SSCs is intended to support pupils who have an Education, Health and Care
Plan (previously statements of SEN).
SSC
Causton Junior School
Maidstone Infant School
Castle Hill Infant School
Castle Hill Junior School
Sidegate Primary School
Gorseland Primary School
St Gregory C of E VCP Primary School

Locality
Felixstowe
Felixstowe
Ipswich
Ipswich
Ipswich
Ipswich
Sudbury

Number of funded places

15
10
10
20
25
25
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2.8 All of the seven centres have been established for several years, whilst an eighth
(Abbots Green Primary School) was closed at short notice in the summer of 2014 at the
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request of the schools governing body. Each centre is intended to serve an area that is
wider than the catchment for the school in which it is located. The authority provides
transport for those children who live outside the immediate area. Special Support Centres
(SSCs) were previously commissioned by Suffolk County Council on behalf of all schools
following agreement from the Schools Forum to use Dedicated Schools Grant funding for
this purpose.
2.9 The SSCs were originally designed to offer flexible and local early intervention provision
for SEN children to avoid the need for this cohort having to travel across the county to
access specialist provision. This has proved difficult to achieve for a number of reasons,
including the unequitable geographic distribution of the seven SSCs. This was due to the
centres being established where schools offered to host these settings, rather than being
based in an area of defined need.
2.10 All SSCs are monitored through the work of service level agreements which will end on
31st August 2016 unless they are renewed.
3. REVIEW FINDINGS
This section provides a summary of the key findings from the specialist provision review
process. The findings illustrate that despite the considerable investment made by the LA and
a number of partners with a commitment to improving the outcomes for vulnerable learners
that locally, that there remains in place a number of gaps in the local offer and the quality of
provision that is made available in response to need.
3.1 Continuum of provision
3.1.1 The rising number of children and young people needing to be educated in non
Suffolk educational settings acutely illustrates that the local continuum of provision has gaps
in response to meeting needs.
3.1.2 There is limited access to CAMHS provision for children and young people with SEND.
3.1.3 Good opportunities are provided for children with sensory impairment to access their
full entitlement and inclusion in both the primary and secondary phases.
3.1.4 There is evidence of good multi-agency working in assessing needs and planning and
reviewing provision, with a clear and effective focus on early identification and intervention.
For example the work of the County Inclusive Resource (CIR) is well regarded by the SSCs.
3.1.5 There is no evidence of locality and strategic connectivity in planning across special
schools, SSCs and mainstream schools, leading to a fragmented and non- cohesive/ fluid
continuum of provision.
3.1.6 The current DfE designations of the SSCs and special schools are at variance with the
actual functions of most of the settings, the needs of the pupils attending and the needs of
the pupils locally.
3.1.7 The commissioning of residential and the SCC provision has not been informed by
recent outcome based data or information about the changing local demand.
3.1.8 In response to the need for reform, a dedicated task and finish group has recently been
commissioned to review the work of the existing SEN banding system, with a view to
23

develop a new model that will be future proofed and further responsive and flexible to local
needs.
3.2 Post 16 Offer
3.2.1 There are considerable capacity pressures locally in providing sufficiency of provision
for post 16 learners with SEND. Whilst developments are underway to develop new
provision and extend existing provision, currently the level of demand exceeds supply. The
change from a five to three day offer being provided by Suffolk One, has led to an
unequitable learning offer for post 16 aged learners with SEN in the southern part of the
county.
3.2.2 Following the SEND Reforms anecdotal evidence proves that there has been an
increase in interest for young people with SEND seeking to be able to access vocational
education. Unfortunately the limited post 16 provision offer in some localities has impacted
on the ability to convert the raised interest into actual participation rates for this cohort, with
local participation outcomes currently the lowest in the region.
3.3 Special support centres
3.3.1 SSCs in Suffolk are long-standing and an integrated part of a number of inclusive
primary schools. Parents and carers of children accessing the SSCs are very supportive and
appreciative of the provision, feeling that the settings have allowed their children to make
progress from previous lower baselines. Pupils are largely placed in SSCs with variable time
spent in mainstream lessons.
3.3.2 The level of need of pupils who attend or are supported through the SSCs currently
varies considerably. At one extreme there are some pupils with severe learning difficulties
who might later transfer to a special school, and at the other extreme there are some
learners who could have their needs met in local primary schools with funds from the
schools own resources.
3.3.3 In the SSCs, staff working with learners with social and emotional difficulties often
struggled to get external support from agencies other than the local authoritys educationbased behaviour support and CIR services.
3.3.4 The SSCs are not fulfilling all of the originally planned purposes. Whilst all of the
settings appear to provide all learners with a positive and in many cases a progressive
experience, in an environment that is conducive to teaching and learning, the majority of
users fail to make sufficient progress to prevent the need for placement at a special school
at the end of the primary phase (90% of year six SSC learners over last three years have
gone to special schools).
3.3.5 The learners mainstream experience is variable across the settings. Some settings
were more structured than others with regards to planned SSC learner integration with
mainstream lessons and activities. Some settings failed to extend the SSC learners beyond
some only accessing integration opportunities in social periods such as breaks and lunch
time.
3.3.6 In some SSC settings there is a degree of mismatch between need and provision
3.3.7 There is a different average funding level per pupil across SSCs owing to unused
places, with all SSCs susceptible to fluctuations in numbers (low incidence need).
24

3.3.8 The involvement of support staff is most effective in the progress that special
educational needs pupils make because they are briefed very well by the teachers.
3.3.9 The seven SSCs in the main provide provision for learners from their cluster area, but
do not provide countywide coverage. It should be noted that from the seven centres, one (St
Gregory) is situated in the western part of the county and there are no centres in the
northern area of the county. The current SSC commissioning arrangement leaves six of the
centres located in the southern area and this fails to deliver an equitable offer across the
county.
3.3.10 Almost all SSC leadership teams identified the need to unify leadership of all aspects
of the SSCs across Suffolk to work towards an integrated or virtual provision approach
where possible. SSC schools stated that a central LA point of contact to provide challenge
and support, would result in a more strategic, effective and cohesive model.
3.3.11 In recent years the SSCs have not been subject to periodic review, monitoring or
evaluation and as a result, despite some operational joint working, the centres were until
recently working more in isolation than was originally intended. There have been recent
developments being driven by SSC leaders and staff to improve joint working and sharing of
practice.
3.3.12 The authority could secure improved value for money outcomes by ensuring that the
resources within these centres form part of a coherent and consistent graduated response to
SEND that is accessible county-wide.

3.4 MLD Residential

3.4.1 The LA currently commissions residential provision for learners with moderate learning
difficulty needs at the Ashley and Priory Special Schools. Whilst the provisions in both
settings are well utilised, in light of the changing demographic and increasing complexity of
need amongst Suffolks SEND population, there is an urgent need to review the need and
sustainability of the current arrangements in response to local needs.
3.4.2 It is recognised by local schools and stakeholders that the current MLD residential
models as is and without change in terms of the cohort these provide for will struggle to
remain a commissioning priority for the LA to continue to support. Review findings suggest
that the residential offer currently in place at these settings has not been driven by a needs
or demand led requirement and therefore appears to maintain a historic approach to when
more MLD settings nationally retained residential facilities. Currently it is the school and not
the LA that determines if learners are allocated placement in the residential setting. The
threshold of need for the cohort of learners currently accessing the residential provision is
questionable considering local needs.
3.5 Alternative Provision
3.5.1 Although Suffolk appears to have sufficient Alternative Provision when compared to
similar Local Authorities, the cost of the provision per pupil place remains high compared to
the national average which is between 12,000 and 18,000 (source Charlie Taylor AP
reforms 2012). As the Local Authority is not able to reduce the budgets of PRU provision
because of the Minimum Funding Guarantee (MFG), the only option available would be to
increase the number of pupils accessing each provision without increasing the PRU budget.

25

3.5.2 Through the work of the SLA framework the Local Authority has requested that all Key
Stage 1 to 3 PRUs (an average of 27,275 per place) increase the numbers on roll by 20%
and Key Stage 4 PRUs (an average 20,071 per place) by 10%. This approach where
implemented will create an additional 74 places for the county across all Key Stages and
bring the average per place cost down to 20,417.
Local Authority

Key Stages
Supported

Total No. of AP
placements

% of
placements per
school
population

Total No. of AP
placements +
EBSD Specialist
provision

% of
placements per
school
population

Essex
Cambridgeshire
Norfolk
Cornwall
Derbyshire
Devon
Gloucestershire
Hertfordshire
Kent
Suffolk

14
34
14
14
14
14
15
15
15
14

276
120
250
290
367
285
260
247
669
406

0.14
0.13
0.20
0.37
0.33
0.28
0.29
0.13
0.30
0.38

436 (160)
372 (252)
304 (54)
290 (0)
460 (93)
285 (0)
285 (25)
464 (217)
918 (248)
406 (0)

0.22
0.41
0.25
0.37
0.41
0.28
0.32
0.24
0.41
0.38

3.5.3 To match the approximate per head PRU cost of other Local Authorities, we would
need to increase our PRU establishment by another 100 places in addition to the 20% uplift.
This would provide Suffolk with 580 places in AP compared to the 406 we have currently and
a per place cost of approximately 16,000. It would also mean that we would achieve 0.55%
of places per school population that would place Suffolk well ahead of comparable
authorities. A key question for local stakeholders is why would Suffolk require so much
provision by comparison with other similar local authority areas? It should be noted that
more provision places does not equate to being an inclusive authority.
4. REVIEW RECOMMENDATIONS
4.1 Continuum of provision
4.1.1 Targeted work should be undertaken to explore whether some current out-county
pupils could be placed in SSCs or Suffolk SEN provision as part of the local offer to their
home locality.
4.1.2 There is a need to review referral pathways to CAMHS provision/ services for SEND
children. Findings from the review show that a high number of young people with social
emotional behavior difficulty (SEBD) needs requiring out of county provision, were previously
unable to access CAMHS provision in their localities and therefore needed to be placed in
specialist educational provision in order to access timely therapeutic interventions.
4.1.3 The work of the Local Offer in addition to good inclusive practice in a number of
schools has proven to enhance the capacity of mainstream schools to be able to meet the
increasing complexity of need of learners with SEND. The ability of schools to manage
needs locally at a higher threshold level, should in the future lead to specialist provision
providers being expected to cater for a higher threshold of learner complexity and need in
response to local demand.

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4.2 Post 16 Offer

4.2.1 The LA should undertake targeted activity with post 16 provision providers to increase
the local educational and training offer for this cohort. The review process identified that
there is a limited offer for post 16 learners with complex needs.
4.2.2 Through the work of the RPA Board targeted work should be undertaken to map need
and review the post 16 provision offer to identify gaps and inform future commissioning
priorities.
4.3 Special support centres
4.3.1 Revise the strategic purpose of the SSCs and the existing delivery model, and ensure
that these are coherent with the aims and objectives of the authoritys wider strategies for
children and young people. The level of spend on SSCs is currently 1.3m per annum with
128 places being commissioned across the seven settings. The review process highlighted
that more effective use of this funding can be made in response to need.
4.3.2 There is an opportunity to secure more efficient and effective use of the funding
currently allocated to the SSCs by assessing the role and purpose of the centres, as part of
a coherent graduated response to meeting additional needs across the county. The options
provided below were identified by stakeholders during the review process as possible
solutions for the future use of the investment made to SSCs:
1.
2.
3.
4.
5.

Reconfiguration and/ or extend the remit of the provision

Amalgamate provision where appropriate
Changing of provision designation
Potential closure of provision(s)
Explore scope to deploy existing SSC provision and resource to reconfigure existing
provision in response to local needs and develop locality ASD and/ or BESD SSC
type provision to contribute to the local offer continuum of provision.
6. Explore scope for developing an SSC academy with a BESD and/ or ASD focus in
response to local needs.
7. Explore scope for developing a hub and spoke model with outreach support
8. No changes to the existing delivery model
4.4 MLD residential
4.4.1 Work with local providers and stakeholders to formally consult on changing the existing
criteria for accessing the provision. Unless this provision caters for the needs of the learners
that the LA and local schools are struggling to provide for, then it may be necessary to
decommission and seek an alternative approach with the available resource.
4.5 Commissioning
4.5.1 The recently developed Joint Commissioning Framework with Health partners is a
positive development. Work needs to be done to ensure all partners contribute effectively to
the implementation of the framework.
4.5.2 The LA should establish SLAs with each Special and SSC school to clarify model and
expected outcomes.

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4.6 Alternative provision

4.6.1 To secure improved value for money outcomes from the current level of finance
invested in local AP, it is recommended that the LA with the support of local stakeholders
consider a range of co- produced options through a formal consultation process (which will
include children, young people, families and schools), to discuss the future organisation and
commissioning of AP locally. This agenda has been subject to monitoring and scrutiny in
recent months by the work of the locality governance groups. This is primarily in response to
a heightened level of stakeholder dissatisfaction being driven by limited access to quality
provision despite the level of financial investment made.
Options:
1) To continue with the current AP commissioning arrangements including the
respective 20% and 10% uplift that will be achieved through the SLA framework.
2) Over time incrementally increase the numbers of pupils we are expecting the PRUs
to accommodate, by increasing the % when reviewing the SLA each year until we
reach 580 places. Many of these places could be provided through smaller satellite
provision in the rural areas of Suffolk and introducing creative curriculum models.
3) To offer the running of any Suffolk PRU not representing best value (between
16,000 and 21,000 per placement) because of high placement cost to the
Alternative Provision market.
4) To offer the running of Suffolk PRUs to the Alternative Provision market through a
procurement process with an estate worth 9,318,953.
5) To progress a provision review and redesign programme for the future work of AP in
Suffolk The future delivery model will be informed by the needs of the In year fair
access panel.
6) To develop a locality management approach to AP/ PRUs, with the existing centres
integrating, federating or aligning to develop a single AP offer for each of the
localities. This would be facilitated by single leadership and governance
arrangements for each locality, from the current model which sees 14 PRUs, 14 head
teachers and governing bodies, 14 separate URNs (unique reference numbers), that
are subject to 14 different inspection regimes.
Financial Implications
Suffolks High Needs Block funding allocation is low compared to other LA areas nationally
and is the third lowest in the country. This places considerable challenge for the LA in being
able to effectively discharge the statutory duty to ensure there is sufficiency of provision for
pupils with special educational needs and / or disabilities.

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APPENDIX B: REDESIGN PROGRAMME TIMEFRAME

The key programme milestones and timescales are provided below:

8 December 2015

Specialist Provision report to Cabinet regarding specialist

provision redesign and potential decommissioning activity;

14 December 2015

Commencement of equality impact assessment process (post

Cabinet) prior to formal consultation phase starting in the New
Year;

4 January 2016

Start of formal six week stakeholder consultation phase

5 January 2016

County Councillor Forum to discuss proposals

14 February 2016

End of formal stakeholder consultation phase;

19 February 2016

Post consultation phase report to Cabinet Member and Childrens

Services DMT to consider options and agree next steps;

22 March 2016

Specialist Provision report to Cabinet with outcome of

consultation and recommended next steps;

28 March 2016

If the decision is to proceed with any form of change and/ or

decommissioning, then a public notice will be written and
published at any affected schools and local communities;

28 March 24 April
2016

Following a published notice, there will be a further 4-week period

whereby people can make representations to the Council that
can be both objections as well as expressions of support for the
proposals. This is the final opportunity for people and
organisations to make their views known;

25 April 1 May 2016

Cabinet Member for Education and Skills will consider any

representations in response to the notice and will decide whether
to proceed with the proposal(s) or not;

2 May 2016

Subject to final Cabinet Member ratification a final and formal

public notice will be written and published at any affected schools
and local communities, advising that any changes will take effect
from the 1 September 2016 onwards (or as soon thereafter);

2 29 May 2016

Should a decision be made to reconfigure, amalgamate or

decommission provision any specialist provision, then a formal
four week staffing consultation process would take place
including identification of staff that would be vulnerable to
redundancy or changes in terms and conditions;

1 September 2016

If the decision is made to proceed with any or all of the proposals,

this is the earliest date from which planned changes to affected
specialist provision can commence from.

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