"Dear Mr. Donnini,
I am writing to you on behalf of the Cumbria Parent Carer Forum, of which I am the Chair of the Board of Trustees.
I am sure you are well aware that as representatives of parent carers of young people with special educational needs and disabilities in Cumbria, we are recognised by central government as having a role in monitoring the local authorities and ensuring that the needs of the people we represent are met by those local authorities, and that this role is confirmed in the statutory guidance issued by the Department for Education and the Department of Health.
Several of our members have been in contact with us relating to their concerns over transport matters. We are monitoring the issues raised and following a meeting with some of your officers we have made a statement which we have published and drawn our members' attention to. A copy of our statement is attached for your information. We would very much like to have a meeting with you, or one of your senior officers, to discuss the issues we have identified, and an open and continuing dialogue would also help ensure problems do not arise in the future. Of course, we would appreciate the Council's written response to show our members as soon as possible.
I look forward to hearing from you.
Cumbria Parent Carer Forum
Registered Charity number 1175734
STATEMENT BY CUMBRIA PARENT CARER FORUM (CPCF) ON HOME TO SCHOOL TRANSPORT PROVISION BY CUMBRIA COUNTY COUNCIL FOR PUPILS WITH SEND
CPCF has been contacted by many parents expressing dissatisfaction by transport matters. There has been great concern recently regarding changes to transport arrangements for James Rennie students brought about by the latest round of retendering of contracts, where new arrangements commence in April 2018.
A meeting was arranged at James Rennie School on 21st March which was attended by two representatives of CPCF, 3 parent carers and 3 members of Cumbria County Council staff led by Caroline Watson who is the commissioning manager for this service.
An extremely frank discussion was held with the parents putting forward their views very well to Cumbria County Council, with support from CPCF. Questions were asked by the parents and by CPCF in relation to the procurement and commissioning of these services. Some questions were answered at the meeting, and others to be answered after the meeting. As at the date of preparation of this statement, further information has been received or confirmed, but CPCF believes further dialogue with the Council is necessary. CPCF may amend or make a new statement on these issues at a later date.
WHAT ARE THE PROBLEMS PARENTS FACE WITH NEW TRANSPORT ARRANGEMENTS?
1. There is a lack of consultation with parents. Some pupils with autism, for example, find change disruptive but with good management, this can be minimised. Some pupils, however, have transport which is very well attuned to their needs and therefore highly effective, but with a change of transport arrangement which proves less sympathetic, there is a risk of reducing the benefit and effectiveness of their education if they arrive at school upset. This is a cost, which may be difficult to quantify in monetary terms, but is still a cost to be taken into account. Other costs to the student include adverse effects on their general and mental health wellbeing, where the Council will be well aware of the potential cost of public expenditure. There is also a risk the parents are adversely affected by their children becoming upset, which is a further cost to be taken into account. CPCF believes Cumbria County Council should take measures to ensure these children are identified and extra care is taken to consult with parents prior to any planned change of transport arrangements and for these extra costs to public expenditure to be factored into the procurement process; if the Council agree to these proposals, CPCF would appreciate details of how these proposals will be met.
2. The consultation with parents has not been effectively carried out by Cumbria County Council. Meetings were held in September 2017 where the Council would
"discuss the tender process, timescales and any specific questions you may have about your own child’s transport arrangements. These sessions will be on a one to one basis to ensure confidentiality and attendance needs to be booked in advance".
Notification as to these meetings was sent by post to parents, but it appears many parents did not receive the letters. If the Council truly wishes to consult with parents, it should consider a multi-layered approach of having general meetings as well as individual meetings, and ensure notification is through more than one source, for example providing leaflets for the school to distribute with students' daily notes for parents, emailing through a parental database or using the school's email system, and notifying parental organisations such as CPCF with requests to publicise. CPCF would appreciate details of how the Council intends to improve its parental consultation processes.
3. New arrangements start in April 2018 rather than September 2018. Cumbria County Council has stated the Easter start date was at the request of CPCF, James Rennie School, and the SEND Team, but unfortunately, Cumbria County Council have got their facts wrong as is evidenced by minutes the Council provided in May 2016. The proposal for changing the start date was made by the Council in a meeting in May 2016. In the minutes of the meeting Cumbria County Council prepared, it was the Council who said:
"Introducing new contracts in September when there are new starters, pupils transferring and general changes, with little ability to contact schools for information or to discuss changes in pupil mix, could be lessened by having contracts starting at a different time of the year, eg Easter. This would be explored as part of the review."
However, although the Council decided to carry out a review it appears they did not consult with parents, and no members of CPCF were in attendance at any review meetings. Effective consultation with parents and CPCF would ensure the views of the users of this service are made known to the Council. Cumbria County Council has agreed in the past to ensure there are adequate and regular consultations, but the Council has not put this into effect. This should be addressed by the Council, and CPCF would like to know how this will be done.
4. Cumbria County Council Transport confirmed students' EHCPs are not shared with them by Children's Services as part of the process of commissioning services. There is no statutory or sensible reason why a necessary information should not be disclosed to Transport, and this will assist in ensuring effective and sympathetic transport is commissioned which meets the needs and wellbeing of students. This should be addressed by Cumbria County Council, and CPCF would appreciate confirmation and details of how this will be achieved.
WHAT CUMBRIA COUNTY COUNCIL SAY ABOUT THEIR PROCUREMENT AND COMMISSIONING POLICY
5. Cumbria County Council confirmed that ultimately the contract is awarded at the lowest overall price to the Authority (subject to all other safety and licensing criteria being met). CPCF believes the Council's policy does not comply with legal requirements. As a public body, the Council has to procure services on a value for money basis. This is generally defined as economy, effectiveness, and efficiency, and this does not mean simply agreeing to the lowest quote obtained. Other costs must be considered, such as the cost of students not having the most effective education because of poor transport arrangements, the cost of students' poorer general and mental health wellbeing and the cost to parents affected by this. It appears to CPCF that Cumbria County Council has perhaps lost sight of its statutory duty to provide services that comply with the social law when carrying out its procurement of these services. These other costs may be difficult to quantify, but CPCF asserts Cumbria County Council are bound to consider these costs in its procurement process. CPCF welcomes details from the Council as to how they propose addressing this.
CUMBRIA PARENT CARER FORUM
7TH APRIL 2018