What should Non-School AP leaders be thinking about this summer?

18 Aug

As we all get some time to breathe and think over the summer break I wanted to look at some helpful thinking for Non-School AP leaders. There’s been a whole host of recent guidance and DfE consultations affecting AP and, with a new Education Minister maybe there’s more to come. That creates uncertainty and change so I wanted to unpack the guidance a bit and think about where Non-School AP sits in the future direction of the sector. I also wanted to draw together a bit of a summer to-do list for NSAP leaders both long-term strategy to think about and immediate tasks from the guidance. In any period of change it is worth staying on your toes and being prepared to think ahead and adapt as much as possible.

Someone recently said to me that the DfE were doing all they could to shut down NSAP’s. I don’t know what their context was exactly but what I read, see and the people (including from the DfE) I speak to suggests otherwise. I think that we are in a time of evolution and change and rising standards. In any situation like this there it will be an element of survival of the fittest, NSAP is still going to play an important part in the system but you may have to do some adapting and preparing to make sure that your AP is the fittest and thrives. This article looks at the recent DfE white paper, the voluntary Non-School AP standards, the recent EOTAS consultation as well as the themes we see in wider documents like KCSIE 2026, and new attendance and restraint DfE publications. The links to these, if you want some more detailed summer reading are at the end of the article.

The biggest theme across all the sector publications (and the updated Ofsted framework) is a move from the ‘unregistered’ AP sector which was unregulated and informal - even the DfE didn’t know how many AP’s there were or who they were. The push now is for the sector to be regulated (through local authorities and the Non-School Standards) and for NSAP to be more standards-based and a QA’d established partner within the system. Most AP’s we work with really welcome the increase in credibility and structure this brings but it will mean that, for some settings, they will have to increase their standards.

The DfE see NSAP as fitting into a more sharply defined section of the inclusion system than it is currently. It is trying to get away from AP ending up as a destination for young people – the ethos that runs through all the white paper changes and inclusion base work is that mainstream is the best destination. We work closely with children and young people with all sorts of needs and know that, probably, that isn’t the case for everyone. Some young people will never thrive in mainstream education – at least in its current structure. However, this is the direction of current DfE and Ofsted thinking, so, if you want your AP to thrive then you’ll have to learn to work in this direction.

The white paper talks about three roles for AP:

1) Support and outreach for mainstream settings. To be honest, this partnership would be brilliant but happens so little at the moment that settings developing this would be breaking new ground. I think that probably the first settings doing this well and really working in close partnership with mainstream settings will either be those whose model uses delivery on school premises or those who have established close links already. It’s definitely worth exploring whether you could develop school relationships to work more in a supportive outreach model to complement the schools inclusion strategies.

2) Time-limited placements with an aim at re-integration. Both the white paper and non-school standards talk about 12 week temporary placements in AP to support reintegration into mainstream – if they are strictly time-limited in this way then they could be full-time without getting into the difficulties of Ofsted registration. Those of us who work with young people know that 12 weeks is a very challenging time-frame to support change and successful re-integration but some settings do have success with this model. As a leader it could be worth thinking about whether your setting offers a really focussed journey. For the young people you work with what would it take to move them towards reintegration? Are you explicitly teaching these skills in an intentional way across the placement? Would your curriculum need to change if you were looking at reintegration as an outcome?

3) Longer-term specialist placements. If a young person needs it then the placement can be longer (but would have to be part-time – 2 days or 4 sessions a week). This option would work well for those delivering a specialist vocational AP or working to meet the need of one of the new specialist provision pathways. If you’re currently an AP working with primarily EHCP students then it’s worth looking at these as they develop and tailoring your provision to be able to meet need around these as well as possible. It’ll make the job of persuading LA’s and school to commission you easier as the provision pathways kick in. As an aside, if you are looking to work primarily with EHCP students then evaluating whether you should move to full Ofsted registration is worth thinking through. The DfE having mentioned moving to LA’s having to approve new registered provision applications before you can put them in. It might be a good time to move now, before that happens if that’s something you’re thinking of.

In any of these pathways the guidance is clear about an increased burden on LA’s and schools to make sure that AP is child-centred, based around their needs and is regularly reviewed. You can help by making sure that each young person has a strong plan in terms of the needs you will meet, the interventions you will use, the duration of the placement and the support for transition. It will mean evidencing assessment, -planning and reintegration outcomes if you don’t already. That works in individual cases but base-lines and outcomes (for the academic but also attendance and SEMH markers) are also great evidence for showing commissioners that what they are paying for is working so start to track them if you don’t already.

Another key theme across recent documents is a strong partnership emphasis driven across LA’s. It’s really tempting as champions of struggling young people to always challenge the local authority and end up fighting their decisions. Remember, they could end up being your biggest customer, the direction of travel is for more LA oversight of AP both strategically and in QA. It pays and will pay more to build strong relationships with your local authority. Do you know the key contacts who make commissioning decisions at the LA? How could you make sure they see you as a key part of the inclusion ecosystem in your area (this could need a long-term project communication plan!). Do you share your successes with them so they know how well you work?

The DfE’s voluntary standards involve local authorities moving to QA providers in their area. Lots of LA’s are moving to these standards already and we’re seeing them more often as frameworks and tenders open. In some cases, this is making for a hugely rigorous tendering process. In a recent LA tender we helped organisations with, you needed to provide over 90 documents to evidence you were meeting the standards. Whilst that was wildly over-complicated compared with most the key point to note from this is that it was much easier if a setting was already working to the standards. If you’re not then the tendering process becomes much more difficult to evidence. There are currently 25,000 children in non-school settings but the standards are going to professionalise and consolidate the sector. If you want to make sure of thriving as they come in you need to be working to meet them now. If you need help then we do offer a support package that includes a structured guide to the evidence you may need and templates for anything you may be missing: https://www.closethegaps.co.uk/non-school-ap-standards

In our experience the biggest gaps in practice that providers have are around the need to formalise curriculum policies and planning and to structure pupil induction and planning. There are some policies that are needed that even the strongest providers don’t always have too – a risk assessment policy and induction policy for example, there is also a requirement for a staff medical fitness check which was previously only really seen in schools. Don’t presume that because you’ve always met QA’s in the past you’ve got the DfE standards met. We’ve an self-audit you can download to help you evaluate yourselves here if it’s helpful.

Several additional pieces of guidance back up the expected role for NSAP. The role of being a valued part of the sector where it’s time-limited and focussed, standards are higher and it partners more closely with schools and LAs. The KCSIE 2026 guidance talks about schools always needing to know where pupils are – so attendance tracking and follow up by APs needs to be strong. It also talks about staffing checks for APs and that these should be updated and the school informed where staffing changes in the AP across a year. It also talks about AP placements being reviewed on a half-termly basis. Whilst the onus is on schools to do this they are often busy and this gets pushed out. It makes you a more appealing prospect as an AP if you have this structure already in place and make the review as easy as possible for whoever at the school oversees the AP placements. The changes in KCSIE 2026 in general do have some wider implications for practice in a NSAP and we’ve outlined those in a bit more detail here: https://www.closethegaps.co.uk/updates/kcsie-2026-for-non-school-aps

We also offer (at a small cost) a package to cover what you need for September in terms of the changes: training materials, a summary for DSL’s and wording for policy changes – details for that are here: https://www.closethegaps.co.uk/kcsie-support-2026-changes-nsap

In addition to the big levers of change in the sector there have also been a couple of smaller releases worth noting. The DfE have released guidance around restraint, mobile phones and also updated their attendance documents in the last few months.

Direct statutory duties for schools don't formally bind NSAP but in practice they do effect you, and providers who ignore DfE documents could lose referrals. Placing schools and LAs remain accountable for children, and normally require providers to meet equivalent standards as a condition of placements. In terms of the restraint there is now a duty for schools (and therefore by extension NSAP’s) to record every significant use of force and any seclusion/restraint incident, capturing SEND needs, rationale, injuries and post-incident support. The guidance requires reporting any incidents to parents the same day. Some APs we work with say they have a policy of no physical intervention and therefore don’t send staff for any training around it. The DfE documents make it clear that settings shouldn’t have a no physical intervention approach. It sounds good on paper but working in AP we see extreme behaviours. What happens if a young person was openly self-harming in your setting? You’d want to be able to physically intervene if necessary, how could you do that safely without staff training? I’d recommend staff training in de-escalation and trauma-informed practice, along with physical intervention if you reach a situation where all else fails. NSAP disproportionately serves SEMH/SEND cohorts where restraint is most likely, so exposure is high.

Many APs have a relaxed attitude to mobile phones, some because it’s easier with disaffected young people, some because the young people need them for self-regulation. The guidance for schools now is that mobile phones are not allowed, if you decide, as a NSAP to continue to allow young people to use their phones then you should expect to be questioned on this by commissioners. In an environment where the government has banned them in schools and is in the process of banning social media for under 16’s you’ll need to present a strong and persuasive argument to continue to allow pupils access.

In terms of the attendance data there is now more of a responsibility on commissioners (including LA’s) to track daily attendance to both AM and PM sessions. A school should know where it’s pupils are at all times. To make sure you are as appealing as possible to commissioners you need to be reporting attendance promptly to each session and leading follow up for young people who fail to attend communicating closely with commissioners over this.

So in terms of summer thinking what are the key things to ensure you keep adaptive and ready to thrive in a changing education system? I’ve divided the list into two – the longer-term strategic points to think about and the practical actions to get done to be ready in response to all the new guidance.

Strategic long-term thinking

Define your offer – make sure you’re not just ‘an Alternative Provision’ but you clearly define the needs you work to support. This definition helps you communicate clearly with commissioners and helps you find your niche within the sector. To help you think about this think about: What can you do better than anybody else? Where do you see the most success with young people?

Do you need to specialise around one of the DfE’s suggested AP types? In the documents it was suggested that AP should be either outreach, temporary placements based on reintegration or longer term specialist placements. Where would your AP fit? Is there work you could do to increase your ability to deliver any of these routes?

Are you prepared for the national standards? Local authorities are moving to benchmark quality using these standards, they are likely to become mandatory soon. Have you checked through the standards to see if your provision meets them

Feed into the EOTAS consultation – the DfE have set up a consultation to hear from people around the future of EOTAS. When they did this around AP there was a really small input from people who worked in, what was, at the time called unregistered AP (there was only just over 300 responses in total and less than a third were from providers). Those who work with EOTAS children need to be sharing their expertise. You can respond to the consultation here: https://www.gov.uk/government/consultations/send-reform-education-otherwise-than-at-school

Develop stronger links with your local authority - think about how you can help the LA to understand your value. Cultivate connections to build as strong a partnership as possible.

Practical do-now list

Update and review policies for KCSIE 2026 changes
Prepare training for staff on KCSIE changes - we have some training packs you can access here.
Check staff physical intervention training is in place
Review attendance policies to make sure reporting is prompt and absences are followed up
Check you’ve read all the recent guidance
Self-evaluate your practice against the non-school AP standards

If you’d like more support with any of these aspects including thinking through your long-term strategy and sustainability or audits and support against the standards then do get in touch. We’d love to hear from you.

What should Non-School AP leaders be thinking about this summer?

Further reading

KCSIE 2026 for Non-School APs