Guidance

High needs place change process: 2024 to 2025 academic year

Updated 19 December 2024

Applies to England

1. About this guidance

This guide is primarily for local authorities, schools and colleges. It sets out the process for local authorities to notify the Education and Skills Funding Agency (ESFA) of provider level changes to their 2024 to 2025 high needs place numbers. The guide should be read alongside the High needs funding 2024 to 2025: operational guide, which sets out further details about the allocation of place and top-up funding, and the How to complete the place change workbook guidance. Where we refer to schools and colleges, this relates only to those in scope of the place change process.

For changes to hospital education funding, local authorities should also read the 2024 to 2025 local authority hospital education funding guidance.

2. New for 2024 to 2025

The place change process is broadly the same as last year.

3. Changes requiring a deed of variation

We require trusts to produce a deed of variation for requests relating to a new age range at academies or for new resourced provision at mainstream academies. For this change to be reflected in the academy’s general annual grant statement, the deed of variation must be signed and submitted by the trust to us by 8 December 2023. As with last year, we can update the initial allocation, provided the deed of variation is signed and with us by 19 April 2024. In this instance, we will send a revised allocation by the end of August 2024.

4. Section 1: the place change process

The place change notification process enables provider local authorities (the local authority in which the school or college is located) to notify us of any changes to the number of high needs or hospital education places at those schools and colleges funded via us. If no change is requested, the 2023 to 2024 academic year place numbers will be used. Local authorities can also request a change to their hospital education funding if there is a change in healthcare or medical provision in their area.

5. Changing place numbers

5.1 Overview

Discussions between local authorities, relevant schools and colleges in their area (see below for the list), schools and colleges out of their area that they use for placements, and those schools’ and colleges’ provider local authorities, should begin as soon as possible to ensure local authorities can submit their returns to us by the 10 November 2023  deadline. In line with section 9 and section 13 (for alternative provision academies) of the high needs funding: 2024 to 25 high needs operational guide, it is important schools and colleges are proactive and engage with their provider local authorities, especially if they believe the number of places funded in the current academic year may not be appropriate for the following year. Similarly, local authorities commissioning places at a school or college for which they are not the provider authority, should ensure their places are included. This is particularly important if there is likely to be a significant change in the numbers commissioned.

Local authorities should undertake detailed work to forecast the number of places they and neighbouring authorities will need in the forthcoming academic year; they should consult with their schools and colleges to plan where new placements will be needed. Any confirmed increase in the number of pupils or students at a school or college should be reflected in an increase in the number of places. The costs of expanding specialist provision should be shared proportionately.  Schools and colleges might be expected to meet the marginal cost of a small number of additional pupil or student placements above funded places, without additional place funding, but a planned significant increase should be included in the place numbers submitted by local authorities. Further information on how the place and top-up funding should work is set out in the high needs operational guide.

We expect local authorities, and schools and colleges to agree in writing the number of places to be funded before completing the high needs place change workbook. This helps avoid disagreements and disputes at a later point. We recognise there may be exceptional cases where local authorities, and schools and colleges do not agree on the number of places to be funded. In these cases, the provider local authority may submit a return but must record it as ‘not agreed’. ‘Section 2: outcomes’ explains how we determine these and reflect them in the published outcomes.

We will issue the place change notification process outcomes in late January 2024. There will be a 2-week window for local authorities, schools and colleges to query outcomes following their publication. This also provides an opportunity for local authorities and their schools and colleges to agree and submit revised place numbers where plans have changed.

5.2 Providers in scope of the place change notification process

The following providers are funded from a local authority’s dedicated schools grant (DSG), via us, and are, therefore, within scope of the 2024 to 2025 place change notification process:

• mainstream primary and secondary academies with special units, resourced provision or sixth forms
• mainstream free schools with special units, resourced provision or sixth forms
• studio schools
• university technical colleges (UTCs)
• special academies
• special free schools
• AP academies
• further education (FE) colleges
• independent learning providers (ILPs)

The process should be used to notify us of changes to the number of funded high needs places, hospital education places and changes to the hospital education per-place funding amount at the above schools and colleges. In addition, this process should be used to notify us of 2024 to 2025 place numbers for:

• special post-16 institutions (SPIs) that meet the initial eligibility criteria for receiving place funding directly from us in 2024 to 2025, as set out in ‘Section 2.3 SPI-due-diligence-process’, and we do not currently fund in 2023 to 2024 (they will normally be providers that already receive funding from the commissioning local authority, but may include new providers)
• maintained primary and secondary schools with special units, resourced provision or sixth forms, maintained special schools and PRUs that convert to academy status on, or by, 1 January 2024
• post-16 place numbers at academies, or pre-16 place numbers for special educational needs (SEN) units or resourced provision at mainstream academies being funded as part of the place change process for the first time. The trust must sign and submit an appropriate deed of variation to us by 8 December 2023 for changes to be reflected in the initial funding allocations to be issued by the end of March 2024. If the deed of variation is not in place by 8 December 2023, a further deadline of 19 April 2024 will be provided for changes to be reflected in revised funding allocations that are to be issued by the end of August 2024.

5.3 Changes to local authority hospital education funding

As in previous years, local authorities can request changes to the hospital education funding factor in their DSG where there has been a permanent change to medical provision locally, or where such a change will occur during the next funding period. Local authorities must submit requests for changes through the high needs place change workbook. We have published a separate guide explaining the criteria for requesting additional 2024 to 2025 local authority hospital education[WB5]  funding and the evidence we require.

5.4 Providers out of scope of the place change notification process

The following are outside the scope of this process:

• maintained primary and secondary schools, maintained special schools and PRUs:
  • changes to pre-16 and post-16 place numbers in maintained schools are funded directly by the maintaining local authority and do not need to be notified to us through this process
  • when a local authority-maintained school converts to an academy, the local authority must notify the DfE project lead of the current place numbers before converting
• AP free schools – we will contact AP free schools in November 2023 for information to determine their place funding allocations for the 2024 to 2025 academic year
• non-maintained special schools (NMSSs), SPIs (except for the SPIs seeking place funding from us for the first time in the 2024 to 2025 academic year) and a small group of FE colleges and ILPs – we fund these schools and colleges are funded directly using the school census and individualised learner record (ILR) data respectively
• where there is an age range change at academies, pre-16 place numbers for SEN units or resourced provision at mainstream academies, and we have not received an appropriate signed deed of variation by 19 April 2024. In such cases, a local arrangement should be made
• FE colleges and ILPs that will not receive element 1 funding from ESFA in 2024 to 2025 academic year

Although local authorities do not need to return place numbers to us for these schools and colleges, they should consider:

• the entirety of the high needs provision available across both mainstream and specialist schools and colleges
• how that provision is currently meeting the needs of children and young people
• what changes are necessary to meet their needs in future

This should be an important feature of local authorities’ strategic planning processes and discussions with all schools and colleges offering special provision for their young people.

6. Important dates and actions

6.1 October 2023

DfE:

• launches the process and publishes guidance
• publishes the January 2023 school census data for special academies and free schools (we issued 2022 to 2023 ILR R06 data for colleges to local authorities with the import/export adjustment for the 2023 to 2024 financial year in June 2023)
• publishes the 2023 to 2024 high needs place allocations to providers (opened as of 1 October 2023)

Local authorities:

• continue discussions with schools and colleges about the 2024 to 2025 place numbers, taking into account forecasts and plans for increases and decreases
• engage with other local authorities where they commission a number of places at a school or college in their area, to ensure the total number of places reflects this

Schools and colleges:

• continue discussions with local authorities about commissioning high needs places for 2024 to 2025
• consult with their provider local authority to agree the total 2024 to 2025 funded places, including places commissioned by other local authorities

6.2 10 November 2023

Local authorities:

• deadline to submit 2024 to 2025 high needs place number changes
• deadline to submit requests for changes to local authority hospital education funding

6.3 End of November 2023

DfE:

• completes the initial validation of returns (we may request a resubmission)

Local authorities:

• respond to our requests to resubmit the workbook

6.4 8 December 2023

Schools:

• submit signed deed of variation to us for changes in the age range at academies, or pre-16 place numbers for SEN units or resources provision at mainstream academies being funded as part of the place change process for the first time, in order for the change to be reflected in the allocation to be sent by end of March 2024.

6.5 Mid to late January 2024

DfE:

• publishes the outcomes of the place change notification process
• the 2 week enquiry window opens for issues relating to the published outcomes
• publishes the 2022 to 2023 post 16 ILR R14 data
• writes to relevant local authorities confirming outcome of hospital education funding requests

Local authorities:

• check published outcomes are correct

Schools and colleges:

• check the published outcomes are correct

6.6 Early February 2024

Local authorities:

• the 2 week enquiry window closes for issues relating to the published outcomes

Schools and colleges:

• the 2 week enquiry window closes for issues relating to the published outcomes

6.7 March 2024

DfE:

• issues the 2024 to 2025 high needs allocations to FE colleges, free schools, academies, NMSSs, SPIs (funded by us in the 2023 to 2024 academic year) and ILPs, including those with changes requiring a deed of variation in place by 8 December 2023

Schools and colleges:

• check the 2024 to 2025 allocations are correct, inclusive of high needs place numbers (we may not change place numbers if not previously notified through the place change notification process)

6.8 April 2024

DfE:

• updates the 2024 to 2025 DSG to reflect the outcome of the 2024 to 2025 place change notification process and high needs place deductions (DSG allocations are updated termly for in-year academy conversions)
• publishes the 2024 to 2025 high needs place numbers at provider level

6.9 19 April 2024

Schools:

• submit signed & sealed deed of variation to us for a change in age range at academies, or pre-16 place numbers for SEN units or resourced provision at mainstream academies being funded as part of the place change process for the first time, in order for the change to be reflected in revised allocations sent by end of August 2024

6.10 May to August 2024

DfE:

• issues allocations to new SPIs being funded for high needs places in the 2024 to 2025 academic year for the first time. Allocations will be issued once SPIs have passed the due diligence process and relevant set up actions have been completed. Details of the actions required will be sent to each institution directly
• issues revised 2024 to 2025 allocations for schools with changes requiring a deed of variation to be signed and received by us by 19 April 2024

7. How to determine the number of funded places

As in 2023 to 2024, places funded should broadly reflect both local authorities’ recent commissioning activity and strategic planning, to secure suitable special educational needs and disabilities (SEND) provision and AP in line with their statutory responsibilities. In determining the number of funded places, local authorities should consider all of the schools and colleges in their area that are funded based on the number of places  ; and must take account, not only of their own commissioning plans and decisions, but also those of other local authorities. In the case of AP, they should also consider local schools’ commissioning activity and plans.

Collaborative relationships and early dialogue between local authorities, and schools and colleges play an important part in the preparations for academic year 2024 to 2025. To agree appropriate allocations of high needs and hospital education place funding to providers:

• provider local authorities should discuss both current numbers of places being taken up, and the number of places required in future, with their schools and colleges
• schools and colleges should raise cases with their provider local authorities where they believe they are not being funded for the correct number of currently commissioned places or where the number of commissioned places is likely to change
• local authorities commissioning places for which they are not the provider local authority should engage with the school or college so that they are aware of any change in the number of places to be commissioned. Where there is likely to be a significant change to the number of places they commission, local authorities commissioning the places should also contact the provider local authority to ensure this is reflected in the number of places funded

The funded places should include the total number of places required to meet the needs of all local authorities, not just those of the provider local authority. This is important as the import/export adjustment should ensure that funding in the local authority’s DSG reflects those pupils and students with high needs who are resident in one local authority area and attend a school or college in other areas. Read the ‘how local authority high needs allocations are calculated’ section of the high needs funding arrangements for 2024 to 2025 for more information on the import/export adjustment.  

It is important that local authorities, and schools and colleges work together to agree and submit place numbers that reflect the needs of all local authorities, ensuring that place numbers submitted are as accurate as they can be from the start of the academic year. This ensures an allocation is appropriate and reduces the need for commissioning places in excess of the allocated place numbers. Read the ‘high needs place funding section’ in the high needs operational guide 2024 to 2025 for more information. The section ‘Example: where pupil or student numbers exceed allocated places in a school or college’ also gives advice on funding arrangements in cases where local authorities commission additional places significantly in excess of the place numbers funded for that year.

Local authorities fund increases in place numbers from their high needs budgets. Changes to the 2024 to 2025 high needs place numbers will not change a local authority’s allocation of high needs funding, which is calculated through the national funding formula.

We will publish allocations for the 2024 to 2025 high needs funding block of the DSG for each local authority (calculated using the high needs national funding formula) in December 2023.

8. Section 2: outcomes

We will publish the outcomes of this process in January 2024. If a provider does not appear on the published outcomes, this is because it was not entered on the local authority’s return and the 2023 to 2024 academic year place numbers will be used. The outcomes are based on the local authority returns in line with the principles set out below.

Local authorities, schools and colleges need to check these to ensure the place numbers are correct. If a provider does not appear on the published outcomes, they will continue to be funded on the same place numbers as in academic year 2023 to 2024.   

9. Changes recorded as agreed with the school or college

We will update the 2024 to 2025 place funding to reflect the numbers the local authority notifies to us, where recorded as ‘agreed’ with the school or college. This will be reflected in the outcomes published in January.

Where there is an agreed age range change at academies, SEN unit or resourced provision at mainstream academies not funded in 2023 to 2024, we will check that the academy’s funding agreement allows for the change. For these changes to be considered as part of this process, local authorities should, ensure during their discussions with academies, that the required deed of variation has been signed and provided to us by 8 December 2023. This will result in changes being reflected in initial funding allocations issued by the end of March 2024. If the deed of variation is not in place by 8 December 2023, a further deadline of 19 April 2024 will be provided for changes to be reflected in revised funding allocations issued by the end of August 2024. 

If the deed of variation is not in place by the 19 April 2024, we will not fund the places in the 2024 to 2025 academic year and a local arrangement should be made. For further advice about this, please refer to the section on ‘Where pupil and student numbers differ from allocated places’ in the high needs funding operational guide 2024 to 2025.

SPIs will be agreed subject to the due diligence process described in section 2.3.

10. Changes recorded as not agreed with the provider

10.1 Mainstream academies, free schools and AP academies

Where place number changes are marked as ‘not agreed’ for mainstream academies, free schools or AP academies, we will not make a change in place numbers and the January published outcomes will remain as the 2023 to 2024 place numbers that have been funded.

We expect there to be continuing dialogue between the relevant local authorities, and schools and colleges to agree the place numbers. Local authorities, schools or colleges may then use the enquiry window to notify us of changes in place numbers agreed after 10 November 2023.

10.2 Special academies, special free schools, 16 to 19 academies, FE colleges and ILPs

We will consider notifications of place changes marked as ‘not agreed’ with a special academy, special free school, 16 to 19 academy, 16 to 19 free school, FE college or ILP. We expect to receive very few requests that are not agreed. If a change is not agreed, local authorities must report the number of places they are prepared to fund, reflecting the needs of all local authorities, and not the number of places the provider is seeking.

We will use the principles set out below to determine the 2024 to 2025 academic year place numbers (published in January 2024), where place numbers are marked as ‘not agreed’ with special academies, special free schools, 16 to 19 academies, 16 to 19 free schools, FE colleges and ILPs. Decisions will be informed by the published January 2023 school census and 2022 to 2023 ILR R14 data. We will publish the ILR R14 data for the 2022 to 2023 full academic year in January 2024.

These principles should assist local negotiations and can be used to resolve any disputes.

We will only consider 2024 to 2025 place change notifications that are not agreed with the provider, where the change is either:

• at least 10% of the total 2023 to 2024 academic year places for a provider with more than 50 high needs places
• at least 5 places for a provider with less than 50 high needs places in the 2023 to 2024 academic year

For those changes that do not meet the above thresholds, we will use the 2023 to 2024 place numbers. For those changes that exceed the above thresholds, we will determine the 2024 to 2025 place number by using 2022 to 2023 ILR R14 (for FE colleges, ILPs and 16 to 19 academies and free schools returning ILR data) and the January 2023 school census data (for special academies and free schools), and adopt the following 3 principles:

• where the notification and ILR or school census data confirm a reduction to the 2023 to 2024 place data, we will change the 2024 to 2025 place numbers to the higher of the ILR/census data or the notification (see provider A below)
• where the notification and ILR or school census data confirm an increase to the 2023 to 2024 place data, we will change the 2024 to 2025 place numbers to the lower of the ILR/census data or the notification (see provider B below)
• where a notification to change the 2023 to 2024 place data is not confirmed by the trend in the ILR or school census data, we will not make any change to the place numbers and the 2023 to 2024 numbers will be used (see provider C below)

10.3 Examples of how this will work for these providers are shown below:

	Provider	2023 to 2024 high needs places	Local authority notified	Per cent change notified	ILR/census data	ESFA decision	Basis for ESFA decision
Decrease to the 2023 to 2024 places	A	93	65	-30%	67	67	Notification and data show reduction to high needs places. ESFA decide on higher number, which in this case is the data.
Increase to 2023 to 2024 places	B	100	120	+20%	130	120	Notification and data show increase to high needs places. ESFA decide on lower number, which in this case is the local authority notification.
Decrease to the 2023 to 2024 places	C	50	44	-12%	51	50	Notification shows a decrease to high needs places, but data is higher. ESFA therefore roll forward 2023 to 2024  high needs places.
Decrease to the 2023 to 2024 places – below the threshold	D	40	36	-10%	36	40	Notification change is 10%, but for 4 places which is below the 5 place threshold. Change not agreed.
Increase to the 2023 to 2024 places on the 5 place threshold	E	30	35	17%	36	35	Change notification is on the 5 place threshold. Notification and data show increase to high needs places. Agree to 35 places.

11. SPIs: due diligence process

Local authorities should submit details of any SPIs that they propose we fund directly for the first time in 2024 to 2025. The local authority in which the SPI is located is responsible for including these in their place change notification return. The return must include the total number of student places for which the SPI is to be funded and must take account, not only their own commissioning decisions, but also the commissioning decisions of other local authorities. To be eligible to be considered for ESFA funding, these SPIs must:

• have at least 10 student places identified for 2024 to 2025
• have been actively trading for a minimum of 3 months
• be able to supply management accounts for that period

Local authorities should also include SPIs which have been unsuccessful in the due diligence process in previous years, if they want them to be considered for ESFA funding in the 2024 to 2025 academic year.

The deadline for the local authority workbook is 10 November 2023. New SPIs will be subject to a due diligence process that we will undertake to assess if they are eligible to be funded. The costs of these places will mainly be met from local authorities’ high needs allocations on a lagged basis through the operation of the import/export adjustment in the national funding formula.

Following the place change notification process, we will contact eligible SPIs to begin a due diligence process. Further information on the process and the requirements providers must meet to become eligible for ESFA funding will be published in October 2023. Local authorities can commission and fund the full cost of placements in those SPIs that are not in receipt of funding from us, subject to their own due diligence. Therefore, it is only necessary to include in the details of those SPIs for which the local authority is requesting that we pay place funding directly for the first time.

12. Enquiry window

There will be a 2-week window for local authorities, schools and colleges to review the information and raise any enquiries with us following publication of the place change outcomes in January 2024. This includes where a place number previously marked as ‘not agreed’ in the original return has subsequently been agreed. Queries received outside of the enquiry window are unlikely to be considered.

An enquiry can be made by a local authority, school or college. This is also an opportunity for local authorities who commission places at schools and colleges outside their local authority area to ensure the place numbers accurately reflect their needs. If an enquiry is raised in relation to a commissioning position that has not been agreed, we would expect there to be continuing dialogue between the relevant local authorities and school or college to resolve the issue.

We will only consider a request to review place change outcomes where either:

• there is clear evidence of agreement on the 2024 to 2025 place number between the local authority, school or college after a previous position that was not agreed
• the impact on place numbers is significant; this is a change of either:
  • at least 10% of the total 2023 to 2024 academic year places for a provider with more than 50 high needs places
  • at least 5 places for a provider with less than 50 high needs places in the 2023 to 2024 academic year

To submit an enquiry about the outcome of the process, a local authority, school or college must contact [email protected] within the 2-week enquiry window in January 2024 and include ‘2024 to 2025 high needs place number: enquiry’ in the subject line. If a local authority is requesting a change, the relevant school or college must be copied into the email. If a school or college is requesting a change, the relevant local authority must be copied into the email. Please set out the nature of the enquiry clearly and include any background information that provides further context to enable us to consider it.

Local authorities, schools and colleges may provide further information via the enquiry window process in the exceptional circumstance that a place number change cannot be agreed. We will consider requests to change the number of places and may seek additional information. We will consider all available pupil number and other data when considering the requested change. The 2023 to 2024 place numbers may be used, unless there is evidence that another number would be more appropriate. Alternatively, we may hold funding back from the school or college by providing an allocation based on a lower place number. We would make a deduction from the local authority’s high needs allocation based on a higher place number, until a place number can be agreed.