Element 3 Funding 2025-26

Introduction and context 

This guidance covers the revised approach to Element 3 funding for Norfolk for 2025/26 academic year and is as a result of significant review work involving many school leaders across multiple engagement opportunities, culminating in Norfolk's Schools Forum review and feedback regarding the principles of this approach at their December 2024 meeting.  Papers for Norfolk's Schools Forum are available here.

Everyone's time, effort and contribution has been greatly appreciated.   

At its heart, the Local First Inclusion (LFI) programme has the aim of shifting the educational landscape in order for Norfolk's children to receive the right support, in the right place at the right time in order to FLOURISH. This includes the implementation of a SEND and Inclusion Support Model (SISM) so schools, families and children have access to multi-disciplinary support and information in order to be empowered to meet the needs of their young people, as well as navigate clear routes through the educational landscape. The funding that schools receive is an integral part of shaping their offer; Element 3 is part of this.  

Element 3 (E3) funding, sometimes referred to as 'top-up' funding, is the funding required over and above the core funding (elements 1 and 2) that a school or college receives to enable a pupil or student with high needs to participate in education and learning. Element 3 (or top up) funding is intended to contribute to the costs of special educational provision for children and young people with high needs, taking into account other elements of funding that also contribute to meeting such costs, such as mainstream schools' core funding to meet the cost of additional support up to £6,000 per pupil. 

The DfE published the High Needs Funding: 2025 to 2026 Operational Guide on 28 November.  This guide outlines how the high needs funding system will operate for the 2025/26 Dedicated Schools Grant (DSG) financial year, detailing the roles of local authorities, schools, and colleges in funding arrangements. It includes information on top-up funding and how it supports students with special educational needs and disabilities (SEND) in mainstream settings. 

The publication of the DSG conditions of grant for 2025/26 are awaited, but the current conditions are available for 2024-25 DSG financial year, which places a duty upon local authorities to ensure that the DSG grant monies are spent on the purpose for which they are intended.  

This guidance is intended to provide the detail to enable to schools to plan and prepare for the 2025/26 academic year in relation to distribution of Element 3 funding, including the information required to be submitted to the Local Authority to enable the provision of indicative allocations by Easter 2025.  

Please see the relevant website pages for further context information.

Intentions and high-level principles of the revised Element 3 model 

Through the work undertaken with school leaders since May 2024, along with reviews of how Element 3 funding works in other local authorities, we have developed a set of high-level principles for Norfolk's Element 3 model going forward. 

The intention is to achieve a model that combines the benefits of a 'needs led' and 'money follows the child' approach, whilst considering cohorts as well as individual children. The LA also wants to provide the certainty and stability that formula funding via proxy indicators can achieve.  This is with the aim of supporting schools to meet need earlier and more effectively, consequentially reducing the escalation of need and demand for specialist provision.  

Through the join work, we co-produced with system leaders the following high-level principles and key features to be in place: 

• Funding to be applied fairly and transparently across the county 
• Controls for funding 
• Mechanisms to ensure funding is being used for its intended purpose 
• To focus funding where there is most complex need 
• Funding to be able to be used flexibly by schools across their high SEND cohorts  
• Funding needs to be linked to evidence 
• A mechanism to recoup funding that is not used appropriately 
• To work collectively within the system to meet high needs within the budget available 

Alongside these high-level principles, schools and academies are encouraged to consider the outcome of recent national reports, such as the ISOS Partnership report published in July 2024, which included key findings in relation to provision in mainstream schools including:  

• Inclusive polices that promote high outcomes for all students  
• Flexible and accommodative curriculum  
• Strong and supportive school leadership  
• Equitable distribution of resources  
• Teachers who are trained in inclusive pedagogy and view it as their role to teach all learners in a diverse classroom 

This aligns with the principles that high-quality teaching is an expectation of all settings, delivered within an ethos of inclusion that enables young people to access their learning environments successfully, through adaptations and scaffolding to ensure success. Consistency in this practice should be throughout a setting in order for a young person to be fully included every day.     

The LA believes that these can be summarised through 5 Es that can lead to helpful questions for schools to consider as provision is designed and implemented. 

Do we have an ethos of an intentional commitment to inclusion? 

Does our environment prioritise a core additional needs offer through a school? 

Are our staff empowered to meet need and support children to FLOURISH through information, Continuing Professional Development and outreach? 

Expectations of Ordinarily Available Provision and Element 2 Funding (Notional SEN allocations) 

The LA currently has published PEaSS (Provision Expected at SEN Support) guidance that has been historically co-produced, and subsequently reviewed, by both parents and professionals.  Although the name suggests that it is focused on SEN Support provision (Targeted), it actually covers Norfolk's expectations of Ordinarily Available Provision (Universal), as well as touching upon Enhanced provision.   

Through the Graduated Provision Map (GPM), schools are asked to identify provision across three categories: Universal provision (available to all as needed, i.e. ordinarily available provision), Targeted provision (small group interventions and the support that would be expected to be funded from Element 2 funding either for children and young people identified as having SEN support needs or with an EHCP) and Enhanced provision (bespoke provisions for a small number of children and young people with the highest levels of SEN). 

On a small number of occasions, due to the combination of both the number and high needs of children within a school, the school may have insufficient core funding (Elements 1 and 2) to fund all Targeted provision.  The notional SEN budget for mainstream schools: operational guide 2024 to 2025 provides the option for LAs to provide targeted funding to supplement a school's notional SEN budget, but this is not a requirement.  The LA is not intending to introduce such a budget on the basis that, where this is the case, it should be apparent through the Graduated Provision Map, and the school level approach to Element 3 funding proposed will allow for dialogue as to whether provision can be adapted to remain both adequate and affordable within the resources available or whether additional top-up funding (Element 3) is required (i.e. is, as the DfE guidance asks, the school over identifying needs, or does the school have a significant mismatch between notional SEN (Element 2) and the actual costs of Targeted provision because of a disproportionate number of children with SEN or pupils with needs of a particular kind that are not captured by the formula factors and values used).   

Element 3: Formulaic allocation from September 2025 

The LA has published a view to move towards either reducing or removing the High Needs to Schools Block transfer as per 19 November 2024 Schools Forum meeting (papers available here, item 5(5), page 68), though subject to agreement with the DfE given that the principle is currently a key aspect of the Safety Valve agreement. 

This is in response to the significant engagement undertaken with school leaders along with reviews of our closest physical, as well as statistical, neighbours' arrangements.   

The aim is to ensure schools have all the funding allocated to them via the National Funding Formula (NFF), alongside increasing Notional SEN allocations to align with the national average (and neighbouring authorities), to enable them to meet the needs of the majority of children with SEND. In turn, this would reduce the level of E3 resource required to be distributed. 

To support transition in this direction, the LA will, from September 2025, distribute a proportion of Element 3, equivalent to the block transfer value anticipated to be £9.7m if agreed by the Secretary of State, via NFF factors and values, mirroring what a school would have received if there was not a block transfer for the autumn 2025 and spring 2026 terms. This is to enable schools to have the funding in their budgets to plan effectively to support high levels of inclusive practice within all schools across the county.   

This means that the LA expect that the vast majority of children currently funded at bands 1 to 4a would be unlikely to require Element 3 funding on an individual or cohort basis.  However, the LA are aware that there may be exceptions that would need to be considered either due to specific individual needs combined with a particular school context, or due to a particular cohort's needs, and this is covered below. 

Element 3: Cohort and individual funding from September 2025  

The LA will use a relationships-based approach with individual schools that links needs assessment (Identification of Needs Descriptors in Education Settings, INDES), the school's Graduated Provision Map (GPM), self-evaluation of a setting's preparedness to meet need (Inclusion and Provision Self-Evaluation Framework, IPSEF), and 'assess, plan, do, review' approach to child-level provision.  Funding is considered for the whole school, considering particular cohorts and individuals within the school, to ensure that schools are adequately and appropriately funded to meet the needs of children with high-level SEND. 

This means individual children will not be funded by bands as they have been in previous E3 arrangements.  For small schools, the 'cohort' may just be an individual child with high-level SEND where funding is necessary to enable the appropriate provision is in place to meet their needs.   

This is as opposed to an application basis for individual children that is commonly utilised in other local authorities, because we want to work as a system in collaboration with joint ownership, responsibility and accountability for meeting the needs of our children and young people in Norfolk.  Regular dialogue with schools about their cohorts and provision plans will enable a setting's context to be considered alongside the needs of individual children and cohorts.  To do this, the LA expect schools to work in an open way to co-design the best possible use of resources across Norfolk. 

To enable provisional allocations to be indicated to schools at the earliest opportunity, to enable their planning and preparation, for 2025-26 academic year, schools are required to submit their updated documentation (see below) by a deadline. Documentation and other information available to the LA will then be reviewed and a view indicated.  This would also utilise other information e.g., dialogues that have already taken place, such as Team Around the School meetings or engagement with SEND advisors, as well as considering access to other SEND services and outreach that the school may not be currently accessing.   

To enable provisional allocations for autumn '25 and spring '26 to be indicated by Easter, the LA will request that schools submit the information required by February half term 2025.  Following the notification of the provisional allocations, the LA will make arrangements to allow for schools to be able to raise any concerns and, if appropriate, enter into a dialogue ahead of September.   

This timeline allows for early planning for phase transitions (i.e. infant to junior and junior / primary to secondary) and entry into reception (including Bridging Funding), with the expectation that conversations will need to continue to finalise arrangements as school place offers are finalised.  

For those schools who have already completed graduated maps and have kept INDES and IPSEFs up to date, it would be expected that there is minimal additional work required, other than to review for the latest circumstances of the school.   

In the long run, the LA is of the view that consideration of requests for Element 3 funding would benefit from a multi-agency approach, as seen in neighbouring authorities. However, due to the speed of initial decisions required ahead of 2025-26 academic year to allow schools to plan effectively, an LA only approach in dialogue with the school will be utilised whilst longer term arrangements are put in place.   

 The LA are aware that moving to a revised system will take time and, given that Norfolk has c. 400 mainstream schools, introducing a new approach may cause challenges that we will need to work together to overcome. 

Documentation

Schools are asked to submit the following documentation by February half-term to enable the LA to provide an indication of cohort funding from September 2025: 

• INDES for children identified with SEN with a clear support plan utilising the 'assess, plan, do, review' approach and identifying SMART outcomes to be able to review against in the future, and that links with the school-level GPM 
• IPSEF for the school that identifies the school's strengths and development areas for supporting differing SEND 
• School-level Graduated Provision Map (GPM), including Universal provision (available to all as needed, otherwise known as ordinarily available provision), Targeted provision (small group interventions and the support that would be expected to be funded from Element 2 funding either for children and young people identified as having SEN support needs or with an EHCP) and Enhanced provision (bespoke provisions for a small number of children and young people, including Enhanced SEND Provisions (ESP) where appropriate).  A GPM is expected to be a dynamic tool that is constantly under review and reflects the provision in place for all children. GPMs will form the basis of conversations within the SEND and Inclusion Support Model (SISM).  

Due to the need for information to be in a consistent format we are asking that schools use the NCC GPM format. 

INDES	IPSEF	PEaSS	GPM
CYP-level information	School-level information	Provision ideas	School provision map

Moderation arrangements 

The LA will continue to facilitate the INDES moderation process (IMP). Settings are encouraged to moderate INDES and SEN support plans internally as part of their identification of needs processes within their SEND policy. Ideally, external moderation between settings in a local area or Multi-Academy Trust could take place as well.  

Additional considerations in decision making 

Given the that introducing a revised system for c. 400 mainstream schools in Norfolk over a relatively short period of time will, no doubt, be challenging, the LA will also utilise other information and intelligence held in relation to individual schools alongside the documentation submitted by schools to identify initial, indicative allocations.   

While not an exhaustive list, this will include: 

• Settings who have received an outcome 1 from the INDES Moderation Panel (IMP) will be subject to a 'light-touch' review because the IMP process has already enabled the school to demonstrate good practice in identification of needs and appropriate individual and cohort provision planning, which leads the LA to have confidence that the school is able to plan effectively and identify appropriate provision to meet need. 
• The approach of the school to ensuring an ethos and environment that is highly inclusive, and the empowerment of the staff involved. 
• Dialogue and data shared through Team Around the School approaches.

Phase transition arrangements 

Phase transition conversations with feeder schools will take place through local transition arrangements between settings, providers and families. Any support required from LA teams can be sought through the SISM via Team Around School (TAS) discussions or via the phoneline. Where TAS support is not in place, SEND and Inclusion Advisers will continue to work with their designated schools to support planning for the new academic year. It is advised that schools keep their GPM under review utilising the data available through the offers process to support early planning.  

Year R Bridging Fund will continue in its current format being a time-limited allocation targeted to support the transition of children identified with particularly high needs entering into the mainstream school system. The fund is given to allow children time to settle into their new schools and for settings to get to know them and understand their needs. During the summer term, LA officers will use point-in-time information to construct a list of children with high needs and their mainstream education settings destinations. This information will be communicated to schools following finalisation. 

Mid-phase new starters and leavers 

There is an expectation that schools will review the GPM to reflect those children and young people who start or leave mid-phase and make any necessary adjustments, which will be discussed within Team Around a School conversations, including any implications for E3 cohort funding.  

A GPM needs to take account of children who are temporarily attending other provision, such as off-site AP or a sessional SRB, including consideration of successful reintegration into full time attendance at the home school. A GPM will also be adjusted once a child has left the setting, for example, through exclusion or moving to another setting either within or outside of Norfolk. 

Attendance 

The LA's attendance support, information and guidance can be accessed here.

As a reminder, the attendance policy should be considered, particularly with regard to reduced timetables where: 

'In very exceptional circumstances, where it is in a pupil's best interests, there may be a need for a school to provide a pupil of compulsory school age with less than full-time education through a temporary part-time timetable to meet their individual needs.  

For example, where a medical condition prevents a pupil from attending school or another setting full-time and a part-time timetable is used to help the pupil access as much education as possible.  

A part-time timetable should not be used to manage a pupil's behaviour. A part-time timetable should:  

• Have the agreement of both the school and the parent the pupil normally lives with.  
• Have a clear ambition and be part of the pupil's wider support, health care or reintegration plan.  
• Have regular review dates which include the pupil and their parents to ensure it is only in place for the shortest time necessary.  
• Have a proposed end date that takes into account the circumstances of the pupil, after which the pupil is expected to attend full-time, either at school or alternative provision. It can, however, be extended as part of the regular review process. In some limited cases, a pupil with a long-term health condition may require a parttime timetable for a prolonged period. Where the pupil has a social worker, the school is expected to keep them informed and involved in the process.' 

See Attendance forms and templates.

As with any other changes that affect provision, children and young people on reduced timetables and with high rates of absence or non-attendance, will need to be factored into a setting's Graduated Provision Map.  

One-off funding considerations

There may be some occasions where one-off funding could be considered the best value approach to meeting a specific need in the school, for example, staff training or environmental adjustments. Such conversations should be raised within SEND and Inclusion Support Model (SISM) meetings such as Team Around a School (TAS) and considered within the Graduated Provision Map. Under usual circumstances, staff training should be planned within a setting's CPD budget therefore the distinction between 'one-off' and ongoing CPD will need to be made during planning conversations. 

Staffing cost assumptions for utilisation in Graduated Provision Maps with respect to Element 3 funding 

Review of other local authorities approaches to Element 3 highlighted that neighbouring authorities provided either:

1. Indicative hourly rates for staff that could be used by schools and academies when costing provision, to ensure an equitable approach across their county
2. The equivalent amount of teaching assistant time per week per child that would be expected to be funded from a schools' Notional SEN allocation (i.e. the schools' contribution of the first £6,000 towards the support) 

It is recognised that settings can pay their staff at different rates, but to support the desire for an equitable approach across all of Norfolk, Element 3 funding staff time should use the following hourly rates provided below as a maximum (actual cost where this is lower, or the school would be expected to return unused funds).  The equivalent number of hours that would expect to be funded through the first £6,000 of support from Notional SEN allocations per child supported is shown for information.   

The LA expects that support plans for children and young people, along with the school's overall Graduated Provision Map, will indicate the level of staff required to deliver identified interventions.  Where an intervention is to be delivered by a higher level of staff, it is expected that the school is clear as to why this higher level of skills and experience are needed to enable successful delivery.   

These calculations are based upon payment for 44.65 weeks per year, which allows for a 38 weeks +1 contract along with associated contractual holiday pay.  The midpoint salary has been uplifted to allow for the increase in National Insurance and an assumed 3% pay increase for 2025/26.  The rates will be reviewed once any pay award has been agreed.

Expectations of use of E3 and conditions of grant

Under the DSG conditions of grant, LAs are required to ensure that high needs funding is used effectively and efficiently, including that the LA's Chief Financial Officer (CFO) is required to provide assurance to Department for Education (DfE) / Educations Skills and Funding Agency (ESFA) that monies are spent on the purpose for which they are intended.  The LA is also expected to maintain proper arrangements to ensure value for money in relation to DSG monies.  

 It is expected that unneeded funds are returned to the LA where a school or academy does not require some or all Element 3 funds for the purposes that it was provided, i.e. to top-up schools core funding to secure the necessary provision to enable the needs of children and young people with high SEND to be met.  This is to ensure that best value is delivered for this funding, i.e. that these funds are used for necessary and appropriate purposes in effective and efficient ways.   

Schools and academies are, therefore, expected to keep appropriate records and documentation that clearly identify the needs and support plans for children and young people with high SEND, the SEND provision within the setting to meet those identified needs and plans, and the supporting documentation accounting for, or evidencing how, Element 3 funding has been used.   

The Element 3 budget is a significant proportion of the High Needs Block, which has seen significant growth in recent years.  The LA's internal audit team will continue to undertake assurance work to enable the CFO to provide these assurances to the DfE.  

 The HNB funding is provided for specific purposes and so, to gain this assurance, a sample of schools would be required to trace the funding allocated through to spend.  From a schools' viewpoint, given the funding is provided for a specific purpose, both the funding and spend should be easily identifiable as being outside of normal budget shares. 

Upon receipt of funding, it will be assumed that settings are agreeing to compliance of the above terms including partaking in any assurance activity undertaken by the LA.  

Clear expectations associated with use, and methods for assurance of the use of E3 funding, include expectations for children to develop independence over time that also builds confidence for the young person and family. The LA therefore encourages settings to review plans to ensure targets are working towards achieving this for each child. Targets need to empower children towards independence and requesting adjustments that allow themselves to be included in all school activities, and to develop skills that can be applied outside of the school environment and into adulthood.   

Below is a list of provisions that may be sourced from E3 high needs funding. This list is not exhaustive but gives examples.  All provisions should be those which sit above the setting's Universal and Targeted offer and are specific to a child or young person or small group: 

• Bespoke interventions/ child or young person specific provisions 
• Specific curriculum delivery support,  
• External professional commissioned and time-limited support 
• Child or young person specific resource 
• Time-limited alternative provision 
• Enhanced careers education, information and guidance 

Below is a list of examples where Element 3 funding should not be used to contribute to or subsidise: 

• SENDCo salary 
• Staff who are contracted to work with all children and young people in the setting such as Head Teachers, Pastoral Leads and Designated Safeguarding Leads.  
• Administrative posts 
• Provision which is already funded via a different mechanism, such as funds linked to ePEPs or Pupil Premium