Analysis Of Responses To The Consultation On Draft Statutory Guidance For Parts 4, 5 & 18 (Section 96) Of The Children And Young People (Scotland) Act 2014

12 The Child's Plan

12.1 Section 11 of the statutory guidance concerned the preparation, review and management of Child's Plans. This guidance relates to Part 5 (Sections 33-45) of the Act. The consultation asked 14 questions about Section 11 (Questions 25-38). Respondents' views in relation to the first five of these questions (Questions 25-29) will be discussed in this chapter. Chapter 13 discusses Questions 30-35, and Chapter 14 covers Questions 35-38.

Q25: Child's Plan requirement

12.2 Question 25 concerned sections 11.2.4 - 11.2.5 of the guidance and asked: 'Is the draft guidance clear about the definition and explanation of what constitutes a 'targeted intervention?'. Table 12.1 shows that 54% of organisations and 15% of individuals agreed, while 46% of organisations and 85% of individuals disagreed.

Table 12.1: Question 25

	Yes		No		Total
Respondent type	n	%	n	%	n	%
Local authorities	7	(50%)	7	(50%)	14	(100%)
Health organisations	8	(50%)	8	(50%)	16	(100%)
Partnership bodies and joint responses	10	(67%)	5	(33%)	15	(100%)
Other national public sector bodies	4	(80%)	1	(20%)	5	(100%)
Third sector organisations	11	(42%)	15	(58%)	26	(100%)
Professional groups	7	(64%)	4	(36%)	11	(100%)
Other organisational respondents	4	(57%)	3	(43%)	7	(100%)
Total organisations*	51	(54%)	43	(46%)	94	(100%)
Individual respondents	3	(15%)	17	(85%)	20	(100%)

* Two respondents ticked both 'yes' and 'no'. These responses are not included in the table.

Percentages do not all total 100% due to rounding.

12.3 Local authorities and health organisations were divided in their views on this question, while third sector respondents were less likely than other organisational respondents to say that the guidance was clear.

12.4 Altogether, 105 respondents (96 organisations and 9 individuals) commented at Question 25.

Aspects of the guidance respondents found helpful

12.5 Respondents who ticked 'yes' at Question 25 often prefaced their comments by stating, 'The guidance is clear but…', and then went on to highlight issues for which they wanted clarification. In terms of what they found helpful, respondents pointed to statements within the guidance that: (a) the judgement of whether a child requires a Child's Plan will be made 'based on a holistic knowledge of child, informed by the use of the National Practice Model', and (b) that the wellbeing needs of the child 'can most often be met by support from their family, community resources or the support generally available within universal services'.

Aspects of the guidance that were less helpful or which require clarification

Definition of a targeted intervention

12.6 Respondents who ticked 'no' at Question 25 generally wanted clarification about the definition of a 'targeted intervention', while those who ticked 'yes' said that the definition of a 'targeted intervention' was clear, but (a) they had concerns about the definition and / or (b) they felt the examples given of targeted interventions were unhelpful or unclear.

12.7 The main point made by both groups was that the approach set out in the draft guidance - which links the creation of a Child's Plan to the need for a 'targeted intervention' - and the definition of a targeted intervention, which is based on local context and service design - will result in considerable variation and inconsistency between local areas in the number of Child's Plans created. Respondents saw this as problematic because:

• It could cause confusion, both for practitioners in universal services, and members of the public (families in particular).
• For the purposes of national reporting, it means that the number of Child's Plans will not reflect levels of vulnerability in local areas, but rather local service arrangements.
• If a child moves from one area to another, the support they had been receiving through universal services in the first area may be considered to be a targeted intervention in another area, and so may not be available.

12.8 Respondents repeatedly requested clarification about the distinction between 'services that are available generally' and a 'targeted intervention', often presenting specific scenarios to illustrate their queries. For example:

• Is a Family Nurse Partnership a targeted intervention?
• If a GP refers a child to speech therapy, is this a targeted intervention?
• Is an Individualised Educational Programme a targeted intervention?

12.9 Some suggested that the guidance should set out what comprised universal services (or services that are available generally), as this would clarify what a targeted intervention is. Respondents also thought that the lack of distinction in the guidance between a 'targeted' and a 'specialist' intervention was confusing.

Examples given in the draft guidance

12.10 Respondents frequently stated that the examples given in the draft guidance (at paragraph 11.2.5) were 'unhelpful'. Such comments were made both by those who ticked 'yes' and those who ticked 'no' at Question 25. In particular, speech and language therapy input, inclusion in a school nurture class and parent and child participation in a healthy weight programme were all considered to be available through universal services, and thus not requiring a targeted intervention or a Child's Plan.

12.11 Respondents made many suggestions about other examples of targeted interventions they wanted to see in the guidance:

• Targeted interventions (including intensive support services) provided by a third sector or other non-statutory organisation
• Targeted interventions for disabled children
• Early years nursery provision for children under three.

12.12 In addition, it was thought that if a targeted intervention could also include the provision of support to parents (and not just children), this should be made explicit in the guidance, and not just listed as an example.

Other issues / suggestions

12.13 Respondents variously wanted the guidance to include:

• Discussion of 'staged assessment processes'
• Clarification about when an intervention begins and ends
• Details about how third sector agencies delivering targeted interventions not under a contractual arrangement will be involved in the planning process.

Comments from individual respondents

12.14 Individual respondents commented that the definition of a targeted intervention could not be clear so long as the definition of wellbeing is unclear. There were also concerns about the policy being used for the purposes of state surveillance.

Q26: Child's Plan requirement

12.15 Question 26 concerned paragraphs 11.2.7 - 11.2.12 of the guidance and asked: 'Are the arrangements for seeking the views of the child, parents and others during consideration of the need for a Child's Plan set out clearly in the draft guidance? Table 12.2 shows that 77% of organisations and 9% of individuals agreed, while 23% of organisations and 91% of individuals disagreed.

Table 12.2: Question 26

	Yes		No		Total
Respondent type	n	%	n	%	n	%
Local authorities	13	(87%)	2	(13%)	15	(100%)
Health organisations	15	(94%)	1	(6%)	16	(100%)
Partnership bodies and joint responses	13	(100%)	0	(0%)	13	(100%)
Other national public sector bodies	4	(80%)	1	(20%)	5	(100%)
Third sector organisations	12	(44%)	15	(56%)	27	(100%)
Professional groups	9	(90%)	1	(10%)	10	(100%)
Other organisational respondents	4	(80%)	1	(20%)	5	(100%)
Total organisations*	70	(77%)	21	(23%)	91	(100%)
Individual respondents	2	(9%)	20	(91%)	22	(100%)

* Two respondents ticked both 'yes' and 'no'. These responses are not included in the table.

Percentages do not all total 100% due to rounding.

12.16 Most organisational respondents thought the arrangements for seeking the views of the child, parents and others were clearly set out in the guidance - apart from third sector respondents, a majority of whom thought the guidance was not clear on this point.

12.17 Altogether, 88 respondents (76 organisations and 12 individuals) commented at Question 26.

Aspects of the guidance respondents found helpful

12.18 Respondents welcomed the requirement to consult parents and children in considering whether the child has a need in relation to their wellbeing. There was particularly strong support for the statement that the requirement to consult a child should be irrespective of whether the child has a communication or learning difficulty. Respondents also thought that the statement about involving other key people in discussions about the content of the Plan was helpful (paragraph 11.2.9).

Aspects of the guidance that were less helpful or which require clarification

Getting the views of children and young people

12.19 The two main points made by respondents (third sector respondents, in particular) were that, the guidance should be amended as follows:

• In paragraph 11.2.7, 'so far as reasonably practicable' should be removed from the second sentence: respondents wanted the guidance to reflect the presumption that the views of children and young people and their parents are always sought and taken into account, in line with their rights, unless there are exceptional circumstances for not doing so.
• Similarly, in paragraph 11.2.8, the statement that a child's views may be given 'less weight' should be removed: this statement was seen to be contrary to the UNCRC Article 12 and the UN Convention on the Rights of Persons with Disabilities Article 7, which require that the views of the child / disabled child are given full consideration. Respondents argued that even very young children (below the age of 12) are able to give their views, and suggested that practice guidance should include information / tools to support practitioners in this.

12.20 In relation to these points, respondents suggested a range of inclusive methods / tools to assist in communicating with children and young people, such as: Boardmaker, BSL, Talking Mats, Easy Read, My World Triangle. There was also a reference to a published article on guidelines for communicating with children with learning disabilities,^[8] and there was a suggestion that there should be a requirement to provide interpreters for asylum seekers.

Where there is disagreement between practitioners and parents / children

12.21 Respondents felt the guidance needed to include information about: (a) the procedures if the parent (or child) is not in agreement with the plan; (b) what arrangements should be in place for addressing dissatisfaction / disagreement; (c) mechanisms for appeal or redress.

12.22 There was a view that the Child's Plan should be drawn up based on the needs of the child, and not triggered by parental request. However, there was also an argument that parental disagreement should not be a valid reason for not having a Child's Plan.

Other areas for clarification, or suggestions for improvement

12.23 Other points, raised less often, were that:

• Section 11.2.7 states that the child's parent should be involved in the discussion about whether a Child's Plan is needed; however, this would not necessarily apply if: the child is in the care of someone else (as suggested in 11.2.9) or if the child was over 16 (thus able to make independent decisions).
• Clarity is needed about how Self-Directed Support arrangements would apply. In such situations, it may be the parent, not the Lead Professional, who decides on the appropriate interventions.
• If the views of a parent or child are sought and not received, or if information is not shared with the parents, the reason for this should be recorded.
• It was suggested (both by health and third sector organisations) that the guidance should explicitly state (at 11.2.9, part b) that third sector organisations who provide a service to the child should be consulted.

Views of individual respondents

12.24 Individual respondents generally thought that the views of parents should not only be sought, but respected and given priority. Some perceived that the draft guidance was suggesting that the views of parents could be disregarded on subjective grounds. Some individuals also thought the parents (not the Named Person) should decide if a child needs a Child's Plan.

Q27: Content of a Child's Plan

12.25 Question 27 focused on paragraphs 11.3.1 - 11.3.9 of the guidance and the draft Child's Plan Order. The question asked, 'Do you agree that the content of the plan, as set out in the Schedule to the draft Order and described further in the draft guidance, is clear and covers the full range of likely circumstances?' Table 12.3 below shows that 67% of organisations and 14% of individuals agreed, and 33% of organisations and 86% of individuals disagreed.

Table 12.3: Question 27

	Yes		No		Total
Respondent type	n	%	n	%	n	%
Local authorities	13	(81%)	3	(19%)	16	(100%)
Health organisations	13	(81%)	3	(19%)	16	(100%)
Partnership bodies and joint responses	10	(67%)	5	(33%)	15	(100%)
Other national public sector bodies	4	(80%)	1	(20%)	5	(100%)
Third sector organisations	11	(53%)	10	(48%)	21	(100%)
Professional groups	5	(45%)	6	(55%)	11	(100%)
Other organisational respondents	4	(80%)	1	(20%)	5	(100%)
Total organisations	60	(67%)	29	(33%)	89	(100%)
Individual respondents	3	(14%)	18	(86%)	21	(100%)

Percentages do not all total 100% due to rounding.

12.26 While two-thirds of organisational respondents overall thought the content of the Child's Plan was clear, the views of third sector organisations and professional groups were divided.

12.27 Altogether, 91 respondents (82 organisations and 9 individuals) commented at Question 27.

Aspects of the guidance respondents found helpful

12.28 Different respondents highlighted the following aspects of the guidance which they found helpful: the explanations given at paragraph 11.3.5 regarding the minimum content of the Child's Plan; the emphasis on the Plan being written in language which is accessible to all partners, including children and parents; and that the guidance makes clear that certain information may be sensitive (or not relevant) to include in the Child's Plan.

Aspects of the guidance that were less helpful or which require clarification

12.29 Respondents requested clarification about several aspects of the guidance on this section. These comments are summarised below

Disparities between the guidance, the draft Child's Plan Order and / or existing guidance / legislation

12.30 Some respondents thought there were disparities between: a) the minimum data set specified in Part I of the draft Child's Plan Order, and b) various statements made in the guidance. Thus, they were not sure what should and should not be included in the Child's Plan. For example, the guidance (paragraph 11.3.3) states that the Plan should include information about the child's strengths and resilience; however, this is not included in the dataset in the draft Order. This same paragraph states that 'surplus' information (for example, information about a child's educational attainment) should not be recorded in the Child's Plan. Respondents wanted further details about what was considered to be 'surplus' information.

12.31 At the same time, the minimum data set in the draft Order did not include information which would be required in different decision-making forums, for example, in Children's Hearing, courts, or adoption panels. Respondents made the point that if the intention is to have a single Plan for a child, then the content of the Plan needs to be sufficient for all these forums. Related to this, respondents queried the statement in 11.3.4 that the Child's Plan should not contain the full multi-agency assessment, but rather only a summary of the assessments. Respondents noted that full multi-agency assessments are required by a Children's Hearing, and they expressed confusion about whether the Plan should contain the assessment or not.

12.32 Respondents called for a (national) Child's Plan template, along with examples of completed Child's Plans.

Chronology of significant events

12.33 There were frequent requests for clarification in relation to paragraphs 11.3.8 and 11.3.9 (regarding chronology of significant events). Respondents were unclear about whether the Child's Plan should include a single agency chronology, or multi-agency chronology - and whether the chronology was to be incorporated into the document, or attached as a separate document.

12.34 Some thought the guidance should emphasise the importance of an integrated (multi-agency) chronology. However, there was also a query about how to manage a multi-agency chronology so that only significant and relevant information was shared to inform the creation of the Child's Plan.

12.35 Some respondents wanted more detail on what the chronology should contain, while others suggested it would be helpful for the guidance to include a link to the national guidance on the use of chronologies.

Involving parents and children

12.36 Respondents (particularly third sector respondents) strongly supported statements in the guidance about the importance of involving parents and children in the process of creating the Child's Plan, and they agreed with the requirement for the Child's Plan to be written in language that would be accessible to parents and children. However, the point was made that, for some disabled children (and indeed, for their parents), the process of involving them may itself require significant preparation and planning. Respondents questioned whether this would, in reality, be achieved.

12.37 There was also some concern about the need to manage expectations of families (particularly families with disabled children) as to what they will receive as a result of the Child's Plan. Respondents wanted to the guidance to state clearly the circumstances in which it would not be appropriate to involve parents in the review of a Plan (e.g. in situations of domestic abuse), or to share information with a parent about the residence of the child / other parent.

Concerns about 'targeted interventions'

12.38 Respondents considered it to be problematic that a targeted intervention could only be included in the Child's Plan if the authority that should provide it agreed to do so. Respondents thought the guidance needed to explain how differences of professional opinion could be resolved about which intervention(s) may be needed for a child.

Other issues / areas for clarification

12.39 Different respondents commented that:

• Respondents with expertise in speech and language therapy thought the Child's Plan minimum dataset should include information about the child's (and parents') speech, language and communication capacity /needs.
• The guidance contained no information about how parents / children could challenge decisions or the information contained in a Plan.
• It was unclear who was responsible for holding the information contained in the Child's Plan.
• The guidance would benefit from including a flowchart.

Views of individual respondents

12.40 Individual respondents commented that: this section of the guidance was 'too vague', and that the role of parents appeared to be marginalised, rather than central. There was also a view that SHANARRI did not seem to provide an appropriate basis for creating a good plan. It was rather suggested that the plan should be positively focused on goals, not needs.

Q28: Clarity of arrangements and processes

12.41 Question 28 focused on paragraphs 11.4.1 - 11.4.6 of the guidance and asked: 'Are the arrangements and processes set out in the draft guidance for preparing the child's plan clear?' Table 12.4 below shows that 63% of organisations and 15% of individuals thought they were, and 38% of organisations and 85% of individuals thought they were not.

Table 12.4: Question 28

	Yes		No		Total
Respondent type	n	%	n	%	n	%
Local authorities	11	(73%)	4	(27%)	15	(100%)
Health organisations	7	(58%)	5	(42%)	12	(100%)
Partnership bodies and joint responses	8	(57%)	6	(43%)	14	(100%)
Other national public sector bodies	3	(60%)	2	(40%)	5	(100%)
Third sector organisations	11	(58%)	8	(42%)	19	(100%)
Professional groups	6	(60%)	4	(40%)	10	(100%)
Other organisational respondents	4	(80%)	1	(20%)	5	(100%)
Total organisations*	50	(63%)	30	(38%)	80	(100%)
Individual respondents	3	(15%)	17	(85%)	20	(100%)

* Three respondents ticked both 'yes' and 'no'. These responses are not included in the table.

Percentages do not all total 100% due to rounding.

12.42 The overall pattern of agreement / disagreement was similar across all organisational sectors.

12.43 Altogether, 79 respondents (71 organisations and 8 individuals) made comments at Question 28.

Aspects of the guidance respondents found helpful

12.44 There was disagreement between respondents about what was helpful in this section of the guidance, and where clarification was needed. Some thought that the guidance was clear in relation to: the responsibility of the Named Person in initiating a Child's Plan; the relationship between the Named Person and the Lead Professional; and the circumstances in which the Named Person would act as the Lead Professional. It was also thought that the guidance was clear about what should be done when there is a dispute about which service should prepare the Plan. However, it was more common for respondents (including those who ticked 'yes' at Question 28) to request clarification about these same issues.

12.45 Different respondents commented that it was helpful that the guidance emphasised the rights of children and their parents to have their views heard in the process of preparing the Child's Plan.

Aspects of the guidance that were less helpful / required clarification

Relationship between the Named Person and Lead Professional

12.46 The main issue raised by respondents in their comments at Question 28 concerned the relationship between the Named Person and the Lead Professional. Respondents repeatedly asked for further details about this relationship, and there were frequent queries about the statements in paragraph 11.4.5 of the guidance which suggests that the Named Person will, in many cases, be responsible for preparing the Child's Plan, co-ordinating the delivery of the targeted intervention(s), and acting as the Lead Professional. Respondents expressed concerns about the capacity of the Named Person to take on these additional tasks, given the large number of children and young people the they would already have responsibility for as a Named Person.

12.47 Some respondents thought it was unlikely that the Named Person would be the best person to initiate a Child's Plan for children who are deaf or disabled. Other respondents suggested that, where a child requires the statutory intervention of a social worker, the social worker should act as the Lead Professional.

12.48 Respondents also queried how the Named Person and Lead Professional roles (if they are filled by different people) will work together, particularly if the Lead Professional is not a member of school staff.

12.49 There were further concerns about the statement in 11.4.6 that, 'if there are disagreements about who is the most appropriate person to take on the Lead Professional role, there should be processes in place … to make alternative arrangements….' Respondents thought this statement was too vague, and wanted greater clarity about these processes (including possible interim arrangements while disagreements were resolved), along with timescales for resolving disagreements.

12.50 Different respondents suggested the guidance should be revised to say explicitly that:

• The Lead Professional will be agreed (i.e. it should not be assumed that the Lead Professional will be the Named Person, even in situations where the targeted intervention(s) are provided by the education authority).
• The Lead Professional will be the main contact with the parents / family.
• The Named Person will consult with colleagues to determine the most appropriate intervention(s) for the child.

Role of the Named Person

12.51 There were additional comments, specifically about the role of the Named Person in preparing the Child's Plan. Specifically, respondents made the following points:

• Guidance was needed about how different Named Persons would work together in relation to children of different ages in the same family.
• Clarification is needed about the powers of the Named Person and who is accountable for delivery of the Child's Plan.
• The guidance should enable other professionals to suggest to the Named Person that a Child's Plan may be beneficial.
• The Named Person may need training to be able to identify and act on a child's mental health problems.

Involving families in the creation of a Child's Plan

12.52 Respondents reiterated the importance of involving children and their parents in the creation of the Child's Plan, and there were suggestions the guidance in relation to this could be strengthened. For example, it should be assumed that disabled children and even very young children are capable of contributing; and that the guidance could be amended to use 'must' rather than 'should' in relation to engaging with families. However, there was also a recognition that some families will be difficult to engage in the process, and respondents thought the guidance should provide details of how to handle these situations.

Other issues / requests for clarification

12.53 Respondents wanted more detail about the processes for: initiating a Child's Plan, completing an assessment and preparing a Child's Plan, and further information about who, in a range of different circumstances, would have the main responsibility for producing and managing the Plan.

Views of individual respondents

12.54 Different individual respondents commented that this section of the guidance was 'vague' or 'unclear'. Others commented that parents should have a central role in the preparation of a Child's Plan, and that the guidance should explain what 'weight' will be given to the views, values and circumstances of families. There was also a suggestion that parents should be permitted to have a say in the choice of the Lead Professional.

Q29: Integration of Child's Plan and Co-ordinated Support Plan

12.55 Question 29 focused on paragraphs 11.4.7 - 11.4.10 and asked, 'Does the draft guidance give clear support on how the child's plan and the co-ordinated support plan should be integrated?' Table 12.5 shows that 58% of organisations and 26% of individuals thought it did, and 42% of organisations and 74% of individuals thought it did not.

Table 12.5: Question 29

	Yes		No		Total
Respondent type	n	%	n	%	n	%
Third sector organisations	9	(47%)	10	(53%)	19	(100%)
Local authorities	9	(60%)	6	(40%)	15	(100%)
Health organisations	11	(69%)	5	(31%)	16	(100%)
Partnership bodies and joint responses	5	(38%)	8	(62%)	13	(100%)
Professional groups	10	(83%)	2	(17%)	12	(100%)
Other national public sector bodies	3	(60%)	2	(40%)	5	(100%)
Other organisational respondents	3	(50%)	3	(50%)	6	(100%)
Total organisations*	50	(58%)	36	(42%)	86	(100%)
Individual respondents	5	(26%)	14	(74%)	19	(100%)

* Two respondents ticked both 'yes' and 'no'. These responses are not included in the table.

Percentages do not all total 100% due to rounding.

12.56 Among the organisational respondents, professional groups (i.e. Royal colleges, trade unions and regulatory bodies) were most likely to agree that the guidance was clear on this point. Third sector organisations and partnership bodies were more likely to disagree.

12.57 Altogether, 74 respondents (67 organisations and 7 individuals) made comments at Question 29.

Aspects of the guidance respondents found helpful

12.58 Some respondents who ticked 'yes' in response to Question 29 said that the guidance was very helpful and clear, and that the requirement for effective multi-disciplinary approaches for the purposes of integrating more than one plan was well articulated in the guidance. However, it was more common for respondents (including those who ticked 'yes') to say that the guidance was vague or that clarification was needed on a number of issues.

Aspects of the guidance that were less helpful / required clarification

12.59 The main point made by respondents in their comments at Question 29 was that 'the guidance indicates that the Child's Plan and Co-ordinated Support Plan (CSP) should be fully integrated, but does not say how this should be done'. Respondents thought the guidance was contradictory in places, and requested clarification about whether the intention is for the CSP to be part of the Child's Plan, or a separate plan that stands alongside it.

12.60 Respondents recognised the statutory nature of the CSP, and understood that it must be a standalone document, but they did not think that the draft guidance had adequately explained how the 2014 Act would interact with the 2004 Act. Specifically:

• It was noted that a CSP requires a Support Plan Co-ordinator. This is a statutory role under the provisions of the 2004 Act, which is not acknowledged in the draft guidance. Respondents thought the guidance should explain how this role would relate to that of the Named Person and Lead Professional.
• Similarly, the 2004 Act gives parents a number of rights (including the right to refer to the ASN tribunal), but it is unclear what statutory rights parents will have in relation to the Child's Plan. Could the contents of a Child's Plan be disputed at an ASN tribunal if the CSP and Child's Plan are integrated?
• There was also a request for clarification about the difference between staged intervention (in the 2004 Act) vs targeted intervention (in 2014 Act).

12.61 In general, respondents wanted to see integration / alignment of the Child's Plan and CSP processes, to avoid duplication of effort. Some respondents (mainly local authorities and partnership bodies) suggested that there was no need for two plans if the Child's Plan was implemented effectively. (The question was asked: Are there any circumstances in which a child would have a CSP but not have a Child's Plan?) Among this group, there were some who suggested that the Additional Support for Learning legislation might be now repealed in light of the provisions of the 2014 Act. Alternatively, the CSP could be integrated into the Child's Plan as an annex - which can be produced as a standalone document where necessary. Therefore, any child who required a CSP would also, automatically, have a Child's Plan.

12.62 However, other respondents expressed concern about the legal status of the CSP being lost if the CSP was merged with the Child's Plan, and there were also concerns about information contained in the CSP being shared (as part of a Child's Plan) with individuals / practitioners who do not need to see it.

Disputes between authorities related to the preparation of the Child's Plan

12.63 The second point, made less often by respondents in their comments at Question 29, concerned paragraph 11.4.10, which referred to the possibility of disagreements between different authorities about which of them should prepare the Child's Plan.

12.64 The paragraph highlights that any disputes about preparation or management of the Child's Plan should be addressed through local procedures. However, it was suggested that the guidance should stipulate who has ultimate authority. Respondents expressed the view that relevant authorities should not be able to 'opt out' if the responsibility lies with their service. It was also thought that it would be helpful to specify the timescales for resolving disputes.

Other issues for clarification

12.65 Other issues raised by respondents in relation to this section were that:

• The difference between 'responsible authority' and 'relevant authority' in this section is not clear.
• The guidance should be clearer about the distinction between targeted and universal interventions, particularly in relation to schools that are solely for children with complex health and social care needs.
• The guidance should provide further details about the management of the Child's Plan in the context of organisations like the Scottish Prison Service.

Views of individual respondents

12.66 The substantive comments from individuals mainly focused on the difficulty of the language (perceived jargon) in this section.