Project Semh

School pre-registration inspection report

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Project Semh Unit 2 Lancaster Park, Bowerhill, Melksham, Wiltshire SN12 6TT

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Main inspection findings

Part 1. Quality of education provided Paragraph 2(1)(a), 2(1)(b) and 2(1)(b)(i)  Following the previous pre-registration inspection, leaders have taken steps to ensure that there is a written curriculum policy. There are also published schemes of work for some subjects, in each key stage. However, these do not take account of all that pupils need to learn.  The plans lack clear expectations or curricular goals to support pupils’ progress. Sequences of learning are not well thought through in most subjects. For example, there is currently a confused approach to teaching humanities. Plans include aspects of geography, history and religious education, but none of these are accounted for in a logical order, or with the integrity of each subject in mind. As a result, teaching is likely to be confused and lead to dysfluency and gaps in pupils’ knowledge.  Leaders do not have sufficient knowledge of the different subjects to implement a

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Main inspection findings

coherent curriculum, including how to provide an effective early reading and phonics programme for pupils who may still need this. As a result, pupils are unlikely to know and remember more through the school’s planned curriculum.  The curriculum does not consider the different starting points of pupils well enough. Given the proposed school aims to teach pupils with special educational needs and/or disabilities (SEND) and pupils who have missed previous education, this means that they are unlikely to get off to a good start or catch up quickly in a range of subjects.  The standard in this paragraph is unlikely to be met. Paragraph 2(2)(a) and 2(2)(b)  Curriculum plans are weak. Limitations in the curriculum offer are likely to limit pupils’ experiences, knowledge and readiness for the next stage of their education, training or employment.  Leaders do not take enough account of the breadth of learning that pupils are likely to

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Main inspection findings

need. As a result, it is unlikely that pupils will acquire deep knowledge over time.  Leaders have not given enough thought to the full range of pupils’ learning and the experiences that they are likely to need, including linguistic, mathematical, scientific, technological, human and social, physical and aesthetic, and creative education. This is likely to hold pupils back, particularly given the SEND of the pupils and the need for pupils to catch up.  Plans for teaching physical education (PE) are poor. This aspect of the curriculum has not been considered well enough and narrows the curriculum significantly. As a result, pupils are unlikely to be well supported in their physical development.  The proprietor ensures that there is an appropriate relationships and sex education programme in place, suitable for the different ages of the pupils.  The requirements in these paragraphs are unlikely to be met.

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Main inspection findings

Paragraph 3,3(a),(c),(e)  Leaders’ lack of clear curricular intentions means that pupils are unlikely to acquire new knowledge and make good progress in a range of subjects, across all year groups.  Leaders and staff lack the depth of expertise needed to teach subjects to an acceptable standard. Consequently, pupils who have fallen behind before joining the school are unlikely to catch up.  Leaders have not considered the requirements of the whole curriculum. Therefore, teaching methods, activities and lessons are not likely to be good enough to teach for the full range of pupils’ needs and abilities. It is not clear how different subjects are likely to be taught effectively on a day-to-day basis.  Where leaders do not have a good understanding of what they expect pupils to learn, they have not yet taken the right steps to consider what, or how, teachers will accurately assess pupils’ knowledge. As a result, assessment is likely to be weak in

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Main inspection findings

most subjects.  The standard in this paragraph is unlikely to be met. Paragraph 2(1)(b)(ii), 2(2)(d)(i) – (ii), 2(2)(i)  Despite the issues raised above, leaders are keen to help pupils learn, including those who have experienced difficulties in mainstream education or other schools. Their strong ethos pervades their thinking, so that pupils’ social and emotional development is likely to be supported well, including through trained staff to deliver timely and appropriate behavioural support.  Schemes of work and other medium-term plans demonstrate a firm commitment to providing a relevant personal, social, health and economic (PSHE) education. They include a range of well-planned activities to promote pupils’ self-esteem and restore their confidence. For example, learning ‘life skills’ and engaging in wider community- based activities are likely to help pupils with their personal, social and emotional

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Main inspection findings

development.  Leaders’ strong vision actively promotes respect for other people, including those with the protected characteristics set out in the Equality Act 2010.  Leaders clearly articulate a vision for how they intend to help pupils to be tolerant and accepting of others. For example, fundamental British values are taught as a core part of the school’s PSHE education programme to ensure pupils learn about life in British society.  The proprietor ensures that there is a purposeful and well-planned careers strategy in place. As a result, pupils have access to high-quality independent advice and guidance, as well as tailored work experience, to help them in their next steps for employment, education and training.  The requirements in these paragraphs are likely to be met. Paragraph 3(b),(d),(f) – (j)  Leaders’ plans are likely to encourage pupils to be resilient and teach them how to be successful in different situations. Leaders demonstrate a secure understanding of the

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Main inspection findings

kinds of challenges that pupils will have when they arrive at the school, including those with social, emotional and mental health (SEMH) needs. As a result, leaders have appropriate expectations and the expertise to manage pupils’ behaviour well.  Leaders have given due consideration to how they might support pupils in managing their behaviour. Behaviour systems and positive rewards are in place. These are likely to help pupils make the right decisions and to cope well.  Pupils in the current provision show good behaviour and positive attitudes. Staff form mutually positive relationships so that pupils can enjoy time in lessons and start to restore lost confidence.  Classrooms are suitable spaces for teaching lessons. There are areas for pupils to work together or ‘break out’ for further individual support and interventions.  The curriculum is likely to promote fundamental British values.  The requirements in these paragraphs are likely to be met.

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Main inspection findings

Paragraph 4  Leaders have an agreed framework for monitoring pupils’ performance. For example, there are summative assessment opportunities in place to track pupils’ progress. These are used to provide information about pupils’ learning to parents and other relevant bodies. This fulfils the basic requirement of this standard.  The standard in this paragraph is likely to be met.  However, the standards in this part are unlikely to be met, overall. Part 2. Spiritual, moral, social and cultural development of pupils Paragraph 5 – 5(d)(iii)  The proprietor is committed to promoting pupils’ spiritual, moral, social and cultural (SMSC) development. This is at the heart of leaders’ ethos and their imperative for opening a school. Leaders are determined to give pupils a vital chance of recovery in education and to succeed more widely in society.  Although the proprietor does not have separate SMSC development or PSHE education

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Main inspection findings

policies in place, there are schemes of work that show a strong commitment to promoting pupils’ personal, social and emotional development.  Schemes of work clearly demonstrate a range of activities aimed at teaching right from wrong, and to respect civil and criminal law. The timetable will include reflective times for pupils to talk about the consequences of their words and deeds.  Leaders use inspirational visitors to help pupils make the right decisions, for example how to avoid drug and alcohol misuse or being in a gang. As a result, pupils are taught about the implications of their actions and their effect on others in society.  Leaders ensure that pupils are engaged in meaningful work to develop their cultural capital. For example, pupils have recently visited Bristol to provide gifts for a homeless shelter charity. These opportunities are likely to help pupils, particularly those with SEMH needs, to understand the importance of fundamental British values, including

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Main inspection findings

respect for others.  Leaders will promote the Equality Act 2010, including the protected characteristics. They challenge stereotypes and any radical, or partisan views, so that pupils learn to be more tolerant and understanding. Different religious beliefs and world faiths are taught as part of the provider’s approach to teaching PSHE education.  The standard in this part is likely to be met. Part 3. Welfare, health and safety of pupils Paragraph 7,7(a) – (b)  The proprietor ensures that the current safeguarding practices and procedures comply with the latest safeguarding guidance issued by the Secretary of State. The proprietor, who is also a designated safeguarding lead, demonstrates appropriate knowledge to keep pupils safe.  The safeguarding policy is published on the school’s website.  The proprietor ensures that all staff are trained appropriately and are suitable to work with pupils. For example, all the necessary checks on staff and governors comply with

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Main inspection findings

the requirements of ‘Keeping children safe in education (2021)’.  The proprietor uses external services or experts to help implement and maintain appropriate health and safety standards for pupils, including for pupils currently using the provision. Paragraphs 9 – 10  The proprietor has ensured that there is a written behaviour policy. The policy takes full account of the vulnerable nature of the pupils attending the provision, including those with SEMH needs.  Leaders promote positive behaviour. They consider the use of sanctions, including exclusions, to be a last resort. The school is likely to have effective procedures for understanding and managing pupils’ behaviour.  There is an acceptable anti-bullying policy in place. This reflects leaders’ aims and the provision’s ethos of helping pupils to overcome personal, social and emotional barriers. The anti-bullying policy is reflected in other key policies, including the

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Main inspection findings

behaviour and exclusion policies. Paragraph 11  At the time of the previous pre-registration inspection, this standard was not likely to be met due, in large part, to a fault leading to hot water presenting a scalding risk to pupils. This problem has now been fully rectified.  The proprietor has an appropriate health and safety policy. This covers all relevant matters, including fire risk management, first aid and administering medication. As a result, this standard is now likely to be met. Paragraph 12  Leaders are fully aware of their duty to comply with the Regulatory Reform (Fire Safety) Order 2005. The accommodation and premises on both sites have fire extinguishers, clear emergency signs and directions for evacuation and designated fire assembly points. Alarms and other equipment are checked regularly in accordance with regulations. As a result, the proprietor takes all practicable steps to safeguard

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Main inspection findings

pupils, staff and visitors appropriately.  The proprietor uses external experts to provide timely and appropriate advice and to help manage any risks associated with fires. Consequently, pupils, staff and visitors are likely to be kept safe. Paragraphs 13 – 15  The proprietor has ensured that there is a suitable first aid policy on the school’s website.  Staff receive appropriate first aid training. There are designated first aid responders allocated to both sites.  Leaders anticipate that most, if not all pupils, are likely to have an education, health and care (EHC) plan. As a result, they expect pupils will have close supervision, as required by these plans. The proprietor has also appointed additional staff, including qualified teachers, so that high staff-student ratios are maintained, including for any off-site education.  The proprietor is likely to ensure that admission and attendance records will be

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Main inspection findings

maintained rigorously and in accordance with the Education (Pupil Registration) (England) Regulations 2006. These will be used for reporting to parents and the local authority, as required, as well as for monitoring pupils who may be at risk of missing education. Paragraph 16,16(a) , (b)  Since the failings at the previous pre-registration inspection, the proprietor has taken effective action so that the requirements in this standard are now likely to be fully met.  The proprietor ensures that there is an appropriate written risk assessment policy and that it is now being implemented effectively.  Leaders ensure that there are a range of relevant risk assessments in place to reduce the risk of harm for pupils, including during off-site activities. Risk assessments are implemented for different activities, including off-site trips and visits.  Individual risk assessments take full account of pupils’ needs, including those with an

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Main inspection findings

EHC plan. Staff understand the unique challenges of the pupils who are already using the provision, particularly with SEMH difficulties. Staff frequently review pupils’ risk assessments to make sure that pupils are kept as safe as possible.  The standards in this part are likely to be met. Part 4. Suitability of staff, supply staff, and proprietors Paragraphs 18(2) – 21(7)(b)  The proprietor is likely to ensure that all necessary pre-employment checks are completed in accordance with the statutory guidance issued by the Secretary of State and the independent school standards.  The provider has an appropriate single central register (SCR) in place. The proprietor ensures that the full range of relevant checks are completed before staff work with pupils.  The proprietor does not use supply staff. This is to provide continuity and familiarity for pupils, as well as ensuring staff’s eligibility to work safely with pupils.

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Main inspection findings

 The school does not have any governors or use additional volunteers. However, should this change, the SCR and safeguarding processes are in place to accommodate this.  The SCR is well maintained and legible. It is kept in an electronic format.  The standards in this part are likely to be met. Part 5. Premises of and accommodation at schools Paragraph 23(1)(c)  The proprietor has not ensured that the school’s proposed sites has suitable showering facilities for pupils who receive physical education. There are no firm plans or arrangements in place to provide these, as required.  The requirements in this paragraph are unlikely to be met. Paragraph 29(1)(a)  Leaders do not have suitable curricular plans for PE. The two sites are not yet developed, or designed well enough, to promote this aspect of the school’s curriculum.  There is a small gravelled area for outdoor play and games at the Station Approach

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Main inspection findings

site. The main site, at Bowerhill, has some local facilities, including a park that may be used for outdoor games and recreation. However, leaders have not yet considered how the school sites, or local amenities, can support a high-quality PE curriculum. The current arrangements for implementing effective PE are not fit for purpose.  Weaknesses in the physical accommodation at both sites, as well as leaders’ poor intentions for PE, restrict the likelihood that pupils will be able to enjoy a broad and balanced PE curriculum.  The requirements in this paragraph are unlikely to be met. Paragraph 23(1),23(1)(a),(b) – 23(2)  Both sites have suitable toilet and washing facilities which may be used accordingly for the sole use of pupils. They are clean and well maintained.  There are individual toilets. These can be secured from the inside for pupils’ privacy and dignity.  The requirements in these paragraphs are likely to be met.

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Main inspection findings

Paragraph 24 (1)(a)–(c)  The previous pre-inspection found that there were too many limitations and that the accommodation for the short-term care of pupils would be unlikely to meet the standards. However, following work at the Station Approach site and since moving to the new Bowerhill location, both sites now have suitable facilities that mean pupils who become temporarily sick or injured can be cared for appropriately.  The medical rooms, on both sites, are near to washing and toileting facilities.  The requirements in these paragraphs are likely to be met. Paragraph 25  There have been changes to the sites being used since the previous pre-registration inspection. The smaller Station Approach site has been retained and improved following the concerns raised at the previous inspection.  The general presentation of the accommodation on both sites is acceptable. The premises are clean, tidy and orderly. As far as is reasonably practicable, the proprietor

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Main inspection findings

ensures that the health, safety and welfare of pupils is ensured. For example, the proprietor has recently installed a fob entry system to keep pupils safe at Bowerhill and prevents pupils from being able to run straight out into the car parking area.  The standard in this paragraph is likely to be met. Paragraphs 26 – 28(2)(b)  Acoustic conditions are wholly appropriate to activities on both sites.  External lighting is installed at the entrances to both school sites. Other lighting is in place, where appropriate, to ensure the safe passage of pupils and school users.  Toilets have an adequate supply of hot and running cold water.  Pupils can access drinking water from the mains supply at both sites. Leaders also provide water bottles for each pupil to remain hydrated during the day.  The proprietor has taken action to ensure that all taps, including those previously presenting a scalding risk at the Station Approach site, are now safe for pupils.

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Main inspection findings

 The standards in these paragraphs are likely to be met. Paragraph 29(1)(b)  Pupils can go outside to play or walk on both sites.  The requirement in this paragraph is likely to be met.  Overall, the standards in this part are unlikely to be met. Part 6. Provision of information Paragraphs 32(1) – 32(4)(c)  Since the previous pre-registration inspection, the proprietor has continued to meet the requirements and standards for this part. The proprietor ensures that all relevant information about the school, including required policies, are accessible to parents on the school’s website, or can be made available in hard copies on request.  The school’s website publishes the necessary information to comply with the independent school standards. For example, written curriculum, health and safety, and behaviour policies are provided. The website also provides contact details, the complaints policy and safeguarding information, including the safeguarding and child

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Main inspection findings

protection policy.  The proprietor has ensured that the school’s remote education policy is available on the school’s website. This fully complies with the latest guidance, ‘Review your remote education provision (January 2021)’, as set out by the Department for Education.  The proprietor’s aims and vision are presented clearly through a range of documentation and on the school’s website. Leaders’ present their intentions to provide a positive learning experience so that pupils, who may be disengaged due to previous poor experiences in education or trauma, can join the school and begin to rebuild their education.  The proprietor provides appropriate information and reports for parents about the progress of pupils. The school is also likely to be able to account for the funding of all pupils, including those with an EHC plan, to relevant placing local authorities.  The standards in this part are likely to be met.

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Main inspection findings

Part 7. Manner in which complaints are handled Paragraph 33, 33(a) – (k)  The proprietor continues to have a complaints policy that fulfils the requirements of the independent school standards. The policy provides information about how to pursue formal and informal complaints, and the process for resolving these.  The complaints policy is readily available and published on the school’s website.  The policy sets out how to raise or escalate complaints. It includes timescales and guidance for what a complainant may reasonably expect as a complaint is investigated.  The policy contains appropriate information for complaints to be considered by a panel, should this be required. The proprietor understands that the panel must include at least one member who is independent of the running of the school.  The proprietor is keen to work closely with parents and resolve any concerns at the earliest possible stage. However, when needed, it is likely that the school will take

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Main inspection findings

complaints seriously and record these appropriately. Records of any complaints will be made available for inspection, as necessary.  The standards in this part are likely to be met. Part 8. Quality of leadership in and management of schools Paragraph 34(1)(a) – (b)  As was the case at the previous pre-registration inspection, leaders do not have good enough knowledge of the independent school standards (ISS) or how to run an independent special school. As a result, pupils are unlikely to achieve as well as they reasonably could, particularly those with an EHC plan, who are most likely to attend.  Leaders do not know how to construct a high-quality curriculum to meet the full range of the pupils’ needs. Leaders lack the depth of curriculum understanding and expertise to implement a high-quality curriculum. This leads to weak curricular plans, including for reading, PE and in other subjects.  The proprietor works well with external partners, including Wiltshire local authority. As

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Main inspection findings

a result, there are some useful links which aid the work of leaders. For example, the proprietor liaises with placing schools.  The standard in this paragraph is unlikely to be met. Paragraph 34(1)(c)  Since the previous inspection, leaders have taken appropriate action to ensure the welfare, health and well-being of pupils on both sites. For example, previous issues with the premises and taps causing a scalding risk are fully resolved. The school’s sites now have facilities to an acceptable standard to care for the short-term medical needs of pupils.  The proprietor ensures that safeguarding polices, including child protection and those relating to health and safety, are in place and being implemented appropriately. Previous issues with risk assessments have been rectified.  The requirement in this paragraph is likely to be met.  Overall, however, the standards in this part are unlikely to be met.

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Main inspection findings

Schedule 10 of the Equality Act 2010  The proprietor is fully aware of the proposed school’s duties under Schedule 10 of the Equality Act 2010. There is a published accessibility plan, which is fit for purpose.

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Compliance with regulatory requirements

The school is unlikely to meet the requirements of the schedule to The Education (Independent School Standards) Regulations 2014 (‘the independent school standards’) and associated requirements, as set out in the annex of this report.

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Proposed school details

This inspection was carried out under section 99 of the Education and Skills Act 2008, the purpose of which is to advise the Secretary of State for Education about the school’s likely compliance with the independent school standards that are required for registration as an independent school.

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Proposed school details

School status Independent special school

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Proposed school details

Annual fees (day pupils) £20,500 to £32,500

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Proposed school details

Date of previous standard inspection Not previously inspected

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Provider already operating

Number of pupils of compulsory school age 21 Number of pupils of compulsory school age who have an education, health and care plan, or who are looked after by a local authority Total hours operating as a school per week none

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Provider already operating

Total hours of teaching provided per week 15

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recommendation

Age range of pupils 11 to 18 11 to 18 11 to 18 Number of pupils on the school roll none 35 20

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recommendation

Reason for inspector’s recommendations  If the school opened, the inspector’s opinion is that the accommodation across both sites could only realistically guarantee the effective working and safety of a maximum of 20 pupils.

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School’s current position School’s proposal

Number of full-time pupils of compulsory school age none 35

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School’s current position School’s proposal

Number of pupils with special educational needs and/or disabilities 21 35

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School’s current position School’s proposal

Of which, number of pupils with an education, health and care plan 19 35

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School’s current position School’s proposal

Of which, number of pupils paid for by a local authority with an education, health and care plan 19 35

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School’s current position School’s proposal

Number of full-time equivalent teaching staff 3 14

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School’s current position School’s proposal

Number of staff in the welfare provision 11 11

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Information about this proposed school

 The proposed school is located on two different sites on a large industrial estate in Melksham, Wiltshire. The largest site at Bowerhill was taken over by the proprietor in September 2021. This is the first time that this site has been inspected. The smaller site at Station Approach was inspected during the previous pre-registration inspection.  Wiltshire local authority are currently using the provider as an alternative provision for some pupils with EHC plans. These pupils are on short-term and time-limited timetables, to prevent the provision from meeting the definition of an independent school.  The school intends to admit pupils with complex SEND needs, most prominently those with SEMH difficulties, as well as others. For example, some may have autism spectrum disorder. All pupils who attend the school are likely to have an EHC plan.  The proposed school is expected to operate without a governing board.

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Information about this proposed school

 The current provision opened on 28 October 2019.

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Information about this inspection

 This pre-registration inspection was commissioned by the Department for Education to evaluate the provider’s readiness to open as a school. The inspector checked all relevant independent school standards, including Parts 1 to 8.  This was the second pre-registration inspection. The first took place on 15 June 2021.  The inspector evaluated a range of evidence, including policies and plans relating to each part of the independent school standards. The inspector scrutinised health and safety documentation, including the safeguarding and child protection policy. The inspector checked the school’s staff recruitment and vetting processes, and the SCR.  The inspector undertook a tour of both proposed sites at Bowerhill and Station Approach to evaluate the suitability of the school’s accommodation and premises for the purposes of being an independent SEND special school.  The inspector worked with the proprietor for all inspection activities. The inspector

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Information about this inspection

also had a telephone conversation with two representatives of Wiltshire local authority who place pupils in the current provision.  Project SEMH is currently operating for 21 pupils as an alternative provision, 19 of whom have an EHC plan. The age range for this provision is for pupils from 11 to 18 years, most of whom have SEMH needs.  The inspector observed part of a key stage 3 intervention session, aimed at providing tailored personal, social and emotional support for pupils.

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Inspection team

Stewart Gale, lead inspector Her Majesty’s Inspector

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Part 1. Quality of education provided

 2(1) The standard in this paragraph is met if– – 2(1)(a) the proprietor ensures that a written policy on the curriculum, supported by appropriate plans and schemes of work, which provides for the matters specified in sub-paragraph (2) is drawn up and implemented effectively; and – 2(1)(b) the written policy, plans and schemes of work- – 2(1)(b)(i) take into account the ages, aptitudes and needs of all pupils, including those pupils with an EHC plan.  2(2) For the purposes of paragraph (2)(1)(a), the matters are– – 2(2)(a) full-time supervised education for pupils of compulsory school age (construed in accordance with section 8 of the Education Act 1996), which gives pupils experience in linguistic, mathematical, scientific, technological, human and social, physical and aesthetic and creative education; – 2(2)(b) that pupils acquire speaking, listening, literacy and numeracy skills.  3 The standard in this paragraph is met if the proprietor ensures that the teaching at

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Part 1. Quality of education provided

the school– – 3(a) enables pupils to acquire new knowledge and make good progress according to their ability so that they increase their understanding and develop their skills in the subjects taught; – 3(c) involves well planned lessons and effective teaching methods, activities and management of class time; and – 3(e) demonstrates good knowledge and understanding of the subject matter being taught.

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Part 5. Premises of and accommodation at schools

 23(1) Subject to sub-paragraph (2), the standard in this paragraph is met if the proprietor ensures that– – 23(1)(c) suitable changing accommodation and showers are provided for pupils aged 11 years or over at the start of the school year who receive physical education.  29(1) The standard in this paragraph is met if the proprietor ensures that suitable outdoor space is provided in order to enable– – 29(1)(a) physical education to be provided to pupils in accordance with the school curriculum.

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Part 8. Quality of leadership in and management of schools

 34(1) The standard about the quality of leadership and management is met if the proprietor ensures that persons with leadership and management responsibilities at the school– – 34(1)(a) demonstrate good skills and knowledge appropriate to their role so that the independent school standards are met consistently; – 34(1)(b) fulfil their responsibilities effectively so that the independent school standards are met consistently. guidance ‘Raising concerns and making a complaint about Ofsted’, which is available from Ofsted’s website: www.gov.uk/government/publications/complaints-about-ofsted . If you would like Ofsted to send you a copy of the guidance, please telephone 0300 123 1231, or email enquiries@ofsted.gov.uk .

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Part 8. Quality of leadership in and management of schools

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Part 8. Quality of leadership in and management of schools

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Part 8. Quality of leadership in and management of schools

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Part 8. Quality of leadership in and management of schools

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Part 8. Quality of leadership in and management of schools

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Part 8. Quality of leadership in and management of schools

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