First Thought Independent School

School pre-registration inspection report

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First Thought Independent School 164 Hucclecote Road, Gloucester GL3 3SH

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Main inspection findings

Part 1. Quality of education provided Paragraphs 2(1) to 2(1)(b)(ii), 2(2)(h), 2(2)(i), 3 to 4  The proprietor proposes to open an independent school for pupils with autism, severe learning difficulties and complex needs for pupils aged 5 to 11. The proprietor runs an alternative provision (AP) in the same building for pupils between the age of 6 to 19. The proprietor intends that it will continue to operate the AP as a separate business. The proprietor expects that a small number of pupils currently attending the AP may be admitted to the school full time should it open.  There is a curriculum policy in place. It is in writing and specifies the proposed school’s approach to the curriculum. The proprietor has considered how the curriculum at the proposed school will differ to the curriculum at the AP, including the teaching approaches that are likely to enable pupils to engage in and access learning.

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Main inspection findings

 There is an assessment policy and assessment framework that the school intends to use. The assessment framework aims to assess subject areas as set out in the independent school standards (the standards). However, the content of the assessment system and curriculum are not sufficiently well matched. The current schemes of work do not include essential subject content to meet the requirements of the standards. There is a strong likelihood that pupils who attend will have considerable gaps in their learning, due to prolonged school absences, for example. As such, the intended curriculum does not include all the necessary mathematical subject content it should. It does not set out the breadth of knowledge that pupils need to learn over time, in number, for example. The proposed school was unable to provide evidence of how the curriculum will be adapted to meet the ranging needs and aptitudes of pupils it intends to admit.

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Main inspection findings

 The proprietor intends to deliver a phonics curriculum for pupils at the early stages of reading. The phonics curriculum sets out exactly the order of what pupils will learn and when. Beyond phonics, there are considerable gaps in the intended curriculum. For example, in how the proposed school intends to develop pupils’ ongoing reading and writing knowledge. There is important subject content missing.  These paragraphs in this part are not likely to be met. Paragraphs 2(2) to 2(2)(d)(ii), 2A(1) to 2A(1)(a), 2A(1)(d) to 2A(2)  This proposed school has organised a well-thought-out personal, social, health and economic (PSHE) education programme. The curriculum will build pupils’ self- confidence, self-esteem and independence over time. It will also teach pupils about risks, such as online safety and managing money.  A relationships and health education policy is in place. The curriculum to implement

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Main inspection findings

this policy includes everything it should.  These paragraphs in this part are likely to be met.  The proprietor has not ensured that all the standards in this part are likely to be met.

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Main inspection findings

Part 2. Spiritual, moral, social and cultural development of pupils Paragraphs 5 to 5(d)(ii)  The proposed school has suitable plans in place that specify how the school will promote fundamental British values. This includes learning about right and wrong, individual liberty, criminal law and democracy. Additional events across the year will also provide pupils with a range of knowledge about the world beyond school.  The school intends to provide teaching that will support pupils to be tolerant, polite and to take responsibility for their actions. It also intends to develop pupils’ knowledge and skills of how to build independence and become resilient.  In addition, the curriculum will teach pupils to value difference, understand moral and ethical issues and learn to respect others, including people with protected characteristics as outlined in the Equality Act 2010.  The proprietor has ensured that all the standard in this part is likely to be met.

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Main inspection findings

Part 3. Welfare, health and safety of pupils Paragraphs 7 to 7(b), 9 to 16(b)  The proprietor intends to conduct safeguarding monitoring activities that will hold the proposed school to account for implementing of the guidance set out in ‘Keeping Children Safe in Education’.  The proprietor has ensured that there is an effective recording system in place to report safeguarding concerns. Staff who have been appointed have completed necessary safeguarding training so that they have the skills and knowledge to keep pupils safe. The proprietor intends to have a robust induction process for new staff. This will include safeguarding training for all staff.  There is a suitable behaviour policy and anti-bullying strategy. The proprietor already has a detailed record system in place to record any misbehaviour or sanctions. The proprietor intends to train all staff so that they can apply the school’s policies

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Main inspection findings

consistently.  The proprietor has ensured compliance with the Regulatory Reform (Fire Safety) Order 2005 for the intended premises of the proposed school. A fire risk assessment was completed in October 2025. Fire safety equipment is installed around the building and is checked regularly. Fire doors, external lighting and the fire alarm are checked and recorded routinely. It is intended that the ratios of staff to pupils will be high. The proprietor knows that the maximum number of persons to be in the building at any one time must not exceed 62 as stated on the fire risk assessment. Therefore, the proprietor intends to ensure that any mixed use of the building beyond the proposed school does not take the numbers of people in excess of 62.  There is a first-aid policy. It provides appropriate guidance for staff to administer first aid. The proprietor intends to provide staff with first-aid training as part of their

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Main inspection findings

induction. First-aid boxes are well stocked.  There are already detailed and suitable arrangements in place to administer uncontrolled and controlled medicines.  There is an electronic admissions register. Leaders understand how to maintain the school’s admission and attendance registers. The proprietor and head of education understand the legislative requirements set out in ‘Working together to improve pupils’ attendance’, including accurate coding for attendance.  The proprietor has not yet appointed sufficient staff. However, he has considered the number of staff that are likely to be required across each aspect of the school day to ensure that supervision is adequate.  There is a risk assessment policy. The proprietor has detailed risk assessments in place that are closely linked to the context of the school. For example, site risk assessments consider how the proposed school will mitigate the risk of pupils from

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Main inspection findings

the school encountering pupils at the AP on site. The proprietor knows that this will require regular review to mitigate any safeguarding risks over time. For example, when considering the suitable supervision of any areas of the proposed school that are shared with the AP, such as the outside recreational space, because it admits pupils up to 19.  The proprietor has ensured that all the standards in this part are likely to be met.

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Main inspection findings

Part 4. Suitability of staff, supply staff, and proprietors Paragraphs 18(2) to 18(2)(e), 18(3), 19(2) to 19(2)(d)(ii), 19(3), 20(6) to 20(6)(c), 21(1) to 21(3)(b), 21(5) to 21(5)(a)(ii), 21(5)(c), 21(6)  There is a single central record (SCR). This includes all the staff that have been appointed. The proprietor’s central team carry out all required pre-employment checks. The proprietor has a strong working knowledge of safer recruitment and intends to have close oversight as new staff are appointed to ensure that the SCR is kept up to date.  The proprietor intends to appoint staff, who will solely work at the school and not across the alternative provider and school. To date, the proprietor has appointed an assistant head for the quality of education. She takes up her role in January 2026. She has previous experience of teaching primary-age pupils in mainstream and specialist settings and currently works at the AP. A head of education has been appointed with

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Main inspection findings

experience of compliance outside the education sector. She does not have experience of leading a school previously.  The proprietor has started the recruitment process to appoint a qualified leader of special educational needs and/or disabilities. The proprietor aims to appoint additional teachers and support staff to meet supervision requirements set out in pupils’ individual education, health and care (EHC) plans. However, at the point of the pre- registration inspection recruitment for staff is only just starting.  The proprietor does not intend to use supply staff. However, he understands the checks that would apply if supply staff were used.  The proprietor has ensured that all the standards in this part are likely to be met.

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Main inspection findings

Part 5. Premises of and accommodation at schools Paragraphs 23(1) to 23(1)(c), 24(1) to 24(1)(b), 24(2), 25 to 29(1)(b)  The proposed school is on the first floor of a two-story building. The AP owned by the proprietor is on the ground floor. There is one joint entrance for both. During the pre- registration inspection, alterations were made to the sign-in procedures to ensure that the sign in arrangements to the AP and proposed school are separate.  In order to enter the first floor, there is a communal space serving both the proposed school, AP and head office for First Thought Care Services Ltd. The proprietor has put a ‘fob system’ in place to ensure that pupils attending the AP on the ground floor are unable to access the proposed school on the first floor.  Classrooms are newly refurbished. They are light and provide adequate ventilation. All windows include opening limiters to assure pupils’ safety. At the front of the building,

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Main inspection findings

there are original sash windows. During the pre-registration inspection, maintenance staff from First thought Care Services Ltd added protective film to the windows where safety glass is not present.  There are separate toilets for staff and pupils. There is also an accessible toilet on the ground floor. In the proposed school, all toilets are for single use and lockable from the inside. However, some pupil toilets contain baths. This creates a significant health and safety risk. The proprotor boarded up the baths and removed the bath taps during the pre-registration inspection to negate this risk. Nevertheless, all baths need to be removed. The proprietor is expecting to do this prior to a legionella risk assessment visit that is booked for 5 January 2026  There is a suitable medical room on the first floor. It contains a sink and there is a toilet close by. There is also a medical room on the second floor. At the point of the

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Main inspection findings

pre-registration inspection, the lockable storage for medicines for the proposed school was kept on the second floor. This is not part of the proposed school. Therefore, the proprietor intends to relocate all lockable storage for medicines relating to the proposed school in the first-floor medical room should it be registered. Pupils from the AP will not use the school’s medical room.  There are several rooms which will be used as flexible spaces. Currently, as the AP is already operating, pupils attending the AP up to the age of 19 can access these. There is a cinema room, games room, music room, kitchen, multi-faith room, art room and sensory space. The proprietor notes pupils attending the AP will not have access to these rooms during the school day should the school be registered.  There is a regulation room. The proprietor aims for this to be a calming space for pupils. It has soft padded walls. It has a window. There is no lock or handle on the

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Main inspection findings

door to ensure that pupils can freely enter and leave at any time. During the pre- registration inspection, the proprietor decided to order a door containing a safety glass panel to increase available observation into this room. Pupils who attend the AP will not have access to this room.  There is a well-maintained outside area at the back of the building. Beyond this, there is also a field area that is newly fenced. These areas provide ample space for recreation and physical education activities. These spaces will also be used by pupils who attend the AP. The proprietor has already put risk assessments in place to ensure safe use of this space. For example, pupils in the AP will not have access to the outside area during the proposed school’s timetabled lunchtimes and breaktimes. There are effective plans for the effective supervision of pupils.  The proprietor is in the process of ordering enough furniture for classrooms.

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Main inspection findings

 The proprietor does not propose to open the school should it be registered until March 2026. Therefore, it is feasible that there is sufficient time to complete purchasing orders for classroom furniture, additional resources and ensure the removal of baths.  The proprietor has ensured that all the standards in this part are likely to be met.

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Main inspection findings

Part 6. Provision of information Paragraphs 32(1) to 32(1)(d), 32(1)(f) to 32(1)(j), 32(2) to 32(2)(b)(ii), 32(20(c) to 32(3)(g)  The school’s website went live on the day of the pre-registration inspection. It includes all the information it should. It is easy to navigate. For example, it already includes policies describing the school’s approach to managing behaviour, reducing bullying, admission arrangements and the school’s child protection policy. The proprietor has ensured that all the relevant policies have been written and refer to up- to-date legislation when necessary.  Contact details for the proprietor and the head of education are already on the website. The proprietor intends to add information about the proposed local governance arrangements to the website when these are finalised.  The proprietor intends to work closely with appropriate external agencies to review pupils’ EHC plans. It will provide information to local authorities about looked after

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Main inspection findings

children and pupils with an EHC plan.  The proprietor intends to hold the school to account for providing parents and carers with an annual report with information about their children’s attainment and progress.  The proprietor has ensured that the standard in this part is likely to be met.

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Main inspection findings

Part 7. Manner in which complaints are handled Paragraphs 33 to 33(k)  The complaints policy sets out clearly the timescales in which complaints will be dealt with. This includes ensuring that complaints can be considered on an informal basis at the first stage.  The complaints policy sets out how complaints can be considered on a formal basis. This includes a panel hearing if a parent is not satisfied. The proprietor knows that it is a requirement for one member of any panel hearing to be independent of the management of the school and that a parent can be accompanied at a hearing should they wish.  The proprietor knows to store records of complaints and any actions taken securely. It is aware of the need to publicise the number of complaints from the previous year on its website should the school be registered.  The proprietor is in the process of training new leaders; this includes having a detailed

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Main inspection findings

knowledge of the complaints processes. The school is not intending to open until March 2026 should the DfE decide to register it. Therefore, it is feasible that the proprietor will have upskilled those staff in leadership roles so that they fully understand the complaints process.  The proprietor has ensured that the standard in this part is likely to be met.

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Main inspection findings

Part 8. Quality of leadership in and management of schools Paragraph 34(1) to 34(1)(b)  The proprietor has not ensured that all the standards in Parts 1 and 8 are likely to be met. For example, there is not a suitable curriculum in place. The proprietor has not ensured that the proposed school is likely to meet all the independent school standards consistently were it to be registered.  The proprietor has not ensured that staff in leadership roles are knowledgeable in the requirements of the independent school standards. In addition, not all leaders have prior experience of leading school curriculums or monitoring the quality of education. The proprietor knows that more training is required to ensure that all staff in leadership positions understand the independent school standards and have sufficient knowledge and understanding to lead a school.  The proprietor has not ensured that the requirements in this part are likely to be met.

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Main inspection findings

Paragraph 34(1)(c)  The proprietor is committed to providing an inclusive and nurturing education for the pupils the school aims to admit.  The proprietor has detailed systems in place to safeguard and promote the well-being of pupils. For example, it uses an electronic record keeping system to record safeguarding concerns and works with external agencies as necessary. The proprietor ensures that it addresses any actions as soon as they arise from any external evaluations from commissioning bodies for the alternative provision that is already operating.  The proprietor intends to provide ongoing training for all staff, to ensure that they meet the requirements set out in current legislation.  While the proprietor took action to mitigate any immediate risks in pupils’ toilets by removing taps to baths and boarding them up, the proprietor knows that all baths need to be removed as a matter of urgency.

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Main inspection findings

 The proprietor has ensured that requirement in this paragraph is likely to be met.  Overall, the proprietor has not ensured that the standard in this part is likely to be met.

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Main inspection findings

Schedule 10 of the Equality Act 2010  There is an accessibility plan in place. The school is likely to fulfil its responsibilities under Schedule 10 of the Equality Act 2010 if it opens.

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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

Type of school Other Independent Special School

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Proposed school details

Proprietor First Thought Care Services Ltd

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Proposed school details

Annual fees (day pupils) £48,960 to £71,400

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Proposed school details

Email address jack.cook@ftcareservices.com

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Provider already operating

Number of pupils of compulsory school age 18 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 0

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Provider already operating

Total hours of teaching provided per week Between 10 and 15

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n

Age range of pupils 6 to 19 5 to 11 18 Number of pupils on the school roll 18 25 18

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n

Reason for inspector’s recommendations  The proposed school will be on the first floor of a two-storey building. The building will not solely be used as a school. The size of most classes is adequate for two pupils rather than the three that the proprietor planned for. Currently, there is limited furniture and resources in these rooms. There are larger classrooms rooms downstairs. However, these are designated for the alternative provision, which will remain open and be separate to the school. There are also several other rooms on the first floor, such as a music room, art room and sensory space. However, these are not designed to be full- time teaching spaces. Due to the planned adult to pupil ratio, 18 pupils is the recommendation to allow for enough space for staff to work alongside pupils.

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School’s current position School’s proposal

Gender of pupils Mixed Mixed Number of full-time pupils of compulsory school age 18 25

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School’s current position School’s proposal

Number of pupils with special educational needs and/or disabilities 18 25

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School’s current position School’s proposal

Of which, number of pupils with an education, health and care plan 17 25

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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 18 25

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School’s current position School’s proposal

Number of full-time equivalent teaching staff 1 6

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School’s current position School’s proposal

Number of part-time teaching staff 10 14

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Information about this proposed school

 The proposed school intends to admit pupils with complex special educational needs and/or disabilities (SEND), for example pupils with autism, severe learning difficulties and complex needs.  The proposed school is located in a large building that was originally a house on a main road on the outskirts of Gloucester. The building is not for the sole use of the proposed school. For example, it is the head office for First Thought Care Services Ltd. The proprietor also operates an AP for pupils aged 6 to 19 in this building.  The AP currently operates on two sites. Pupils attend no more than 15 hours per week. This is split into three sessions between 8.00 to 13.00, 10.00 to 15.00, and 13.00 to 18.00. The AP on the same site as the proposed school is situated on the ground floor of the main building. Gloucestershire local authority is currently using it as an alternative provider. There is also a satellite provision in Hereford at 5 Pineapple Place,

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Information about this proposed school

Wide Marsh Street Hereford HR4 9HE. In total there are 18 pupils registered to the alternative provision across both sites, 17 out of these pupils have an education, health and care (EHC) plan. Eleven of these pupils attend the main Gloucester Road site.  The proprietor does not intend for pupils admitted to the proposed school to use any alternative provision, including that which is on the same site as the proposed school.  The proposed school does intend to have a governing body. However, this is at the planning stage. No governors have been appointed.  Recruitment of staff is underway. Currently, there is a head of education, who has a social care background. There is also a head of education for quality who has experience of teaching primary-age pupils and pupils with SEND. She currently works at the AP on the same site and takes up her role in January 2026. No other staff have been appointed. The proprietor intends that he will appoint a special needs and/or

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Information about this proposed school

disabilities coordinator and other suitably skilled teaching and support staff.  The proprietor does not intend for the pupils registered to the AP to use the flexible spaces, such as the games room, cinema room and music room situated in the proposed school during the school day should the DfE decide to register the school.

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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. Inspectors checked all relevant independent school standards, including Parts 1 to 8.  This is the first application to register as a school. The inspector evaluated a range of evidence, including policies and plans relating to each of the standards and the school development plan and self-evaluation documents. The inspector scrutinised health and safety documentation, records relating to safeguarding, child protection, pupils’ misbehaviour, including those in the AP. The inspector also checked the school’s staff recruitment and vetting processes, and the single central record.  The proprietor, the head of education or head of education for quality undertook all activities relating to Parts 1 to 8 alongside the inspector. The inspector and proprietor undertook conversations to establish the accountability structures that the proposed

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Information about this inspection

school plan to implement.  The inspector undertook a tour of the proposed site with the proprietor and head of education to evaluate the suitability of the school’s premises for the purposes of being an independent school. In addition, the inspector reviewed the premises of the ground floor and second floor that will not form part of the school. She undertook a review of spaces that will be shared with the AP, such as for recreation outside.

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Inspection team

Julie Carrington, lead inspector His 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; and  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; – 2(2)(h) that all pupils have the opportunity to learn and make progress; and

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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; and 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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