Element 3 funding

Introduction and context  

This guidance covers the revised approach to Element 3 funding for Norfolk for 2025/26 academic year and is as a result of significant collaborative work involving many school leaders across multiple engagement opportunities, culminating in Norfolk's Schools Forum. 

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

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

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

On a small number of occasions, due to the combination of both the number and high needs of children within a school, the school may have insufficient core funding (Elements 1 and 2) to fund all Targeted provision.  The notional SEN budget for mainstream schools: operational guide 2025 to 2026 provides the option for LAs to provide targeted funding to supplement a school's notional SEN budget, but this is not a requirement.  The LA has not introduced such a budget on the basis that, where this is the case, it should be apparent through the Graduated Provision Map, and the school level approach to Element 3 funding allows for dialogue as to whether provision can be adapted to remain both adequate and affordable within the resources available or whether additional top-up funding (Element 3) is required (i.e. is, as the DfE guidance asks, the school over identifying needs, or does the school have a significant mismatch between notional SEN (Element 2) and the actual costs of Targeted provision because of a disproportionate number of children with SEN or pupils with needs of a particular kind that are not captured by the formula factors and values used).    

Element 3: Formulaic allocation from September 2025  

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

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

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

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

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

Element 3: Cohort and individual funding from September 2025   

The majority of schools will have received confirmation of formulaic and cohort-based Element 3 (E3) funding allocations for autumn 2025 and spring 2026. 

Cohort allocations have been determined using child and setting contextual information provided by schools via: 

• Identification of Needs in Educational Settings (INDES) 
• Graduated Provision Map (GPM),  
•  Inclusion and Provision SEF (IPSEF) 

Thank you to all schools for continuing to share this information; continuing to share your information with us enables: 

• Schools to be adequately and appropriately funded to meet the needs of children with high-level SEND. 
• Shape the LA's support offer, including training, professional development, and on-demand resources. 
• Schools and the LA to respond effectively to the evolving needs of children, young people, and education settings across Norfolk. 

The LA remains committed to working in partnership with our schools to support them to embed inclusive, high-quality provision, enabling all our Norfolk children and young people (CYP) to Flourish. 

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

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

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

Moderation arrangements  

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

Phase transition arrangements  

Phase transition conversations with feeder schools should take place through local transition arrangements between settings, providers and families. Any support required from LA teams can be sought through the SEND and Inclusion Support Model (SISM) via Team Around the School (TAS) discussions or via the phoneline.  

Mid-phase new starters and leavers  

There is an expectation that schools will review the GPM to reflect those children and young people who start or leave mid-phase and make any necessary adjustments, which will be discussed within a Team Around the School conversation, including any implications for E3 cohort funding.  It is anticipated that schools will likely have the available provision in their graduated provision map to meet the majority of need for CYP joining their setting. 

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

Attendance  

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

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

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

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

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

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

See Attendance forms and templates. 

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

Types of provision that could be included within Graduated Provision Maps with respect to Element 3 funding  

Below is a list of provisions that may be sourced from Element 3 high needs funding. This list is not exhaustive but gives examples.  All provisions should be those which sit above the setting's Universal and Targeted offer and are specific to a child or young person or small group:  

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

It is expected that provision should support children to develop independence, to prepare them to progress through the phases of education, and to build confidence for the young person and family. Therefore, the LA encourages settings to review plans to ensure targets are working towards achieving this for each child. Targets need to empower children towards independence and requesting adjustments that allow themselves to be included in all school activities, and to develop skills that can be applied outside of the school environment and into adulthood.   

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

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

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

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

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

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

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

These calculations are based upon payment for 44.65 weeks per year, which allows for a 38 weeks +1 contract along with associated contractual holiday pay.  The midpoint salary in the preparation guidance for 2025/26 was uplifted to allow for the increase in National Insurance and an assumed 3% pay increase for 2025/26.   

The pay offer has now been agreed, leading to a small difference of between £55 to £65 on the annual amount depending upon pay grade, meaning that the rounded hourly rates remain valid.  For reference purposes, the 'midpoint of scale' and 'equivalent of hourly rate' columns have been updated.   

The projected 26/27 pay rates, approx. hours and rounded hourly rates to use for GPMs will be reviewed and updated ahead of 2026/27.   

Expectations of use of E3 and conditions of grant 

Under the Dedicated Schools Grant (DSG) conditions of grant, LAs are required to ensure that high needs funding is used effectively and efficiently, including that the LA's Chief Financial Officer (CFO) is required to provide assurance to Department for Education (DfE) / Educations Skills and Funding Agency (ESFA) that monies are spent on the purpose for which they are intended.  This includes the Element 3 budget and ensuring that the funds are used for the purposes that they are provided for.  As a system, we need to ensure that spend is necessary and appropriate, and that we are delivering value for money.   

• Assurance involves having effective processes established at the outset to support informed decision making, as well as systems in place to review the outcomes of interventions and the allocation of resources, thereby facilitating future decisions.  The model from 2025/26 academic year, including child level needs and support identification, school-based provision mapping and Team around the School discussions of provision, is designed to support the provision of such assurance that funds are being used appropriately and for their intended purposes.   
• For these arrangements to be effective, and to ensure that funds are being utilised effectively and efficiently, schools and academies are expected to engage in open and transparent dialogue with the LA, in line with 7.3.3. of the DfE High Needs Funding: 2025-26 Operational Guide1 states: 

The local authority should consider evidence from the school or college about the costs of offering provision for the pupils and students with high needs, including cost increases such as for utilities and staff pay awards that are not met from other sources.  Schools and colleges should be transparent about their costs and how they contribute to delivering the overall provision for the pupils and students with high needs.

• The Department for Education (DfE) have advised that such evidence of the use of Element 3 funding to support the needs of children and young people with SEND, can be both in advance of the allocation of funds and through review processes to support future decision making regarding the support needs of the child or young person, as well as to provide the LA with the appropriate assurance regarding use of funds.  

The published guidance and frequently asked questions advise what to do if provision needs to be amended (increased or decreased) and the process to follow.  It is acknowledged that this can involve contractual implications and the timeline for changes can be discussed as part of provision discussions in Team Around the School meetings and as part of funding change requests. 

If funding is not required for the purposes that it was provided, then the LA should be notified via the E3 funding mailbox, and the school or academy may be asked to return them to the LA.   

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

• If schools and academies are fully engaging in an open and transparent way with the system in place in Norfolk, then this should provide the LA with sufficient evidence to enable both decision-making regarding future funding and assurance regarding the use of funds.  This includes, for example, keeping up to date individual child needs identification and support plans (such as INDES) and graduated provision mapping, active participation and engagement in Team around the School meetings, and effective completion of EHCP annual reviews.   
• However, if this is not the case, then the LA may need to request additional information to support a request for a funding decision or for assurance as to how funds have been used for the purposes provided, rather than just for schools funding more generally.  It is hoped and anticipated that any disputes can be resolved amicably between a school or trust and the LA.  However, if a dispute that remains unresolved between a school or trust and the LA, then section 7.5 of the DfE's High Needs Funding: 2025-26 Operational Guide would need to be followed.  

LA Maintained schools only: In line with the risk-based approach to maintained schools' audits being introduced for 2025-26, consideration will be made in the preparation of routine audit programmes as to whether or not Element 3 funding and expenditure will be audited. 

Upon receipt of funding, it will be assumed that settings are agreeing to these arrangements.  

An overview of the Element 3 funding Process 2025-2026 

The diagram below outlines the Element 3 (E3) funding process that is now implemented across Norfolk from September 2025. It provides a step-by-step overview of how schools and settings apply the new model to support children and young people with high-level SEND needs.

A fully accessible version of the diagram is available below.

Start with

1. School actions: Review and amend your setting's Graduated Provision Map (GPM)

Then

2. Meetings and discussions: Discussion at Team Around the School meetings

Next step

3. Decision Points: Are there any implications for Element 3 Funding (increase or decrease)?

This can result in either:

4. School actions: Setting requests a review at the Element 3 Funding Panel
   or 
   4a. School actions:

• Continue using the GPM as a working document for strategic provision planning. 
• Regularly review the impact of provision.

4a then leads back to repeating the whole process

If the first alternative (4) applies, then

5. Information sharing: Information collected for Element 3 Panel

Which results in 

6. Meetings and discussions: Half-termly Element 3 Funding Panel

This can result in either:

7. Decision Points: Panel Outcome: Change to cohort funding if required
   or
   7a. Decision Points:  Panel Outcome: No change to cohort funding required

If the first alternative (7) applies, then

8. Information sharing: Change to cohort funding processed

Leading back to repeating the whole process

If 7a applies, then

4a. School actions:

• Continue using the GPM as a working document for strategic provision planning. 
• Regularly review the impact of provision.

Leading back to repeating the whole process