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What does ‘reasonable adjustment’ mean for schools?

Rebecca Parker highlights what schools can sometimes overlook when it comes to drawing up their accessibility plans...

  • What does ‘reasonable adjustment’ mean for schools?

All schools must comply with the Equality Act 2010 and have an accessibility plan.

The latter details how a school will ensure that equal access is extended to all staff, visitors and pupils, and must also show how access can be improved for users with disabilities within a given timeframe by undertaking ‘reasonable adjustments’ where possible.

According to the wording of the Act, schools have a duty to “To take such steps as it is reasonable to have to take to avoid the substantial disadvantage to a disabled person caused by a provision, criterion or practice applied by, or on behalf of a school, or by the absence of an auxiliary aid.”

The funding context

The National Audit Office has stated that increasing pupil numbers and staff costs will force schools to cut their per-pupil spending by 8% during the 2019/2020 school year – a significant reduction that virtually all schools will struggle to implement.

Schools as a whole may be in receipt of more government funding than they were five years ago, but rising costs in areas such as staffing and pensions has made it hard for them to keep up.

Assuming this 8% reduction in per pupil spending comes to pass, schools will be under significant pressure to make cuts. We saw some evidence of that in the summer of this year, when a Norwich junior school sought ‘volunteer painters, gardeners and decorators’ to help staff prepare for the new school year.

In September, it was then reported that 20 schools in Birmingham were planning to close for half a day each week to reduce costs.

Schools are effectively being forced to make redundancies, close early, and in some cases even drop curriculum subjects. With teachers’ salaries continuing to make up the vast proportion of budgets, it’s hardly a surprise that schools are consequently trying to manage with fewer members of staff.

Unfortunately, schools’ accessibility planning seems to be one of those spending areas that’s liable to get pushed to the bottom of the priority pile, despite its increasing importance.

That’s perhaps because a school’s lack of accessibility planning only crops up when a specific issue comes to light, such as the arrival of a disabled visitor or a pupil with SEND.

Headteachers who are under vast amounts of pressure and constantly having to juggle many competing demands on their time will be keenly aware of their need to have an accessibility plan – but due to lack of resources, the plans they produce will often be insufficiently comprehensive, lacking in detail and neglect to cover some important areas.

The ‘tick box’ approach

There are numerous checklists available online that will provide a superficial ‘tick box’ approach to evaluating a school’s physical accessibility, yet too often this will be an avenue pursued by many in order to try and save money.

The school SENCo or site manager will typically be the one given the task of carrying out school access audits and writing an accessibility plan based on such a checklist, but there can be two big problems with this.

The first is that an online checklist will usually just refer to physical access, compounding the regrettably common misconception that accessibility plans need only address physical issues.

In actual fact, physical access should account for around a third of a school’s accessibility plan, with the remaining two thirds considering access to the school’s curriculum and access to information.

The second issue can be that the SENCo or site manager may lack the knowledge to discern what can and can’t be considered a ‘reasonable adjustment’ – a common stumbling block for many organisations trying to undertake their own access audits.

One the other hand, an experienced access consultant – one sensitive to the budgetary issues at play within school settings – will be able to suggest practical ways of ensuring compliance with equality legislation without recourse to costly works.

Complicating matters further, the Equality Act 2010 itself doesn’t specifically state what should be considered ‘reasonable’. This may seem confusing, but it actually stems from a desire to make the legislation flexible. After all, what might be considered reasonable in one circumstance may well not be reasonable in another.

It’s obviously impossible to say what measures would or wouldn’t be reasonable in any given situation without an understanding of the relevant context.

However, there are some factors which may help schools to decide – namely the financial cost of making an adjustment, the practicality of the adjustment in question, the resources available to the school and the adjustment’s subsequent impact on other pupils.

Erroneous assumptions

Many of the schools we’ve advised in the past have originally tried to take on the work themselves following the kind of thought process outlined above, but in virtually all cases this has proved more expensive.

Not only does it take up the precious time of those involved, it can also result in unnecessary and costly building works, owing to the lack of accessibility training on the part of those undertaking the work.

For instance, simply by ensuring that all classes for a pupil using a wheelchair are situated at ground level, a school will have demonstrated that they’ve made a ‘reasonable adjustment’ that grants the pupil access to both the building and the school’s curriculum.

This would be deemed perfectly reasonable and cost nothing; contrast that to the expense of installing a stair lift.

Also, bear in mind that pupils with the same disability may still need different adjustments to overcome certain barriers.

It’s important not to make any assumptions about a disabled pupil’s particular needs, as this may cause a school to make an adjustment that’s completely ineffective for what’s required. Again, this is something we see far too often when schools attempt to undertake access audits of their own.

For example, consider an incoming school starter who is deaf. The school’s SENCo undertakes an access audit and concludes that induction loops must be installed in all teaching rooms – yet the school doesn’t consult with the pupil first.

It later emerges that the pupil doesn’t actually use a hearing aid, and is therefore unable to benefit from the induction loop.

Instead, the pupil reads lips. In this instance, a better reasonable adjustment would have been to instruct all staff to ensure they face the pupil when speaking to him.

Savings versus outcomes

As previously noted, the considerations in a school’s accessibility plan mustn’t be limited to only those with physical impairments; pupils with sensory impairments, cognitive impairments, intellectual impairments and those affected by mental illness will require adjustments of their own.

Needless to say, it can be extremely difficult for an untrained eye to deem exactly what can be considered reasonable in any given circumstance.

Consider, for example, an independent school that provides extra sessions with a specialist teacher for a dyslexic disabled pupil, but adds the cost of these to the pupil’s fees. This would amount to discrimination.

It’s no secret that schools are under significant budget constraints, and desperately struggling to cope with funding cuts – yet the importance of accessibility planning shouldn’t be underestimated. Schools which resort to undertaking such work themselves risk producing ineffective results and failing to capture all salient aspects of a pupil’s accessibility needs.

Using a checklist downloaded from the internet might seem at first glance like a convenient time and cost saving, but it’s one that typically comes at the expense of good outcomes for those with accessibility needs.

Opting to instead enlist an access consultant possessing a breadth and depth of accessibility expertise needn’t carry a significant cost, and will make it that much more likely that your school obtains an accessibility plan which clearly demonstrates its desire to be inclusive to all.


Rebecca Parker is an access auditor at EA Audits.

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