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SEND REFORM

The real implications of 'benevolent' SEN reform


LYNN ATTWOOD

Consultation of the DfE's Green Paper, Support and Catalyst for change
Aspiration: A New Approach to Special Educational
The Government's Green Paper (DfE, 2011a, p. 16),
Needs, provoked considerable debate among public and
Support and Aspiration: A new Approach to Special Educa-
private sector professionals, parents and young people tional Needs and Disability, acknowledged that several
over the planned special educational needs reform. reports had served as the catalyst for SEN reform; among
Since then, publication of the Children and Families Bill these were Lamb's Review of parental confidence (DCSF,
in 2013 indicates definitive changes in law, while the 2009a), the Rose Review on dyslexia (DCSE, 2009b),
revised SEN Code of Practice, which will provide pro- Tickefl's Review of early years education (DfE, 201 lb) and
OFSTED's (2010) report which asserted there had been
fessional guidance, is awaited. There are implications
over-identification of children with special educational
to this reform beyond those which have already been needs. Consultation with professionals and parents further
published, although alluded to in the Green Paper. This contributed to the Green Paper's proposals, resulting in the
article will explore the influence of language in the Government's opinion that the existing system 'is no longer
deconstruction of disability, the implications of raising fit for purpose' (DfE, 2011a, p. 15).
the threshold before a categorisation of SEN applies,
concerns arising from implementation of the Single Many of the proposals have since been incorporated into the
Assessment Process and, finally, how funding reforms Children and Families Bill (DfE, 2013) which will receive
Royal Assent in spring 2014. Key elements of reform
will negate some of the anticipated benefits for parents
include introduction of the Single Assessment Process
and their children. through which children will obtain Education, Health and
Care Plans, replacing Statements of Special Educational
Key words: special educational needs, SEN, decon- Needs, while informal methods of assessment will be
struction, normalising, false consciousness. adopted for children with less significant difficulties; teach-
ers will be upskilled on specific learning difficulties and
disabilities; local authorities, as 'Champions for Parents'
(DfE, 2010, 2011a), will publish 'local offers'; integrated
working will be strengthened; while the 'third sector' will be
integral to the delivery of services. The Schools' Funding
Reform 2013-2014 (DfE, 2012b) contributes to SEN reform
Introduction by increased delegation of funding to schools and explains
how provision for children with Education, Health and Care
This article has been written from the perspective of a Plans will be funded.
former Parent Partnership Service manager, with experience
in managing a statutory service which provided support to
parents of children with special educational needs (SEN).
Through this role the author gained considerable insight into Raising concerns
the range of difficulties experienced by parents and their
children as well as knowledge of strategies adopted by pro- While Education, Health and Care Plans (EHCPs) are wel-
fessionals with respect to addressing children's needs and comed, the downside is that the Children and Families Bill
working in partnership with parents. Concerns being raised (DfE, 2013) only requires that agencies 'commit' to dehver
are supported by anecdotal evidence and quotations services written into EHCPs, although local authorities
from recorded parental interviews, undertaken as part of 'must' secure special educational provision overall, failing
the author's own research, with regard to the British to reassure parents that services will be provided. Particular
Educational Research Association's Ethical Guidelines for concerns relate to: (a) the threshold for SEN being raised
Educational Research (2004, 2011). Anonymity is retained (DfE, 2011a); and (b) how revised funding arrangements
throughout by adoption of fictitious names, while signed will impact upon eligibility for additional support as well as
consent from parents permits publication and use of the 'capping' budgets per child. Integral to these issues is the
material in any format. extent to which parents may exercise 'choice' atid 'control'

© 2013 NASEN
DOI: 10.1111/1467-9604.12032
Table I. The language of needs Danforth and Rhodes (1997, p. 359) assert that deconstruc-
New terminology Original language
tion, as a political perspective, is underpinned by the
assumption that disability is fiuid. Notions of disability arise
Learning difficulties (included mild, Educationally subnormal
moderate and severe) from individuals' thoughts, use of language and their
Specific learning difficulties Related to specific conditions responses to disability in social situations, which then re-
such as reading difficulties inforce concepts of disability upon those so labelled. The
Emotional or behavioural difficulties, Maladjusted
later known as emotional, social 'disabled' must then choose whether to accept or reject such
and behavioural difficulties categorisation, both in their attitudes and choices regarding
Source: Wamock, 1978, pp. 43, 44, how they live their lives (Danforth and Rhodes, 1997),
although this is not an option for all. When children and
young people in education present with difficulties, these
over proceedings relating to their children. Inherent within are often explored by professionals, who through dialogue
these reforms are conceptual changes regarding the nature define the problem, assign a label and then collectively
of SEN provision. 'Benevolent' SEN reform will be detri- agree strategies for management, corroborating Danforth
mental to some children, denying them vital support, which and Rhodes' (1997, p. 360) assertion that language is central
will have wider implications for society. to the deconstmction of disability.

The author has witnessed 'deconstruction in action'. While


Influential legislation and policy supporting families, there were occasions when speech and
language therapists were definitive about the full nature of
The Warnock Report (1978) instigated a cataclysmic shift children's difficulties, while paediatricians were sometimes
with respect to children with additional needs by decon- more reticent. Subsequent dialogue between professionals
struction of assumptions regarding 'ability' and 'disability' resulted in formal paediatric diagnoses to explain and
and reconfiguration of prevailing ideas associated with support children's difficulties in school.
special educational needs and disabilities (SEND). Children
with short-term support needs, medical conditions and
'hidden' disabilities (such as autistic spectrum disorders)
became encapsulated within SEN alongside those with Definitions of SEN and disability
complex and profound difficulties. Warnock's new classifi-
cations were hierarchical and, through changes in language, The current system of SEN provision is underpinned by the
the emphasis shifted from a model of personal 'deficit' to Education Act 1996, Part IV, the Equality Act 2010 and the
one that focused on the types of difficulty being experienced SEN Code of Practice (DfES, 2001). The Children and
by children. Table 1 illustrates this. Families Bill (DfE, 2013) has repealed Part IV of the 1996
Act and made provision for new Regulations and a revised
Furthermore, the preference for segregated institutions was SEN Code of Practice, which will detail systems of
replaced by integrated mainstream provision, which subse- professional practice. The existing definition of special
quently became known as 'inclusive' education. Parents educational needs is being maintained although applicable
were expected to collaborate with professionals, as pivotal to children and young people in post-16 provision who
parties to SEN processes, under the guise of 'partnership'. experience:
To aid this process. Parent Partnership Schemes (later
known as 'services') were developed, reinforcing the notion '(a) greater difficulty in learning than the majority of
of 'partnership working', while providing parents with others of the same age or (b) have a disability which
information, advice and support. prevents or hinders children from making use of facili-
ties' (DfE, 2013, p. 17; DfES, 2001, p. 6).

Deconstruction New professional guidance on identifying special educa-


tional needs will ensure that only children whose needs
Labelling is often viewed as derogatory even when it targets exceed provision 'normally available in schools' (DfE,
specific difficulties rather than the whole person; it remains 201 la, p. 58) will be placed on school-based SEN support.
implicit that the individual has a deficit of some kind This 'raised threshold' will effectively 'de-classify' many
(Terzi, 2010, p. 37). Language distinguishes individuals children currently on SEN registers.
as 'them' or 'outsiders' who are on the periphery of main-
stream society and, as a consequence, clients, consumers
and patients, who are in receipt of services, can be vulner- Social justice
able to mistreatment by others (Nunkoosing, 2000, pp. 53,
57, 59). Conversely, while restricting engagement in The Government's position is complex and, at times, con-
some areas of life, labelling 'opens doors' to individuals tradictory. Fundamentally, social justice is being applied
receiving support and accessing welfare benefits, which through the principles of educational equality: first, this is
justifies such use. evidenced by the entitlement of all children to a state

182 Support for Learning • Voiume 28 • Number 4 • 2013 1 2013 NASEN


education; and second, equality is demonstrated through learning difficulties or disabilities have few outward signs or
their attendance at mainstream schools where 'inclusive when educational professionals misinterpret the difficulties
practices' enable access to whole school curriculum and presented.
participation in school activities, as much as possible
(Terzi, 2010, pp. 26, 158). Wamock (1978) acknowledged
Generalised assumptions regularly underpinned the con-
the dilemma of treating all children the same while needing
cerns of parents, supported by the author. Parents have
to vary the learning environment to help children access the
reported that educational professionals either denied that
curriculum.
their children had any difficulties or, when acknowledged,
applied whole class strategies to address key characteristics
of conditions such as dyslexia or autistic spectrum dis-
Models of disability orders, without consideration of individual presentation,
severity and differences in learning style.
SEN reforms are reinforcing the application of two primary
models of disability. The medical model of disability
predominates for children with complex and profound
difficulties. EHCPs will be issued, for many children, Deconstruction and social construction
following identification and assessment of difficulties in
early infancy. Hypothetical judgements regarding children's Medical professionals determine the parameters of 'normal'
educability arise from medical and educational assessments and 'abnormal' functioning. Normality leads to 'opportu-
and, combined with the practicalities associated with nity' while individuals categorised as 'abnormal' often have
meeting needs, many children with complex and profound their opportunities curtailed. Assumptions about ability
difficulties are assigned places in specialist schools due to become the 'lived' experience when children choose to
their requirement for intensive support. In the author's ex- accept 'labels' assigned to them and act in accordance with
perience, children with complex and profound disabilities, limitations that have been externally imposed by others
such as those who require breathing and feeding apparatus, (Danforth and Rhodes, 1997, p. 358). Mrs F and her son,
usually attend local special schools. James, illustrate this point:

'It's almost like a dogma - "this is so and you have to


The processes associated with statutory SEN provision re-
deal with it", are the messages given to James. Eor
inforce the medical model of disability; as currently applies
instance, I never told him that he had severe learning
for Statements of SEN, children will be required to undergo
difficulties, but he was told by a professional that he did.
medical assessment for EHCPs and, while agencies commit
Afterwards, he threw down his pen, and said, "I can't do
to deliver services, there will be a need for ongoing medical
it because I've got really bad learning . . . really bad. . .
monitoring. Annual reviews further reinforce this model
my brain really doesn't work". That's really difficult
by the requirement that professionals submit up-to-date because I didn 't choose to tell him that, but I did say,
reports. "you have some difficulties in some certain areas'"
(Mrs F, in Attwood, 2007, Appendix C6, p. 39).
Conversely, the social model of disability adopts the posi-
tion that disability is primarily caused by the structural and
institutional aspects of society and that, by removal of bar- James accepted the professional's 'truth' and became more
riers, individuals with disabilities are no longer disabled. disabled as a result, supporting Danforth and Rhodes'
This position fails to acknowledge the effects of impairment (1997) claim that disability has an element of choice; cer-
on individuals and their own psychological approach to their tainly James chose to become more 'disabled' than his
disabilities and life in general. Inclusive educational prac- (genuine) disability justified.
tices seek to remove barriers that may prevent engagement
and participation of the disabled (Terzi, 2010, p. 19). This While 'labelling' can be detrimental to individuals, 'raising
model is being applied through the Government's policy to the threshold' before children meet the criteria for
'de-classify' many children who, under the current system, individualised support is also harmful. 'Normalising' chil-
are viewed as having special educational needs, on the dren with disabilities or learning difficulties denies them
premise that most difficulties can be addressed through good appropriate support to help overcome their difficulties.
teaching practice and in-school resources (DfE, 201 la). Furthermore, children then experience the challenge of
operating from a position of 'false consciousness', with the
This position is further compounded when educational expectation that they compete with non-disabled peers on
professionals adopt a positivistic position that only accepts equal terms (Low, 2006, p. 108). Pretending that a problem
the existence of observable phenomena and assumes that does not exist does not make it go away. It does, however,
all individuals with the same conditions will exhibit the amount to social injustice when children's needs are not
same characteristics and respond in the same manner addressed, causing them intolerable strain, both during their
(Nunkoosing, 2000, p. 52). Positivism and whole class school lives and beyond. Social injustice already applies
strategies have significant implications for children whose when pupil difficulties remain unidentified or there is lack of

© 2013 NASEN Support for Learning • Volume 28 • Number 4 • 2013 183


consensus between professionals. Mrs D, speaking about (Danforth and Rhodes, 1997, p. 360). This position could
her son, George, demonstrates this point; explain the Labour Govemment's emphasis on parenting,
under the Every Child Matters Agenda (DfES, 2004), which
'Preschool staff said, "there is something quirky here; effectively gave professionals licence to blame parenting
something isn't right". Both the speech and language styles for poor behaviour. This was reinforced through the
therapist and paediatrician both claimed George was appointment of 'parenting commissioners' with respon-
within normal boundaries because he had been able sibility for commissioning parenting services, including
to line up with other children. I went to a different GP evidence-based parenting programmes. To ascertain the
who informed the health visitor, he didn 't think there was 'root causes' of challenging behaviour, parents are at risk of
a problem. The health visitor replied, "you don't live being subjected to intrusive conversations while profession-
with him". At school Behaviour Support said, "there's als determine whether their methods (or other family
something's quirky here". We saw a second circumstances) are the cause. There is significant risk of
paediatrician, who asked what I thought it was. I said, more parents being expected to attend parenting courses as
"I think he's got Asperger's". She said, "yes". It was a result of such 'investigations', while deflecting the need
that clear cut. He wasn 't even borderline; he came well for professionals to examine whether school dynamics
within it. He was four and a half when we got the diag- and/or teacher-pupil relationships are contributing factors.
nosis, and that was early!' (Mrs D, in Attwood, 2007,
Appendix C4, pp. 22, 23).

Behavioural difficulties, when due to 'hidden' disabilities or The influence of schools


mental health concems, are often attributed to rebellion,
disaffection or poor parenting. As a consequence, difficul- Ultimately, the position adopted by one professional agency
ties are not always thoroughly investigated. Mrs B obtained influences the practice of others. When schools no longer
a complete diagnosis for Barry when he was 13 years old, consider certain behaviours and difficulties as special edu-
having fought since his pre-school days. In the intervening cational needs, this will impact upon paediatric manage-
years, a Statement had supported ADHD and Barry periodi- ment of cases. In the author's experience, both parents and
cally received fixed-term exclusions; educational professionals input their views into paediatric
assessments for possible 'hidden' disabilities. Differences in
opinion often result in lack of clarity regarding the nature
'Well, when we got the final diagnosis, a year and a half
and extent of difficulties, resulting in a 'wait and see
ago, I was just relieved really. Some people had said that
approach' being adopted.
Barry was quite destructive and there was a lot of
behavioural stuff- he was very impulsive and also obses-
sive, I knew instinctively that Barry had no awareness of As educational professionals input information into paedi-
some of the stuff he was doing and that he really couldn 't atric assessments, this will disincentivise the need for
help himself, I was proved right because the diagnosis paediatric diagnoses, when milder difficulties are no longer
revealed it was Asperger/ADHD and other leaming categorised as SEN. In the author's experience, sometimes
problems such as not understanding language' (Mrs B, definitive diagnoses are only provided to help children secure
in Attwood, 2007, Appendix C2, p. 10; Attwood, 2013, additional resources. Lack of corroborative evidence will
p. 164). make it harder for parents to 'prove' their children's difficul-
ties, with only the most overt, complex and profound
The Govemment's Green Paper (DfE, 2011a) asserts that difficulties qualifying for school-based support or EHCPs.
educational professionals should ascertain the root causes of Children's difficulties are sometimes inaccurately perceived
poor behaviour to ameliorate the need for school exclusions. or missed entirely and, under the politics of reform, this will
Such investigations will be an additional burden upon teach- be exacerbated. The following anecdotal story illustrates this.
ers and drain resources; there is a risk of schools being
reluctant to await the investigative outcomes before imple- Mrs C contacted a support service, following the local
menting what they consider to be appropriate disciplinary
authority's refusal to undertake statutory assessment. Her
action.
14-year-old son, Luke, already had a diagnosis of autistic
spectmm disorder and had been unable to make educational
In the author's experience, educational professionals are
progress. Following the support service's referral for speech
often unaware of pending investigations and lack knowledge
and language assessment, subsequent diagnosis confirmed
of how specific disabilities present in individual children.
They do, however, view it as their right to discipline severe speech, language and communication difficulties,
challenging behaviour, irrespective of cause. Furthermore, resulting in a Statement being issued. Educational profes-
educational professionals are sometimes reluctant to expend sionals had failed to identify these difficulties.
additional resources on children who are considered
unco-operative. Children failed by the education system have fewer oppor-
tunities available to them such as college places, training,
Deconstmction enables professionals to deny the presence employment and independent living. Undiagnosed diffi-
of disability in their work with parents and children culties deny children and young people an appropriate

184 Support for Learning • Volume 28 • Number 4 • 2013 ) 2013 NASEN


education as well as state benefits and other services. relation to the execution of some tasks. Eunctions such as
Professional mistakes can, therefore, have significant and leading and co-ordinating transition planning are not neces-
long-term implications. sarily specific to one professional role and there is risk of
tension arising between professionals due to their reluctance
or inability to take on additional responsibilities which
The capability approach could be fulfilled by others. Therefore, transition planning
commitments may prove no more effective than the existing
Sen's capability approach addresses justice and equality in system.
education from the perspective of the 'practical opportuni-
ties' presented to individuals and the extent to which they Explicit implementation details of the Single Assessment
subsequently achieve well-being and fulfilment (Mitra, 2006, Process are awaited, although with the Government's pref-
p. 236). This theory examines the way opportunities are erence for multi-agency meetings (DfE, 2011a) there is a
presented and how individuals can use them to their advan- strong possibility that such meetings will contain an assess-
tage, with regard to impinging environmental, economic, ment component or professionals will review evidence
social and cultural factors (Mitra, 2006, p. 237; Sen, 1992, obtained from previous assessments. The author's research
cited in Terzi, 2010, p. 87). Even when presented with the concluded that family attendance at multi-agency meetings
same opportunities. Sen noted that disabled individuals are can cause considerable stress. Children are objectified by
unable to function in the same way as non-disabled, conclud- professionals and are sometimes mortified to hear others
ing that disadvantaged individuals require different types and discuss their weaknesses, experiencing both anticipatory
amounts of compensation (Sen, 1992, 1999, cited in Terzi, anxiety and emotional reactions afterwards. Such experi-
2010, p, 87). This has significance for the proliferation of ences are contrary to protecting children's health and well-
whole class strategies which are meant to address the needs being (DfE, 2012a), Parents, irrespective of social class and
of children with the most prevalent learning difficulties professional background, experience heightened emotional
and disabilities. This is an inappropriate strategy for those reactions (Attwood, 2007),
who cannot access the curriculum without receiving
individualised support to meet their needs, thereby increas- When planning the organisational arrangements associated
ing the risk of children being failed by the system. with the Single Assessment Process, professionals should
have regard for the impact upon families as well as the
effective use of resources. The Government's proposal to
Transition planning and assessment use such assessment to support applications for other ser-
vices and disability benefits is welcomed (DfE, 201 la).
The Single Assessment Process (SAP) was originally intro-
duced for older people, under the NHS and Community
Care Act 1990, becoming statutory provision in 2005, and it Funding arrangements
has now been adopted as the model for statutory assessment
for children and young people expected to require EHCP The School Eunding Reform: Arrangements for 2013-14
provision. The new plan should benefit young people who (DfE, 2012b) have increased delegated funding; this will
previously might have 'fallen through the net' during trans- enable schools to support children's special educational
fer from children's to adult services. However, it is already needs at school-based level as well as contributing £6,000
a requirement that transition planning takes place for chil- towards provision for children with EHCPs and existing
dren with Statements during Year 9, when arrangements Statements, Eunding for statutory provision will be 'capped'
should take place for future attendance at college, training or at £10,000, with local authorities contributing the remaining
independent living (where possible). £4,000, The total sum of £10,000 will be insufficient to
address the needs of many children with EHCPs and State-
ments, although 'top-up' funding may be granted, upon
When the author contributed to a new local authority Tran-
parental application. This approach will necessitate parents
sition Protocol, under the Government's Transition Support
'presenting their case', which could trigger further stress for
Programme (DCSE, 2008), professionals were concerned
them. Successful applicants will have additional funds cal-
about having sufficient human resources to deliver the
culated on 'real time' required for specific services, which
service to all eligible children and young people. The author
will restrict parental choice when commissioning services.
has supported parents of children with Statements, where
transition planning either did not take place at the appropri-
ate time or was tokenistic regarding post-compulsory
education arrangements. Implications and concerns

There are a number of concerns arising from these reforms,


Since the Government's Comprehensive Spending Review
outlined as follows;
(HM Treasury, 2010), many local authority teams that
deliver key services are under-resourced. Inter-agency • Children will effectively be segregated into 'assessment
working has, to an extent, blurred professional boundaries in streams', with the Single Assessment Process being

© 2013 NASEN Support for Learning • Volume 28 • Number 4 • 2013 185


implemented for those perceived to need EHCPs while considered normal range, with repercussions for medical
'informal' methods will be adopted for school-based diagnoses, social care support and access to classroom
provision (DfE, 2011a, 2012a). When children's diffi- support, and increasing the likelihood of educational
culties are incorrectly or partially identified, this denies failure. Whole class teaching strategies cannot address the
them necessary support. Parents will, inevitably, have individual manifestations of disabilities and learning diffi-
to 'fight' to have their children reassessed, resulting in culties, despite the proposed upskilling of teachers. The
the new system proving no better than existing mecha- effects of 'normalisation' will follow children through
nisms for assessing needs. school, college (if attended) and into adulthood as they step
Enforced 'normalcy' of children with milder disabilities out into wider society and attempt, if possible, to gain some
or learning difficulties risks disaffection which, in turn, form of employment. For some it may mean a 'grey exis-
exacerbates emotional, social and behavioural difficul- tence' where they have an undiagnosed disability (albeit
ties, increasing the risk of fixed-term and permanent probably mild), but without protection afforded under the
exclusions. Unacknowledged disabilities will deny Equality Act 2010.
children 'reasonable adjustments' under the Equality
Act 2010. The number of children with Statements has declined in
There is a risk of inadequate contingency by schools to recent years and this reform will ensure that only the most
support newly categorised 'high cost, low incidence profound and severe difficulties will qualify for EHCPs
SEN' pupils. under the medical model of disability. The deconstruction
Despite having additional funding, schools could be of some forms of special educational need will address
reluctant to commission expensive specialist expertise OFSTED's assertion of an over-identification of SEN,
for pupils, relying on in-house support only. resulting in significant savings on the SEN budget. With
Without ring-fencing, there is the potential for schools fewer children identified with special educational needs, the
to use SEN funds for other purposes. Government can justifiably reduce the centralised SEN
Parents of children with EHCPs may optionally become budget, claiming that its reforms have been successful. As
'budget holders', with some using the 'Direct Pay- schools have autonomy regarding SEN expenditure, except
ments' system (DfE, 2011a, 2012a). Regulations wifl for their contribution towards EHCPs, the Government is
determine the proportion and extent of parental influ- distanced from blame when children are not adequately
ence in commissioning services. If parental influence is provided for. Race and Malin (2011) note the drive towards
limited to local authority funding only, their input will managerialism. This approach is evident from increased
be significantly compromised and there is risk of dis- delegated funding, a reduction in local authority support
continuity of provision if other funding sources are services and through specialist services, such as speech and
treated differently. language therapy, being delivered by support staff such as
Educational psychologists will cease being centrally teaching assistants (or similar roles), following appropriate
provided by local authorities. The upskilling of teach- training, and this practice is likely to increase. The evidence
ing staff may serve a dual purpose. While enhancing is stacking up that SEN reform is a cost-cutting exercise
professional practice, there is a risk of teachers being under the guise of benevolent reform. These issues are
expected to make decisions regarding learning difficul- further explored in Attwood (2013).
ties and disabilities that were formally the province of
Parental 'choice' of school has, to an extent, been eroded
educational psychologists. This will place unrealistic
by academies, with respect to children with Statements.
burdens on teachers, while denying children specialist
Although expected to comply with SEN legislation.
assessments, unless parents have sufficient funds to
Academy Funding Agreements permit independent opera-
commission private reports.
tion, enabling some to 'sidestep' this requirement, as
reported in The Guardian (24 May 2012). A 'double-edged
sword' applies for children operating under 'normalcy';
Conclusion
where 'hidden' disabilities fail to meet the criteria for being
SEN, it should be easier to gain admission to academies
Disability and special educational needs are deconstructed
although children's 'normalised' status will provide no pro-
through revisions in terminology, usually initiated by those
tection under the Equality Act 2010 or from experiencing
in power such as policy makers and professional bodies.
the full weight of school disciplinary procedures. Ulti-
Following the Coalition Government's Comprehensive
mately, children with 'hidden' disabilities may be in for a
Spending Review (HM Treasury, 2010), some services were
tumultuous ride. It is hoped that this article will stimulate
completely dismantled while others suffered significant
further debate and consideration of potential pitfalls before
reductions in human and financial resources. The reforms
it is too late.
have been presented as an improvement on the current
system, and not as a cost-cutting exercise, although the
reality appears somewhat different. References

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