Public Audit Committee consideration of Audit Scotland's ASL report
The Public Audit Committee wrote to Education Unions to seek their views on the evidence heard by the committee about Audit Scotland's report on implementation of the ASL Act. AHDS's response is set out in full below (it was accompanied by a copy of our 2025 Workload Survey Report which is referred to in the response).
"Introduction
AHDS is a trade union for promoted teachers from Scotland’s nursery, primary and ASN schools. We have around 2800 members, including 80% of primary HTs in membership.
AHDS welcomes the opportunity to comment on the issues raised in the Public Audit Committee’s consideration of the recent Audit Scotland report on Additional Support for Learning.
Background
It is worth highlighting at the outset that AHDS members very much recognise the picture presented in the Audit Scotland briefing paper. Indeed, it aligns with the key recommendation flowing from the AHDS Annual Workload survey 2025 which found that ‘proper support for inclusion’ was the number one issue for AHDS members up and down Scotland. This resulted in one of four recommendations flowing from our workload survey report:
“Recommendation 1: Following the gaps in funding highlighted by the Audit Scotland report on this theme, urgent and significant investment is required to enable schools to effectively support pupils with additional needs. A consistent national funding formula should be adopted to address the current variability of provision.”
Our full workload survey report has been provided to the Committee but we wanted to share, here, a chart which highlights the degree to which members see the need for increased investment in ASN as their number one priority – when asked to select their top priority, 45% of members who responded selected “support for ASN/distressed pupils”, a vastly higher proportion than for any of the other options:
Data and funding
It was clear from the committee’s discussion with the Accounts Commission and Auditor General on 19 March that there was a keenness for more robust, consistent and comparable data to be gathered regarding ASL. While the Scottish Government and CoSLA also recognised the value of data to inform policy they, CoSLA in particular, introduced a note of caution about focussing on efforts to record ASL consistently rather than focussing on the activity being undertaken to address need. This was a nuanced argument, but two points are at the core of the CoSLA position. The first is that collating data consumes time and money. The second is that capturing data on identified needs is not the same as capturing data on the work done to support those needs. Both these points are entirely sound.
AHDS members, in common with many others directly involved with delivery, have identified a need for significant increases in expenditure on ASN in an effort to meet the needs that they are presented with in school each day.
While we understand that there is a policy need for better data recording of need/support delivered, we would argue that expenditure in time and resource on improving data should only ever be a small part of increased resource applied to this area. If restricted resources are available, then the focus should be on passing that resource to the system enabling local authorities and school leaders to determine how it is best spent. Only if there was to be a substantial increase in resourcing should there be a movement from filling a known resource gap to designing and implementing changes (or increased detail) to data collection and scrutiny measures. In any resource situation, data gathering should be highly streamlined, efficient and meaningful to gain only the necessary data and to do so with the least absorption of resources which could be applied to delivery.
Diagnosis and provision of support
In both evidence sessions, the discussion returned to the point that there need not be a diagnosis in place to access additional support. AHDS highlights two themes in response to this discussion.
Theme 1: Confusion
The discussion in Committee both recognised that the needs covered by the ASL Act were very wide, but discussion went on to focus on the narrower point of diagnosis – which would only ever apply to a sub-set of those who were designed to be supported through the inclusive way in which the ASL Act was drafted. The implication being on one hand that the definition was too wide to defy accurate recording, while it was also inferred that there was a barrier to accessing support without a specific diagnosis.
Theme 2: Resources
Discussion considered the acceleration in demand/need identified and queried this. In part, the discussion edged towards an argument that definitions needed to be refined but it also returned repeatedly to the fact that no diagnosis is required to access support.
For AHDS, the issues of diagnosis and resources are interlinked.
Member experience reported to us could not be clearer. The current level of resource available is inadequate to address the needs presenting in schools around Scotland.
The intentionally broad nature of the legislation and the variety of appropriate supports for different situations and individuals means that the diagnosis point is sometimes a red herring. By that we mean that, for example, while a child who has suffered a bereavement, and is deemed under the legislation to have an additional need, will get support without a diagnosis (as there is no diagnosis to give) while a child without an ADHD diagnosis may not. This is because, while the legislation is inclusive, finances are finite. As a result, where a need is diagnosable, those with a diagnosis will be first in the queue.
To free teachers up for their core role and for the intention of the policy and legislation to be recognised, a considerable increase in funding for ASN is required. This relates to the need for increased support assistants in classrooms, additional ASN teachers, additional places in specialist provision and increased capacity in the range of services outside the school which are essential to enabling children with additional support needs to thrive.
Greg Dempster
AHDS General Secretary"