Mr. Greg Browne:

On behalf of my colleagues, we thank the committee for meeting us today. The publication of Circular 39/25 has greatly alarmed not only our staff members but also our parents and the schools our pupils come from. The circular threatens our designation and, fundamentally, our ethos, which, in reality, is created by the pupils we teach.

It is important that committee members understand the characteristics of mild general learning disabilities which, we feel, will explain more fully our deep concerns. Between 5% and 7% of the population has a mild general learning disability, which makes it the largest cohort of students in education with a disability. The IQ range for our schools is from 50 to 79, which makes it the widest band in learning disability. Often referred to as a hidden disability, it has a number of characteristics. There are expressive and receptive language difficulties in the moderate to severe range of language disability, which on a practical level means that pupils with a mild general learning disability cannot process a huge amount of what they hear at any given time. They have major difficulties with abstract concepts, especially in maths, including time, fractions, decimals and many other maths skills required for living. They have below average reading and comprehension levels, and most pupils with a mild general learning disability lag behind their peers by several years. Many will never reach a functional reading age of nine years. They have poor self-esteem and a lack of self-management skills. They have major difficulties with fine and gross motor skills. They have major difficulties with memory, resulting in difficulties with the retention of knowledge as well as poor concentration skills. They have an inability to absorb the complexities of their environment and to make generalisations and associations from what they learn. They have an inability to see danger and imagine outcomes or consequences.

The famous educational psychologist Lev Vygotsky stressed the importance of language in one's overall cognitive development and the importance of structured scaffolding in the learning process, which is key to understanding a learning disability. In up to 66% of cases, a mild general learning disability is accompanied by a co-occurring disability, which impacts directly on the pupil’s ability to learn. There is co-occurrence with autism, whereby 50% of all pupils with an autism diagnosis have a mild general learning disability.

Almost 10% of pupils with a mild general learning disability have challenging behaviour. Approximately 36% of pupils and adults with a mild general learning disability have a psychiatric disorder, which is by far the greatest cohort with psychiatric difficulties. Many of our students are being seen by the child and adolescent mental health services, CAMHS. Other disabilities include Down's syndrome, attention deficit disorder, ADD, and attention deficit hyperactivity disorder, ADHD, fragile X syndrome, Prader-Willi syndrome, global developmental delay, epilepsy, dyspraxia and selective mutism, to name but a few.

Why are MGLD schools so important? The development of specials schools in Ireland was initially led by religious orders and concerned parents and groups, who recognised that mainstream education did not suit the needs of a significant section of the school-going population MGLD schools have consistently shown that their pupils have greater access to an inclusive education in an environment where the pupils are at ease and work at their own pace. This allows them to access the curriculum in a more meaningful way at primary and secondary levels, with many completing junior cert levels 2 and 3, the leaving certificate applied and Quality and Qualifications Ireland, QQI, levels 1 to 4.

MGLD schools cater for those pupils who become marginalised in mainstream education because of learning disabilities and are in greater danger of expulsion in mainstream schools. MGLD is 14 times higher in prison inmates than in the main population, with up to 50% of all inmates having major literacy difficulties. MGLD schools have a great success rate in keeping pupils with learning difficulties in school up to the age of 18. They also have great success in providing access to either third level or further rehabilitative or vocational training, thus avoiding juvenile delinquency in their formative years.

MGLD schools are seen as the only hope for parents if their son or daughter is overwhelmed by the demands of mainstream education, where in many cases they have no friends as the gap between them and their peers widens with each passing year. Our schools seem to better suit the increasing number of pupils with school refusal difficulties. The right to a suitable educational placement is a cornerstone of democracy, and the right of each parent to choose our type of education is as equal as the right of any other parent to choose Educate Together schools, Gaelscoileanna or whatever they would like for their children.

MGLD schools have a higher proportion of students from disadvantaged areas who otherwise would have dropped out of education. They are not restrictive in their designation. In fact, what I have just stated clearly shows that our schools are the most diverse schools in Ireland.

Staff in MGLD schools have been some of the most innovative people in Irish education. The present-day levels 1 and 2 programmes owe their origin to the self-designed programmes that MGLD schools created over the last seven decades.

Our schools cater for more pupils from broken homes or in foster care and residential care than mainstream schools. We are often the one constant in their lives over many years of upheaval, and are advocates for them both while in school and when they have left after the age of 18.

Our schools build up networks of contacts with social workers and the HSE. In an age of online danger with social media, our school structure allows us to be most diligent about child protection for the most vulnerable and at-risk pupils.

Our schools cater for boys and girls whose learning disability results in severe shyness, oddities in behaviour and social interaction, low self-morale and self-esteem, autistic traits even if undiagnosed and those who might not attend school daily if we did not exist. In respect of our pupils with autism, the majority are not in autism-specific classes with a ratio of one teacher to six pupils but rather in larger MGLD classes with a ratio of one teacher to 11 pupils. The educational value of this is obvious, especially regarding socialisation and language development.

On Circular 39/25, our schools have major concerns. The first relates to our admissions policies. Until now, parents of prospective students applied to our schools directly, with a copy of an educational assessment showing that the pupils had a mild or borderline mild general learning disability and a recommendation for a place in our schools. These applications would then be approved at board of management level, followed by approval by our school special educational needs organiser, SENO. The circular proposes to majorly restrict the role of the board of management in its own admissions. Parents now have to seek approval from their own school SENO first to be eligible to apply for our schools. In my own case, up to ten different SENOs would determine who can or cannot apply to my school. This restrictive practice raises the question as to what will happen if a request for a letter of eligibility is refused by a SENO despite the pupil meeting the criteria of the school’s enrolment policy. Principals of MGLD schools may not even be aware of who is seeking a place in their schools.

No other sector in education would allow such control of admissions. To expect that parents and schools would have applied to their SENO by 1 October in the year previous to enrolment in our schools is unacceptable, to say the least, with the continuous difficulties in trying to get National Educational Psychological Service, NEPS, or private assessments. Our own system at present has its proper checks and balances for admissions. Our schools do not canvass for pupils but parents approach us, often in desperation, seeking our help. Most of our schools accept pupils only after they have experienced mainstream education and parents are then in a better position to make an informed decision.

Our immediate concern is that pupils with a borderline mild general learning disability will not be recognised, as recent National Council for Special Education, NCSE, pressure on our schools not to accept these pupils indicates. The circular states, "Category of special educational needs that is not in line with NCSE guidelines for the operation of special classes." That is a direct threat to our schools and the ethos, experience, superb teaching practices and dedication our schools have cultivated since the 1950s.

Second, our principals, staff and parents see in the circular as a clear attempt to initiate a drastic change in all special schools with the creation of a one-size-fits-all special school where the range of disability would cover all forms. We believe our schools would be used to rob Peter to pay Paul, with places going to children with much more complex needs. None of us will disagree with the need for proper provision for these children, but not at the expense of children with other needs and disabilities. This is neither just nor fair.

In my 40 years in special education, the increase in autism diagnoses is probably the most significant issue to affect special schools. Our schools have carried a huge proportion of this load, with up to 50% of our intake now having an autism diagnosis, coupled with the slow but steady increase in the number of students with pathological demand avoidance. There has been no proper definition of the term "complex needs" but it is taken to mean pupils with very challenging behaviour along with non-verbal difficulties, allied to learning difficulties in the moderate to severe range of learning disabilities. With the increase in pupils with such complex difficulties, a comprehensive plan needs to be formulated not just for their school years but also for after-school provision. This will take time but should not be done at the expense of pupils with a mild general learning disability. Pupils with complex needs need a suite of therapies on site along with purpose-built classrooms to cater for their needs.

Mild general learning disability schools have been in existence for many years and have served their students and families well. We are an integral part in the continuum of provision of suitable educational opportunities for those pupils with a mild or borderline mild general learning disability.

Our schools are the envy of many teachers from Europe and elsewhere in the world, who visit us regularly and comment that their educational systems need our approach. Our work gives a much more educational and human meaning to the term "inclusion", which is often bandied about. The right of every student to attend a school of their choosing applies as equally to our students as to the boy or girl who seeks the primary or secondary school of their choice. Were our schools to be forced to change their designation, the immediate problem of the lack of places for pupils with complex needs would be replaced by the greater problem of increased school drop-out and expulsions. That a disability is not initially apparent does not mean it does not exist. The success of mild intellectual disability special schools in helping our students to access education should not be used as a reason to say our pupils would survive in mainstream schools with supports. For them, this has already been tried and has failed.

Our schools are not just places of learning; they are the homes and communities that most would not otherwise have. The term "complex" can be applied as easily to our students as it can to those with extreme behavioural needs. The demand for our schools is greater than ever, with over half having increased enrolments in recent years, while others are at full capacity given the restrictions of their sites. We simply ask that we be allowed to continue the good work we have been doing for those pupils whose disability is not as evident as that of others but nevertheless every bit as real.