Troubling draft guidance ~ School Medical & Nursing Services
The English Government is currently consulting on draft updated statutory guidance on Supporting Pupils with Medical Conditions in Schools. It is a daunting (122 page) draft; it is troubling and sadly the deadline for responding is 1st May 2026 (although it appears that this may now be extended for a further two weeks). It is a serious concern that this consultation is being overlooked at a time when all the attention appears to be on the proposed SEND Reforms
A number of parents and key organisations have expressed grave concern about the ‘direction of travel’ that the draft guidance represents. To access the draft, click here and to access the survey click here.
Dr Ana Laura Aeiello and I have published research concerning the dreadful impact on disabled children resulting from the continuing failure of NHS bodies to commission suitable (or in some cases ‘any’) paediatric continence services: this is not an education / schools responsibility, it is a core function of the NHS.
Sadly, the proposed guidance risks further blurring (fundamentally) the boundary between education and healthcare in ways that undermine pupils’ rights and create unsafe and unclear arrangements in practice.
A joint union position statement prepared by Unison with a number of other key national organisations can be accessed by clicking here. This calls for a ‘needs‑led, NHS‑commissioned clinical school nursing service embedded in all state‑funded education settings, with any delegated clinical tasks undertaken by NHS‑employed staff (for example, healthcare assistants), operating alongside local authority‑commissioned public health nursing services’.
Joanna Parry, National Officer, Education and Children’s Services at UNISON has summarised her Union’s particular concerns as follows:
-
- The guidance does not clearly articulate the statutory role and responsibility of the NHS in meeting children’s healthcare needs in school settings, instead framing “health” in terms of individual professionals rather than NHS bodies with legal duties.
- Healthcare activities are effectively being reframed as school “support”, despite assurances that delegated healthcare tasks are outside scope. Expectations around administering prescription medication and other health interventions appear to place responsibility on schools by default.
- The proposed approach to individual healthcare plans risks shifting clinical responsibility onto schools, by requiring them to own and maintain documents that incorporate diagnoses, medication regimes and monitoring, despite being framed as “non-clinical” documents. The long-term plan to incorporate these plans into Individual Support Plans under the proposed SEND reforms concerns us because this would legally formalise a system which cuts out NHS responsibility for clinical care.
-
- Overall, there is insufficient clarity on accountability, creating a real risk that schools are left filling gaps in healthcare provision without appropriate NHS commissioning and oversight.
We are particularly concerned that this guidance is being progressed ahead of promised joint DfE/DHSC/NHS England non‑statutory guidance on how clinical healthcare activity should be delivered in schools, which risks entrenching confusion before those fundamental issues are resolved.
Unison, the GMB and Unite union strongly advise all those who are able, to lobby their MPs and to respond to the survey. For a note briefing note on responding to your MP, click here and for a template email click here:
Posted 24 April 2026