However, when making such changes it is essential to ensure that there are no unintended consequences. This requires careful consideration and testing against the experience of a number of those who have to use the guidance in various roles. This consultation is therefore welcome, but its short timescale, especially as it coincides with the Easter vacation, has not allowed for such careful testing. The Department for Education (DfE) has more than once been criticized by Parliamentary committees for not allowing sufficient time for consultations and for conducting them during holiday periods. There has clearly been another failure of planning in this case.

That being said, the proposed changes do appear to provide greater clarity and to clear up some of the faults of the previous guidance document.

Read the full response here.