Special education systems in the US and UK use different terminology to describe similar concepts, which can confuse educators working with transatlantic resources. This guide translates core special education terms, helping you navigate both systems confidently. Whether you're a UK teacher encountering US frameworks or a US educator exploring UK SEND practices, this glossary bridges the language gap.
Educational professionals increasingly work across borders. A UK teacher might reference US research on RTI; a US school might adopt UK-style provision mapping. Without understanding the terminology bridge, confusion arises about legal obligations, intervention intensity, and role expectations. This guide ensures you're using equivalent terms accurately, so comparisons remain valid and partnerships function smoothly.
The two systems reflect different philosophies. US special education is rights-based and litigious (influenced by IDEA's due process protections), whilst UK SEND emphasises graduated whole-school support and local authority planning. Understanding these underpinnings helps you see why terminology differs.
| Aspect | US System | UK SEND System |
|---|---|---|
| Core Law | IDEA 2004 and Section 504 of the Rehabilitation Act 1973 | SEND Code of Practice and Children and Families Act 2014 |
| Primary Document | Individualised Education Program (IEP) | Education, Health and Care Plan (EHCP) |
| Less Formal Support | 504 Plan (covers accommodations only) | SEND Support (graduated approach; provision map) |
| Age Range Covered | Ages 3-21 (IDEA); some services until 22 | Ages 0-25 (part of SEND Code of Practice) |
| Who Holds Authority | School district; federal oversight | School (SEND Support); local authority (EHCP) |
| Dispute Resolution | Due process hearing; mediation | SEND Tribunal; mediation |
The table below provides comprehensive term-by-term translation. Use it as a quick reference when you encounter unfamiliar terminology or need to explain UK concepts to US colleagues and vice versa.
| US Term | UK Equivalent | Notes |
|---|---|---|
| 504 Plan | Reasonable Adjustments / Access Arrangements | Both allow equal access without altering curriculum. UK term covers exams explicitly. See 504 accommodations guide for US context. |
| Accommodation | Reasonable Adjustment / Access Arrangement | Changes to how learning is delivered without changing what is taught. Examples: extra time, scribe, coloured overlays. See accommodations versus modifications for detailed comparison. |
| Modification | Differentiated Curriculum / Alternative Curriculum | Changes to what is taught; the curriculum content itself is altered. UK term reflects broader differentiation approach. |
| IDEA (Individuals with Disabilities Education Act) | SEND Code of Practice; Children and Families Act 2014 | IDEA is federal law guaranteeing FAPE. UK Code is statutory guidance; the Act provides the legal framework. Different enforcement mechanisms. |
| FAPE (Free Appropriate Public Education) | SEND Provision Duty | Both require schools to provide necessary support. FAPE is explicitly defined in IDEA; UK duty is in Part 3 of the Children and Families Act 2014. |
| IEP (Individualised Education Program) | EHCP (Education, Health and Care Plan) OR IEP | US IEP is school-based. UK EHCP is local authority-issued for high-need pupils. Some UK schools use "IEP" for SEND Support level (informal). |
| LRE (Least Restrictive Environment) | Inclusive Education / Mainstream Provision | Both require inclusion in general education where possible. UK law presumes mainstream education unless mainstream cannot meet needs. See SEND Hub for UK context. |
| RTI (Response to Intervention) | Graduated Approach (Assess, Plan, Do, Review) | Both use tiered intervention. US RTI often emphasises Tier 1 (universal), Tier 2 (targeted group), Tier 3 (individual). UK graduated approach is more flexible. See RTI guide and Quality First Teaching. |
| MTSS (Multi-Tiered Systems of Support) | Whole-School SEND Approach / Whole-School Graduated Support | Both integrate academic and behavioural support systems. MTSS is more formally structured in US; UK approaches vary by school. |
| PBIS (Positive Behavioural Interventions and Supports) | Positive Behaviour Support / SEMH Strategies | Both emphasise preventive, evidence-based behaviour management. See PBIS guide for detailed framework. |
| IEP Team | EHCP Annual Review Team / SEND Support Review Group | Both include parents, teachers, specialists. US team meets annually; UK EHCP reviews are also annual. SEND Support reviews are less formal and school-based. |
| Special Education Teacher | SENCO / Special Educational Needs Teacher | US teacher holds SPED certification; UK SENCO is a specific leadership role (often SEND-qualified teacher). See SENCO role guide. |
| Paraprofessional / Aide | Teaching Assistant (TA) / Learning Support Assistant (LSA) | Both support teachers and pupils in classrooms. US aides require specific certification in some states; UK TAs have varying qualifications. |
| School Psychologist | Educational Psychologist (EP) | Both conduct assessments and advise on interventions. US psychologists may work directly with schools; UK EPs are employed by local authorities or private services. |
| Related Services | Additional Support Services / Therapeutic Provision | Both include speech therapy, physiotherapy, occupational therapy. US IDEA mandates these; UK provision depends on EHCP or commissioning. |
| BIP (Behaviour Intervention Plan) | Behaviour Support Plan / Individual Behaviour Plan (IBP) | Both target specific challenging behaviours with interventions. US BIPs often follow FBA; UK plans may be less formally structured. |
| FBA (Functional Behaviour Assessment) | Functional Analysis / ABC Analysis (Antecedent, Behaviour, Consequence) | Both identify why a behaviour occurs. IDEA requires FBA before disciplinary action; UK schools use these informally more often. |
| Transition Planning | Preparing for Adulthood (PfA) / Transition Planning | Both prepare pupils for post-secondary life. IDEA requires IEP transition goals by age 16; UK EHCP has PfA outcomes from age 14. |
| SDI (Specially Designed Instruction) | Quality First Teaching with Targeted Intervention | US term for curriculum modified to meet IEP goals. UK emphasis on universal excellent teaching plus targeted support. See Quality First Teaching guide. |
| Progress Monitoring | Progress Review / Assess-Plan-Do-Review Cycle | Both track pupil progress against targets. US monitoring is frequent (weekly/monthly); UK reviews typically termly or annual. |
| Due Process | SEND Tribunal / Mediation | Both allow parents to challenge decisions. US due process includes hearings before independent officers; UK Tribunal is a formal court-like body. |
| ESY (Extended School Year) | Holiday Provision / Summer Catch-Up Programmes | US ESY prevents regression over long breaks. UK schools offer holiday programmes but not universally mandated; typically for pupils with EHCP. |
| Assistive Technology (AT) | Assistive Technology | Same term, different funding. IDEA covers AT devices on IEP; UK schools fund via school budget or occasionally via local authority specialist services. |
| Gifted and Talented (G&T) | More Able / High Attainers / Able Learners | Both identify high-achieving pupils. US G&T is often a separate programme; UK approach is typically differentiation within classroom. |
| ELL / ESL (English Language Learner / English as Second Language) | EAL (English as an Additional Language) | All terms describe pupils learning English in school. ELL is current US term; ESL is older. EAL is standard UK terminology. |
| Manifestation Determination | No direct equivalent | IDEA requires schools to determine if misbehaviour is linked to disability before exclusion. UK schools use FBA informally; no statutory requirement for this formal determination. |
| Section 504 Coordinator | No direct equivalent | US schools designate staff to oversee 504 Plans. UK schools have SENCOs but no formal 504 coordinator role (reasonable adjustments are school-wide responsibility). |
| Child Find | Early Identification / Early Help | IDEA requires US schools to actively identify pupils with disabilities. UK law presumes schools identify need; no formal universal screening mandate like Child Find. |
| Annual Review | Annual Review | Both terms used, but different processes. US annual IEP reviews are school meetings; UK annual reviews for EHCP are formal multi-agency meetings led by the local authority. |
| Inclusion | Inclusion / Inclusive Education | Same term broadly means educating pupils with SEND in mainstream settings alongside peers. Both systems aim for this, with varying degrees of success. |
| Scaffolding | Scaffolding | Same term, rooted in Vygotsky's Zone of Proximal Development. Both systems use this instructional strategy widely. See scaffolding guide. |
How do schools identify pupils with SEND? The processes differ markedly. The US relies on comprehensive multi-disciplinary evaluation (MDE) using standardised testing to determine IDEA eligibility. Schools must assess cognitive, academic, behavioural, and social-emotional functioning. A child must have a disability (one of 13 IDEA categories) AND require special education services to qualify.
In the UK, there is no single "assessment" that determines SEND status. Instead, schools use continuous observation, baseline checks, and specialist assessments (if needed) to identify SEND Support needs. A child has SEND if they require provision "additional to and different from" the norm. For an EHCP, evidence is gathered through observation, teacher reports, specialist assessments, and parental input before a local authority decides if an EHCP is necessary.
The US model is more legalistic: evaluation is triggered by parent or teacher request, must follow strict timelines (120 days), and results determine legal eligibility. The UK model is more fluid: SENCOs monitor all pupils continuously, conversations with parents are ongoing, and support is stepped up gradually without a formal "diagnosis" gate.
Both systems expect early intervention. The US provides services under IDEA from age 3 (or birth under Part C for infants). The UK SEND Code of Practice covers ages 0-25. However, US services are legally mandated once identified; UK provision depends partly on school budgets and specialist commissioning.
Once a pupil is identified, what support looks like differs. In the US, an IEP specifies present levels of performance, annual goals (measurable), services to be provided, accommodations, and modifications. The school is legally bound to deliver these services and progress-monitor weekly or monthly. Services are detailed: speech therapy is scheduled Tuesdays 2pm for 30 minutes; resource room instruction is Mondays, Wednesdays, Fridays for maths.
In the UK at SEND Support level, schools use provision mapping: a visual overview of what support each pupil receives. An EHCP is similar in spirit to an IEP, with outcomes and provision listed, but it is legally binding only on the local authority (not the school). Schools can and do update support without formal plan revision more flexibly than in the US.
The US system emphasises measurable annual goals written in SMART format (Specific, Measurable, Achievable, Relevant, Time-bound). Progress toward IEP goals is reported to parents at least as often as for non-disabled peers, but typically more frequently. UK systems use differentiation and targeted interventions (like small-group phonics), without always writing formal annual goals on a SEND Support plan.
Interventions in the US are often intensity-focused: a pupil receives 1-to-1 support, resource room instruction, or special day school placement. UK intervention is typically mainstream provision plus in-class support, scaffolding, and specialist visits (e.g., from a visiting SEND teacher or Educational Psychologist). Specialist schools exist in the UK but are less common than resource-heavy US placements.
Who leads SEND work? In US schools, the special education teacher and school psychologist hold primary responsibility. The special education teacher holds SPED certification (requirements vary by state) and delivers instruction, often in a resource room or pull-out setting. The school psychologist conducts evaluations and recommends interventions.
In UK schools, the SENCO leads SEND work. SENCOs are typically senior staff with SEND-specific training (though not always a formal qualification). They coordinate support, liaise with external agencies, and drive school SEND strategy. Classroom teachers remain responsible for all pupils' learning, including those with SEND, with SENCO support.
For formal plans, US schools convene the IEP Team: special ed teacher, general ed teacher, special ed administrator, school psychologist, parent, and pupil (if age-appropriate). Meetings are annual but can be called more often. In the UK, an EHCP annual review includes the school, parents, child (if age-appropriate), local authority officer, and external professionals. The annual review is the formal touchpoint; between reviews, schools adjust support more flexibly.
Disputes are handled differently. US parents unhappy with an IEP can request due process (a formal hearing before an impartial officer) or mediation. UK parents unhappy with SEND provision can appeal to the SEND Tribunal (a court-like body) or use mediation. Both systems allow lawyers and formal representation, though rates differ.
The US system is built on IDEA 2004 and Section 504 of the Rehabilitation Act 1973. IDEA is federal law that guarantees all children with disabilities have access to FAPE (Free Appropriate Public Education) in the least restrictive environment (LRE). Section 504 is a civil rights statute that protects anyone with a disability (broader than IDEA) and requires reasonable accommodations to ensure equal access. A child may be on a 504 Plan without an IEP if they do not require special education services but do need accommodations (e.g., extended test time for a pupil with ADHD who does not qualify for IDEA).
The UK system is built on the Children and Families Act 2014 and the SEND Code of Practice (statutory guidance). The Act establishes the legal framework; the Code explains how it should be implemented. UK law presumes mainstream education and requires schools and local authorities to support pupils with SEND, but there is no equivalent to FAPE. Schools must provide appropriate support, but what counts as "appropriate" is less legally defined than in the US.
IDEA defines 13 disability categories: autism, deaf-blindness, deafness, emotional disturbance, hearing impairment, intellectual disability, multiple disabilities, orthopedic impairment, other health impairment, specific learning disability, speech or language impairment, traumatic brain injury, and visual impairment. A pupil must fit a category AND need special education to qualify. The UK has no such categories; a pupil has SEND if they require support "additional to and different from" standard provision, regardless of label.
Both systems allow parents to challenge decisions. The US due process system is formal and litigious; parents can hire lawyers, subpoena records, and win compensatory education awards. The UK SEND Tribunal is also formal but rarely involves compensation; it focuses on whether the local authority's decision about EHCP provision was correct.
Tip 1: When reading US resources (RTI, PBIS, SDI, etc.), map to UK equivalents. US research on Response to Intervention is directly applicable to UK schools, but translate RTI's three-tier structure into the Graduated Approach: universal good teaching (Tier 1 / Quality First Teaching), targeted group intervention (Tier 2 / SEND Support), and individual specialist support (Tier 3 / EHCP or specialist placement). See the RTI guide and Quality First Teaching article to understand this bridge.
Tip 2: Understand that "accommodations" and "modifications" are distinct US concepts. US schools distinguish: accommodations change HOW a pupil accesses the curriculum (extra time, scribe) without changing WHAT they learn. Modifications change the curriculum itself (simpler texts, fewer problems). The UK uses "reasonable adjustments" (similar to accommodations) and "differentiated curriculum" (similar to modifications). Do not assume the two terms map 1-to-1. See accommodations versus modifications for examples.
Tip 3: Remember that a 504 Plan is not equivalent to an EHCP. A 504 Plan covers accommodations only and is school-based. An EHCP is local authority-issued and covers education, health, and care across settings. A child on a 504 might attend mainstream classes with accommodations; a child with an EHCP might attend mainstream, attend specialist classes part-time, or attend a specialist school. See 504 accommodations guide for US context and the SEND Hub for UK equivalents.
Tip 4: When hearing about IEPs, ask: which system? US IEPs are school-based, annual, and legally binding. Some UK schools use "IEP" informally for SEND Support pupils, but this is not standard; the formal equivalent is an EHCP (for high-need pupils) or a school-based provision map. Ask colleagues which system they mean to avoid confusion.
Tip 5: US behaviour language focuses on function; UK language focuses on support. US schools use FBA (Functional Behaviour Assessment) to ask "What is the behaviour doing for the child?" This leads to BIPs (Behaviour Intervention Plans) targeting the function. UK schools ask "What support does the child need to behave differently?" This leads to behaviour support plans and positive behaviour strategies. Both are evidence-based, but the framing differs.
Tip 6: Know the difference between SEND support and a legal category in the US. In the US, you might hear "She's a special ed student" or "He's categorised as emotional disturbance." This legal categorisation carries rights and can trigger due process protections. In the UK, saying a pupil has SEND does not imply a diagnosis or legal category; it simply means they need additional support. This is culturally significant: UK SEND is less stigmatised because it is not category-based.
Technically, yes, but it is not standard practice. UK schools following an EHCP must align with local authority requirements and the SEND Code of Practice. At SEND Support level, schools can design their own documentation. Some UK schools have adopted US IEP templates if staff were trained in the US system, but this is rare. If you are moving from the US to the UK, expect to adapt your IEP format to match the EHCP structure or your school's provision map approach.
No. A diagnosis is evidence, but SEND status in the UK depends on need. A pupil diagnosed with ADHD might have adequate strategies in place and require no additional school support, in which case they would not be flagged as SEND. Conversely, a pupil with similar symptoms but no diagnosis might be SEND because they need targeted support. UK schools focus on impact and need, not diagnosis alone. Diagnoses help SENCOs understand likely difficulties and design support, but they do not automatically determine SEND status.
A 504 Plan is not legally recognised in UK schools. However, the accommodations listed are still relevant and should be implemented. Inform the new UK school of the 504 Plan details, and request a meeting with the SENCO to discuss reasonable adjustments. The school will likely document this via their own provision map or a school-based support plan. If the pupil has significant needs, the SENCO may recommend requesting an EHCP assessment through the local authority. See 504 accommodations guide for what accommodations typically look like in the US context.
Both use a tiered, problem-solving approach to intervention. US RTI typically has a strict three-tier structure: Tier 1 is universal good teaching with data-driven screening; Tier 2 is small-group intervention for at-risk pupils; Tier 3 is intensive individual support. The UK Graduated Approach is less rigid: schools start with universal good Quality First Teaching, then add targeted SEND Support, then pursue an EHCP if needed. RTI emphasises frequent progress-monitoring and data-based decision-making; the Graduated Approach emphasises observation, planning, and review cycles (often termly rather than weekly). Both work; the US system is more formalised and data-intense, whilst the UK system is more flexible. See the RTI guide for details on the US approach.
Yes, absolutely. An EHCP outlines a pupil's support, including behaviour support if needed. PBIS strategies (positive reinforcement, clear expectations, proactive teaching) are whole-school approaches that benefit all pupils, including those with EHCPs. Many UK schools are adopting PBIS principles as part of their behaviour management framework. An EHCP pupil with challenging behaviour would typically have both the EHCP's individual behaviour support plan and access to the school's whole-school PBIS system. The two are complementary, not competing.
Understanding US and UK SEND terminology is essential for educators working across borders or learning from transatlantic research. Whilst the systems differ in structure and law, both aim to provide appropriate support to pupils with SEND. Use this glossary as a reference when you encounter unfamiliar terms, and remember that context matters: a term may have a slightly different nuance depending on which system it originates from.
Start with the system overview table, then dive into the complete glossary. For deeper context on any topic, follow the internal links to our specialist articles on RTI, PBIS, accommodations versus modifications, and the UK SEND Hub. Whether you are a UK teacher exploring US evidence or a US educator discovering UK best practices, this bridge should help you navigate with confidence.
Special education systems in the US and UK use different terminology to describe similar concepts, which can confuse educators working with transatlantic resources. This guide translates core special education terms, helping you navigate both systems confidently. Whether you're a UK teacher encountering US frameworks or a US educator exploring UK SEND practices, this glossary bridges the language gap.
Educational professionals increasingly work across borders. A UK teacher might reference US research on RTI; a US school might adopt UK-style provision mapping. Without understanding the terminology bridge, confusion arises about legal obligations, intervention intensity, and role expectations. This guide ensures you're using equivalent terms accurately, so comparisons remain valid and partnerships function smoothly.
The two systems reflect different philosophies. US special education is rights-based and litigious (influenced by IDEA's due process protections), whilst UK SEND emphasises graduated whole-school support and local authority planning. Understanding these underpinnings helps you see why terminology differs.
| Aspect | US System | UK SEND System |
|---|---|---|
| Core Law | IDEA 2004 and Section 504 of the Rehabilitation Act 1973 | SEND Code of Practice and Children and Families Act 2014 |
| Primary Document | Individualised Education Program (IEP) | Education, Health and Care Plan (EHCP) |
| Less Formal Support | 504 Plan (covers accommodations only) | SEND Support (graduated approach; provision map) |
| Age Range Covered | Ages 3-21 (IDEA); some services until 22 | Ages 0-25 (part of SEND Code of Practice) |
| Who Holds Authority | School district; federal oversight | School (SEND Support); local authority (EHCP) |
| Dispute Resolution | Due process hearing; mediation | SEND Tribunal; mediation |
The table below provides comprehensive term-by-term translation. Use it as a quick reference when you encounter unfamiliar terminology or need to explain UK concepts to US colleagues and vice versa.
| US Term | UK Equivalent | Notes |
|---|---|---|
| 504 Plan | Reasonable Adjustments / Access Arrangements | Both allow equal access without altering curriculum. UK term covers exams explicitly. See 504 accommodations guide for US context. |
| Accommodation | Reasonable Adjustment / Access Arrangement | Changes to how learning is delivered without changing what is taught. Examples: extra time, scribe, coloured overlays. See accommodations versus modifications for detailed comparison. |
| Modification | Differentiated Curriculum / Alternative Curriculum | Changes to what is taught; the curriculum content itself is altered. UK term reflects broader differentiation approach. |
| IDEA (Individuals with Disabilities Education Act) | SEND Code of Practice; Children and Families Act 2014 | IDEA is federal law guaranteeing FAPE. UK Code is statutory guidance; the Act provides the legal framework. Different enforcement mechanisms. |
| FAPE (Free Appropriate Public Education) | SEND Provision Duty | Both require schools to provide necessary support. FAPE is explicitly defined in IDEA; UK duty is in Part 3 of the Children and Families Act 2014. |
| IEP (Individualised Education Program) | EHCP (Education, Health and Care Plan) OR IEP | US IEP is school-based. UK EHCP is local authority-issued for high-need pupils. Some UK schools use "IEP" for SEND Support level (informal). |
| LRE (Least Restrictive Environment) | Inclusive Education / Mainstream Provision | Both require inclusion in general education where possible. UK law presumes mainstream education unless mainstream cannot meet needs. See SEND Hub for UK context. |
| RTI (Response to Intervention) | Graduated Approach (Assess, Plan, Do, Review) | Both use tiered intervention. US RTI often emphasises Tier 1 (universal), Tier 2 (targeted group), Tier 3 (individual). UK graduated approach is more flexible. See RTI guide and Quality First Teaching. |
| MTSS (Multi-Tiered Systems of Support) | Whole-School SEND Approach / Whole-School Graduated Support | Both integrate academic and behavioural support systems. MTSS is more formally structured in US; UK approaches vary by school. |
| PBIS (Positive Behavioural Interventions and Supports) | Positive Behaviour Support / SEMH Strategies | Both emphasise preventive, evidence-based behaviour management. See PBIS guide for detailed framework. |
| IEP Team | EHCP Annual Review Team / SEND Support Review Group | Both include parents, teachers, specialists. US team meets annually; UK EHCP reviews are also annual. SEND Support reviews are less formal and school-based. |
| Special Education Teacher | SENCO / Special Educational Needs Teacher | US teacher holds SPED certification; UK SENCO is a specific leadership role (often SEND-qualified teacher). See SENCO role guide. |
| Paraprofessional / Aide | Teaching Assistant (TA) / Learning Support Assistant (LSA) | Both support teachers and pupils in classrooms. US aides require specific certification in some states; UK TAs have varying qualifications. |
| School Psychologist | Educational Psychologist (EP) | Both conduct assessments and advise on interventions. US psychologists may work directly with schools; UK EPs are employed by local authorities or private services. |
| Related Services | Additional Support Services / Therapeutic Provision | Both include speech therapy, physiotherapy, occupational therapy. US IDEA mandates these; UK provision depends on EHCP or commissioning. |
| BIP (Behaviour Intervention Plan) | Behaviour Support Plan / Individual Behaviour Plan (IBP) | Both target specific challenging behaviours with interventions. US BIPs often follow FBA; UK plans may be less formally structured. |
| FBA (Functional Behaviour Assessment) | Functional Analysis / ABC Analysis (Antecedent, Behaviour, Consequence) | Both identify why a behaviour occurs. IDEA requires FBA before disciplinary action; UK schools use these informally more often. |
| Transition Planning | Preparing for Adulthood (PfA) / Transition Planning | Both prepare pupils for post-secondary life. IDEA requires IEP transition goals by age 16; UK EHCP has PfA outcomes from age 14. |
| SDI (Specially Designed Instruction) | Quality First Teaching with Targeted Intervention | US term for curriculum modified to meet IEP goals. UK emphasis on universal excellent teaching plus targeted support. See Quality First Teaching guide. |
| Progress Monitoring | Progress Review / Assess-Plan-Do-Review Cycle | Both track pupil progress against targets. US monitoring is frequent (weekly/monthly); UK reviews typically termly or annual. |
| Due Process | SEND Tribunal / Mediation | Both allow parents to challenge decisions. US due process includes hearings before independent officers; UK Tribunal is a formal court-like body. |
| ESY (Extended School Year) | Holiday Provision / Summer Catch-Up Programmes | US ESY prevents regression over long breaks. UK schools offer holiday programmes but not universally mandated; typically for pupils with EHCP. |
| Assistive Technology (AT) | Assistive Technology | Same term, different funding. IDEA covers AT devices on IEP; UK schools fund via school budget or occasionally via local authority specialist services. |
| Gifted and Talented (G&T) | More Able / High Attainers / Able Learners | Both identify high-achieving pupils. US G&T is often a separate programme; UK approach is typically differentiation within classroom. |
| ELL / ESL (English Language Learner / English as Second Language) | EAL (English as an Additional Language) | All terms describe pupils learning English in school. ELL is current US term; ESL is older. EAL is standard UK terminology. |
| Manifestation Determination | No direct equivalent | IDEA requires schools to determine if misbehaviour is linked to disability before exclusion. UK schools use FBA informally; no statutory requirement for this formal determination. |
| Section 504 Coordinator | No direct equivalent | US schools designate staff to oversee 504 Plans. UK schools have SENCOs but no formal 504 coordinator role (reasonable adjustments are school-wide responsibility). |
| Child Find | Early Identification / Early Help | IDEA requires US schools to actively identify pupils with disabilities. UK law presumes schools identify need; no formal universal screening mandate like Child Find. |
| Annual Review | Annual Review | Both terms used, but different processes. US annual IEP reviews are school meetings; UK annual reviews for EHCP are formal multi-agency meetings led by the local authority. |
| Inclusion | Inclusion / Inclusive Education | Same term broadly means educating pupils with SEND in mainstream settings alongside peers. Both systems aim for this, with varying degrees of success. |
| Scaffolding | Scaffolding | Same term, rooted in Vygotsky's Zone of Proximal Development. Both systems use this instructional strategy widely. See scaffolding guide. |
How do schools identify pupils with SEND? The processes differ markedly. The US relies on comprehensive multi-disciplinary evaluation (MDE) using standardised testing to determine IDEA eligibility. Schools must assess cognitive, academic, behavioural, and social-emotional functioning. A child must have a disability (one of 13 IDEA categories) AND require special education services to qualify.
In the UK, there is no single "assessment" that determines SEND status. Instead, schools use continuous observation, baseline checks, and specialist assessments (if needed) to identify SEND Support needs. A child has SEND if they require provision "additional to and different from" the norm. For an EHCP, evidence is gathered through observation, teacher reports, specialist assessments, and parental input before a local authority decides if an EHCP is necessary.
The US model is more legalistic: evaluation is triggered by parent or teacher request, must follow strict timelines (120 days), and results determine legal eligibility. The UK model is more fluid: SENCOs monitor all pupils continuously, conversations with parents are ongoing, and support is stepped up gradually without a formal "diagnosis" gate.
Both systems expect early intervention. The US provides services under IDEA from age 3 (or birth under Part C for infants). The UK SEND Code of Practice covers ages 0-25. However, US services are legally mandated once identified; UK provision depends partly on school budgets and specialist commissioning.
Once a pupil is identified, what support looks like differs. In the US, an IEP specifies present levels of performance, annual goals (measurable), services to be provided, accommodations, and modifications. The school is legally bound to deliver these services and progress-monitor weekly or monthly. Services are detailed: speech therapy is scheduled Tuesdays 2pm for 30 minutes; resource room instruction is Mondays, Wednesdays, Fridays for maths.
In the UK at SEND Support level, schools use provision mapping: a visual overview of what support each pupil receives. An EHCP is similar in spirit to an IEP, with outcomes and provision listed, but it is legally binding only on the local authority (not the school). Schools can and do update support without formal plan revision more flexibly than in the US.
The US system emphasises measurable annual goals written in SMART format (Specific, Measurable, Achievable, Relevant, Time-bound). Progress toward IEP goals is reported to parents at least as often as for non-disabled peers, but typically more frequently. UK systems use differentiation and targeted interventions (like small-group phonics), without always writing formal annual goals on a SEND Support plan.
Interventions in the US are often intensity-focused: a pupil receives 1-to-1 support, resource room instruction, or special day school placement. UK intervention is typically mainstream provision plus in-class support, scaffolding, and specialist visits (e.g., from a visiting SEND teacher or Educational Psychologist). Specialist schools exist in the UK but are less common than resource-heavy US placements.
Who leads SEND work? In US schools, the special education teacher and school psychologist hold primary responsibility. The special education teacher holds SPED certification (requirements vary by state) and delivers instruction, often in a resource room or pull-out setting. The school psychologist conducts evaluations and recommends interventions.
In UK schools, the SENCO leads SEND work. SENCOs are typically senior staff with SEND-specific training (though not always a formal qualification). They coordinate support, liaise with external agencies, and drive school SEND strategy. Classroom teachers remain responsible for all pupils' learning, including those with SEND, with SENCO support.
For formal plans, US schools convene the IEP Team: special ed teacher, general ed teacher, special ed administrator, school psychologist, parent, and pupil (if age-appropriate). Meetings are annual but can be called more often. In the UK, an EHCP annual review includes the school, parents, child (if age-appropriate), local authority officer, and external professionals. The annual review is the formal touchpoint; between reviews, schools adjust support more flexibly.
Disputes are handled differently. US parents unhappy with an IEP can request due process (a formal hearing before an impartial officer) or mediation. UK parents unhappy with SEND provision can appeal to the SEND Tribunal (a court-like body) or use mediation. Both systems allow lawyers and formal representation, though rates differ.
The US system is built on IDEA 2004 and Section 504 of the Rehabilitation Act 1973. IDEA is federal law that guarantees all children with disabilities have access to FAPE (Free Appropriate Public Education) in the least restrictive environment (LRE). Section 504 is a civil rights statute that protects anyone with a disability (broader than IDEA) and requires reasonable accommodations to ensure equal access. A child may be on a 504 Plan without an IEP if they do not require special education services but do need accommodations (e.g., extended test time for a pupil with ADHD who does not qualify for IDEA).
The UK system is built on the Children and Families Act 2014 and the SEND Code of Practice (statutory guidance). The Act establishes the legal framework; the Code explains how it should be implemented. UK law presumes mainstream education and requires schools and local authorities to support pupils with SEND, but there is no equivalent to FAPE. Schools must provide appropriate support, but what counts as "appropriate" is less legally defined than in the US.
IDEA defines 13 disability categories: autism, deaf-blindness, deafness, emotional disturbance, hearing impairment, intellectual disability, multiple disabilities, orthopedic impairment, other health impairment, specific learning disability, speech or language impairment, traumatic brain injury, and visual impairment. A pupil must fit a category AND need special education to qualify. The UK has no such categories; a pupil has SEND if they require support "additional to and different from" standard provision, regardless of label.
Both systems allow parents to challenge decisions. The US due process system is formal and litigious; parents can hire lawyers, subpoena records, and win compensatory education awards. The UK SEND Tribunal is also formal but rarely involves compensation; it focuses on whether the local authority's decision about EHCP provision was correct.
Tip 1: When reading US resources (RTI, PBIS, SDI, etc.), map to UK equivalents. US research on Response to Intervention is directly applicable to UK schools, but translate RTI's three-tier structure into the Graduated Approach: universal good teaching (Tier 1 / Quality First Teaching), targeted group intervention (Tier 2 / SEND Support), and individual specialist support (Tier 3 / EHCP or specialist placement). See the RTI guide and Quality First Teaching article to understand this bridge.
Tip 2: Understand that "accommodations" and "modifications" are distinct US concepts. US schools distinguish: accommodations change HOW a pupil accesses the curriculum (extra time, scribe) without changing WHAT they learn. Modifications change the curriculum itself (simpler texts, fewer problems). The UK uses "reasonable adjustments" (similar to accommodations) and "differentiated curriculum" (similar to modifications). Do not assume the two terms map 1-to-1. See accommodations versus modifications for examples.
Tip 3: Remember that a 504 Plan is not equivalent to an EHCP. A 504 Plan covers accommodations only and is school-based. An EHCP is local authority-issued and covers education, health, and care across settings. A child on a 504 might attend mainstream classes with accommodations; a child with an EHCP might attend mainstream, attend specialist classes part-time, or attend a specialist school. See 504 accommodations guide for US context and the SEND Hub for UK equivalents.
Tip 4: When hearing about IEPs, ask: which system? US IEPs are school-based, annual, and legally binding. Some UK schools use "IEP" informally for SEND Support pupils, but this is not standard; the formal equivalent is an EHCP (for high-need pupils) or a school-based provision map. Ask colleagues which system they mean to avoid confusion.
Tip 5: US behaviour language focuses on function; UK language focuses on support. US schools use FBA (Functional Behaviour Assessment) to ask "What is the behaviour doing for the child?" This leads to BIPs (Behaviour Intervention Plans) targeting the function. UK schools ask "What support does the child need to behave differently?" This leads to behaviour support plans and positive behaviour strategies. Both are evidence-based, but the framing differs.
Tip 6: Know the difference between SEND support and a legal category in the US. In the US, you might hear "She's a special ed student" or "He's categorised as emotional disturbance." This legal categorisation carries rights and can trigger due process protections. In the UK, saying a pupil has SEND does not imply a diagnosis or legal category; it simply means they need additional support. This is culturally significant: UK SEND is less stigmatised because it is not category-based.
Technically, yes, but it is not standard practice. UK schools following an EHCP must align with local authority requirements and the SEND Code of Practice. At SEND Support level, schools can design their own documentation. Some UK schools have adopted US IEP templates if staff were trained in the US system, but this is rare. If you are moving from the US to the UK, expect to adapt your IEP format to match the EHCP structure or your school's provision map approach.
No. A diagnosis is evidence, but SEND status in the UK depends on need. A pupil diagnosed with ADHD might have adequate strategies in place and require no additional school support, in which case they would not be flagged as SEND. Conversely, a pupil with similar symptoms but no diagnosis might be SEND because they need targeted support. UK schools focus on impact and need, not diagnosis alone. Diagnoses help SENCOs understand likely difficulties and design support, but they do not automatically determine SEND status.
A 504 Plan is not legally recognised in UK schools. However, the accommodations listed are still relevant and should be implemented. Inform the new UK school of the 504 Plan details, and request a meeting with the SENCO to discuss reasonable adjustments. The school will likely document this via their own provision map or a school-based support plan. If the pupil has significant needs, the SENCO may recommend requesting an EHCP assessment through the local authority. See 504 accommodations guide for what accommodations typically look like in the US context.
Both use a tiered, problem-solving approach to intervention. US RTI typically has a strict three-tier structure: Tier 1 is universal good teaching with data-driven screening; Tier 2 is small-group intervention for at-risk pupils; Tier 3 is intensive individual support. The UK Graduated Approach is less rigid: schools start with universal good Quality First Teaching, then add targeted SEND Support, then pursue an EHCP if needed. RTI emphasises frequent progress-monitoring and data-based decision-making; the Graduated Approach emphasises observation, planning, and review cycles (often termly rather than weekly). Both work; the US system is more formalised and data-intense, whilst the UK system is more flexible. See the RTI guide for details on the US approach.
Yes, absolutely. An EHCP outlines a pupil's support, including behaviour support if needed. PBIS strategies (positive reinforcement, clear expectations, proactive teaching) are whole-school approaches that benefit all pupils, including those with EHCPs. Many UK schools are adopting PBIS principles as part of their behaviour management framework. An EHCP pupil with challenging behaviour would typically have both the EHCP's individual behaviour support plan and access to the school's whole-school PBIS system. The two are complementary, not competing.
Understanding US and UK SEND terminology is essential for educators working across borders or learning from transatlantic research. Whilst the systems differ in structure and law, both aim to provide appropriate support to pupils with SEND. Use this glossary as a reference when you encounter unfamiliar terms, and remember that context matters: a term may have a slightly different nuance depending on which system it originates from.
Start with the system overview table, then dive into the complete glossary. For deeper context on any topic, follow the internal links to our specialist articles on RTI, PBIS, accommodations versus modifications, and the UK SEND Hub. Whether you are a UK teacher exploring US evidence or a US educator discovering UK best practices, this bridge should help you navigate with confidence.
