Section F and Section B of an EHCP: why these two parts matter most

The draft EHCP arrived as a PDF on Tuesday. You scrolled through it three times trying to feel pleased and instead felt a slow, sinking sense that something was wrong. The needs section is detailed. The provision section sounds reasonable. Yet when you compare them, the bits that should match don't. The SENDCO has told you it's “a good first draft.”

What you are actually looking at is the two most important sections of the plan, and how they hold each other accountable. Here is what each does, what they should look like, and how to read whether the plan you have been sent will actually work.

An EHCP is a structured document. Knowing the architecture is how you read it. A statutory EHCP has eleven sections, labelled A to K.

B is the “what does my child need” section. F is the “what will be put in place” section. Most appeals to the SEND Tribunal are about one or both of these, plus Section I (the school).

Section B is the foundation. Every other section refers back to it. If B is incomplete, F cannot be complete.

B should describe your child's special educational needs across four areas of need set out in the SEND Code of Practice 2015:

1. Communication and interaction. Speech, language, social communication, autism-related needs.
2. Cognition and learning. General learning needs, specific learning differences (dyslexia, dyscalculia), slower processing.
3. Social, emotional and mental health (SEMH). Anxiety, depression, attachment, ADHD, behaviour-related needs.
4. Sensory and/or physical. Hearing, vision, sensory processing, hypermobility, mobility.

Within each area, B should list specific needs identified by the professionals who assessed your child. Each need should be described specifically enough that someone reading the plan in five years' time who has never met your child would understand what they need help with.

F is the legally enforceable bit. The local authority has a duty under section 42 of the Children and Families Act 2014 to secure exactly what is set out in F.

F should describe, for each need identified in B, the provision that will be put in place. Specifically:

• What the provision is (speech therapy sessions, 1:1 teaching assistant time, specific intervention programmes, sensory equipment).
• How much of it (hours per week, minutes per session, number of sessions per term).
• How often (weekly, daily, fortnightly).
• By whom (a qualified SaLT, a teaching assistant trained in [specific approach], a specialist teacher).
• In what setting (1:1, small group, in class, withdrawn).

The simplest and most useful audit you can do on a draft EHCP is the B-to-F audit. Print Section B and Section F side by side. For each need in B, ask: is there a specific, quantified piece of provision in F that addresses this need? If yes, draw a line between them. If no, that's a gap.

The bad version of the same draft would have Section B listing all four needs and Section F saying something like: “The class teacher will differentiate work as appropriate. The SENDCO will monitor progress. Access to sensory equipment will be available.” That F is not quantified, not specific, and not enforceable. The plan can be technically present and practically empty.

Three tests. A provision is specific and quantified if all three give a clear answer.

1. How much, by amount? Hours per week, minutes per day, number of sessions. “5 hours per week.” Not “regular sessions.”
2. How often, by frequency? Daily, twice weekly, every fortnight. “Daily.” Not “as required.”
3. By whom, by role? Specific qualification named. “An HCPC-registered SaLT.” Not “a member of staff.”

If the LA pushes back that quantified provision is unrealistic, the legal answer is clear: the statutory test is what the child needs, not what the LA wants to spend. The Code of Practice and the case law are unambiguous on this.

Specific phrases to delete on sight in any draft Section F. They are exactly as common as they are damaging.

• “Access to…” Access is not provision. Access means the thing exists somewhere in the school; not that your child gets it.
• “Opportunities for…” Same problem. Opportunity is not guaranteed delivery.
• “As appropriate” / “as needed” / “where appropriate” All of these put the decision in the hands of whoever decides what is appropriate on the day. Not enforceable.
• “Where possible” / “wherever possible” Same. Discretion-heavy phrasing.
• “Will be considered” Means nothing.
• “Differentiated curriculum” Used as a catch-all where specific provision is needed. Ask what is differentiated and by how much.
• “Regular support” Not quantified.
• “Will have the opportunity to access…” A double weasel; both “opportunity” and “access” doing weasel work.
• “A range of strategies” Without naming them, not provision.

When you find these phrases in a draft, IPSEA's standard approach is to redraft the sentence with the specific, quantified version and submit your redraft to the LA. Most LAs accept significant chunks of redraft at draft-plan stage rather than face a tribunal.

The kitchen table, 10pmDraft plan stage

A practical pass-through to use on any draft.

1. Does every need in Section B have a matched provision in Section F?
2. Is every provision in F specific (what, how, by whom)?
3. Is every provision in F quantified (hours per week, sessions per term)?
4. Are weasel words (access to, opportunities for, as appropriate, where possible) absent?
5. Are professional qualifications named where relevant (for example, HCPC-registered SaLT, qualified ELSA, specialist teacher of dyslexia)?
6. Where therapy is named (SaLT, OT), does it specify direct therapy hours as against supervision of TA-delivered programmes?
7. Is the setting named (1:1, small group, in-class, withdrawn)?
8. Does F match the recommendations in the underlying specialist reports (the Section K appendices)? Where a specialist report recommends X hours and F says half X, that's a flag.

You have multiple opportunities to push back. Use them in order.

1. At draft plan stage. You have 15 days from receiving the draft to comment. Submit a redraft of F (and B), with specific quantified provision, in writing. This is the easiest moment to fix things.
2. At final plan stage. If the final plan still has vague F, you can appeal contents to the SEND Tribunal. See our piece on EHCP refused or appealing for the route.
3. At annual review. You can ask for amendments to F. If the LA refuses, that refusal is appealable.
4. If the plan is in place but the LA is not delivering Section F: the LA has an absolute duty under CFA 2014 s.42 to secure F. Enforcement routes include written formal complaint, complaint to the Local Government & Social Care Ombudsman, and (in some cases) judicial review. IPSEA holds detailed enforcement guidance. (IPSEA, enforcing Section F. See References.)

Three things.

IPSEA's guidance is free and its helpline is 0300 030 0080. If you want a second pair of eyes first, a Remarkable Minds SEND specialist will sit with you and go through Sections B and F, highlight the gaps and the weasel words, and help you draft specific redraft language. For formal legal advice IPSEA and SOSSEN remain the lead UK routes. Find a specialist (£60 for a 45-minute video call).

The sources behind every claim in this article.

• Statutory basis. Children and Families Act 2014, section 42: duty to secure special educational provision. SEND Code of Practice 2015, paragraphs 9.69 and 9.55–9.74 on sections of an EHCP.
• IPSEA guidance on Section F. IPSEA, What sections should an EHC plan have?; IPSEA, Enforcing Section F.
• Case law on specificity. L v Clarke and Somerset CC [1998] ELR 129; subsequent case law consistently requires special educational provision to be specific and quantified.
• Free SEND legal advice. IPSEA helpline 0300 030 0080; SOSSEN 020 8538 3731; your local SENDIASS; Council for Disabled Children.
• Drafting practitioner perspective. SEND consultants and SENCOs widely advise running the B-to-F audit and weasel-word search. See Enhance EHC Ltd, How to write specific and quantified provision for a practitioner-side view of common drafting failures.

This article is general information about the structure of EHCPs and the SEND framework, not legal advice for your specific plan. It has been reviewed by a UK SEND specialist but does not replace input from IPSEA, SOSSEN, your local SENDIASS, or a SEN solicitor for your specific case.