Section F EHCP: Kent Examples of Strong Provision Wording
Side-by-side examples of vague and clearer wording, the details to check, and how a Working Document can record proposals during a contents appeal.
✅ Quick Answer
Section F of a Kent EHCP should be detailed and specific and normally quantified: it should identify what is provided, how much, how often, by whom, and for how long. Wording like "access to", "opportunities for", "regular" or "as appropriate" may be too vague without those details. A practical check is whether a new person could read Section F and know what to arrange.
💡 In This Guide
- What Section F is and why it matters
- The legal test: specified and quantified
- Phrases that may need clarification (with rewrites)
- Worked example 1: TA support
- Worked example 2: Sensory breaks
- Worked example 3: SALT input
- Worked example 4: OT input
- Worked example 5: Emotional regulation
- The Working Document phase
- Kent-specific tips
- FAQ
Section F states the special educational provision. Under section 42(2) of the Children and Families Act 2014, the local authority must secure the provision specified there, subject to the statutory exceptions. This is a body-specific duty: it does not mean Section F is the only part of an EHC plan with legal consequences or that the school replaces the local authority as the duty-holder.
During a contents appeal, the Tribunal's case-management directions may require the parties to maintain a Working Document showing agreed and disputed wording. Either side can propose changes and each proposal should be tied to evidence. There is no reliable settlement percentage or outcome promise for an individual Kent appeal.
What Section F is and why it matters
Different sections engage different duties and remedies:
- Section F — the special educational provision the local authority must secure under section 42(2).
- Section G — the health care provision the responsible commissioning body must arrange under section 42(3).
- Section I — the school or type of school; specified educational institutions can have a separate duty to admit under section 43, and eligible Section I decisions can be appealed.
Sections B, C and D describe needs; Sections H1 and H2 record social-care provision under different statutory frameworks. A SEND Tribunal appeal can directly determine specified education issues and may make non-binding recommendations on health and social-care matters when the legal conditions are met. Do not treat the whole plan as equally enforceable through one route.
Practical consequence: each special educational need in Section B should map to provision in Section F. If that link is missing or vague, it can be difficult to identify what the local authority must secure under section 42.
The legal test: specified and quantified
The SEND Code of Practice at paragraph 9.69 says provision must be detailed and specific and should normally be quantified, including the type, hours and frequency of support and the level of expertise required.
A useful practical check is: could a fresh person reading Section F identify what must be arranged without guessing? If not, ask for the ambiguity to be resolved against the assessment evidence.
Specified and quantified means saying:
- What the intervention is (e.g. "individual Speech and Language Therapy programme targeting expressive language and social communication")
- How much ("30 minutes per session, 1 session per week, term-time" = 30 minutes × 38 weeks = 19 hours/year)
- How often ("weekly during term time")
- By whom ("delivered by an HCPC-registered Speech and Language Therapist" — naming the qualification level matters: an HLTA delivering "speech work" is not the same as an SLT delivering therapy)
- How monitored ("with progress reviewed termly via SLT report shared with parent and SENCO")
Section F Phrases That May Need Clarification
These phrases may be too vague in a draft Section F unless the plan adds the missing detail.
| Weak phrase (may be too vague) | Why it fails |
|---|---|
| "Access to a teaching assistant as required" | No hours, no frequency, no qualification specified. "As required" is decided by the school, not the EHCP. |
| "Opportunities for sensory breaks" | Not quantified. "Opportunities" creates no duty to actually provide them. |
| "Regular SALT input" | "Regular" is undefined. It could mean very different frequencies and may be too vague to identify the provision. |
| "Support from the SENCO as appropriate" | "As appropriate" delegates the decision back to the LA/school, defeating the EHCP's purpose. |
| "Differentiated curriculum" | Every school is supposed to differentiate; this is the universal offer, not provision additional to it. |
| "Small group work where possible" | "Where possible" is a get-out clause. Group size, frequency, duration unspecified. |
| "Visual supports to aid learning" | No detail of which supports, who creates them, where they live, who refreshes them. |
| "To be supported by school staff" | Generic. No skill specification, no time allocation, no supervision arrangement. |
Worked example 1: TA support
Weak draft (KCC pattern):
"Access to a teaching assistant as required."
Strong rewrite (parent Working Document submission):
"[Child] requires 1:1 adult support from a TA experienced in working with autistic children, for 25 hours per week during term time. The TA will (a) support transitions between activities and lessons, (b) deliver the visual schedule and now-and-next board, (c) implement the sensory regulation programme as advised by the OT (see provision 3.4 below), and (d) act as a key point of consistency through the school day. The TA will receive 1 hour of supervision and planning time per week from the SENCO. The named TA will be consistent across the academic year wherever practicable; if the named TA is absent, a designated cover TA familiar to [Child] will be used."
What changed: hours quantified (25), days specified (term time), qualification specified (TA experienced in autism), the four functions named, supervision built in, continuity addressed.
Worked example 2: Sensory breaks
Weak draft:
"Opportunities for sensory breaks during the school day."
Strong rewrite:
"3 timetabled sensory regulation breaks per school day of 10-15 minutes each, scheduled at mid-morning, post-lunch, and mid-afternoon, in a designated low-stimulus space (the school's quiet room or equivalent agreed with the OT). Breaks include access to proprioceptive input equipment (weighted lap pad, resistance band, wobble cushion) as specified in the OT sensory profile dated [date]. Additional breaks at [Child]'s request to be facilitated without need for explanation. The sensory diet is reviewed and updated termly by the OT."
What changed: number quantified (3), duration quantified (10-15 min), times specified (mid-morning / post-lunch / mid-afternoon), location specified, equipment named, additional access permitted, OT review schedule built in.
Worked example 3: SALT input
Weak draft:
"Regular SALT input as required."
Strong rewrite:
"Direct Speech and Language Therapy delivered by an HCPC-registered SLT: 1 individual session of 30 minutes per week during term time (38 sessions per year, totalling 19 hours), targeting expressive language and social communication as set out in the SLT report dated [date]. Plus indirect support: the SLT will provide a written programme for the TA to implement daily for 15 minutes (5 sessions per week × 38 weeks = 1,900 minutes per year). The SLT will train the TA termly (3 × 1-hour training sessions per year). Progress reviewed termly via written report shared with parent and SENCO."
What changed: direct vs indirect input separated, qualification of deliverer specified (HCPC SLT), exact session length and frequency quantified, total annual hours calculated for transparency, training of TA included so the indirect work is delivered competently, monitoring built in.
Worked example 4: OT input
Weak draft:
"OT advice available as needed."
Strong rewrite:
"Occupational Therapy programme delivered by an HCPC-registered Paediatric OT: an initial sensory profile assessment in the autumn term of each academic year (3-hour assessment), followed by a written sensory diet plan for school staff. The OT will visit school termly (3 visits per year, minimum 90 minutes each) to (a) review the sensory diet with school staff, (b) train staff on any new techniques, and (c) observe [Child] in class. Fine motor skills support: 1 individual OT session of 30 minutes per week during term time (38 sessions per year), targeting handwriting, scissor skills, and self-care goals as set out in the OT report dated [date]. The OT to provide a written annual report contributing to the EHCP Annual Review."
What changed: assessment vs treatment split, frequency and duration quantified at every level, qualifications specified, school engagement built in (training and observation), annual review contribution explicit.
Worked example 5: Emotional regulation
Weak draft:
"Support with emotional regulation when needed."
Strong rewrite:
"Emotional Literacy Support Assistant (ELSA) programme delivered by a trained ELSA: 1 individual session of 45 minutes per week during term time (38 sessions per year), focused on emotional vocabulary, recognising body cues of dysregulation, and using the agreed regulation toolkit. Plus a written 'When I am dysregulated' plan co-produced with [Child] and shared with all teaching staff, listing (a) [Child]'s known triggers, (b) the early warning signs to look for, (c) the agreed de-escalation steps and where they take place, and (d) the recovery routine afterwards. The school's behaviour policy will be applied with reasonable adjustments for [Child]'s identified disability needs, in line with the Equality Act 2010; meltdowns arising from sensory overload or autism-related dysregulation will not be sanctioned."
What changed: intervention named (ELSA), frequency and duration quantified, written plan formalised with four explicit components, and the reasonable-adjustments duty made explicit. That wording does not guarantee that exclusion can never occur; any exclusion decision must still be made lawfully on its own facts.
The Working Document phase
The Working Document is the formal mechanism for rewriting Section F (and Sections B and I) during a SEND Tribunal appeal. After the council files its response to the appeal, the case management directions usually require both sides to exchange a Working Document showing the EHCP with each side's proposed wording for every disputed section.
How to use it well:
- Use track changes or coloured text to show what each side wants. Keep the original wording visible; mark insertions and deletions clearly.
- Cite the supporting evidence for each piece of provision. After your proposed wording, add a parenthetical reference: "(see Educational Psychologist report, Dr Smith, dated 14 March 2026, page 12 paragraph 4.7)".
- Use professional evidence accurately. Where a report recommends provision, quote it faithfully and identify the report, page and paragraph. Do not add a qualification, frequency or duration that the author did not support.
- Ask for vague recommendations to be clarified. If a report says "regular OT input", ask the author to specify the clinically supported frequency and duration rather than inventing a number.
- Address every disputed issue in the directions. The Tribunal determines the appeal before it on the evidence and may direct how the Working Document is completed.
- Do not concede on legal duties. The Equality Act 2010 reasonable adjustments duty, the Section 42 duty, and the Children and Families Act 2014 framework underpin all of this. Push back on wording that softens these.
For the full appeal process see our EHCP Appeal Guide for Kent. The current official appeal route and form are on the GOV.UK SEND35 page.
Kent-specific tips
- Check the individual draft against its evidence. Identify each need in Section B, the matching Section F provision and the source report. Ask KCC to explain omissions or wording that is not supported by the evidence.
- Use independent evidence only where it is relevant and affordable. No report guarantees an amendment or appeal result. See independent Kent Educational Psychologists if you are considering an assessment.
- OT and SALT independent reports for sensory and language provision. See independent Kent Occupational Therapists and Kent Speech and Language Therapists.
- Use Kent IASK as a sounding board. Free statutory advice service, can review your Working Document submission. Phone 03000 41 3000, email iask@kent.gov.uk.
- Check the current official route. Kent's mediation and appeals page links to its current mediation provider and GOV.UK Tribunal guidance.
FAQ
What is Section F of an EHCP?
The section setting out the special educational provision the local authority must secure under section 42(2) of the Children and Families Act 2014, subject to the statutory exceptions. Section G has a separate section 42 duty on the responsible commissioning body.
What does "specified and quantified" mean?
Provision must say what, how much, how often, by whom, and for how long. The IPSEA test: could a fresh person deliver it without asking for clarification?
What Section F phrases may need clarification?
"Access to", "opportunities for", "regular", "as required", "as appropriate", "where possible". These may be too vague without details about what, how often, for how long and by whom. Ask for clarification at draft stage or follow the Tribunal directions if an appeal is underway.
Can I change Section F at Annual Review?
Yes. The Annual Review is the formal yearly opportunity. If KCC refuses to amend, you have the right to appeal to the SEND Tribunal under Section 51(2)(c) of the Children and Families Act 2014.
Who can rewrite Section F: parent, school, or local authority?
All three can propose wording. The LA drafts. At Working Document stage parents, schools and advocates can submit alternatives. Independent professional reports usually contain recommended wording that can be adopted directly.
How many hours of TA support should be in Section F?
There is no legal minimum. Hours must reflect the child's individual needs and the evidence. Do not copy a generic number or invent a quantity that a professional report does not support.
What if the school says they cannot deliver Section F as written?
Tell KCC in writing. The local authority holds the section 42 duty to secure Section F provision, subject to the statutory exceptions. The response may require additional arrangements or consideration of placement; the correct challenge route depends on the decision and facts.
Next Steps
- If you are at draft EHCP stage, read the draft against this guide and identify every weak phrase. Draft your alternative wording for each.
- If you are at Working Document stage, consider getting an independent EP, OT or SALT report to underpin the rewrites.
- If KCC refuses your wording and the decision carries a right of appeal, check the decision letter, mediation-certificate rules and deadline, then organise the evidence against each disputed issue.
- For the full appeal process, see our EHCP Appeal Guide for Kent.
- For Annual Review timing, see our Annual Review guide.
Disclaimer: This article was written by a Kent parent with lived experience of the SEND system. It is information only and does not constitute legal advice. Primary sources checked 26 July 2026: Children and Families Act 2014, section 42, the SEND Code of Practice and the GOV.UK appeal guide. Seek case-specific advice from IPSEA or Kent IASK.
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