Try a quick thought experiment. Two versions of the same EHC plan (Education, Health and Care plan) are written for the same child, with the same support in mind.
Version one says the child “will have access to speech and language therapy and regular adult support in class”.
Version two says the child “will receive two 30-minute sessions of direct speech and language therapy each week, delivered by a speech and language therapist, plus 15 hours a week of support from a teaching assistant trained in autism support”.
Now imagine the therapy quietly stops next term. Under version two you can point at the gap: two sessions a week, 30 minutes each, from a specific professional. Under version one, what exactly has been broken? There is still “access”. Nothing measurable was promised, so nothing measurable has been missed.
Same child, same intentions, only one enforceable plan. The whole difference is wording. This guide covers why soft phrases weaken Section F (the part of an EHCP that sets out your child’s special educational provision), the standard the SEND Code of Practice sets, and how to get the Local Authority (you may hear it called the council) to tighten the words while they are still easy to change.
The soft phrases
Section F should describe real help, delivered by real people, on a real timetable. Soft phrases blur all three. Circle these whenever they appear.
- “Access to.” Access means availability, not delivery. “Access to speech and language therapy” is satisfied if a therapist exists somewhere in the school’s arrangements. It never says your child receives anything, from anyone, at any point.
- “Opportunities for.” An opportunity is a chance, not a session. “Opportunities for small-group work” can mean weekly, termly or hardly ever, and every version matches the words.
- “As appropriate” (and its cousin, “as required”). This hands the decision to whoever is delivering the support. If the school decides it was not appropriate this term, the plan has still been followed. A line that can never be breached protects nobody.
- “Regular.” Regular is not a number. Fortnightly is regular; so is once every six weeks. When sessions thin out, “regular” gives you nothing to measure against.
- “Up to.” “Up to five hours of support” sets a ceiling, not a floor. One hour meets it.
The pattern is the same. If you cannot count it, you cannot show it is missing. If you cannot show it is missing, it is hard to get it back.
The standard the Code sets
None of this is a matter of taste. The SEND Code of Practice, the government’s statutory guidance on the SEND system, sets the standard for Section F. It sits in the table in chapter 9 of the Code, just after paragraph 9.69:
“Provision must be detailed and specific and should normally be quantified, for example, in terms of the type, hours and frequency of support and level of expertise”.
Read the two verbs closely. Provision must be detailed and specific: that part is firm. It should normally be quantified: numbers for type, hours, frequency and level of expertise are the default, with room for genuine exceptions. The Code does not demand a number on every line, but a Section F with barely any numbers is a long way from “normally”.
The same table adds:
“Provision must be specified for each and every need specified in section B.”
Section B lists your child’s special educational needs, and Section F has to answer all of them. A need with no matching provision is a gap, however polished the drafting.
Why does this matter? Because of what happens once the plan is final. Section 42(2) of the Children and Families Act 2014 says:
“The local authority must secure the specified special educational provision for the child or young person.”
That duty attaches to what is specified. Two named sessions a week either happened or they did not, so the duty has something to bite on. “Access to support as appropriate” stretches to cover almost anything, so it gives the duty almost nothing. Specific wording turns section 42 from a fine sentence into a working lever.
The four questions
You do not need legal training. Ask four questions of every line in Section F.
- Who? Who delivers this, and at what level of expertise? A speech and language therapist, a teaching assistant with named training. Not “an adult” or “staff”.
- Doing what? What is the actual support? Direct therapy, a structured literacy programme, supervised sensory breaks.
- How often? Sessions per week or per term. “Regularly” is not an answer.
- For how long? The length of each session, and how long the arrangement runs before it is reviewed.
A line that answers all four can be checked in a week. A line that cannot answer them is a hope, not provision.
At the draft stage
The cheapest moment to fix wording is before the plan is final. When the draft arrives, you have the right to make representations before the Local Authority finalises it. No appeal or review is needed: the wording is still open. The timetable for finalising a plan sits in regulation 13 of the SEND Regulations 2014, so respond promptly.
A simple way to respond:
- Circle. Print Section F and mark every soft phrase: access to, opportunities for, as appropriate, regular, up to.
- Ask. For each circled line, put the four questions in writing: who delivers this, doing what, how often, and for how long? You are simply asking for the standard the Code itself sets.
- Get it into the plan. When an answer comes back (“in practice that means two 30-minute sessions a week with the therapist”), reply with one request: please write that into Section F.
The third step is the one families miss. Reassurances in an email, a meeting or a phone call are not part of the plan, and the section 42 duty attaches to what the plan says. Staff move on, inboxes get archived, and next September a new SENCO will read only the plan. If it matters, it goes in Section F.
If the plan is already final
EHCP Section F wording can still be improved after the plan is finalised, and the main route is the annual review. Every plan must be reviewed at least once every 12 months, and you can ask for an early review if weak wording is causing problems now. Bring your circled phrases, ask for Section F to be amended to meet the Code’s standard, and make sure your request is recorded. Our guide to preparing for the annual review walks through the process step by step.
Frequently asked questions
Does Section F have to be quantified?
The Code’s exact words matter here. Provision “must be detailed and specific” and “should normally be quantified”. Detail and specificity are firm; quantification is the normal expectation rather than an absolute rule. Numbers are the starting point, so a Section F with few or none is worth challenging. If the Local Authority resists numbers, ask it to explain in writing why your child’s case is an exception to “normally”.
Is “access to” ever acceptable in Section F?
It is a weak way to describe provision, because it promises that something is available rather than that your child receives it. Even where support genuinely is about availability (a quiet space at unstructured times, for example), the plan is stronger when it says who makes sure it happens and how often. In a draft, ask the four questions and request wording that describes delivery.
The school has confirmed the support by email. Is that enough?
An email is useful evidence of intent, but it is not the plan. The section 42 duty attaches to the provision specified in the plan itself, so support that lives only in an email sits outside it. Ask for the same commitment in Section F: through representations if the plan is still in draft, or through the annual review if it is final.
This guide describes the system in England; Wales, Scotland and Northern Ireland run their own. You do not have to work it out alone. IPSEA, the specialist SEND legal charity, gives free legally based advice on EHC plans and wording, and your local SENDIASS (SEND Information, Advice and Support Service) offers free impartial support with reviews and representations.
What to read next
- Wording right, delivery missing? EHCP Section F Not Being Delivered? How to Enforce It sets out who is responsible and the exact steps to take.
- Want the full picture? The SCOPE is our free course on understanding and using your child’s SEND rights, one short lesson at a time.
This article is information, not legal advice. For advice on your own situation, contact IPSEA or your local SENDIASS.