EHC Needs Assessment Advice for OTs, SLTs and Physios: What Section F Needs From You

What does the law say the advice has to contain?

Regulation 6(1) tells the local authority what to ask for, and the same sentence tells you what to write. The authority "must seek the following advice and information, on the needs of the child or young person, and what provision may be required to meet such needs and the outcomes that are intended to be achieved by the child or young person receiving that provision". Needs, provision, outcomes. Not a paragraph in your report. The structure of it.

Three routes bring a therapist into this list. Regulation 6(1)(c) is "medical advice and information from a health care professional identified by the responsible commissioning body", which is how an NHS therapy service is asked. Regulation 6(1)(f) is "advice and information from any other person the local authority thinks is appropriate". Regulation 6(1)(h) is "advice and information from any person the child’s parent or young person reasonably requests that the local authority seek advice from", which is how an independent therapist gets the letter. The duty on what the advice must address is the same whichever route brought you in.

Two smaller points from the same regulation. Where the child is in year 9 or beyond, 6(1)(g) adds advice on provision for preparation for adulthood and independent living, so a report on a 14-year-old that stops at the classroom is incomplete. And 6(4) lets the authority reuse advice it already holds, but only if the authority, the person who wrote it and the parent or young person all agree it is sufficient. If your last report is eighteen months old, expect to be asked again.

How long do I have?

Six weeks from the date the request arrives. Regulation 8(1) says a body asked to co-operate "must comply with such a request within 6 weeks of the date on which they receive it". Regulation 8(2) allows only three exceptions: exceptional circumstances affecting the child or family during those six weeks; the child or family being absent from the authority’s area for a continuous period of not less than four weeks in that window; or the child failing to keep an appointment for an examination or test made by the body during it. Workload is not on the list. Neither is a waiting list.

The clock runs from receipt, not from your first appointment. Put the request date in the report itself, on the first page. Caseworkers look for it.

Where does your advice end up? Sections A to K

An EHC plan is set out in lettered sections. Your advice is appended to the plan in Section K, but the words in it are quarried for the sections that matter.

The B to F line is the one that pays

Speech and language therapy is the clearest case: the SEND Code of Practice says therapy "addressing speech and language impairment should normally be recorded as special educational provision unless there are exceptional reasons for not doing so" (paragraph 9.74). The same logic reaches an occupational therapist’s handwriting or self-care programme and a physiotherapist’s programme that a teaching assistant delivers in school. If it teaches the child something, say so, and say which section it belongs in. Do not leave the caseworker to decide.

What order do local authorities expect?

There is no statutory format. RCSLT’s public guidance for speech and language therapists prescribes four parts: background; speech, language and communication skills; suggested outcomes; provision. Local authority forms add front matter and a per-outcome table, and they differ from one authority to the next, so use the one the letter came with if it came with one. The order below is the one that survives contact with a caseworker, a parent and, if it comes to it, a tribunal panel.

• The child’s details, the setting, your name, profession and HCPC number, the service, the report date and the date the authority asked.
• Why the report exists: advice for an EHC needs assessment under the Children and Families Act 2014, requested by the named authority on the named date. Two sentences.
• Sources: named assessments with dates and settings, observations, file review, who you spoke to. The Code asks for evidence that is "clear, accessible and specific" (paragraph 9.51).
• History, including what has already been tried and how the child responded.
• The child’s own views and the family’s, in their words.
• Strengths, before needs. Always.
• Needs by domain, each tied to one of the Code’s four areas of need, with named tools, dates and scores.
• The effect of each need on learning, on social participation, and from year 9, on preparation for adulthood. This is the paragraph that turns a clinical finding into special educational provision under section 21(5).
• Outcomes.
• Provision, specified and quantified, each item tagged to Section F or Section G.
• How progress against the outcomes will be measured, and by whom.
• Signature, profession, HCPC number, date.

Needs, outcomes and provision have to line up

Every need should lead to an outcome, every outcome to at least one item of provision. A need with no provision is a gap a tribunal will find. Provision with no outcome is a service looking for a reason.

How specific does provision have to be?

Specific enough that nobody has to guess. The Code of Practice, paragraph 9.69, on Section F: "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". The case law says the same thing in older words. In L v Clarke and Somerset County Council [1998] ELR 129 the court asked whether provision was "so specific and clear as to leave no room for doubt as to what has been" decided, and the Upper Tribunal applied that test to the 2014 framework in [JD v South Tyneside Council [2016] UKUT 9 (AAC)](https://caselaw.nationalarchives.gov.uk/ukut/aac/2016/9), where a plan that offered "individual programmes tailored to her needs" without saying what the programmes were was found wanting. In [B-M v Oxfordshire County Council [2018] UKUT 35 (AAC)](https://www.gov.uk/administrative-appeals-tribunal-decisions/b-m-and-b-m-v-oxfordshire-county-council-sen-2018-ukut-35-aac) the Upper Tribunal returned to the same ground under the heading of specificity.

A provision sentence that meets that bar has five parts, and the fifth is the one therapists leave out.

Your own time is part of the provision

The fifth row comes from RCSLT’s guidance, which requires speech and language therapy advice to state the time required to "support staff, attend meetings including with parents and carers, write reports, review the evidence base and measure outcomes, as well as level and frequency of monitoring". Nothing in that sentence is specific to speech and language therapy. If a teaching assistant delivers your programme, the plan has to fund the hours that make the programme yours.

Which phrases get struck out?

A short list, drawn from the cases and from what tribunals send back.

• "Access to". Access is not delivery. "Access to occupational therapy" secures nothing.
• "Regular". Weekly is regular. So is termly.
• "As required", "where necessary", "as appropriate". Each hands the decision to whoever is paying.
• "Opportunities to". Write-ups of B-M v Oxfordshire single this one out as vague and unenforceable, and the point holds whatever the exact words of the judgment: an opportunity is not an obligation.
• "Would benefit from". Write "requires". You are the expert; say what the child needs.
• "Up to X hours". Zero is up to X.
• "Small group" with no number. Two is small. So is eight.
• "A programme tailored to her needs" with no content. The exact phrase the Upper Tribunal found insufficient in JD v South Tyneside.

Two versions of one line

Fails: "Sam would benefit from regular access to speech and language therapy in a small group."

Passes: "Sam requires a 30-minute speech and language therapy session once a week, delivered 1:1 by an HCPC-registered speech and language therapist, plus a daily 10-minute language programme delivered by a teaching assistant trained by that therapist, with 4 hours per term of therapist time for training, programme review and outcome measurement."

The second is longer. It is also the only one of the two that Section F can hold.

Why are outcomes not provision?

Because the Code separates them, and caseworkers merge them. An outcome describes the benefit or difference the child will experience; provision describes what is done to get there. "Ella will receive weekly OT" is a service. "By the end of Year 4, Ella will manage her own coat, zip and buttons at the start and end of each school day without adult help" is an outcome. Write the outcome first, date it to the end of a key stage or phase where you can, then write the provision that reaches it. If you find provision creeping into an outcome, move it down a section.

What changes in 2029, and what does not?

England is rebuilding the SEND system. The House of Commons Library briefing on the reforms, published on 1 September 2026, is precise about timing: the reformed system "is not expected to come into effect until September 2029", "no changes to support received through education, health and care plans (EHCPs) would take place before at least September 2030", and until then the current system would remain in place.

So the framework on this page is the law today: the Children and Families Act 2014, the 2014 Regulations and the 2015 Code. Advice you write this term will be judged against them. We will date this page and update it when that stops being true.

Where Carearoo fits

If you are writing EHC advice as an independent therapist, the invoice comes first. Carearoo’s free invoicing for UK therapists is live at carearoo.com/uk, and the question of whether that invoice carries VAT is answered in our guide to VAT on therapy reports. The adult equivalent of "needs, then provision" is the Care Act assessment, and the Care Act needs assessment guide covers what a council reads in one.

The EHCP / SEND contribution report type is in build and listed on the UK page. It is not live yet. One thing worth saying about it now, because a professional body has already raised it: the Association of Educational Psychologists has warned that commercially produced, generic software has not always produced individual, person-centred advice. That is the right worry. A drafter built from regulation 6 and paragraph 9.69 is judged on one thing, whether the provision it drafts is quantified and specific to this child, and the clinician who signs the advice decides that before anyone else sees it. If you want early access when the type goes live, say so on the UK page.

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