Summary: We upheld a complaint from Mrs B, finding the Council failed to properly consider if it owed a duty to make alternative education provision for her son during his absence from school. We considered this contributed to a loss of education provision for him, which was an injustice. The Council has accepted these findings and agreed action we recommended to remedy that injustice, comprising an apology and symbolic payment to Mrs B. It has also amended relevant policy to address what it will do when children miss school in similar circumstances.

The complaint

1. Mrs B complained the Council failed to ensure that her son, C, had access to education between January and July 2025 when he could not attend school. Mrs B also complained about how the Council handled her complaint about this matter.
2. Mrs B said the Council’s failure to meet C’s special educational needs both during this time, and during an earlier time, led to him becoming too ill to attend school. She had to reduce her employment to stay at home to provide education for C. Mrs B also paid for him to receive private therapy she considered the Council should have provided. Mrs B said she experienced her own mental health illness, arising from these events.

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The Ombudsman’s role and powers

3. We investigate complaints of ‘maladministration’ and ‘service failure’. I have used the word fault to refer to these. We consider whether there was fault in the way an organisation made its decision. If there was no fault in how the organisation made its decision, we cannot question the outcome. (Local Government Act 1974, section 34(3), as amended)
4. We must also consider whether any fault has had an adverse impact on the person making the complaint. I refer to this as ‘injustice’. If there has been fault which has caused significant injustice, or that could cause injustice to others in the future we may suggest a remedy. (Local Government Act 1974, sections 26(1) and 26A(1), as amended)
5. We cannot investigate all complaints we receive. The law says we cannot normally investigate a complaint when someone has a right of appeal, reference or review to a tribunal about the same matter. However, we may decide to investigate if we consider it would be unreasonable to expect the person to use this right. (Local Government Act 1974, section 26(6)(a), as amended)
6. The First-tier Tribunal (Special Educational Needs and Disability) considers appeals against council decisions regarding special educational needs. We refer to it as ‘the Tribunal’ in this decision statement.
7. If satisfied with an organisation’s actions or proposed actions, we can complete our investigation and issue a decision statement. (Local Government Act 1974, section 30(1B) and 34H(1), as amended)
8. Under our information sharing agreement, we will share this decision with the Office for Standards in Education, Children’s Services and Skills (Ofsted).

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What I did and did not investigate

9. I did not investigate any part of Mrs B’s complaint concerned with the therapy services C should have received as part of an Education, Health and Care (EHC) Plan.
10. I noted in February 2025 the Council issued C with an updated version of his EHC Plan. This carried with it appeal rights, to the Tribunal, if Mrs B considered the proposed education provision for C (set out in Section F of the Plan) inadequate.
11. After issue of the Plan Mrs B showed dissatisfaction the Council had not specified that C should receive specialist private therapy in his Plan, that she already paid for. The view of the Council, explained to Mrs B, was that it considered C's education setting could meet his need for support in this area.
12. I considered it was not our role to come to a view on this dispute. The Tribunal has the experience and expertise to come to a view when parents and local authorities disagree over the specific therapeutic support a child needs. It also has statutory powers to compel a council to amend an EHC Plan to change a child’s education provision. We have no equivalent qualifications or power.
13. That said, we must still consider if any good reasons might have prevented the complainant making an appeal. In this case Mrs B asked me to note that around February 2025 C was unwell, experiencing something of a crisis which needed intervention with his GP. This in turn put much strain on Mrs B and led to her own mental health declining and needing support from her GP. At the same time, Mrs B said she had to contact C’s school and the Council about his absence from school and ongoing education needs. So, this did not leave her with the time or ability to make an appeal.
14. I did not dispute any of Mrs B’s evidence provided around C’s health, nor her own, summarised above. I also accepted the period around February and March 2025 when she might have appealed C’s Plan was a stressful one for her. However, I noted Mrs B engaged in sometimes lengthy correspondence with the Council around this time. This covered not only C's immediate circumstances but also looked back to when Mrs B had raised concerns previously about the Council’s response to his special educational needs. And it looked forward, at what provision C needed, including that therapeutic provision Mrs B thought C should have included in his Plan.
15. I did not accept therefore that Mrs B could not have made an appeal to the Tribunal if unhappy with the content of the February 2025 Plan. I found she had both the opportunity and ability to do so. Without good reasons I could not make an ‘exception to the rule’ and so I did not investigate the content of the February 2025 Plan.

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How I considered this complaint

16. I considered evidence provided by Mrs B and the Council as well as relevant law, policy and guidance.
17. I gave Mrs B and the Council chance to comment on a draft version of this decision statement. After receiving comments I corrected this and issued a second draft version for comment. I took account of any further comments they made, or further evidence provided, before putting this statement in its final format.

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What I found

Key law and guidance

Special Educational Needs and EHC Plans

18. A child or young person with special educational needs may have an Education, Health and Care (EHC) Plan. This document sets out the child’s needs and the arrangements made to meet them. The document has different sections, including Section F, which sets out details of the special education provision needed by the child or young person.
19. The council has a duty to make sure the child, or young person receives the special educational provision set out in section F of their Plan (Section 42 Children and Families Act). The Courts have said councils owe the duty to arrange this provision personally to the child. This means if the council asks another organisation to make the provision and that organisation fails in that, the council remains liable (R v London Borough of Harrow ex parte M [1997] ELR 62), (R v North Tyneside Borough Council [2010] EWCA Civ 135)  
20. We accept it is not practical for councils to keep a ‘watching brief’ on whether schools and others provide all the special educational provision in section F for every pupil with an EHC Plan. But we consider councils should retain oversight and gather enough information to fulfil their legal duty. So, we expect them to: 

• check the special educational provision is in place after issuing a new or amended EHC Plan or following a change in educational placement; 
• check the provision at least annually during the EHC review process; and 
• quickly investigate and act on complaints or concerns that suggest provision is not in place. 

Alternative Provision

21. Section 19 of the Education Act 1996 requires a council to arrange suitable alternative educational provision when it finds that a child cannot attend school because of a permanent exclusion, an illness, or for any other reason making the school inaccessible. The alternative educational provision must be suitable to the child’s age, ability and aptitude, and any special educational needs they have.
22. If a council discovers a child’s prolonged absence from school, it should consider the reasons for this. It should take account of evidence from relevant parties (such as the child’s school, parents, and medical professionals). It must then decide whether it has a duty to make alternative educational provision. If a council wants to see medical or other evidence, it should ask for it at the earliest opportunity.
23. The Courts have held the key test for the Council when deciding whether to make alternative provision is if the child has education “reasonably available and accessible” to them. (see (R(R) v Kent County Council [2007] EWHC 2135 (Admin) and R(DS) v Wolverhampton City Council [2017] EWHC 1660 (Admin)).
24. Councils should consider any attempts the school is making to support the child. This might include sending work home for the child to complete, arranging disability related support, placing the child on a reduced timetable, or providing online education as a short-term measure. If a clear, effective, and time-bound plan for reintegration exists then there may be no immediate role for the council in providing alternative education.
25. If a child has an Education, Health and Care (EHC) Plan the council also has an ongoing duty to arrange the support guaranteed by the Plan. However, this might not always be possible, such as when SEN support relies on delivery in the child’s normal classroom setting.

Council Section 19 policy

26. I considered a version of this policy dated August 2025, setting out how the Council would consider requests that it provide alternative provision in line with the law summarised above. This said when it became aware of a child’s absence (or anticipated absence) from school for 15 days over an academic year, it would consider if it had a duty to make alternative provision.
27. In cases of illness, the Council said where this was “short-term” it considered the needs of pupils “best met by school support and resources”. But that it may need to “co-ordinate support” for a child. It referred to using targeted support meetings to help agree an approach for “persistently absent pupils where they have barriers to attendance” and using action plans for “severely absent” pupils.
28. In cases of pupils absent for reasons other than illness (but not exclusion), the Council said it would make provision if it assessed it was “not reasonably practicable for the child to access the education that is available to them at their current school”. It said the process for deciding if it should make provision under Section 19 of the Education Act, was for cases go to its ‘Single Panel’. This includes representatives from its children services, schools and a medical representative. The Panel meets fortnightly with cases referred to it through schools. If it decided to make provision, it placed the onus on the “child’s home school” to contact parents and discuss the provision arrangements agreed.
29. The policy made no specific reference to pupils with special educational needs or those with EHC Plans. The Council told me that from April 2026 its policy had been for its EHCP Team to assess requests for alternative provision. That team would meet with its Education Participatory Advice Service (EPAS) to discuss how to respond. Before this date the Council has said its policy was to refer children missing education for reasons linked to their special educational needs to its “Single Panel” (as described above) to consider if it needed to make provision. This was in line with an approach it called the “medical pathway” for pupils possibly too ill to attend school.
30. In general comments on the role of its EPAS, the Council has said that it co-ordinates specialist teams and supports schools with pupil attendance issues. It assigns link officers to schools, delivers training and offers to arrange targeted support meetings. It says that it “oversees returns” to schools, for pupils supported under the Section 19 policy where illness has prevented attendance.

Council complaint policy

31. The Council has told us that it follows advice set out in our complaint handling code, running a two-stage complaint procedure.
32. We expect it therefore to acknowledge complaints within five working days of receipt. At stage one of its procedure it should aim to reply in the next ten working days. It can extend this to the next 20 working days where it has reasons for delay, and it has told the complainant of these. So, in total, it should respond to a stage one complaint in a maximum 25 working days.
33. For ‘stage two’ complaints our expectations are the Council acknowledges within five working days and replies within the next 20 working days. It may extend that timescale to the next 40 working days where it has reasons for delay and tells the complainant about these. So, in total it should respond to a stage two complaint in a maximum 45 working days.

The key facts

34. C is a child with special educational needs, who in January 2025 had an EHC Plan. He was in year 6 of his primary education. He attended a mainstream primary school. A review of his Plan in October 2024 had said he had good school attendance.
35. In mid-January 2025 C stopped attending school. Mrs B contacted the school to say that she considered C on the “brink of [an] autistic burnout”. She linked C’s non-attendance to a complaint she had the school failed to make certain specific provision for C that he needed. The school recorded C as having an authorised absence, because of illness.
36. Before the end of the month a meeting took place at the school. This discussed support the Council had offered to provide C in meeting specific social and emotional mental health (SEMH) needs through its Specialist Intervention Support Services (SISS). The SISS service explained the work it aimed to carry out with C in school.
37. Around the same time the Council said to Mrs B it would look into her concerns that C’s school had failed to make provision set out in his EHC Plan.
38. In mid-February 2025 Mrs B wrote to the school and said C “remains very unwell”. She said she would only be in contact with the school once C was well enough “to return to receiving an education”. She also wrote to the Council and told it of C’s absence, asking how “we can move forward” to enable him to return to education.
39. Separately the Council wrote to Mrs B setting out the school’s response to the suggestion it failed to make some provision available to C. The Council recognised its response to Mrs B did not cover all her concerns and said it would write to her again.
40. In late February, the school contacted the Council about C’s absence. It relayed its understanding of Mrs B’s messages that she did not want it to contact her. The Council said it would give advice and an officer from its EHCP team recorded referring the case to the EPAS.
41. In reply to my enquiries the Council said that its EPAS had no record of involvement in C’s case. But the Council had a record of email exchanges between EPAS and the school which followed from the referral noted above kept by its EHCP Team. The Council therefore clarified the EPAS service had been involvement, but considered it limited to giving advice only. It said it was an error the service had failed to keep its own record of that. Mrs B has also told me about earlier involvement by EPAS in C’s education, during events that pre-dated those covered by this investigation.
42. The emails exchanged in March 2025, showed the school told EPAS it had spoken to C’s GP. It reported the GP saying they could not diagnose C with an “autistic burnout” as it was not a recognised medical condition. The GP said C needed specialist assessment by Child and Adolescent Mental Health services. The school told the Council it did not know when, or if, C would return.
43. In its reply EPAS told the school the case might meet the criteria for “a medical pathway”. It suggested the EHCP Team could ask for an urgent review of C’s Plan. It also suggested the SISS service might offer some support to C at home. But that “ultimately” Mrs B needed to work with the school and C could not “stay off until the end of the year as that is parents’ choice not medical assessment”. The Council says the intent behind this advice was to convey that it needed more professional input to understand the cause of C’s absence and the support he needed.
44. When the EHCP Team saw that advice, it told the school it would not arrange an emergency review of C’s Plan. This was because it considered there had been “no significant changes” since it issued his previous Plan in February 2025. The service advised the school it had to make provision for C, but it could look at supporting it, dependent on what C’s GP advised. After which, the school clarified it had no information in writing from the GP.
45. Separately, at the beginning of March 2025, Mrs B had challenged the school responses to her concerns about how it arranged C’s provision. In that email she said the Council had a legal responsibility to provide him with education in line with his EHC Plan.
46. At the end of March 2025 Mrs B had further correspondence with the Council around C’s provision. She said C’s school had not provided any schoolwork for him. In a separate exchange with the Council, the school said while it noted the Council’s request it provide work for C, it could not do that if Mrs B refused contact.
47. In early May 2025 the school and Council met at a ‘professionals meeting’ to discuss C’s case. C’s GP and an agency providing mental health support for children and young people on the NHS’s behalf also attended. The school noted EPAS had “declined to get involved” and given it “no support”. There was discussion about the cause of C’s absence. During the meeting C’s GP said C was getting some provision at home, but the minutes contain no detail about this. The Council told the school Mrs B wanted schoolwork provided for C and that it should arrange for this, although the Council agreed that it would liaise between the two. After the meeting, Mrs B asked for the school to send work for C by email.
48. Around a week later there was discussion between the Council and Mrs B about the SEMH provision, which the SISS team had agreed to provide C. The Council told Mrs B that it considered C had this provision available to him at school. In her response Mrs B pointed out her view the school had failed to make provision available for C in line with his EHC Plan.
49. The next records on the Council’s file date from late June 2025 when the Council made checks with C’s school about work it provided for him. The school went on to tell the Council that since it began providing work for C, it had not received any work returned. Nor did it know how it could make SEMH provision for C, if he was not in school.
50. I noted Mrs B experienced some difficulties accessing the work through the IT service used by the school. She told the Council about this. Once she accessed the work, she then alerted the Council to concerns about the content saying it was unsuitable for C’s needs (see also paragraph 55).
51. In comments to me Mrs B told me that while C was off school, she provided some work for him at home, based on her own experience working in an academic field. She also said that when C had experienced previous absences from school, she had come to a workable arrangement with the school to provide him work at home. She queried why this was not possible between January and July 2025. Mrs B also explained the context for why her relations with the school had declined.
52. In September 2025 we upheld a complaint from Mrs B about the education service C received between February 2024 and February 2025. This included a finding the Council had been at fault for failing to ensure C’s school made provision for him in line with his EHC Plan.

Mrs B’s complaints

53. In June 2025 Mrs B made a complaint to the Council. This included complaints the Council had:

• not resolved problems with C’s provision she had highlighted;
• failed to ensure C had access to education while absent from school;
• that this amounted to a failure to provide C with education in line with Section 42 of the Education Act;
• failed to ensure C had a Plan that met his needs.

54. Mrs B later added to her complaint, that the Council had initially failed to acknowledge it.
55. In July 2025 Mrs B also complained the Council had failed to respond to her concerns about work sent home to C by his school. In mid-July the Council told Mrs B it would look into her concerns. I saw no later exchanges about this matter.
56. The Council replied to Mrs B’s initial complaint in July 2025. It:

• accepted that it had not always replied to correspondence in five working days as it aimed to;
• defended the conduct of its officers in response to Mrs B’s complaint about problems with education provision;
• said that it considered C’s school had responsibility for providing work for him while he could not attend; that any failure to do so arose from Mrs B asking the school not to contact her;
• did not agree therefore it had failed to meet C’s needs;
• recognised it had been one day late in acknowledging Mrs B’s complaint but said it had replied within 20 working days of that acknowledgement.

57. Unhappy with this reply, Mrs B escalated her complaint to stage two of the Council’s complaint procedure. She said the school had discouraged her contacting it. Mrs B also said she had asked for education provision for C from March 2025.
58. In its final reply, sent in September 2025, the Council continued to defend its approach to Mrs B’s contacts while C could not attend school.

My findings

59. I considered first that part of Mrs B’s complaint suggesting C’s school failed to make provision available for him in line with his EHC Plan. I did not consider I could uphold this part of the complaint.
60. Our previous investigation upheld a complaint made in similar terms which covered the time before January 2025, when C stopped attending school. After that, and for the time I investigated, C was not in school. So, the Council had no chance to observe any classroom provision given to C. But it did pass on Mrs B’s concerns about C’s teaching to the school. It obtained its comments, passed these on to Mrs C, who then commented further.
61. I did not consider the Council could have done more to practically investigate Mrs B’s concerns. But it should have set out its view about whether it considered the school had met its expectations to deliver C’s provision set out in Section F of his Plan, while he attended school.
62. But that said, there was no need for me to come to my own findings on this matter. This was because our earlier investigation considered this matter and upheld Mrs B’s complaint on this point.
63. The focus of this investigation was therefore to consider the duties that remained on the Council, after C became absent from school. Which was for it to consider if he had education available and accessible to him between January and July 2025, or if it needed to make provision for him.
64. The Council had potentially overlapping duties here. First, that owed to pupils with an EHC Plan under Section 42 of the Education Act. Second, that owed to pupils unable to attend school because of illness, exclusion or other reasons, under Section 19.
65. The Council had a policy designed to consider its Section 19 duty, but I found it contained an omission. It did not explain how the Council approached cases involving children with special educational needs who become absent from education, with or without an EHC Plan. Including where their absence related to their special educational needs.
66. The Council clarified that from April 2026 it put the onus on its EHCP Team to make such decisions. I did not find it had updated its policy to reflect this. However, my investigation covered an earlier time. In which case the decision on whether to make Section 19 provision for C should have rested with its Single Panel. But C’s case never went to a Single Panel meeting for discussion. I considered this in turn may have been because there was no clear policy for officers to follow.
67. This by itself, did not make the Council’s response to C’s case flawed. But I considered it may have contributed to a flawed response to his absence.
68. I found the EHCP Team had the central involvement in responding to contacts from Mrs B and C’s school. The record showed that in response:

• it encouraged the school to get in touch with EPAS which then offered its advice;
• it took part in the professionals meeting held in early May 2025 to discuss C’s case;
• it acted as liaison between Mrs B and the school in attempts to have work sent home for C;
• it sought to put in place specialist SEMH provision for C should he have returned to school.

69. None of this was inappropriate, but I considered these efforts were insufficient. Crucially, and including at the professionals meeting, the EHCP Team did not address itself to the critical questions of:

• whether C had education reasonably available and accessible to him at school;
• and if he did not, if the Council therefore had a duty to step in and arrange some provision for him given the overlapping duties it had.

70. The failure of the Council to address itself to these questions, led me to find fault.
71. I found the EHCP Team did not receive clear advice from the EPAS service. It suggested C’s case might be one for its “medical pathway” but was ambiguous on this point. It did not say how the school or EHCP Team might decide on this question nor proceed, making no mention of referring the case to the Single Panel.
72. That said, it did make the potentially helpful suggestion the EHCP Team could arrange an emergency review of C’s case. And recommended an approach to the SISS service to see what support C might need to return to school. I considered it regrettable the EHCP Team did not pursue these suggestions. In particular, I questioned the decision not to schedule an emergency review on the basis there had been no relevant changes in circumstance since the Council last reviewed C’s provision. Because since the previous review and issue of an EHC Plan, he had stopped attending school.
73. These were not these were stand-alone faults in the Council’s service. But had the EHCP Team taken up these suggestions it might have encouraged it ask the questions it did not ask, set out at paragraph 69.
74. I went on to consider the consequence of this fault. C’s case should have gone to the Council’s Single Panel for consideration of whether it needed to make provision for him. But would it have done so?
75. Here, I had to weigh several matters. First, on Mrs B’s own account it appeared that when C first stopped attending school his presentation was more acute than in later weeks (something also implied by his GP at the professionals meeting). It was unclear to me therefore if C could have accessed education before late February / early March 2025.
76. After that, I had limited evidence to inform a view on what education C might reasonably have accessed during the weeks that followed, if not in school. Eventually C’s school did make work available that he could access from home. But it said C failed to engage with that. Although that said, I recognised Mrs B made some provision for him on her own initiative, which she says he did engage with. And I do not dismiss her concerns the work sent home for C was at first difficult to access and then found unsuitable.
77. Added to this is evidence from the professionals meeting that suggested an improvement in C’s presentation after March 2025. So, I found on balance had the Council considered making provision C after this time, it would have done so. However, I considered it unlikely C could have managed a full-time provision.
78. I also had to take account of the breakdown in relations between Mrs B and the school. This was relevant because had the Council stepped in to provide alternative provision, it would have done so in concert with the school to support C’s reintegration. It explained this in its Section 19 policy where the Single Panel agreed such provision. I was not confident Mrs B would have gone with such an approach. She gave the school a clear message in February 2025 that she did not want it to contact her. There was no indication later that her approach to the school became more conciliatory. While I recognised Mrs B’s reasons for this approach, I found it would always have likely hampered C’s access to education. I noted that during a previous absence from school for C, arrangements worked well for the school sending work home for him. But I found no evidence Mrs B bought this to the attention of the Council or the school during C’s period of absence under investigation.
79. I considered this too may have impacted C’s access to education, had the Council offered alternative provision to him. But I did not find the consideration set out in paragraph 78 outweighed that set out in paragraph 77. So, I found the Council’s fault had led to a loss of education provision for C.
80. I therefore recommended a remedy for this complaint following the approach set out in the Ombudsman’s guidance on remedies (Guidance on remedies - Local Government and Social Care Ombudsman). This suggests that where a child has lost education provision because of fault by the Council, we should adopt a tariff approach using a figure of between £900 and £2400 for each school term impacted. To decide the sum, we will consider:

• the age of the child;
• if the loss of provision was in whole or in part;
• whether it is likely but for the fault the child would have accessed full-time provision;
• the impact also on the child’s parent who complains.

81. In this case I took account that:

• C was in the final year of his primary education, although I did not find his absence from school impacted on planning for the secondary phase of his education;
• the only access to education C had was what Mrs B provided on her own initiative;
• I did not consider C could have accessed full-time education;
• Mrs B’s actions would also have impacted any provision made for C.

82. I considered a sum of £1000 a term should apply therefore for a term and a half.
83. My recommendation did not include any loss of earnings Mrs B had while she was at home supporting C. I considered those arose from her need to care and support C when he could not go to school, which in turn arose from his special educational needs preventing his attendance.
84. Finally, I considered the Council’s handling of Mrs B’s complaints. I found that at both stage one and stage two it met our expectations of the time taken to respond to Mrs B’s complaint. No injustice arose from the slight delay in it acknowledging her stage one complaint.
85. But I found fault in how it responded to Mrs B’s complaint about the suitability of schoolwork provided to C. After she raised this matter in June 2025, the Council told her it would “look into” her concerns. But it did not reply. This was a fault that I considered caused Mrs B some modest injustice. It added unnecessarily to her time, trouble and frustration when raising her concerns. Although, with C having now left the school and embarked on a new chapter in his education, I did not recommend the Council revisit Mrs B’s complaint about schoolwork.

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Agreed Action

86. The Council accepted the findings set out above and agreed that within 20 working days this decision it would:
1. provide an apology to Mrs B. Our guidance on remedies sets out our expectations for how organisations should apologise effectively to remedy injustice. The Council agreed to consider this guidance in making its apology;
2. make a symbolic payment to Mrs B of £1600. I recommended it pay £1500 for C’s lost provision and £100 to recognise the avoidable frustration, time and trouble caused to Mrs B by the fault in its complaint handling.
87. The Council will provide us with evidence when it has complied with these actions.
88. Finally, I considered what wider lessons the Council might learn from this complaint. I noted another recent investigation by this office had resulted in the Council agreeing to create an action plan to ensure officers knew how to meet its statutory duties under sections 19 and 42 of the Education Act. I considered this would cover its recording of decisions, actions taken and communication to ensure transparency and accountability. So, the implementation of such a plan was likely to reduce the risk of the fault found in this case recurring.
89. But in addition, I recommended the Council amend its Section 19 policy. I wanted it to include an explanation of its approach towards the absence from education settings of pupils with special educational needs, including those with EHC Plans.
90. I was pleased to note the Council not only agreed this recommendation but issued an amended policy before completion of this investigation, in September 2026. Its revised policy took account of my recommendation and the revised policy (available on its website) includes information for parents and schools on how they can raise concerns about children with special educational needs (and / or an EHC Plan) missing education. It explains how it will address those concerns and factors it will take account of in deciding whether to offer alternative provision.

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Final Decision

91. For reasons set out above I upheld this complaint finding fault by the Council had caused injustice to Mrs B and C. The Council accepted this finding and agreed to take action to remedy that injustice and made improvements to its service. I therefore completed my investigation satisfied with its response.

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Investigator's decision on behalf of the Ombudsman