Summary: Miss X complained the Council took too long to complete an Education Health and Care (EHC) Needs Assessment and to issue a EHC Plan for her daughter, Y. Miss X also complained Y could not access education between September 2023 to July 2024 and the Council did not properly consider her complaints. We found fault by the Council on all elements of Miss X’s complaint. The Council agreed to apologise and make a symbolic payment to Miss X and Y to remedy the injustice caused to them by the fault we found.

The complaint

1. Miss X complained the Council failed to comply with the statutory timescales when completing her daughter, Y’s, Education Health and Care (EHC) Plan Needs Assessment and to issue her with a final EHC Plan. She also stated the current draft plan is inadequate and the Council had failed to ensure the provision in the plan is provided.
2. Miss X also complained the Council failed to properly investigate her complaints or reply within its published timescales.
3. Miss X states the Council’s actions have resulted in her child missing education and provision to meet her needs. She also stated her child’s physical and mental health has deteriorated. Miss X says that her and her family have been caused financial hardship, stress, anxiety, worry and been put to avoidable time and trouble in pursuing this matter.

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The Ombudsman’s role and powers

4. We normally expect someone to refer the matter to the Information Commissioner if they have a complaint about data protection. However, we may decide to investigate if we think there are good reasons. (Local Government Act 1974, section 24A(6), as amended)
5. 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 SEND Tribunal in this decision statement.
7. We investigate complaints about ‘maladministration’ and ‘service failure’. In this statement, I have used the word fault to refer to these. 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)
8. If we are 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(i), as amended)
9. 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 have and have not investigated

10. I have investigated Miss X’s complaint about its handling of Y’s case from September 2022 to July 2024. I decided to exercise discretion to investigate this period despite Miss X having a right of appeal to the SEND tribunal in January 2024. This is because the Council told Miss X it would amend Y’s final EHC plan immediately after it was issued. Therefore, I do not consider it was reasonable to expect Miss X to have used her right of appeal.
11. I have not investigated Miss X’s concerns about the final EHC Plan issued in July 2024. Miss X has a right of appeal to the SEND tribunal and I consider it is reasonable for her to use this to address any concerns she has about the contents of the plan.
12. I have not investigated Miss X’s concerns about breaches of data protection. The Information Commissioner is the body which considers complaints about data protection.

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How I considered this complaint

13. As part of investigation I have:
• discussed the complaint with Miss X and considered the details of her complaint;
• made enquires of the Council and considered its response;
• had regard to the relevant legislation and guidance;
• had regard to our Guidance on Remedies; and
• set out my initial thoughts on the complaint in a draft decision statement and considered Miss X and the Council’s comments in response.

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What I found

14. 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 what arrangements should be made to meet them. The EHC Plan is set out in sections. We cannot direct changes to the sections about their needs, education, or the name of the educational placement. Only the tribunal or the council can do this. 

Timeframes and process for EHC needs assessment

15. Statutory guidance ‘Special educational needs and disability code of practice: 0 to 25 years’ (‘the Code’) sets out the process for carrying out EHC assessments and producing EHC Plans. The guidance is based on the Children and Families Act 2014 and the SEN Regulations 2014. It says the following: 

• Where the council receives a request for an EHC needs assessment it must decide whether to agree to the assessment and send its decision to the parent of the child or the young person within six weeks. 
• The process of assessing needs and developing EHC Plans “must be carried out in a timely manner”. Steps must be completed as soon as practicable. 
• If the council goes on to carry out an assessment, it must decide whether to issue an EHC Plan or refuse to issue a Plan within 16 weeks.
• If the council goes on to issue an EHC Plan, the whole process from the point when an assessment is requested until the final EHC Plan is issued must take no more than 20 weeks (unless certain specific circumstances apply);  
• Councils must give the child’s parent or the young person 15 days to comment on a draft EHC Plan and express a preference for an educational placement.
• The council must consult with the parent or young person’s preferred educational placement who must respond with 15 calendar days.

16. There is a right of appeal to the Tribunal against decisions including:
• the description of a child or young person’s SEN, the special educational provision specified, the school or placement or that no school or other placement is specified.

Personal budgets

17. A Personal Budget is the amount of money the council has identified it needs to pay to secure the provision in a child or young person’s EHC Plan. One way that councils can deliver a Personal Budget is through direct payments. These are cash payments made to the child’s parent or the young person so they can commission the provision in the EHC Plan themselves.
18. A child’s parent or the young person has the right to request a Personal Budget when the council has completed an EHC needs assessment and confirmed it will prepare an EHC Plan. They may also request a Personal Budget during a statutory review of an existing EHC Plan.

19. The final allocation of a Personal Budget must be sufficient to secure the agreed provision specified in the EHC Plan and must be set out as part of that provision.

20. If the council refuses a request for a direct payment, it must set out the reasons in writing and inform the child’s parent or the young person of their right to request a formal review of the decision.

Alternative Provision

21. Councils must arrange suitable education at school or elsewhere for pupils who are out of school because of exclusion, illness or for other reasons, if they would not receive suitable education without such arrangements. [The provision generally should be full-time unless it is not in the child’s interests.] (Education Act 1996, section 19). We refer to this as section 19 or alternative education provision.
22. The courts have considered the circumstances where the section 19 duty applies. Caselaw has established that a council will have a duty to provide alternative education under section 19 if there is no suitable education available to the child which is “reasonably practicable” for the child to access. The “acid test” is whether educational provision the council has offered is “available and accessible to the child”. (R (on the application of DS) v Wolverhampton City Council 2017)
23. The statutory guidance says the duty to provide a suitable education applies “to all children of compulsory school age resident in the council area, whether or not they are on the roll of a school, and whatever type of school they attend”.
24. Suitable education means efficient education suitable to a child’s age, ability and aptitude and to any special educational needs he may have. (Education Act 1996, section 19(6))
25. We have issued guidance on how we expect councils to fulfil their responsibilities to provide education for children who, for whatever reason, do not attend school full-time. Out of school, out of sight? published July 2022
26. We made six recommendations. Councils should:

• consider the individual circumstances of each case and be aware that a council may need to act whatever the reason for absence (except for minor issues that schools deal with on a day-to-day basis) – even when a child is on a school roll;
• consult all the professionals involved in a child's education and welfare, taking account of the evidence when making decisions;
• choose (based on all the evidence) whether to require attendance at school or provide the child with suitable alternative provision:
• keep all cases of part-time education under review with a view to increasing it if a child’s capacity to learn increases:
• work with parents and schools to draw up plans to reintegrate children to mainstream education as soon as possible, reviewing and amending plans as necessary:
• put the chosen action into practice without delay to ensure the child is back in education as soon as possible;

27. Where councils arrange for schools or other bodies to carry out their functions on their behalf, the council remains responsible. Therefore, councils should retain oversight and control to ensure their duties are properly fulfilled.

Suffolk County Council Complaints Policy

28. This sets out how the Council will consider complaints made to it. The policy says that a Stage One complaint will be responded to in 20 working days and Stage Two complaint within 25 working days or 65 working days for complex cases.
29. Stage Two complaint responses will be adjudicated by the Director or Assistant Director of the service complained about.

What happened

30. This section sets out the key events in this case. It is not intended to be a detailed chronology.
31. Y has Global Development Delay and learning difficulties. She is diagnosed with several health conditions which require regular hospital appointments and support.
32. In September 2022 Y was attending a mainstream school and was assigned a special educational needs coordinator (SENCO).
33. On 5 September Miss X requested an Educational Health Care Needs Assessment (EHCNA).
34. On 26 October the Council told Miss X it would carry out an Education Health and Care (EHC) Plan assessment for Y.
35. In February 2023 Y’s SENCO stated that her school would not be able to meet her needs when she transferred to Key Stage One in September. She said that a busy mainstream setting was not appropriate for Y, and she needs to learn in a small group within a specialist setting.
36. On 28 March 2023 the Council issued a draft EHC Plan for Y. The draft plan contained details about another child. Miss X asked the Council to remove the incorrect details and send a corrected plan to her.
37. Miss X chased the Council for a corrected copy of the draft EHC Plan throughout May and early June.
38. On 20 June the Council told Miss X that it would be finalising Y’s draft EHC Plan that week.
39. On 7 July Y’s school held an annual review for her. The Council did not attend. Documents from the review show Y’s school said it could not meet her needs because she finds the school environment overwhelming and distressing. It said Y requires teaching in a small group. It also said that Y requires teaching in a specialist environment. It said that if a placement could not be found for Y it would require an additional adult to help teach her until a placement could be found.
40. The review documents also say Miss X asked for a Personal Budget through Direct Payments so Y could have additional resources to support her health and education.
41. On 3 August the Council issued Y’s amended draft EHC Plan. Miss X requested amendments to the plan and asked for a meeting to discuss this.
42. Also, in August the Council consulted with three specialist placements for Y to see if they could meet her needs.
43. On 14 September Miss X and her mother (who advocates on behalf of Y) met with the officer’s handling Y’s case. The meeting ended without resolution of Miss X’s concerns. No minutes were taken of the meeting.
44. On 25 September Y’s school said it would provide a soft start for her and a part-time timetable. However, Miss X said Y would not return because attending was detrimental to her wellbeing.
45. In October Miss X received a letter from Y’s Specialist Community Paediatrician saying she was on the waiting list to see a clinical psychologist for anxiety issues, which she has.
46. On 22 December the Council issued a new draft EHC Plan for Y. Miss X said she was unhappy with the plan.
47. On 5 January 2024 the Council issued Y with a final ECH Plan. The plan named mainstream in Section I.
48. Miss X was unhappy with the plan and asked for amendments. She also provided additional medical documents. The Council agreed to consider the requested amendments. It was also agreed that Miss X would provide details of her proposals for Y to have elective home education (EHE) or Education Other Than At School (EOTAS).
49. On 31 January the Council’s panel considered Miss X’s proposal for EHE and EOTAS. It said it needed more information to decide the request. It asked Miss X to provide this.
50. In February a meeting was arranged to discuss Miss X’s proposal for EOTAS. Miss X cancelled the meeting, and it was rearranged for March.
51. On 10 April the Council’s panel reconsidered Miss X’s request for EOTAS. It refused the request.
52. On 19 April the Council issued a new draft EHC Plan. Miss X was unhappy with the contents of the plan and the time taken to provide it. She asked for a meeting to discuss her concerns.
53. On 29 April Miss X meet with the Council to discuss the draft plan and her request for EOTAS. It was agreed the plan would be amended to reflect additional information provided by Miss X. The Council asked Miss X to provide additional information to help it decide her request for an EOTAS package.
54. On 15 May a further meeting was held between the Council and Miss X to discuss the contents of the draft ECH plan.
55. In June Miss X requested further additions to the EOTAS package.
56. On 12 July the Council’s panel agreed a personal budget to deliver Miss X’s requested EOTAS package for Y.
57. Also, on 12 July the Council issued a final EHC plan for Y. The plan said Y would receive:
• Two 1:1 sessions of 30 minutes per term with a Speech and Language Therapist. Y’s education provider should be present at the 1:1 sessions and provide 15-20 minutes of carry over work three times per week.
• Personalised, person-centred support to help Y with her communication and language skills including embedded daily sessions of 5-10 minutes throughout the day with her education provider under the guidance of external professionals.
• Daily 15-20 minutes evidence-based interventions to help Y with literacy and numeracy skills and delivery of appropriately differentiated curriculum with twice weekly 15 minutes sessions to deliver this.
• Weekly and personalised sessions to help Y develop her social and emotional literacy delivered by Y’s education provider throughout the day in line with the agreed EOTAS package.
• 3 daily 10-minute sessions of 1:1 support to provide alphabet exercises as advised by a physiotherapist and daily 15-minute session to develop Y’s finger coordination.
• 1:1 support throughout the day to help develop Y’s sensory and physical skills delivered by Y’s education provider or key adult.

Miss X’s complaints

58. In June 2023 Miss X made a stage one complaint to the Council. She complained that:
• She was still waiting for a final EHC plan to be issued for Y;
• the draft EHC Plan issued by the Council contained the details of another child;
• the Council did not attend Y’s annual review; and
• the Council failed to reply to her communications.

Miss X asked for a meeting to discuss matters.

59. The Council replied in late August and did not meet its timescales for replying to stage one complaints. It said:
• It was sorry for the delay in issuing Y’s EHC plan and recognised this meant Y did not have a placement for September.
• It does not routinely attend annual reviews of children who are under special education needs support.
• It had taken appropriate action regarding the data breach which occurred when it included another child’s information in Y’s draft EHC Plan.
• It has introduced a new system for recording contact to its Family Services department and this should prevent a recurrence of the communication issues faced by Miss X.
• Y has a new caseworker who will contact Miss X about her case.

It offered Miss X £500 in recognition of the lack of communication with her and the delays in in issuing Y’s final EHC Plan and acknowledged this frustrated her appeal rights to the SEND tribunal.

60. In late September Miss X escalated her complaint to stage two. She complained about the Council’s handling of the meeting held in September. She said officers:
• were unable to tell her what had been done to rectify the data breach;
• ignored her parental preference and suggestion of EOTAS. She said officer’s spoke over her and her mother and said they would put Y back into school if any agreed EOTAS was not providing her with an adequate education.
• ignored her input about Y’s needs and officers spoke over her. She felt intimidated when suggesting future settings for Y’s education.
• were unprepared for the meeting. There was no agenda and the meeting moved between topics with no resolution or action plan. No minutes were taken.
• could not explain what the £500 offered in its stage one response was for.
• did not answer queries about details in Y’s draft EHC Plan including concerns about the need for 1:1 support and her health needs.

She also complained that:

• delays in issuing a final EHC Plan meant Y did not have a school place for September.
• the Council had consulted placements that were not suitable for Y and did not ask her about them first.
• the Council should attend annual review meetings.
7. The Council asked an external Investigating Officer (IO) to consider the complaint. As part of his investigation, he met with Miss X. He set out his findings in a report. He said:
• There was no evidence Y’s details had been shared with a third party despite Miss X receiving details of another child in a draft ECH plan. It said Miss X should have been referred to the Information Commissioner’s Office to pursue her concerns about this matter.
• Explained he could not comment on the suitability of the draft EHC plan, assessments that informed the plan, SALT provision, decisions on whether to grant Y a Personal Budget or conclusions about what is or is not educationally or clinically appropriate for Y. These are matters can be pursued by challenging the final EHC plan via the SEND Tribunal. However, he acknowledged the Council’s delay in issuing a final plan was frustrating Miss X’s right to appeal.
• The Council failed to meet the statutory timeframes for finalising Y’s EHC plan and this has, in turn, delayed Miss X’s right of appeal.
• The Council has the right to explore all possible options for finding Y a suitable specialist placement.
• The Council did not have a statutory obligation to attend Y’s annual review.
• Communication from the Council was not of an acceptable standard, and it did not keep sufficient oversight of Y’s case.
• The Council did not meet its published timescales for replying to Miss X’s complaints.
• There were shortcomings in how the Council had tried to resolve Miss X’s concerns following her stage one complaint including the 14 September meeting.
• The Council took too long to return documents to Miss X but stated they were safely stored, and no data breach occurred.
8. On 16 February the Council replied to Miss X’s stage two complaint. It said it accepted the IO’s conclusions. It increased the payment offered to Miss X to £1000 in recognition of her frustrated appeal rights and the distress and time and trouble caused to her.
9. Miss X remained unhappy and complained the Ombudsman. She reiterated her grounds of complaint and added the following matters:
• Y has not received an education since the beginning of the September 2023 academic year or any specialist provision to meet her needs.
• The IO was not qualified to consider her complaint and did not provide her with identification when she met with him; and
• The officer who replied at Stage two was involved in the complaint.
10. We made enquiries of the Council. In its response it said:
• It issued a final EHC Plan for Y in January 2024 but following contact from Miss X it agreed to make amendments. It would have issued a new amended final EHC Plan sooner, but Miss X wanted a decision on her proposed EOTAS package before it did so.
• It took too long to decide Miss X’s requests for a personal budget. However, Miss X’s requests for a personal budget altered over this period and this contributed to the delays.
• It accepted there were delays in issuing Y’s final EHC Plan in January 2024. However, it said it had worked with Miss X during this period and this contributed to the delays.
• It worked with Y’s school so she could attend but Miss X refused for her to attend. It told Miss X it was expected that Y would attend her school. It made an offer of education through an alternative provider but Miss X also refused this and has not acted on the Council’s offer that she could explore this at any time.
• It acknowledged it is not providing the SALT provision set out in Y’s final ECH Plan. It is working to arrange provision.
• The external IO is an experienced Investigator who is a specialist in Special Educational Needs. The IO was highly suitable to consider Miss X’s complaint.
• The Adjudicating Officer who replied at Stage Two has responded to contact from Miss X and referred matters to other staff, as appropriate. She was not involved in any decision making on her case.

Finding

Delay in completing the EHCNA

65. The Council should take no more than 20 weeks to issue a final EHC Plan from the time an EHC needs assessment is requested. Miss X’s request for an EHC Needs Assessment for Y was made on 5 September 2022 and so, the final EHC Plan should have been completed by 23 January 2023. The Council did not issue a final EHC Plan until 12 July 2024. This is a significant delay of 18 months. This is fault by the Council.
66. I note the Council issued a final EHC Plan on 5 January 2024. Miss X immediately raised concerns about the plan and in response the Council said it would amend it. Therefore, I do not consider that a final EHC Plan was issued at this time. Consequently, I do not consider it was reasonable for Miss X to use her right of appeal to the SEND Tribunal regarding her concerns about the plan given the Council said it would amend it.
67. The Council’s failure to meet the statutory timescales for completing Y’s EHC Needs Assessment have caused Miss X distress, frustration and put her to the avoidable time and trouble. It also delayed her ability to exercise her right of appeal to the SEND tribunal.

Missed Education

68. Y has been out of school since September 2023. Miss X was clear that she considered Y’s school could not meet her needs and that attending would be detrimental to her wellbeing. The Council have stated that Y’s school offered Y a soft start and part-time timetable in September 2023 and so a suitable educational was available to Y.
69. I recognise that Miss X chose to remove Y from her school however I do not consider that a suitable education would have been available to Y if she had not done so. In February 2023, the SENCO of Y’s school was clear it would not be able to meet Y’s needs once she entered Key Stage One (which she did in September 2023). She also clarified that even with the help of external agencies it would not be able to provide the level of support Y needs. In the July 2023 Annual Review Y’s SENCO said that she needed a specialist unit to meet her needs. She also said that if such a placement could not be found for Y then she would need an additional adult to support her and that she would not be able to enter Key Stage One. No evidence has been provided to suggest that an additional adult was made available to Y from September 2023. For these reasons I am not persuaded that, on the balance of probabilities, that but for Miss X’s decision Y not attend her school, a suitable education would have been available to her.
70. The Council also says it did not provide Y with alternative education because it did not receive any medical information saying Y should not attend school. However, I have seen nothing to suggest the Council sought to clarify if this was the case. A letter from Y’s Specialist Community Paediatrician states that Y has anxiety, but the Council does not appear to have made enquiries as to whether her anxiety was severe enough to prevent her from attending school. The Council should have made suitable enquiries to determine if Y could attend her school or not. Its failure to do so is fault.
71. For the above reasons I consider the Council was aware from September 2023 that Y was not receiving a suitable education. The Council should have provided her with an alternative education between September 2023 and July 2024. Its failure to do so is fault. The Council’s failure means Y missed out on education and support for a whole school year. This is a significant injustice.
72. The final EHC Plan issued for Y sets out the special educational provision Y requires. This includes SALT provision and daily 1:1 sessions to support Y’s sensory, physical, communication, literacy and numeracy skills. On the balance of probabilities, I consider the special educational provision set out in Y’s final plan would have been provided to her sooner, save for the identified delay. The Council’s failure to complete the EHC Plan process in accordance with the statutory timeframes means Y missed out on special educational provision between January 2023, when Y’s final EHC Plan should have been issued, and July 2024 when the final plan was issued. This is a significant injustice.

Personal Budget

73. Miss X initially requested a personal budget for Y as part of the July 2023 annual review. I have seen nothing which demonstrates the Council considered this request nor have I seen a letter providing a decision on her request. This is fault.
74. At the September 2023 meeting Miss X made a further request for a personal budget. Information provided shows this was not heard by the Council’s panel until late January 2024 and a decision not made until July. This is delay by the Council.
75. It is evident the delay in considering the personal budget request is largely due to the lack of a final ECH Plan clearly setting out the provision Y needs. Considering a request for a personal budget will be frustrated if the provision needed has not been agreed. I note the personal budget requests made by Miss X changed between January 2024 and July 2024, however with the ECH Plan remaining at draft stage and subject to amendments it is not surprising Miss X’s request altered.

Communications with the Council

76. Miss X says she did not receive replies to her communications from the Council or updates on the progress of Y’s case. The Council accepts it did not communicate with Miss X as it should have. This is fault. As a result, Miss X was caused frustration, uncertainty and put to avoidable time and trouble. This is injustice.
77. Miss X has raised concerns about a meeting held on 14 September 2023. There are no recorded minutes of the meeting. I would expect the Council to record the details of the meeting. Its failure to do so is fault. The lack of minutes means there is insufficient evidence available to come to a view on Miss X’s concerns about the conduct of the meeting. However, it is clear the meeting did not provide a substantive resolution with Y’s final EHC Plan being issued a significant time after the meeting.

Complaints

78. Miss X says the Council took too long to reply to her complaints. I agree. The Council did not meet its published response timescales. This caused Miss X further frustration.
79. Miss X has raised concerns about the Investigating Officer who considered her complaint. The Council’s response to our enquiries addressed these matters and I am satisfied he was a suitable person to investigate her stage two complaint.
80. The Council’s Stage Two response came from an officer who had previously assisted Miss X with Y’s case. I acknowledge the officer did not make any substantive decisions on Y’s case and was, as per the Council’s complaints policy, the correct person to answer the complaint. However, I consider it would have been appropriate, under the circumstances, for another officer to have adjudicated the Stage Two complaint.

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Agreed action

81. Within one month of my final decision the Council will:
• Apologise to Miss X and Y for the distress, frustration and lack of education caused by the fault I have found; and
• Pay Miss X £7700, made up of:

1. £5400 for the benefit of Y’s education. This payment is in recognition of the education Y missed out on, including specialist provision, between September 2023 and July 2024. The payment has been worked out £1800 per term during this period.
2. £1800 to recognise the frustration, distress and uncertainty caused by the delays in issuing Y’s EHC plan. The payment also recognises Y did not receive any specialist provision between January 2023 and July 2023.
3. £500 to recognise the frustration and distress caused to Miss X in having to pursue this matter.

82. In arriving at the recommended payment, I have had regard to:
• Our guidance on remedies which suggests a financial remedy of between £900 to £2400 per term to acknowledge the impact of the loss of education;
• the impact on Y of missing education and provision in her EHC plan and the costs incurred by Miss X in providing Y with education while she was out of education; and
• the remedy must cover both her missed education and the provision in her EHC plan.
83. I have decided not to make service improvement recommendations on this complaint. This is because we have recently made recommendations to the Council on similar issues. In February 2023 we issued a public report finding fault with the Council’s failure to provide alternative education. We recommended the Council review its policies and procedures. We also recommended the Council carry out in person training for all managers and staff members responsible for arranging alternative provision.
84. More recently Ofsted and the Care Quality Commission (CQC) jointly inspected the Council’s SEND services and published a report in January 2024. This report identifies “widespread and/or systemic failings” in the service. The Council has to submit a priority action plan to Ofsted and CQC setting out how they will address the priority actions and areas for improvement. This includes taking urgent action to improve the timeliness and quality of the EHC Plan process.
85. The Council should provide us with evidence it has complied with the above actions.

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Final decision

86. I have found fault by the Council, which caused injustice to Mrs X and Y. I have not completed my investigation.

Investigator’s decision on behalf of the Ombudsman

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Investigator's decision on behalf of the Ombudsman