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Original poster

We cracked our LA's hidden EHCP "Banding Matrix" Excel formulas - 52% Autism cut & £12k cap

3 replies

iamacarpet · Yesterday 10:50

Hi everyone,

I am a parent in Derby currently in the middle of a SEND Tribunal appeal for my 8yo DS (who is 2e - working at ARE academically, with Autism, ADHD, PDA, SPD, and Dysgraphia). I wanted to share something we uncovered last night because I know dozens of LAs across England are rolling out similar "High Needs Banding Matrices" to calculate Element 3 top-up funding, and so many of us are told "the matrix says Band X" without being allowed to see how the maths actually works.

For 8 months, Derby City Council fought our FOI requests for their Matrix spreadsheet - first claiming for 6 months that confirming whether it existed would threaten "National Cybersecurity" (Section 31!), and then having their Monitoring Officer delete the active formulas under Section 36 claiming parents and schools would "game the system" if we saw how scores were calculated.

Then yesterday, following an MP intervention, the DfE sent us a letter (stamped OFFICIAL - FOR PUBLIC RELEASE) confirming that the DfE has NEVER approved, endorsed, or reviewed Derby's Matrix, reminding the LA that "A local authority cannot force a child's provision to fit into a pre-determined financial band", and mentioning that the Council had quietly uploaded the spreadsheet 9 clicks deep on its Local Offer webpage on 4 September.

When the Council uploaded the Excel workbook (banding-matrix.xlsx), they deleted the active formulas from Row 4. However, they accidentally forgot to delete the hardcoded "FOR OFFICE USE ONLY" calibration rows at the bottom of Tabs 2, 3, and 4! Because Tab 2 plugs a maximum score of 4 into every cell, and Tab 3 displays the exact weighted points that come out, dividing Tab 3 by 4 unlocked 100% of their hidden formulas.

Here is how the spreadsheet is mathematically rigged against neurodivergent children:

  1. NEURODIVERGENT & DYSLEXIA WEIGHTINGS SECRETLY SLASHED BY 52% TO 92%
The formula is: Base Points (Row B=20, Row C=40, Row D=100, Row E=360) x Category Weighting x Score/FIDS (1 to 4). While Physical, Hearing, and Vision impairments are rightly recognised at a 100% standard benchmark with an automatic multiplier of 4 (so a single 'Severe' Row D need automatically scores 400 points = Band 5 / £5,000 top-up), the Council secretly slashed the Category Weightings for all neurodivergent and learning domains:
  • Emotional Wellbeing & Mental Health: 75% weight (-25% cut)
  • Social Behaviour (which is still explicitly titled "Social behaviour NOT SEND" in Cell AE2 of Tabs 2 & 3!): 75% weight (-25% cut)
  • Autism (Social & Communication), Speech & Language, and Learning Readiness: 48% weight (-52% cut)
  • Sensory Processing Needs (SPD): 25% weight (-75% cut - and they copy-pasted the exact same 24-word sentence into both the Moderate and Severe rows!)
  • Specific Learning Difficulties (Dyslexia, Dyscalculia, Dysgraphia, DCD/Dyspraxia): 8% weight (-92% cut) - AND they left the 'Severe' (Row D) and 'Profound' (Row E) cells completely BLANK (0 points)! Even if a child has the most severe Dyslexia or Dysgraphia in Derby, the maximum single-row score is 12.8 points, when you need 189 points just to reach the lowest £1,000 funding band (Band 3).
  1. THE "REASONABLE ADJUSTMENTS / MASKING" CATCH-22 (1-4 FIDS FILTER)
On top of slashing the category weightings, all neurodivergent domains are subjected to a 1-to-4 "FIDS" multiplier (Frequency, Intensity, Duration, Severity) typed into a single cell with no rule on how to average them. In the Council's SENCO training slides (Slide 11), a FIDS score of 2 (which cuts a child's points by a further 50%) is defined under Intensity as "Manageable with support strategies." So if a school puts a TA, visual timetable, or sensory breaks in place so an autistic child can manage - or if the child masks until 3:30 pm - the panel scores them a 2 and cuts their funding points in half because the support is working! A child with Severe (Row D) Autism scored at FIDS 2 gets just 96 points (Band 1 = £0 top-up funding).
  1. BUILT-IN GATEKEEPING TRAPS FOR 2e & AUTISTIC CHILDREN
  • In Column 6 (Autism / Social & Communication), Row A (0 points) is explicitly defined as "Mild / Moderate needs, for example, there may be a need for support such as circle of friends or comic strip communications" (whereas Row A in every other column is "No significant needs").
  • In Column 9 (Learning Readiness), Row A (0 points) is defined as "Working at age related expectations", and Rows B, C, D, and E all require a mandatory "learning delay" alongside executive dysfunction. So cognitively able autistic/ADHD children with severe executive dysfunction automatically get 0 points.
  1. THE SECRET £12,000 MAINSTREAM SETTING CAP
On their public website, the Council publishes the tariff table up to £20,000 (Band 20), leading parents and schools to believe a mainstream pupil can receive up to £20k. Hidden at Rows 27-31 of Tab 4 inside the Excel file is a table marked "For office use only - indication of min and max amounts based on establishment only", which secretly hard-caps all Mainstream schools at £12,000 (Band 12), locking mainstream pupils out of Bands 13-20 completely. (In our case, DS's mainstream primary school told the LA in their statutory consultation response in January that he needed over £20,000 of 1:1 proximity supervision after he broke his arm and dislocated his elbow on playground equipment. The LA refused it, leaving him with a TA only until 11:30 am and zero support every lunchtime and afternoon).
  1. CAUGHT BY ADOBE PDF METADATA (THE 90-MINUTE LEGAL THREAT)
In March 2026 (under FOI) and in a summer Pre-Action Protocol reply from their external solicitors (Browne Jacobson), the Council admitted it held NO Equality Impact Assessment (EIA) for the Matrix (which launched in June 2025). On Sub-Page 9 of their website, we found an undated EIA PDF signed by the Director of Children's Services ticking "Positive impact = Yes" across every disability group and leaving "Date of assessment" blank on Page 1. They forgot to scrub the embedded Adobe XMP metadata - which proves it was created in Word on 10 August 2026 and converted to PDF on Friday 21 August 2026 at 3:24 pm... just 90 minutes before Browne Jacobson emailed me a formal legal threat letter at 4:55 pm claiming our campaign statements were "false"!

We have put together a full, anonymised 12-Page Forensic Breakdown & Visual Guide PDF (with charts on Pages 1-2 and the exact word-for-word criteria and point thresholds for all 10 categories on Pages 3-12) so any parent or SENCO can see how these matrices work under the hood:

drive.google.com/file/d/15kHuHUTbN8HAPjfiw291Ou7DgFlXyC4s/view?usp=sharing

Are other parents on here fighting similar "banding matrices" and FIDS filters in your LA? And for anyone going to Tribunal in an LA that uses a matrix, definitely check the hidden tabs in their spreadsheet!

OP posts:
roaringdragon · Yesterday 12:31

Focus on the provision required being detailed, specified and quantified in F rather than the funding. That way, it can be enforced, including via JR if necessary, and lack of funding/resources/staffing &/or funding bands are not lawful excuses.

It is well known LA funding bands are nonsense with LAs trying to impose unlawful caps (that can be challenged. They aren’t actually the most that can be provided.), inadequate funds and LAs trying to give different needs different weightings. Thankfully, the law means regardless of what funding bands LAs want to use, what is detailed, specified and quantified in F must be provided.

Original poster
iamacarpet · Yesterday 16:16

Thanks @roaringdragon - you are completely spot on about Section F and s.42 CFA 2014, and that is the exact legal hammer we are using at Tribunal (and for JR if they still fail to secure it).

What we found in the Council's internal SOP ("Matrix process. final") and SENCO training slides (Slide 14) is how they use this spreadsheet to rig Section F and school consultations behind the scenes before the final EHCP is even issued:

  1. Their internal process document shows the panel calculates and logs the Matrix funding band with Finance BEFORE they even send the draft plan out to consult schools.
  1. Then, when the draft Section F is written, they strip out or water down the quantified hours so the provision fits inside that pre-calculated Matrix band (and when our mainstream primary school responded to the statutory consultation stating DS needed full-time 1:1 arm's-reach supervision costing £20k+ to stay safe, the Head of Service flatly refused to include or fund it, leaving him with a TA only until 11:30 am and unstaffed every lunchtime and afternoon).
  1. Worse still, many mainstream headteachers and SENCOs don't realise that the Matrix bands aren't the legal limit - so when the LA tells a school "the Matrix only awards Band 3 (£1,000) or caps mainstream at £12,000", schools assume their hands are tied and tell parents they can't staff the afternoon!

That's actually why the DfE letter we got yesterday (Ref: 2026-0092090, stamped OFFICIAL - FOR PUBLIC RELEASE) is so useful alongside the spreadsheet breakdown - the DfE explicitly put in writing that:

"The department has not approved, endorsed or reviewed Derby City Council's High Needs Banding Matrix... An Education, Health and Care Plan (EHCP) must explicitly specify and quantify the child's needs first. A local authority cannot force a child's provision to fit into a pre-determined financial band."

We're hoping that putting this 12-page breakdown and the DfE letter into the hands of local parents and SENCOs stops schools and families being gaslit into accepting watered-down Section F wording just to fit the Council's secret spreadsheet!

OP posts:
roaringdragon · Yesterday 16:23

That is all completely normal LA behaviour, I’m afraid. It doesn’t make it right or lawful, but is commonplace across all LAs and well known about in the SEN world. It is why so many EHCPs contain vague and woolly wording and why checking the draft is so important. It is why so many LA reports sought during the EHCNA are inadequate. It is why so many have to appeal.

Schools not understanding SEN law isn’t uncommon either. It is why the advice is not to trust the school on matters of law or EHCPs. They are often schooled in LA ‘policy’.

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