This is normal, I am afraid. I have seen thousands of drafts from across the country; I am yet to see a draft that does not need any amendments.
You propose the amendments required and reference the evidence.
Go through all the evidence with highlighters. Highlight all DS’s special educational needs in one colour and all the provision to meet DS’s needs in another colour. Each need should have corresponding provision. There should also be corresponding outcomes.
Then go through the draft and make sure all the highlighted needs are in B and the highlighted provision is in F. Make a note of anything the LA has omitted from the draft, any needs without corresponding provision, any woolly and vague wording, and anything the reports have failed to include.
When checking F look out for vague and woolly wording such as “access to”, “or equivalent”, “opportunities for”, “as appropriate”, “would benefit from”, “regular”, “up to”, “would be useful/helpful”, “such as”, “e.g.”, “etc.”, “as required”, “as advised”, “key adult(s)”, “small group”. If provision isn’t detailed, specified and quantified, the EHCP isn’t worth the paper it is written on and cannot be enforced.
When you come across vague and woolly wording, check the reports to see if they are vague and woolly or if the LA has watered down provision. Provision in EHCPs is taken from the reports, so if the reports are vague and woolly, the EHCP will be too. If the reports are vague and woolly, ask the LA to go back to the report writer(s) to make the reports detailed, specified and quantified. If the LA has watered down provision, make sure to request the LA sticks to the wording in the reports.
Also make sure any health or social care provision that educates or trains is in F. For example, LAs like to put things like SALT, OT, physio, etc. in G (health care provision) when it belongs in F.
Is 1:1 detailed, specified and quantified in any of the reports? While not everyone has to appeal to secure watertight wording around 1:1 some, a not insignificant number, but there aren’t statistics on this, do.
Unless money is no object, I wouldn’t spend money on a draft check. I would save your money in case you need to appeal.
Just so you are aware, the LA must give you at least 15 days. Despite how LAs sometimes portray it, it isn’t a maximum of 15 days.