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SEN

Here you'll find advice from parents and teachers on special needs education.

How to strengthen OT wording for EHCP amendments at phase transfer

10 replies

readingrecord · 11/09/2026 13:52

DD is Year 6 ASD, sensory processing difficulties, struggling in state mainstream with very weak EHCP and virtually no support, "working towards" in maths and writing for the last 3 years. Have just received draft of private OT (sensory) report and hope to get EHCP amended at AR (phase transfer) to incorporate report's recommendations.
Among recommendations:
"X requires flexible, bespoke 1:1 teaching which can be provided in the school environment by a 1:1 teaching assistant..."
Is this wording tight enough as it does not appear quantified i.e. how many hours ? How can this wording be improved?

Also, "12 x weekly Ayres Sensory Integration Intervention would benefit X..." Shall I request "would benefit" to be amended to "needs" in the draft OT report, or would the LA ignore such recommendation anyway?
Please help and advise.
Thanks.

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roaringdragon · 11/09/2026 14:04

The wording isn’t good enough. It needs to be detailed, specified and quantified. Think about who, what, when, where, how, ratio, frequency, length of time…

For example, ‘Requires’ doesn’t mean must receive. ‘Can be provided’ doesn’t mean will be. What qualifications, training and experience will the TA have? And is a TA enough, a teacher should be teaching… Will it be in the classroom or outside, how frequency, how long for, teaching of what… ‘Would benefit from’ doesn’t mean must receive. ‘Needs’ isn’t tight enough either. What will the length of the sessions be. Who will it be provided by? Is equipment needed? Will it be provided 1:1 or in a group? Will it be provided in school or not?

Go back to the OT to request the make the reports detailed, specified and quantified as it should be. Is this an OT who has experience of writing medico-legal standard reports?

The LA may ignore it, but you can then appeal, but you need tighter evidence than you have.

readingrecord · 11/09/2026 15:18

@roaringdragon Thank you so much for the advice and I am getting back to the OT. They are from a local clinic that is an Outstanding provider, so hope experienced enough.

In the meantime, I wrote to the school SENCO to find out when the phase transfer AR will be, and they have come back to me to say it will be in the summer term, when a representative of the secondary school can attend!? They are effectively trying to use the Y5 AR as phase transfer review, however this will not include 3 new reports, OT, EP and SaLT review that I was hoping to include in the Y6 AR, before any schools can be considered. I wrote back saying what you advised a previous poster, i.e. that using the Y5 AR for phase transfer review is not lawful and asked for a phase transfer meeting this term. What else should I do to ensure the review happens?

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roaringdragon · 11/09/2026 15:24

If you haven’t already the LA as well. Email the Director of Children’s Services. You could also email the Monitoring Officer. For DC who are on the roll of a school, parts of the AR process are undertaken by the school, but the LA is the one who is ultimately responsible for the AR process.

The LA must finalise the amended EHCP naming the secondary placement by 15th Feb. In order to do this, they must hold a phase transfer review meeting in good time. It must happen in the next couple of months. Despite what some LAs think, phase transfer reviews aren’t optional. Using the Y5 AR is not lawful despite what some LAs often try to say.

If the LA continues to try to refuse, you could look at a pre-action letter.

They are from a local clinic that is an Outstanding provider

Unfortunately, this doesn’t mean they are good at right reports for EHCPs. And it doesn’t mean they have experience of writing tribunal standard reports.

readingrecord · 11/09/2026 20:26

@roaringdragon Thank you, that is very useful. If it comes to pre-action letter, do I need solicitors and any recommendations for East London?

Regarding the OTs, I contacted a few recommended ones with tribunals experience, but they were all booked till late September. If it starts looking like tribunal, can I commission a different OT report within a few months of the current OT report? The current one is in draft form and not shared with the SENDCO or LA yet. It is very useful for me personally though, as it shows how severe DD's sensory processing difficulties are. While DD is also on the pathway for ADHD assessment, her inattentivness can also be explained as a result of her inability to filter sensory stimuli.

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roaringdragon · 11/09/2026 21:01

They don’t need to be local to you. If you need a pre-action letter you could look at: Lawstop, Simpson Millar, Sinclairs, Watkins, Watkins & Gunn or Access to Public Law.

If you (a general you, not you specifically) don’t know what you are doing, it is not advisable to attempt to write your own pre-action letter. In theory, if you know what you are doing, you can write a pre-action letter yourself. However, in practice, the LA may well ignore it, especially these days. This is because sometimes some LAs are ignoring unless via someone with a legal aid contract because they know if they ignore you still have to find someone with capacity to take on the case, which can take perseverance at the moment, and when you find someone they will sometimes want to send another pre-action letter via them. LAs are sometimes taking the chance of kicking the can down the road. I can write my own don’t because our LA laughs and says good luck finding someone with a legal aid contract to take it further. Some advocates will write the,pm, but the same applies. SOSSEN offer them, but I know someone LAs sometimes ignore these too and there is a wait.

Yes, you would be able to commission another assessment if needs be. When professionals undertake assessments close together, there are some assessment tools that can’t be repeated within set timescales, but there are other assessments that can used, so it isn’t an issue that would prevent another assessment.

You didn’t ask for recommendations so feel free to ignore, but if you need another report for a Tribunal standard report, you could try Aniesa Blore (I would use her herself rather than one of the other team members), Melinda Eriksen and Diana Pierags.

readingrecord · 12/09/2026 11:00

@roaringdragon Thank you so much again for all the recommendations. I was not thinking of writing my own pre-action letter and indeed am out of my depth for this. As far as I understand, the pre-action letter is to threaten judicial review of procedure i.e. refusal of the LA to conduct AR of EHCP within 12 months of phase transfer i.e. in autumn term of Year 6. This is different from me contesting the content of the EHCP, for which I think I am now out of time, so tribunal or tribunal grade reports irrelevant. Later on, if I am given a school that is unsuitable, then I should have right of appeal.
If I am correct, they are 2 different pathways and wondering which one is more direct timewise.
I am also told by a medical professional working with SEN children at our school that it is standard practice in our LA to use the AR done in the summer term of Y5 as a phase transfer to secondary and as far as they are aware, this practice has never been challenged. In this case, wondering what chances do I have to successfully challenge the LA? Would it not be quicker to appeal the school allocation that I get, if unsuitable?

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roaringdragon · 12/09/2026 11:25

You are right that JR and appealing to SENDIST are 2 different things.

JR can be used for things such as the LA not complying with the AR process. Also for things like failure to provide the provision in the EHCP or unlawfully refusing transport.

Appealing to SENDIST is for challenging the content of the EHCP. Once the phase transfer EHCP is finalised, you will get the right of appeal. Even if the appeal window from the last AR has closed, you can appeal when you next have the right of appeal. If you need to appeal sooner, you could try asking SENDIST for leave to appeal out of time. It isn’t guaranteed but they sometimes allow late appeals.

It isn’t a matter of which is more direct. Rather which can be used for the issue at hand. This is because, for example, you can’t go the FtT route to force the LA to comply with the AR timescales, and equally you can’t use JR to challenge the content of the EHCP.

A Tribunal standard report isn’t irrelevant. Firstly, you may want to use it for Tribunal later on. But secondly, even if you have no intention of appealing, it signifies the level of the report. All reports should be good enough quality to be used as a Tribunal report. Sadly, they aren’t. Hence looking for a Tribunal standard report.

Just because it is standard practice, doesn’t make it lawful. Using the Y5 AR isn’t lawful. The LA knows this. Don’t believe it has never been challenged just because you are told that. LAs use that line to put parents off and make them feel they are being unreasonable. You can successfully challenge unlawful behaviour.

The problem with using the Y5 AR is there is a chance the LA may turn around in Feb of Y6 and say oh we can’t finalise the secondary placement we need to hold a review first. Yes, you could then take action, but it is a delaying tactic and game playing. This can sometimes be more prevalent if parental preference is wholly independent. This delay then means you can’t appeal straight away. Pressure on court time means the later a phase transfer appeal is submitted, the less likely it is to be settled prior to the start of Y7.

It also means parents have less time to learn the law (e.g. knowing they don’t have to complete the LA’s admission form, knowing they don’t have to state a MS, knowing they don’t need to state multiple placements), less time to make decisions on secondary schooling (especially important if parental preference is a wholly independent school who make decisions on who to offer places to later in Y6. Also important because some schools won’t speak to parents before the autumn term of Y6.) and less time to ensure B&F are right for phase transfer (including ensuring there is updated evidence where necessary. It can be the difference between having watertight evidence and not which is importantly since B+F=I). It means if parents change their mind in September (or October or the beginning of November) they then need to ensure the LA then actually follows the law in order to give them the opportunity to comment on the draft and state a preferred placement.

It means an AR must be held summer term of Y6. Unless of course the LA acts unlawfully again, as many do.

From the LA’s PoV, it also means the LA risks parents taking a case to the LGO or going down the pre-action letter/JR route.

Using Y5 ARs means the LA is likely to breach the statutory timescale for finalising the EHCP following the AR because it is unlikely the LA is going to finalise the secondary placement so early across the board. Delaying finalising frustrates parents’ right of appeal. And they are unlikely to finalise within the timescales with just the current primary named then go through another AR to finalise by 15th Feb with the secondary placement named.

If you give the LA an inch, they will take a mile. If they see parents don’t challenge their unlawful behaviour, LAs will continue to act unlawfully. (They sometimes still act unlawfully even if parents challenge unlawful behaviour, but LAs are more likely to act unlawfully when unchallenged.)

readingrecord · 12/09/2026 14:46

@roaringdragon Thanks again for explaining further and the more I look into it, the more it seems that the whole process is designed to set traps and frustrate parents.
In my case, I have been sent a form asking to give 2 school preferences by 25th of September. This automatically excludes any wholly independent schools, as even the non-selective ones will not make offers so early. Also, using the Y5 AR as phase transfer review will misrepresent DD's needs and effectively mislead secondary schools, as it does not incude the 3 current reports that I was hoping to include in the Y6 AR. We can potentially find ourselves in a situation that the secondary school can not meet needs that it did not know existed.

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roaringdragon · 12/09/2026 15:15

This is all why there needs to be a phase transfer review meeting this term.

You could still name a wholly independent school as your preference even if they haven’t yet offered a place. It is just they won’t be named without an offer.

readingrecord · 12/09/2026 16:50

@roaringdragon
Absolutely. Will push for the phase transfer review this term. Thanks again for the advice and taking the time to explain. So generous of you.😊

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