How to structure comments on a draft EHCP (with template)
A proven structure for your draft EHCP response letter: one numbered amendment per issue, current wording, requested change, reason, and statutory basis.
A good response to a draft EHCP is not an emotional essay — it is a list of specific, numbered amendments. Caseworkers process dozens of plans; make yours easy to act on.
The structure that works
- Opening: state that you are making representations within the 15-day window, and request a meeting with an officer.
- Numbered amendments: one issue per number, each containing:
- the section (B, C, D, E, F…);
- the current wording (quote it);
- the problem in one sentence;
- the requested change (the wording you want);
- the reason it matters for your child;
- the basis — the law or Code expectation it falls short of.
- Closing: ask the council to confirm receipt, respond to each point, and issue the amended draft.
Example amendment
AMENDMENT 1 — Section F
Issue: provision is not quantified.
Current wording: "Regular speech and language support."
Requested: specify the type, provider, frequency, duration and review point — for example "one hour weekly direct therapy by a qualified therapist for 12 weeks."
Reason: without frequency or duration the provision cannot be measured or enforced.
Basis: Children and Families Act 2014 s.42; SEND Code of Practice expectation that provision be detailed and quantified.
Issue: provision is not quantified.
Current wording: "Regular speech and language support."
Requested: specify the type, provider, frequency, duration and review point — for example "one hour weekly direct therapy by a qualified therapist for 12 weeks."
Reason: without frequency or duration the provision cannot be measured or enforced.
Basis: Children and Families Act 2014 s.42; SEND Code of Practice expectation that provision be detailed and quantified.
Tone
Firm, factual, specific. You are not complaining — you are improving a legal document. Councils respond far better to precise amendments than to general dissatisfaction.
Our paid response package generates exactly this structure from your draft, with the current wording quoted and the basis attached to each amendment.
Have a draft plan in front of you? Run the free draft check — it finds weak wording in about two minutes, entirely in your browser.