How we help Get support SEN and disability law SEN and disability case law Case summaries What should be in Section F of an EHC plan? L v Clarke and Somerset County Council  ELR 129: Where special educational provision is set out in Part 3 of the Statement (now Section F of an EHC plan) it must be specific, which will normally involve specifying the number of hours of support. C v Special Educational Needs Tribunal and London Borough of Greenwich  ELR 5: An LA must make decisions about provision when writing a Statement (now an EHC plan), and cannot delegate this responsibility to someone else, such as a school. (For example, the EHC plan should not say anything like “Support to be determined by the setting”.) E v Rotherham MBC  ELR 266,  EWHC Admin 432: A Statement (now an EHC plan) cannot provide for provision to be amended unilaterally by the LA. In this case, the Statement said provision could be changed during the year following a ‘formal discussion’. This was not acceptable – any change to a Statement or an EHC plan should follow a proper process (e.g. annual review) so that the parents have a right of appeal. R v Cumbria County Council ex parte P  ELR 337: Simply referring to a financial banding or an amount of money to describe what special educational provision will be made in Part 3 of a Statement (now Section F of an EHC plan) is not specific enough to satisfy the law’s requirement. Staffordshire County Council v JM (SEN)  UKUT 246 (AAC): Transport is generally not special educational provision and should not usually be included in Section F of the EHC plan.