A few days ago, the Department for Education (DfE) announced more funding to train educational psychologists, following a research report about Education, Health and Care Plans (EHCPs). The report looked at how many hours it takes different people in roles within local authorities to put an EHCP together, and who spends the most time doing it. Aside from educational psychologists, it contained a lot of other data. So, what have we learned from it, how accurate is the data, and what will this data be used for?
Let’s start with some context. The DfE is going to announce some deep-rooted SEND reforms, most likely next week. Rumours abound, including that there’ll be a White Paper for the schools’ side and a Green “discussion” document with a 12-week consultation on the SEND aspect. We expect all will be clear this time next week.
That’s backed up by a few reliable signs that a big policy announcement is inbound. One of those signs is the sponsoring department pushing out supporting research it can point to, to justify its proposals.
This report falls into that category. You can find the report here.
The facts behind the headlines
The stated purpose of this report is to help the DfE “to better understand how much professional time is spent on the process of conducting Education, Health and Care (EHC) needs assessments, and the development and issuing of EHCPs.”
That might well be what the report was commissioned to do. What it’ll be used for over the next few months is something very different—to paint EHCPs as a pointless bureaucratic sinkhole.
The research methodology is problematic if you want to understand why the EHCP process works as it does.
Last summer, the research team sent out a survey to local authority (LA) Directors of Children’s Services. The team wanted to capture survey responses from LA staff members, asking them how many hours they spent on various parts of the EHCP process for the last three EHCPs they worked on.
They got responses from 859 professionals in over 100 LAs. These responses provided data on at least some of the production process across 2,577 EHCPs.
Caveats for data validity
The researchers carefully lay out a set of caveats in the report about how this data should be used. And they’re right to. Because this report is almost useless as a guide to understanding how much time it takes to produce an EHCP. And it’s totally useless as a guide to how high-quality statutory plans could be produced efficiently.
The survey collected retrospective data on the time taken to complete sub-tasks. The data was self-reported, and it wasn’t checked for validity.
Most research in this area tells us that when people are asked to estimate how much time it took to do a job after the fact, they tend to overestimate – sometimes wildly.
- This survey only asked local authority personnel: SEND managers and case officers, educational psychologists, principal EPs, and social workers. It didn’t seek survey inputs from health professionals, SENCOs, or families.
- The survey didn’t differentiate between the time that LA staff spent on EHCP processes specifically required by law, and the time they spent on actions required only by LA policy.
- The survey didn’t include any of the time that LA staff spend on downstream parts of the EHCP process: things like annual reviews, mediation, SEND Tribunal defence.
- And finally, the survey approach looked at individual parts of the EHCP assessment and production process in isolation. It might be that the data the team collected allowed for end-to-end analysis of all processes in a single plan, but it doesn’t look like they tried to do that.
And the results are…
So far, so shite. What did the research team do with this data?
They took the survey responses, weighted them to derive a median number of hours for each profession and each process, and came up with some tentative conclusions, again, appropriately caveated.
The researchers noted that there was a lot of variation. But without knowing more about individual LA practice and the complexity of individual cases, it’s hard to do much with that finding.
Their key findings run as follows:
- It takes LA professionals somewhere between 56-68 hours to develop and issue a single box-fresh EHCP, from receipt of EHC needs assessment request to finalised plan
- Across all LA professionals, educational psychologists and principal EPs spend the most time on the EHCP process: each spending an average of 17.4 hours on a single plan, with most of their time spent at the EHC needs assessment stage.
- SEND case officers, on average, spend 11.3 hours on a single EHCP, with the plan drafting and finalisation stage being the biggest single use of their time.
- SEND managers, on average, spend 9.9 hours on a single EHCP, with their time evenly spread across all parts of the process.
- Social workers, on average, spend 4.8 hours on a single EHCP.
Those figures might raise eyebrows amongst the more sceptical of you. The more waspish of you might be wondering, for one thing, how come it takes a social worker an average of 4.8 hours to type the words “not known to service.”
Click image to enlarge.
Real or fantasy leagues?
So do these estimates bear any relation to reality?
It’s possible to check some of these inputs using other sources, including the census data that LAs submit to the DfE each year on the EHCP process, and various Freedom of Information requests that individuals have submitted to councils about their SEND workforce.
We ran those checks—after which, some of the estimates in this research report look very iffy.
For many LAs, it’s very hard to reconcile their EP workforce data with the number of EHC needs assessments the LA conducts each year, the number of EHCPs they issue each year, and the average number of EP hours this research report says it takes to complete a single EHCP.
There are simply too many hours, too many EHC needs assessments, and too few EPs—including locums and agency staff—for this estimate to be widely plausible.
And for principal EPs, the figures for most LAs would be flat-out impossible without the aid of a time machine or cloning facility.
It’s not possible to say for sure what’s gone wrong here, but the most likely explanation is that many of the survey respondents have, for whatever reason, overestimated their time on task. I suspect most of you won’t be shocked to hear that some of these professionals have a problem quantifying things.
Garbage in, Garbage Out—usage suspicious
So there are reasons to be sceptical about some of the figures. And when thinking about how this research is going to be used, the other reason to be sceptical is that the research question just isn’t focused right.
The EHCP process isn’t just shuffling paperwork. It involves assessment and professional judgement, as well as form-filling and meetings. This research report doesn’t help us separate those things out.
It’s one thing to ask how many hours it takes local authority professionals to run through the EHCP process for a single plan. It’s another thing to accept those figures on trust. And it’s another thing entirely to judge whether this process actually needs to take that much time.
In this report, for both EPs and SEND administrators alike, the ratio of management time to worker time on a single EHCP looks deranged. It’s close to 1:1. No sanely-managed process in the rest of the public or private sector works that way.
Either workers are being nano-managed over every single plan, or the managers are so stretched that they’re having to work as frontliners, meaning that effectively, there’s no management at all.
Your mileage may vary, but in many SEND admin cases, I suspect it’s the former. I’ve seen far too many caseworker-authored plan drafts that have had the guts ripped out of them once they’ve been through management.
Given the low quality of many EHCPs—something highlighted in almost every single area SEND inspection that Ofsted and the Care Quality Commission conduct—how does something so consistently piss-poor take so many hours to produce?
This research report can’t answer that question. It’s not been designed to, either because the customer wasn’t interested or because the researchers didn’t have the time or focus.
But without answering that question, what possible robust conclusion could anyone draw from a headline finding that it takes an average of 56-68 hours of local authority time to produce a single EHCP?
Does it really have to take this many hours to produce a single EHCP? We can’t tell from this report, not least because there’s no accounting for the time taken by families, schools, and health professionals. For parents, 68 hours is almost certainly an underestimation.
But the experience of people enmeshed in the EHCP system screams out of every orifice that there’s potential to run things more efficiently.
Unified templates. Case management systems that run off something better than a shonky Excel spreadsheet. Carefully applied use of AI to reduce plan drafting time. School consultation processes that aren’t just a sham. Packing up the SEND decision-making “panel”, gently patting it on the head, and firing it into the sun. Thinking hard about whether designing, drafting and implementing Byzantine 95-page eligibility criteria documents is really a good use of everyone’s time.
The customer gets what the customer wants
The researchers of this report have done their best with the time and resources at their disposal, and they’ve caveated the tentative nature of their findings appropriately. Many of their coin-operated peers working in this space don’t.
But none of that is going to matter here. The customer—the DfE—set the research question, and the customer has got exactly what it wanted: a superficially robust finding that EHCPs are a bureaucratic time-sink, each one taking many, many hours to produce – and because of that, hard-working professionals are tied up with paperwork rather than delivering early intervention.
Poke at the figures, even for a few minutes, and the findings start to wobble. It’s entirely plausible that the way local authorities administer and produce EHCPs is grossly inefficient. It’s entirely plausible that it doesn’t have to be. And as a reformed SEND system will essentially involve many of the same people working under a different process, it’s entirely possible that it’ll just continue to be grossly inefficient.
Ask better questions of the research and its customer, and the value of this report comes into sharper focus:
- Why are SEND system operators so inefficient?
- Why is their output so consistently poor?
- And why do you expect them to operate any more effectively under a new system with fewer guardrails?
- What parts of the EHCP process take too long: the specialist assessment, the administration, or the management action?
If it’s the assessment—and that’s one potential finding of this report—then how are you going to engineer a process to deliver the right support to a larger number of the right children, without creating a new regime of nano-managed gate-keeping? Is expert individualised assessment just paperwork, or is it an integral part of the job?
I have a horrible feeling that it’s too late now to get answers to those questions.
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Also read:
- Beyond EHCPs: Why Inclusion Needs More Than a Document
- The Unacceptable Truth: 20 SEND legal rights at risk from the Government’s SEND reforms
- How health and family support systems are failing children starting school
- WEBINAR RECORDING! The implications for children’s legal rights to EHCPs and EOTAS of the Government’s SEND proposals
- When things go right: Shining a light on SEND Practitioners making a positive impact [Giveaway!]
- From suspicion to support: why the Government’s child protection reforms matter for disabled children
- Have your say on the future of transport for disabled children and young people
- Unison voices major concerns over SEND reform health plans for sick and disabled children out of school in the EOTAS consultation
- Top Tips for the EOTAS & EHCP consultation: Protect your child’s rights to statutory SEND support
- Navigating constraints: Why a former PCF chair thinks the current model is missing the mark for families
- Dear Secretary of State for Education, Lucy Powell: an Open Letter from Special Needs Jungle and SEND legal charity SOS!SEN
- Research: Disabled young people define inclusive education as “learning in the place that’s right for them”
- Top Tips for the EOTAS & EHCP consultation: Protect your child’s rights to statutory SEND support
- Mainstream SEND Funding: A simple explainer, another consultation, and why it really matters
- EHCPs 2026: A relentless rise, but who’s surprised? Plus SNJ’s annual LA Hall of Shame
- SEND 2026: Tracking a decade of rising need with earlier EHCPs and moves to specialist provision for secondary
- Using “Not Quite Experts” at Hand will be the only solution to staff the Government’s big new plan for school support
- The Government thinks Ofsted will ensure SEND reform accountability. This evidence suggests ‘significant concern’.
- Experts At Hand: A good idea built on wishful thinking and shaky foundations
- Capital carrot, SEND steamroller: The Government’s evidence-light reform route isn’t waiting for anyone
- Accountability after SEND Reform: A system that marks its own homework
- Schools White Paper: What do we know so far about funding for SEND?
- A sceptics eye on government EHCP prep research shows the “deranged” numbers just don’t add up
- SEND cash splash: What does it all add up to—and will ditching debt improve provision?
What kind of government is “bold” enough to scrap statutory EHCPs from vulnerable children?May 16, 2025
The SEND reforms in the Schools White Paper reveal rights given, and rights stripped awayFebruary 24, 2026
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Matt specialises in SEND stats, data analysis, and in-depth investigations of policies. He has given evidence to several Parliamentary Select Committee inquiries, and his articles for SNJ on SEND funding, local government policy, and the SENDIST Tribunal have been quoted in Select Committee inquiry reports and national media.
- Top Tips for the EOTAS & EHCP consultation: Protect your child’s rights to statutory SEND support - August 19, 2026
- Mainstream SEND Funding: A simple explainer, another consultation, and why it really matters - July 22, 2026
- EHCPs 2026: A relentless rise, but who’s surprised? Plus SNJ’s annual LA Hall of Shame - June 27, 2026
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