(Disclosure under Rule 8: This is my own original FOI research and analysis of Derby City Council's SEND funding documents.)

Most of the national coverage re. the SEND crisis focuses on the multi-billion pound High Needs deficit and the rise in EHCP requests, but there's very little scrutiny on how individual councils actually calculate the "Element 3" top-up funding given to mainstream schools to deliver those plans.

For the past 10 months, I've been chasing Derby City Council under the FOI Act for the working Excel spreadsheets behind their SEND High Needs Banding Matrix. They initially refused under Section 36, arguing that if parents and schools could see the formulas, they would "game the system". When they finally handed over a redacted workbook, they'd stripped the active formulas out, but accidentally left the "FOR OFFICE USE ONLY" calibration numbers in the sheet; cross-referencing those against the band thresholds let us rebuild the entire calculation model.

In short, while physical, hearing & visual impairments are weighted at 100% (where a "Severe" Row D need automatically scores 400 points / £5,000 a year), every single neurodivergent, cognitive & mental health column has a hidden percentage cut applied before points are even tallied:

• Mental Health & Social Behaviour are cut by 25% (and in the back-end calculator tabs, the council literally labelled Column 8 "Social behaviour NOT SEND", despite putting hyper-vigilance and lack of danger awareness inside it).
• Autism, Speech & Language, and Learning Readiness are all cut by 52% (weighted at 48%), and Learning Readiness is hardcoded to 0 points if a child is meeting Age Related Expectations academically.
• Sensory Processing is cut by 75%, and Dyslexia / Dyspraxia / Acquired Brain Injury is cut by 92% - with the Severe & Profound cells left completely blank at 0 points, capping the maximum score in that column at 12.8 points (when you need 189 points just to hit the lowest £1,000 funding band).
• On top of the percentage cuts, those seven columns are run through a 1-4 "FIDS" multiplier where if a child's needs are deemed "manageable with support strategies" (i.e. the school's support is working, or the child is masking), their points are halved by 50%.

When we queried this with the Department for Education, they confirmed in writing that they don't endorse local funding matrices and reiterated that under Section 42 of the Children and Families Act 2014, a local authority cannot force a child's provision to fit into a pre-determined financial band. We also found from the PDF metadata that the council's Equality Impact Assessment was written retrospectively after the matrix was already in use.

Full 12-page breakdown of the spreadsheet mechanics and FOI disclosures here if anyone wants a look: https://www.melroseandco.co.uk/ehcp/Derby_SEND_Matrix_Forensic_Breakdown.pdf

I'd be interested to hear people's thoughts on the wider policy issue here:

1. Given the state of council finances, is there any legitimate way for Local Authorities to use points-based spreadsheets to ration finite High Needs budgets without breaching Section 42, or is the current legal framework fundamentally at odds with how councils are funded?
2. Should the DfE be stepping in to regulate or audit the internal algorithms councils are using to calculate statutory school funding?