You've just opened your email and found it: a new EHCP with a Section F that reads "10 minutes daily pre-teaching of key vocabulary" or "small-group phonics intervention three times weekly" or "access to visual timetables and now/next boards". Your stomach drops. You don't have a dedicated teaching assistant. Your class is full. And you feel legally exposed.
Here's what you need to know: that feeling is wrong, and the SEND Code of Practice is on your side.
Section F doesn't require a 1:1 TA. It requires specific, quantified provision. And there's a legally defensible way to deliver it within your existing classroom, using strategies every teacher can implement. This guide walks you through it.
Key Takeaways
Teachers keep responsibility, not TAs: The class teacher remains legally responsible for pupil progress even when interventions are delivered by a TA or specialist. You must plan, link and assess impact (SEND Code of Practice, 2015).
Section F is about *what*, not *who*: Provision can be delivered through differentiated whole-class teaching, small-group work, adapted resources, targeted teacher time, or specialist equipment. A 1:1 TA is one option, not the requirement.
The local authority funds the shortfall: If the school genuinely cannot deliver Section F without additional staffing, that's a resource and funding decision for the local authority, not a reason to say the pupil cannot attend. Document it via annual review.
Evidence beats excuses: Mainstream schools must prove they've exhausted "reasonable steps" before claiming a learner's admission is incompatible. Quality-first teaching, adaptation, and differentiation count as reasonable steps (Schools Admissions Code, 2021).
Section F Decoded: What It Actually Means
Why Section F scares mainstream teachers
The fear is real, and it's understandable. Section F sits at the sharp end of statutory obligation. It's specific, it's quantified, and it carries the weight of the Equality Act 2010 and SEND Code of Practice behind it. A teacher reads "10 minutes daily" and thinks: I don't have a TA. How am I supposed to do that?
What's missing from that thought is context. Section F provision isn't a separate thing bolted onto the side of your class. It's not a TA's job to deliver on behalf of the school. And it's not you, the class teacher, who pays if it doesn't happen. The local authority is legally responsible for funding and ensuring the provision is delivered (SEND Code of Practice, 2015, paragraph 6.50).
Your job is to work with those delivering it, to plan it into your curriculum, and to measure whether it's working. That's a very different and much more manageable position.
What the law actually says about teacher responsibility
Read this slowly, because it changes how you see your role:
"The class or subject teacher should still retain responsibility for the pupil, even if interventions are delivered elsewhere by a teaching assistant or specialist" (SEND Code of Practice, 2015, paragraph 6.52).
Notice what that does not say: it doesn't say the teacher has to deliver the intervention. It says the teacher has to retain responsibility for the outcome. That means:
You work with the TA or specialist to plan what the learner needs.
You check in on whether it's working (not guesswork, actual evidence like phoneme checks, word counts, behaviour logs).
You link what they're learning in the intervention back to your whole-class teaching.
You adjust your core lessons if the intervention is working (e.g., if pre-teaching of vocabulary is successful, you can pace your main lesson faster for that learner).
You speak up at annual review if provision isn't having an impact.
That's responsibility, yes. But it's collaborative responsibility, not solo delivery of everything.
Five ways to deliver quantified provision without a 1:1 TA
Section F comes in many forms. Here are the five most common, and the ways to deliver them in a mainstream classroom without waiting for a TA who may never arrive.
1. Differentiated whole-class teaching
This is the workhorse of Section F. If a learner's Section F says "adapted phonics programme linked to whole-class phonics teaching," you don't need a separate space or a separate adult. You need a differentiated phoneme set.
Your whole class does phoneme jigsaw on /ai/, /oa/, /oi/. The learner you're thinking of does those same phonemes, but on word cards at their desk with syllable supports. Younger, easier, same lesson structure. This counts as delivering quantified provision. You've adapted the resources; the time comes from your normal lesson structure. And it's legal because the learner is accessing the same curriculum as everyone else, just at their level.
The SEND Review 2022 and SEND Improvement Plan 2023 both emphasise that quality-first teaching with differentiation is the starting point for meeting many SEND needs. You don't need specialist status to do this. You need good planning and routines.
2. Small-group interventions delivered by existing staff
Let's say the EHCP says "10 minutes daily small-group phonics". You don't have a dedicated TA. But you do have: a teaching assistant who works across the school, a higher-level teaching assistant, or a parent volunteer trained in phonics.
That person delivers the 10-minute group four times a week. You deliver it once a week yourself. The TA or staff member is pulling the group from the main class during independent work time. You've met the quantified need. The learner gets the intervention; you've not had to hire a new TA.
The key move: get the timetable right. If independent work time overlaps with phonics, the group can be pulled without disruption. If it doesn't, ask the SENCO to shift when the intervention happens (e.g., before school, at the start of lunch, at the end of the day) so it doesn't collide with whole-class teaching.
3. Adapted environment and resources as provision
Some Section F items are about environment, not just time. "Visual timetables," "now/next boards," "quiet workspace," "noise-cancelling headphones," "individualised behaviour board."
These are provision. They're quantified ("visual timetable in place by [date]"; "headphones available during independent work"). And they're free. You're not paying for a TA. You're using design and resources to remove the barrier.
Print the visual timetable on a laminated A4 sheet and clip it to the learner's desk. Draw the now/next board with dry-wipe. Borrow a corner of a cupboard for a quiet workspace. Noise-cancelling headphones cost £15 on Amazon. These are reasonable adjustments, and many mainstream schools are delivering them already.
4. Targeted teacher time within normal lessons
Not all Section F is about separate adult time. Some is about teacher attention. For example: "Explicit feedback from teacher on phoneme formation twice daily," or "Planned teacher check-ins during guided reading to assess comprehension."
This happens in your lesson, with you, no extra staff needed. You build it into your lesson plan. Your guided reading group has five learners; this learner is in the group. You ask them targeted questions about what they've read. You mark their phoneme formation and give instant feedback. That's the provision, and it's logged as evidence.
The time doesn't have to be vast. Thirty seconds per learner, five days a week, is 2.5 minutes of targeted teacher time per day per learner. Across your whole group, that's doable within a normal guided reading slot.
5. Access to specialist advice and equipment (without a separate adult)
Some schools treat EHCP provision as if it means a TA must be present. It doesn't. Sometimes it means the school buys specialist software, gets advice from the educational psychologist, or accesses equipment like standing desks, sloped boards, or speech and language therapy materials.
Those are provision. They cost money (local authority responsibility), but not staff. Once bought or put in place, the learner uses them independently or with normal classroom routines. A speech and language therapy worksheet done as part of your normal literacy session counts. A phonological awareness game run in small group time counts.
The move: ask your SENCO if any unmet Section F can be met through equipment or specialist access rather than TA time.
A worked example: mapping Section F onto a KS2 English lesson
Let's say you're a Year 4 teacher. The new EHCP arrives. Section F says:
Pre-teaching of key vocabulary for texts (15 minutes, three times weekly)
Small-group guided reading with structured questions about inference (10 minutes daily)
Visual supports for phoneme formation in writing (ongoing)
You have no dedicated TA. Here's how you deliver it all in one week.
Monday morning (9.15–9.45 am): Whole-class word work
You're about to start a unit on "The Stone Age". Before the whole class gets the story, three learners (including the one with the EHCP) come in early or work in a small group during early finisher time. You go through five "stone age" words: flint, shelter, tribe, mammoth, spear. You make the words, feel them (flint is hard; shelter is cosy). You draw them. By 9.45, the main class arrives, and they've already heard the words. When the whole-class read starts, they recognise them. That's pre-teaching of key vocabulary. Evidence: simple checklist of words covered + photo of the learner's drawings.
While the rest of the class is doing independent word searches, you sit with a group of four (including the learner). You ask: "Why did the tribe move to the river?" "What does it look like when someone runs away?" "What would you do?" That's structured inference questioning. The learner answers (perhaps with a scaffolded prompt from you: "Was it because... or because...?"). You jot a note: "Inferred reason for migration after prompted choice." That's your daily small-group guided reading, logged.
The learner uses a writing sheet with phoneme sound-buttons printed underneath the lines. Instead of a blank line, they see /m/ /a/ /t/ and they finger-trace the sounds as they form the letters. On Friday, they also get a laminated card showing correct letter formation (starting point marked with a dot, arrows showing direction). That's visual support for phoneme formation, delivered in the main writing lesson, no extra adult needed.
Section F: delivered. No additional TA required.
You've timetabled it into your existing lessons. You've linked it to the curriculum. You've kept evidence. And when you go to the annual review, you can show impact: vocabulary was unfamiliar in week one, but by week three, the learner was using those words independently in their own sentences.
5 Ways to Deliver Section F Without a 1:1 TA
When Section F genuinely needs a TA and how to escalate
Not every EHCP can be met without additional staffing. Some learners have Section F items that genuinely need adult support: frequent behavioural de-escalation, intimate personal care, safety supervision, or constant task redirection.
If you've genuinely exhausted the above five approaches, and the learner is not progressing, here's what you do:
Document it clearly. Keep a brief log: "Attempted pre-teaching using [method]. Learner still unable to retain vocabulary." "Tried small-group phonics withdrawal; learner unable to access without adult redirection every 30 seconds." Be honest and specific.
Raise it at the annual review or via amendment. Tell the SENCO: "I've tried [strategies]. The learner is making minimal progress. This Section F item may need additional staffing." Put it in writing. The school and LA will then consider: Can we add a TA? Can we increase provision funding? Does the learner need a different setting?
Don't shrug and say "I need a TA". The LA's first move is always to ask: "What reasonable steps have the school taken?" If you can't articulate them, you've handed the LA an easy exit. If you can, the burden shifts to them to resource it.
Understand the legal position. The local authority is responsible for ensuring the provision is delivered (SEND Code of Practice, 2015, paragraph 6.50). If it can't be delivered in a mainstream setting with reasonable adjustments, that's a funding conversation between the school and LA, or potentially an issue for the appeals tribunal. But it's not your problem to solve by staying silent.
The "reasonable steps" test and how schools meet it
There's a legal test that comes up in school admissions and disputes: the "reasonable steps" test (Schools Admissions Code, 2021, sections 3.64–3.66). Before a mainstream school can turn a learner away or claim their admission is "incompatible with the efficient education of others", the school must prove it has exhausted reasonable steps such as:
Staff training in positive handling or behaviour strategies
Curriculum adaptation and differentiation
Quality-first teaching approaches
Sensory or environmental adaptation
Access to specialist advice
Targeted small-group work
Adapted resources
If a teacher walks into a meeting and says "we've tried nothing except waiting for a TA", that school has not met the reasonable steps test. The learner may have a case to stay, or to be admitted in the first place.
But if you can walk in and say:
"We've adapted our phonics teaching. We've tried small-group withdrawal. We've got visual supports in place. The learner is making progress, but slowly. This item may genuinely need additional staffing."
Then you've met it. And the LA has to act. The reasonable steps test is your shield, not the other way around.
Record-keeping that protects you
Evidence is your friend. Here's what you need to keep:
Weekly log of Section F delivery. A simple table: Date | Section F item | How delivered (e.g. "differentiated whole-class phoneme jigsaw") | Evidence (e.g. "phoneme card completed, 4/5 words correct") | Notes. Takes five minutes per week per learner.
Before-and-after snapshots. On the day the EHCP is received, do a baseline: "Currently reads 10 words per minute; vocabulary age 4.5 years; cannot blend CVC phonemes." Three months later, retest: "Now reads 18 words per minute; vocabulary age 5.2 years; can blend CVC phonemes in familiar texts." That's impact.
Photos and samples. If visual supports are part of Section F, photograph them in use or keep a sample. If the learner's work improves, keep before-and-after writing samples. If you deliver pre-teaching, jot a two-line note of what was covered.
Communication log with TA or specialist. If a TA delivers part of Section F, keep a simple log of what they did and how the learner responded. "3 Nov: phonics group, learnt /ai/ phoneme, recalled 3/4 words. 4 Nov: phonics group, phoneme introduced, but learner fatigued after 6 min, ended early." Share this with the TA weekly. This shows the school is monitoring impact, not just delivering blind.
Email or meeting notes. If you speak to the SENCO about barriers, send a follow-up email: "Following our chat, I'm trying [strategy] with [learner]. I'll report back on progress at the next check-in." Gets it on record without being confrontational.
You're not building a lawsuit file. You're building evidence that you're doing your job: planning, delivering, assessing, and adjusting. That's what the law expects.
The Legal Chain of Responsibility: Teacher → TA → Outcomes
Section F Provision Mapper
Turn EHCP provision into classroom-ready delivery plans
▼
Recommended Delivery Mode
Implementation Steps
One action for Monday morning
Pick the Section F item that feels most overwhelming. Not the one that needs a TA. The one that you can influence this week.
If it's vocabulary pre-teaching, grab a sticky note and write the five words from next week's text. Say them out loud to the learner once before the lesson starts. That's pre-teaching. Done.
If it's small-group guided reading, add three inference questions to your guided reading plans: "Why did the character...?" "What does the author think about...?" "What would you do?" That's structured questioning. Done.
If it's visual supports, print a phoneme sound-button sheet and tape it to the learner's desk. Done.
You're not waiting. You're not overwhelmed. You're delivering. Section F stops being a threat the moment you stop thinking "I need help" and start thinking "here's how I use what I've got."
Further Reading: Key Papers on Section F Provision
The statutory guidance that defines how EHCPs must be implemented in schools, including Section F provision and the role of class teachers. Paragraphs 6.50–6.52 are directly relevant to teacher responsibility and TA deployment.
SEND Review 2022: Right Support, Right Place, Right Time (Green Paper)View document ↗
Department for Education (2022)
Sets out the government's approach to SEND reform, emphasising quality-first teaching and differentiation as the baseline for meeting many SEND needs. Frames staffing and intervention as complementary to, not replacements for, good teaching.
SEND and Alternative Provision Improvement Plan 2023–2024View document ↗
Department for Education (2023)
Updates the implementation of the SEND Review, with focus on ensuring mainstream schools have the capacity and training to deliver EHCP provision. Specifically addresses the gap between staffing levels and the need for schools to adapt teaching.
Evidence-based guidance on how mainstream schools can effectively support learners with SEND using universal strategies (quality-first teaching, small-group interventions, adapted resources) with modest additional staffing. Shows that not all provision requires 1:1 support.
About the Author
Paul Main
Founder, Structural Learning · Fellow of the RSA · Fellow of the Chartered College of Teaching
Paul translates cognitive science research into classroom-ready tools used by 400+ schools. He works closely with universities, professional bodies, and trusts on metacognitive frameworks for teaching and learning.