What is a Working Document?

At this stage in the case (if not before), the parties should be amending the working document .

This is simply a WORD copy of the final EHC plan – sections of the plan under dispute.  The local authority will send the Working Document for you to edit, showing the proposed changes you would like to see made. You can then return it to the local authority for review. This should be an ongoing process which enables agreement to be reached ahead of the hearing.

You must show the changes you are making so the local authority know the amendments you have made.  There is a suggested key the tribunal ask you to use (make sure you include this)

Normal Type	Original Statement
Underlined type/strike through	Amendments/deletions agreed by both parties
Bold Type	Parents’ proposed amendments
Bold Strikethrough	Parents’ proposed deletions
Italic Type	LA’s proposed amendments
Italic Strikethrough	LA’s proposed deletions

Both parties should finalise the working document by the date specified in the directions – usually two weeks before the hearing.

It is important to check each version of the document to ensure that:

• The Working Document reflects the evidence submitted and the needs and provision are specific and clear
• Try not to copy chunks of information from reports unnecessarily – Tribunal prefer parents to paraphrase or quote key points (referring to the specific report/page etc)
• Evidence base your proposed changes – it can be helpful to do this by providing a footnote reference next to your proposed change. if you have a speech & language report which supports your argument, refer to the report, page number, and name of report reference as a footnote to show the LA that your requested changes are evidence-based).
• Check that local authority agreements are consistently shown in each version;
• the local authority does not amend the wording of the EHC plan for its own purposes – for example, if a mistake has been made this should only be done if the parent or young person agrees.  Local authority amendments therefore should only be in response to the parent or young person’s suggested amended sections of the EHC plan;
• all deletions requested/agreed are left in the document but struck through (no actual deletions are made using ‘cut’ or the delete key);