Matrix Code Cracked: Secret £12k Mainstream Cap, 8% Dyslexia Penalty & A Fake Backdated Assessment
We have cracked 100% of the hidden Excel formulas Derby City Council tried to withhold under FOIA. Even worse, file metadata catches Council leadership red-handed creating a backdated "Equality Impact Assessment" just 90 minutes before their lawyers sent us a legal threat letter!
While the Department for Education has now officially confirmed in writing that it never approved, endorsed, or reviewed Derby's Matrix, the secret "FOR OFFICE USE ONLY" rows inside the Council's spreadsheet expose a £12,000 Mainstream cap and severe mathematical penalties against autistic, neurodivergent, and dyslexic children...
Are you a local parent, carer, guardian, or a current/former employee of the council, a SENDCO, teacher, or teaching assistant? Please email us in strict confidence at sen@melroseandco.uk.
📄 DOWNLOAD OUR 12-PAGE FORENSIC REPORT: Read our complete, plain-English 12-Page Forensic Audit & Reference Guide (including visual charts, how the 'FIDS' filter works, and the exact qualifying thresholds for every single row of all 10 Matrix categories) here: https://drive.google.com/file/d/15kHuHUTbN8HAPjfiw291Ou7DgFlXyC4s/view?usp=sharing
A Quick Confession: Why Nobody Looked on "Sub-Page 9" of the Council’s Website Until This Week
I owe everyone a small confession. When Derby City Council spent eight months fighting my Freedom of Information request (FOI750726532) for the High Needs Banding Matrix - first claiming for six months that confirming its existence would threaten National Cybersecurity (Section 31), and then having their Monitoring Officer (Emily Feenan) sign a formal Section 36 refusal on 28 September 2026 arguing that the formulas had to be withheld because the public had "no awareness of the tool" and would "game the system" - it never occurred to me to check Sub-Page 9 of a buried menu on the Council's website. Why would it?
Then, on 22 October 2026, following an urgent intervention by Jonathan Davies MP to the Secretary of State for Education, the Department for Education (DfE) sent us a defensive reply (Ref: 2026-0092090, stamped OFFICIAL - FOR PUBLIC RELEASE).
In that letter, the DfE tried to wash its hands of Derby's scandal by claiming that "Derby publishes their banding matrix on their local offer and provide comprehensive and sufficient information regarding how their approach to element 3 funding works."
So we went looking on Derby City Council's SEND Local Offer (Allocation of resources). What we found buried inside the website's HTML source code, the PDF file metadata, and the "FOR OFFICE USE ONLY" rows of the Excel spreadsheet is the biggest smoking gun of this entire campaign.
1. Caught Red-Handed by File Metadata: The "Undated" Equality Impact Assessment Created 90 Minutes Before Their Lawyers Threatened Us
Back on 11 March 2026, Derby City Council officially confirmed under the Freedom of Information Act that it held no Equality Impact Assessment (EIA) for the High Needs Banding Matrix ("Information not held"), despite having rolled the Matrix out across Derby's schools nine months earlier in June 2025.
Yet when we checked Sub-Page 9 of the Council's Allocation of resources webpage this week, there was a link to a 17-page PDF titled equality-impact-assessment-resource-matrix.pdf, signed off by Director Sharon Buckby and co-authored by Head of Service Louise Bartos.
Suspiciously, the "Date of assessment" box on Page 1 of the PDF was left completely blank, while the list of authors included a manager marked "(to Oct 2024)" to make it look as though the assessment had been done before the Matrix launched.
Unfortunately for Council leadership, they forgot to scrub the digital forensics:
- Clue 1 (The Past-Tense Slip on Page 5): On Page 5 of the PDF, the author forgot they were supposed to be writing a pre-decision assessment in 2024/2025 and wrote in the past tense: "The application of the proposal was agreed for September 2025. Feedback has been received during the academic year 2025/6." That proves on the face of the text that it was written after the 2025/26 school year had already ended - violating Page 15 of the Council's own EIA template, which states in bold: "Equality impact assessments must be done before decisions are made."
- Clue 2 (The 3:24 PM Adobe Metadata Timestamp on 21 August 2026): When we extracted the hidden XMP metadata embedded inside equality-impact-assessment-resource-matrix.pdf, it revealed the exact minute the file was created:
• Created in Microsoft Word: 10 August 2026 at 09:46 UTC (2026-08-10T09:46:12Z) - 14 months after the Matrix launched!
• Converted to PDF via Adobe PDF Services: Friday, 21 August 2026 at 3:24 pm BST (2026-08-21T15:24:57+01:00).
• Why does Friday, 21 August 2026 at 3:24 pm matter? Because just 90 minutes later (at 4:55 pm on Friday, 21 August 2026), Derby City Council's external law firm, Browne Jacobson LLP, emailed me a formal legal threat letter claiming they had reported our Change.org petition for "false statements of fact" and "misleading content"! Council officers literally generated a backdated, undated EIA at 3:24 pm so their lawyers could send a threat letter at 4:55 pm!
- Clue 3 (The 4 September 2026 Website Upload): The HTML source code of the Local Offer webpage (<meta name="DC.Date.modified" content="2026-09-04" />) and the internal Jadu database IDs (d.en.182843 to 182860) prove that the Council quietly bolted the Matrix and the undated EIA onto its website on 4 September 2026 - ten days before Sharon Buckby's Scrutiny Board presentation and while lobbying the DfE for a ~£20 million High Needs Stability Grant, even while continuing to withhold the FOI files from us until 28 September 2026!
2. We Cracked the Hidden Excel Formulas: How the Algorithm Slashes Neurodivergent Children's Scores by Up to 92%
When the Council uploaded banding-matrix.xlsx to its website on 4 September (and sent us the identical file on 28 September while claiming under Section 36 FOIA that releasing the formulas would let parents "game the system"), they deleted the live Excel formulas from Row 4.
However, they forgot to delete the hardcoded "FOR OFFICE USE ONLY" calibration rows (Rows 7 to 10: Max point B, Max point C, Max point D, Max point E) at the bottom of Tab 2 (Matrix_Score) and Tab 3 (Band_calculator)!
On the webpage, the Council admits the formula for each cell is:
Level Base Multiplier (0 / 20 / 40 / 100 / 360) × Category Weighting (8% to 100%) × Score / FIDS (1 to 4) = Matrix Points
Because the "FOR OFFICE USE ONLY" rows in Tab 2 plug a maximum score of 4 into every cell, and Tab 3 displays the exact resulting point values across all 10 domains and all 4 levels (Row A = 0, Row B Base = 20, Row C Base = 40, Row D Base = 100, Row E Base = 360), dividing Tab 3's numbers by 4 unlocks 100% of the hidden mathematical weightings:
- The 100% Standard Benchmark — Physical, Hearing, and Vision Impairments (100% Weighting + Automatic Score of 4):
• Children with physical, hearing, or vision impairments require vital equipment, adaptations, and specialist support. The Matrix rightly recognises these needs at 100% Category Weight and exempts them from the FIDS rationing filter - automatically awarding the maximum multiplier of 4 (Slide 12 of the SENCO training deck instructs panel officers: "Where there is no FISD [sic] requirement and the pupil has those needs score 4"). Crucially, the Council does not dock a wheelchair user's funding by 50%–75% just because ramps or a Teaching Assistant make their day "manageable." Every disabled child deserves this same parity of support.
• Points awarded: Row B = 80 pts | Row C = 160 pts | Row D (Severe) = 400 pts (Instant Band 5 = £5,000) | Row E (Profound) = 1,440 pts (Instant Band 11 = £11,000).
- The Unregulated 1-to-4 'FIDS' Rationing Filter Applied to All Other 7 Domains:
• For all 7 remaining domains (Neurodivergent, Mental Health, Speech, Sensory, and Learning needs), the Council not only slashes the Category Weightings (down to 75%, 48%, 25%, or 8%), but also subjects the child to a 1 to 4 'FIDS' multiplier (Frequency, Intensity, Duration, Severity).
• The Single-Cell Defect: Even though F, I, D, and S measure four completely different things, there is only one single cell per column to type a 1, 2, 3, or 4, and the Council has no rule on whether to use the highest, lowest, or average score! Worse still, Slide 11 defines FIDS 2 (which cuts a child's points by 50%) as "Manageable with support strategies" - meaning if a school's Teaching Assistant or visual schedule is helping an autistic child cope, or if the child masks until home, their funding score is cut in half!
- 75% Weighting (-25% Cut) + 1 to 4 FIDS Filter (Emotional Wellbeing & Mental Health and Social behaviour NOT SEND):
• Points awarded (from FIDS 1 to Max FIDS 4): Row B = 15 to 60 pts | Row C = 30 to 120 pts | Row D = 75 to 300 pts | Row E = 270 to 1,080 pts.
• The "NOT SEND" Legal Trap: While the Council deleted the words "NOT SEND" from Tab 1's header, Tab 2 (Cell AE2) and Tab 3 (Cell AE2) are still explicitly titled "Social behaviour NOT SEND", and Tab 1 Row D (Cell P9) mixes clinical Autism/ADHD safety traits ("Demonstrates hyper vigilance" and "Limited understanding of personal risk or danger") right next to "aggression with no defined needs/causation"!
- 48% Weighting (-52% Cut) + 1 to 4 FIDS Filter (Social and communication [Autism], Speech & Language, and Learning Readiness):
• Points awarded (from FIDS 1 to Max FIDS 4): Row B = 9.6 to 38.4 pts | Row C = 19.2 to 76.8 pts | Row D = 48.0 to 192.0 pts | Row E = 172.8 to 691.2 pts.
• Built-In Gatekeeping Traps on Tab 1:
• In Column 6 (Autism), Row A (0 pts) is explicitly defined as "Mild / Moderate needs, for example, there may be a need for support such as circle of friends or comic strip communications" (whereas Row A in every other column is "No significant needs").
• In Column 9 (Learning Readiness), Row A (0 pts) is defined as "Working at age related expectations", while Rows B, C, D, and E all require a mandatory "learning delay" - structurally locking out cognitively able ("twice-exceptional") autistic/ADHD pupils with severe executive dysfunction!
• Compare that at Row D (Severe): Under the 100% Standard Benchmark (Cols 1–3), a single Severe (Row D) need automatically receives 400 points (Band 5 = £5,000). A child with Severe (Row D) Autism scored at FIDS 2 ("Manageable with support strategies") receives just 96 points (Band 1 = £0.00), and even at FIDS 3 (Every lesson) gets only 144 points (Band 2 = £0.00) - falling short of the 189 points needed for the lowest £1,000 funding band!
- 25% Weighting (-75% Cut) + 1 to 4 FIDS Filter (Sensory Needs / SPD):
• Points awarded (from FIDS 1 to Max FIDS 4): Row B = 5 to 20 pts | Row C = 10 to 40 pts | Row D = 25 to 100 pts | Row E = 90 to 360 pts.
• Copy-Paste Defect: The Council copy-pasted the exact same 24-word sentence into both Row C (Moderate) and Row D (Severe)!
- 8% Weighting (-92% Cut) + Blank Rows D & E (Specific Learning Difficulties — Dyslexia, Dyscalculia, Dysgraphia, DCD/Dyspraxia, & Acquired Brain Injury):
• Slashed by 92% to an 8% Category Weight, with Rows D and E left completely blank (0 points)!
• Points awarded (from FIDS 1 to Max FIDS 4): Row B = 1.6 to 6.4 pts | Row C = 3.2 to 12.8 pts | Row D = 0 pts (Blank) | Row E = 0 pts (Blank).
• Even if a child has the most severe Dyslexia, Dysgraphia, or Acquired Brain Injury in Derby, the maximum single-row score in that column is 12.8 points (or 19.2 points combining B+C)—less than one-tenth of the 189 points required to reach the lowest £1,000 funding band!
Yet in their backdated August 2026 Equality Impact Assessment (signed by Sharon Buckby and Louise Bartos), the Council ticked "Positive impact = Yes" and "Negative impact = [Blank]" across all protected characteristics, claiming on Page 6 that the Matrix ensures "children and young people with similar needs are allocated similar funding to meet those needs"!
3. The Secret £12,000 "Mainstream Setting Cap" Hidden in Tab 4 (Banding)
When you look at Sub-Page 8 of the Council's webpage (Element 3 funding: Top-up tariff), the Council displays a table running from 125 - 188 points (£0) up to 3421+ points (£20,000.00).
First, notice that the Council deleted Band 0 (0–60 pts = £0) and Band 1 (61–124 pts = £0) from the webpage HTML table so parents and schools wouldn't immediately see that the first three bands (0 to 188 points) pay £0.00 of Element 3 top-up funding!
Second, and far more seriously, hidden at Rows 27 to 31 of Tab 4 (Banding) inside the Excel file (and omitted from the webpage HTML) is a table marked:
"For office use only - indication of min and max amounts based on establishment only"
* Mainstream School: Min Annual E3 amount = - (£0) | Max Annual E3 amount = £12,000 (Band 12 — max £22k total package with £10k school base)
* Enhanced Resource Base: Min Annual E3 amount = £6,000 | Max Annual E3 amount = £10,000 (Band 10 — max £26k total package including £10k school base + £6k ER place grant)
* Special School: Min Annual E3 amount = £10,000 | Max Annual E3 amount = £20,000 (Band 20 — max £30k total package with £10k place grant)
And in Tab 3 (Band_calculator), Column 44 calculates "Amount calculated based on Matrix Score with no setting cap", while Column 45 enforces "Amount calculated based on Matrix Score with setting cap".
What this means for every mainstream child in Derby:
While the Council tells parents and the Department for Education that the Matrix provides up to £20,000 of top-up funding, any disabled child attending a mainstream school in Derby is secretly hard-capped at £12,000 (Band 12), reserving Bands 13 to 20 (£13,000 to £20,000) exclusively for Special Schools!
In my son Charlie's case, his mainstream primary school formally told the Council in January 2026 that he needed over £20,000 of 1:1 support to stay safe after breaking his arm and dislocating his elbow on playground equipment. Because Charlie is academically at Age Related Expectations (Row A = 0 pts in Learning Readiness) and his needs fall into the reduced neurodivergent columns (48%, 25%, and 8%), the Matrix scored him into the lowest bands (leaving him with a morning-only TA who vanishes at 11:30 am every day) - and even if he had scored higher, the secret Mainstream Cap would have blocked the £20,000 his school requested!
4. The DfE Officially Disowns Derby’s Matrix (OFFICIAL - FOR PUBLIC RELEASE)
For months, Derby City Council leadership has tried to tell councillors, headteachers, and the press that their new SEND funding model is backed by the Department for Education.
In the letter we received from the DfE East Midlands Regions Group on 22 October 2026 (Ref: 2026-0092090, marked OFFICIAL - FOR PUBLIC RELEASE), the Department for Education has officially disowned Derby City Council's Matrix:
- The DfE Has Never Approved or Reviewed the Matrix:
"The department has not approved, endorsed or reviewed Derby City Council’s High Needs Banding Matrix and has no remit to do so."
- Pre-Determined Financial Bands Cannot Dilute EHCP Duties:
"The use of indicative funding bands during consultations with schools is not in itself unlawful but cannot be used to dilute the LAs legal duty. An Education, Health and Care Plan (EHCP) must explicitly specify and quantify the child’s needs first. A local authority cannot force a child's provision to fit into a pre-determined financial band."
- The Section 496/497 Statutory Investigation Remains Open:
"We are aware that you have contacted the department previously and there is a current s496/497 investigation in progress regarding your complaint."
We have today submitted the complete mathematical proof of the 48%/25%/8% neurodivergent weighting reductions, the secret £12,000 Mainstream Setting Cap, and the backdated 21 August 2026 EIA metadata - alongside our 12-Page Forensic Report - directly to the Department for Education and Jonathan Davies MP for the Secretary of State's attention.
Please download and share our 12-Page Forensic Report with every parent, SENCO, teacher, headteacher, and councillor in Derby: https://drive.google.com/file/d/15kHuHUTbN8HAPjfiw291Ou7DgFlXyC4s/view?usp=sharing
If your child has been affected by the Matrix or left without afternoon support, email us in strict confidence at sen@melroseandco.uk.