00 10,000 2011–12 2013–14 2015–16 2017–18 2019–20 2021–22 2023–24 Phase 3 Phase 4 Phase 5 Phase 6 Phase 7 Phase 8 Phase 9 Semi-independent living accommodation not subject to Children's Homes Regulations (H5) Secure children’s homes (K1) Children’s homes subject to Children’s Homes Regulations (K2) Independent living with or without formal support (P2) Residential care home (R1) NHS/Health Trust or other establishment providing medical/nursing care (R2) Young offender institution or secure training centre (R5) Residential schools except dual-registered as school and children’s home (S1) 66 5.4 Complex needs ‘low incidence, high cost’ placements We have seen a reduction in what is available to us from external sources, and this means that, in effect, children who need those services [secure and Tier 4 mental health] do not, and cannot, all have access to them, and they are then accommodated in other provision types that are not best suited to meet their needs. We need improved engagement with health around the complex mental health needs of young people to ensure they are being met in the most appropriate location. (Survey, County, Eastern Region) Local authorities have statutory duties to provide secure accommodation where a child is a danger to themselves or others or is regularly placing themselves at risk. They also have duties to uphold children’s rights under Articles 2 and 3 of the European Convention on Human Rights (ECHR). Many of the interviews with DCSs and survey responses foregrounded ‘complexity’ – a term, like vulnerability, that is often used and not always clearly defined. Ofsted published work in 2024 which defined complexity as ‘describing multiple needs which require joined up responses from a range of professional specialists’, which underlines the n