If she struggles with a 38/27 gear, she's going to need to invest a bit money to get something lower. I agree with the triple suggestions. That means she'll need a new bottom bracket, crankset, front derailleur, and long-cage rear derailleur. Swapping out for a triple is usually more expensive than most people expect.

edit: No new shifter needed, apparently. 9-speed Ultegra fronts work with double or triple.