Children’s homes need enough capable staff to meet each child’s needs safely, consistently and with care. Regulation 31 of the Children’s Homes (England) Regulations 2015 focuses on staffing arrangements, continuity, first aid cover and the use of registered nurses. It does not prescribe one universal staff-to-child ratio.
That distinction matters. A rota can look numerically complete and still be unsafe if it lacks the right skills, experience, relationships or management support. Equally, a higher headcount is not a substitute for thoughtful matching and a clear understanding of the children who live in the home.
This guide explains what Regulation 31 requires, how it connects with the Quality Standards and what evidence a provider should be able to show.
Key point:
Staffing decisions should begin with the needs, risks and plans of the children living in the home. The building’s capacity is not, by itself, a safe staffing formula.
Images in this guide are AI-generated illustrations, not photographs of Welcare premises or evidence of a particular home’s facilities.
What Regulation 31 requires
Regulation 31 requires the registered person to ensure that:
These duties sit alongside the wider requirement in Regulation 13 to maintain the leadership and management needed for the home to operate effectively. They also work with Regulation 32 on the fitness of workers and Regulation 33 on staff development and supervision.
There is no single statutory staffing ratio
The 2015 Regulations do not set one fixed ratio for every children’s home. Staffing must be sufficient for the home’s statement of purpose and for the individual children accommodated at that time.
A suitable arrangement may change when:
- a child is admitted, discharged or returns unexpectedly;
- risk related to missing episodes, exploitation, self-harm or aggression changes;
- a child needs one-to-one or two-to-one support for a particular activity;
- appointments, family time or school transport take staff away from the building;
- a new team member needs shadowing;
- the home is using more than one building;
- a waking-night arrangement is required;
- several children have competing needs at the same time; or
- an emergency makes the ordinary rota unavailable.
The home's assessment should explain why the planned number and mix of staff can meet foreseeable needs. It should not rely only on historic practice or the number entered on an old rota template.
Planning staffing levels around children
A practical staffing assessment should consider each child’s placement plan, relevant risk assessments and care plan. It should then look across the whole group to identify likely pressure points.
Useful questions include:
- What direct support does each child require during mornings, school returns, evenings and nights?
- Which activities require additional staff because of transport, community risk or individual support?
- What skills must be present on each shift?
- Can the team respond safely if one child has a crisis while another needs immediate care?
- Who provides management advice outside office hours?
- How will breaks, sickness, training and annual leave be covered?
- Could the arrangement continue safely if an emergency placement is proposed?
- What would trigger a same-day review of the rota?
The answer should produce more than a number. It should identify the roles, competence and deployment needed on each shift.
Skills mix and experience
Temporary and agency workers
Regulation 31 does not prohibit agency or temporary staff. It requires the registered person to ensure that their use does not undermine reasonable continuity of care.
Continuity matters because children should not repeatedly have to explain their history, routines, communication or worries to strangers. Familiar staff are more likely to notice subtle changes and understand how a child’s plans work in practice.
The Department for Education’s Guide to the Children’s Homes Regulations, including the quality standards says providers should avoid an over-reliance on agency staff. The guide indicates that no more than half of the staff on duty at any one time should be from an external agency. This is statutory guidance about how the Regulations should be interpreted and applied, not a ratio written directly into Regulation 31.
When temporary staff are used, the home should:
- check their identity, suitability and relevant experience before deployment;
- provide an effective local induction before they work independently;
- give access to the information necessary to care for each child safely;
- explain emergency, safeguarding, missing, medicines and recording procedures;
- identify tasks they are not authorised or competent to undertake;
- arrange supervision and feedback;
- record which shifts they worked; and
- monitor whether repeated use is affecting relationships, routines or outcomes.
A familiar bank worker may offer better continuity than a sequence of new agency workers. The home should record the reasoning, not assume all temporary arrangements have the same effect.
First aid cover
At least one person with a suitable first aid qualification must be on duty at the home at all times. Suitability depends on the likely situations in the home and the needs of the children, rather than the title of a course alone.
Providers should check:
whether the course content matches the age and needs of the children;
whether certificates are current
whether qualified cover is shown on every rota, including nights
what happens if the qualified person leaves the premises with a child
whether staff can access first aid equipment promptly
how incidents, treatment and follow-up are recorded
whether additional clinical training is needed for a specific child
The duty is about actual cover, not simply the number of trained people on the establishment list. The Regulation 25 fire safety guide explains the related need to plan staff deployment for emergencies and evacuation.
Test the Rota Against Actual Deployment
Imagine that three staff are shown on a shift, but the only suitably qualified first aider is due to take a child to an appointment. The rota’s total does not demonstrate first aid cover for the children remaining at the home. Before the outing, the manager needs to arrange suitable cover and check that the deployment still meets every child’s needs.
This is an illustrative check, not a recommended staffing ratio. An on-call worker elsewhere is not a substitute for the required qualified person on duty at the home.
Registered nurses and delegated health tasks
If a person is employed by the home as a nurse, Regulation 31 requires that person to be registered with the Nursing and Midwifery Council. Registration can be checked using the NMC’s public register.
Many homes support children with health needs without employing a nurse. Staff may carry out tasks following training and delegation from an appropriate health professional. In those cases, the provider should be clear about who has assessed competence, the limits of the task, review arrangements and what staff must do when they are uncertain.
Medicines duties are considered separately under Regulation 23.
Lone working and one member of staff on duty
The Regulations do not automatically prohibit a single member of staff from being on duty. However, the DfE guide says a formal assessment should be completed where the home’s staffing arrangement is likely to involve only one person on duty.
That assessment should address the needs and views of the children, foreseeable emergencies, activities outside the home, access to management support and the ability to preserve privacy and dignity. It should also consider how the worker would respond if two urgent events occurred together.
A generic lone-working policy is not enough. The assessment should be specific to the home, the shift and the children currently placed.
Night staffing and on-call support
Night arrangements should follow evidence about children’s needs and risks. A sleeping-in arrangement may be appropriate in one home while another requires waking-night staff or additional cover.
The plan should state:
- who is physically present;
- whether staff are sleeping or awake;
- how frequently checks are required and why;
- how a second person is called;
- expected response times;
- who makes management decisions;
- how an evacuation would be managed; and
- what happens if a child leaves the home unexpectedly.
On-call arrangements should be tested in practice. A telephone number has limited value if the person cannot answer, attend or authorise necessary action.
The workforce plan
The DfE guide expects the registered person to have a workforce plan that can fulfil the home’s statement of purpose. It should cover staffing structure, experience, qualifications, training, supervision and contingency arrangements.
A useful workforce plan connects strategic needs with daily practice.
It can show:
the roles and responsibilities in the team
the experience and qualification profile required
gaps and recruitment priorities
induction and probation arrangements
the approach to supervision and appraisal
plans for staff to gain the required residential childcare qualification
succession and management-cover arrangements
how agency use and turnover will be reduced
The plan should be reviewed as the children, staff group or service model changes. It should agree with the statement of purpose, rotas and recruitment records.
Contingency planning
What inspectors may look for
Ofsted’s current social care common inspection framework for children’s homes considers whether leaders deploy staff with the experience, qualifications and skills to meet children’s needs. Inspectors can examine impact rather than accepting a rota at face value.
Evidence may include:
- recent and historic rotas;
- actual hours worked;
- staff files and qualification records;
- the workforce plan;
- supervision and appraisal records;
- agency profiles and induction records;
- first aid coverage;
- incident and missing records;
- children’s views;
- placement matching decisions;
- turnover, absence and vacancy data
- actions taken when staffing fell below plan.
Differences between the planned rota and who actually worked should be visible and explained.
Common weaknesses
Common problems include treating the home’s maximum capacity as the basis for a standard ratio, counting an on-call manager as if they were present, leaving first aid gaps when staff escort children, and using unfamiliar agency workers without a meaningful induction.
Other warning signs are frequent rota changes, an inexperienced skills mix, training that has expired, repeated overtime and records that do not match actual deployment. Each may indicate a wider continuity or leadership issue.
Regulation 31 audit checklist
- Staffing levels reflect the current children, not only registered capacity.
- Each shift has the necessary skills and leadership.
- Rota changes and actual hours are recorded.
- Temporary staff use is monitored for its effect on continuity.
- Agency and bank workers receive a local induction.
- Suitable first aid cover is present at all times.
- Night and lone-working arrangements have a current assessment.
- On-call arrangements are clear and tested.
- Any employed nurse has current NMC registration.
- The workforce plan reflects current vacancies, skills and contingencies.
- Admissions are checked against available staffing capacity.
- Children are asked whether staffing feels consistent and supportive.
Frequently Asked Questions (FAQs)
There is no single ratio in the 2015 Regulations. The provider must arrange enough suitably skilled staff to meet the assessed needs of the children and operate in line with the statement of purpose.
Yes. Regulation 31 requires the provider to ensure that temporary staffing does not prevent reasonable continuity of care. Suitability checks, local induction, information sharing and monitoring are essential.
At least one person with a suitable first aid qualification must be on duty at the home. Deployment should ensure the duty remains met when staff accompany children outside the building.
It may be possible where a formal, child-specific assessment shows the arrangement is safe and suitable. The assessment should address emergencies, simultaneous needs, activities, night arrangements and management support.
Yes. The registered person must make suitable arrangements for disposal as well as handling, recording, safekeeping and administration.
No. However, anyone employed as a nurse must be registered with the NMC. Other health tasks should be supported by suitable training, delegation and competency assessment where relevant.
