Were the "comprehensive-support type" and "specific-programme type" introduced for after-school day services? Staffing and add-on labour after the 2024 revision
Joji Uramatsu
Shakai Hoken Roumushi (Certified Social Insurance and Labor Consultant), Gyoseishoshi (Certified Administrative Procedures Legal Specialist), Registered Real Estate Transaction Specialist — 四葉社会保険労務士事務所/四葉行政書士事務所
The two types "comprehensive-support type" and "specific-programme (specialised) type" were not introduced in the FY2024 (Reiwa 6) remuneration revision. They were a proposal at the study stage. What was actually decided was to make comprehensive support covering all five domains the basis, to make preparing and publishing a support programme mandatory (a 15% reduction of the set units if not published, enforced 1 April 2025), and to divide the basic remuneration by support-time bands. The staffing standards themselves did not change. What matters for labour is full-time-equivalent conversion and working-hour management. Designing staffing, FTE, work rules and shifts is a Shakai Hoken Roumushi's work; the designation application belongs to a Gyoseishoshi, and add-on calculation and NHIF billing are done by the establishment, each under a separate contract as an independent business entity.
Bottom line first: The two types "comprehensive-support type" and "specific-programme (specialised) type" were not introduced in the FY2024 (Reiwa 6) remuneration revision. They were a proposal shown at the study stage. What was actually decided was to make comprehensive support covering all five domains the basis, to make preparing and publishing a support programme mandatory (a 15% reduction of the set units if not published, enforced 1 April 2025), and to divide the basic remuneration by support-time bands. The staffing standards themselves did not change. What matters for labour is full-time-equivalent conversion and working-hour management.
Designing staffing and full-time-equivalent conversion for after-school day services and child development support, designing work rules and shifts, and managing the working hours the add-ons require, is work that 四葉社会保険労務士事務所 takes on. The designation application and change notifications belong to a Gyoseishoshi (四葉行政書士事務所), and confirming the property's use district is a real-estate company's area; as an independent business entity separate from 四葉社会保険労務士事務所, you contract with each separately. Add-on calculation and billing to the National Health Insurance Federation (NHIF) are done by the establishment, and individual determinations are made by a qualified professional after a consultation.
Was the reorganisation into "comprehensive-support type / specific-programme type" carried out?
It was not. "Comprehensive-support type" and "specific-programme (specialised) type" were a proposal for the basic remuneration shown within the discussion of the study team toward the FY2024 revision, and they were not adopted in the final revision. The premise itself that "staffing changes under a specialised type" does not exist as a system.
What was actually decided in the FY2024 revision is the following three points.
| What was actually decided | Content |
|---|---|
| Comprehensive support over five domains as the basis | The operating standards state that comprehensive support covering all five domains — health/daily life, movement/senses, cognition/behaviour, language/communication, and relationships/sociality — is to be provided. The individual support plan clarifies the link to the five domains |
| Preparing and publishing a support programme made mandatory | Prepare a support programme and publish it via the internet etc. If not published, a 15% reduction of the set units applies (enforced 1 April 2025) |
| Basic remuneration divided by support time | Basic remuneration is set by support-time bands such as "30 minutes to 1.5 hours", "over 1.5 to 3 hours", and "over 3 to 5 hours" |
An establishment that has provided only a specific therapeutic content may need to review its content or operating policy toward comprehensive support over the five domains. But this does not mean "a separate 'specialised type' category was created". The idea of the staffing standards before and after the revision is set out in Staffing standards and labour for child development support and after-school day services.
How are the staffing standards for child instructors and nursery teachers set?
The staffing standards are set by the Standards on Personnel, Equipment and Operation for Designated Ambulatory Support Businesses etc. under the Child Welfare Act (Ordinance of the Ministry of Health, Labour and Welfare No. 15 of 2012). The FY2024 revision did not change these placement numbers themselves.
At an after-school day service (excluding establishments mainly accepting children with severe physical and intellectual disabilities), you place at least the following number of child instructors or nursery teachers.
| Number of children with disabilities | Number of child instructors or nursery teachers |
|---|---|
| Up to 10 | 2 or more |
| 11 or more | 2, plus 1 for every 5 (or fraction thereof) above 10 |
At least one of these must be full-time, and at least half of the placed staff must be child instructors or nursery teachers. In addition, you place at least one child development support manager, dedicated and full-time, and a manager. Whether you meet the ratio of qualified staff and the full-time requirement is shown in a duty-roster (work-structure) list, so having the scheduled working hours in the work rules and the actual shifts in order is the premise. The duty to prepare work rules is set out in From how many employees are work rules mandatory.
How do you count the full-time equivalent?
"Full-time" means a worker who reaches the "hours a full-time worker should work" set by the establishment. When those hours fall below 32 per week, you judge full-time or part-time on a basis of 32 hours a week.
Full-time-equivalent (FTE) conversion is a method of dividing the total working hours of the staff, including part-timers, by the hours a full-time worker should work, to find how many full-time workers that equals.
| Term | Meaning |
|---|---|
| Full-time | A person who reaches the full-time hours set by the establishment (32 hours/week is the basis where those hours fall below 32) |
| FTE | Total working hours of the staff ÷ hours a full-time worker should work (= how many full-time workers) |
FTE conversion is the aggregation of working hours itself, so it links directly to working-hour management. The same idea is common to FTE in disability welfare and care; see How do you calculate the full-time equivalent, and the staffing standards for employment support type A and B are in Staffing standards and labour for employment support type A and B. The actual way of counting the FTE can differ depending on the treatment of breaks, absences and concurrent duties (unverified).
How do you manage the working hours the add-ons require?
Many add-ons are decided by how many staff, in which work form, you place beyond the standard staffing. This is where working-hour management matters.
| Add-on | Main requirement (example for after-school day services) |
|---|---|
| Additional child-instructor allowance | Beyond the standard staffing, place a target qualified person as full-time-dedicated or FTE 1.0 or more. The units differ by work form and years of experience |
| Specialised support system allowance | Place a physical therapist, occupational therapist, speech-language-hearing therapist, psychology-guidance staff, or a nursery teacher / child instructor with 5 or more years of child-welfare experience (a system-type add-on) |
| Specialised support implementation allowance | Where individual, intensive specialised support is carried out as planned, calculated within the monthly limit on the number of times (an implementation-type add-on) |
To meet "FTE 1.0 or more", you look at whether summing the working hours of several part-timers is enough. This cannot be shown unless the shifts and the working-hour records are in order. Setting the scheduled working hours in the work rules, and keeping the duty-roster list consistent with the actual time cards, is the premise for calculating add-ons stably. Add-on calculation and NHIF billing are the establishment's work; the Shakai Hoken Roumushi handles the design of the work structure and working hours and the preparation of the records. The staffing standards and treatment for a nursery are also set out in Staffing standards and treatment when opening a nursery. The final application of whether a given add-on can be calculated turns on the designating authority's interpretation and the establishment's operating reality (unverified).
Who do you assign the designation, property and add-on calculation to?
Opening and operating an after-school day service involves procedures where the qualifications in charge differ. Each is a separate contract.
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| Procedure | In charge |
|---|---|
| Designation application, change notifications, drafting the operating rules | Gyoseishoshi (四葉行政書士事務所, a business entity separate from this office) |
| Staffing, FTE, work rules, shifts, working-hour management | Shakai Hoken Roumushi (四葉社会保険労務士事務所) |
| Confirming the property's use district and building use | Real-estate company |
| Add-on calculation and NHIF billing | The establishment |
四葉社会保険労務士事務所 accepts work as an independent business entity, and where another professional or business such as a Gyoseishoshi or a real-estate company is needed, we introduce them under a contract you conclude directly, separately. This office takes no referral fee.
What can 四葉社会保険労務士事務所 do?
What this office takes on is designing the labour to meet the staffing and add-ons of after-school day services and child development support.
- Placing child instructors, nursery teachers and the child development support manager, and confirming the ratio of qualified staff and the full-time requirement
- Organising the idea of FTE conversion, and designing the duty-roster list and shifts
- Building a mechanism to manage the working hours the additional child-instructor allowance and the specialised support system/implementation allowances require
- Preparing work rules, notice of working conditions, and working-hour management
- Supporting the review of the work structure that the support-programme publication duty brings
The designation application and change notifications are handled by a Gyoseishoshi, confirming the property's use district by a real-estate company, and add-on calculation and NHIF billing by the establishment. 四葉社会保険労務士事務所 accepts work as an independent business entity, and where another professional such as a Gyoseishoshi (四葉行政書士事務所) is needed, we introduce them under a contract you conclude directly, separately. There is no referral fee.
Consultations are free of charge. Fees are set out in the fee schedule; see also our services and how a consultation proceeds.
Frequently asked questions
Q. Was a "comprehensive-support type" and "specific-programme type" division created for after-school day services?
A. It was not introduced in the FY2024 remuneration revision. It was a type proposal shown in the study team's discussion and was not adopted in the final revision. What was actually decided was to make comprehensive support covering all five domains the basis, to make preparing and publishing a support programme mandatory (a 15% reduction of the set units if not published, enforced 1 April 2025), and to divide the basic remuneration by support-time bands. The staffing standards themselves did not change.
Q. How many child instructors and nursery teachers should we place?
A. At an after-school day service (excluding establishments mainly for children with severe physical and intellectual disabilities), you place child instructors or nursery teachers as follows: for up to 10 children, 2 or more; for 11 or more, 2 plus 1 for every 5 (or fraction) above 10. At least one of these must be full-time, and at least half of the placed staff must be child instructors or nursery teachers. You also place at least one child development support manager, dedicated and full-time (Ordinance of the Ministry of Health, Labour and Welfare No. 15 of 2012).
Q. How do you count the full-time equivalent?
A. You divide the total working hours of the staff by the hours a full-time worker should work at that establishment, to find how many full-time workers that equals. Where the full-time hours fall below 32 per week, you judge on a 32-hour-a-week basis. When an add-on requires "FTE 1.0 or more", you look at whether summing the working hours of several part-timers is enough. Having the shifts and working-hour records in order is the premise.
Q. Can I also ask a Shakai Hoken Roumushi for the add-on calculation and NHIF billing?
A. Add-on calculation and billing to the NHIF are the establishment's work, and the Shakai Hoken Roumushi handles the design of the work structure and working hours and the preparation of records. The designation application and change notifications are a Gyoseishoshi's area, and confirming the property's use district is a real-estate company's area. 四葉社会保険労務士事務所 takes on the design of staffing, FTE, work rules and shifts as an independent business entity, and where another professional is needed we introduce them under a contract you conclude directly. This office takes no referral fee.
Basis for this article
- Standards on Personnel, Equipment and Operation for Designated Ambulatory Support Businesses etc. under the Child Welfare Act (Ordinance of the Ministry of Health, Labour and Welfare No. 15 of 2012) — the staffing standards for after-school day services and child development support (the number of child instructors or nursery teachers, at least one full-time, at least half being child instructors or nursery teachers, and the dedicated full-time placement of the child development support manager) and the idea of full-time / FTE (32 hours a week is the basis where the full-time hours fall below 32)
- The FY2024 (Reiwa 6) revision of remuneration for disability welfare services etc. — for child development support and after-school day services: comprehensive support over the five domains (health/daily life, movement/senses, cognition/behaviour, language/communication, relationships/sociality) as the basis; making preparing and publishing a support programme mandatory (a 15% reduction of the set units if not published, enforced 1 April 2025); the support-time bands for basic remuneration; and the review of the additional child-instructor allowance and the specialised support system/implementation allowances (Children and Families Agency "On the FY2024 revision of remuneration for disability welfare services etc." and Ministry of Health, Labour and Welfare notices, accessed 19 September 2026)
- "Comprehensive-support type" and "specific-programme (specialised) type" were a proposal for the basic remuneration shown at the study stage toward the FY2024 revision and were not adopted in the final revision (Children and Families Agency and related-body revision materials, accessed 19 September 2026)
- Labour Standards Act (Act No. 49 of 1947) — the premise of work rules, scheduled working hours and working-hour records. FTE conversion links directly to the aggregation of working hours
- The final application of the concrete number of staff, the FTE, and whether an add-on can be calculated turns on the designating authority's interpretation and the establishment's operating reality, and on the treatment of breaks, absences and concurrent duties. This article does not conclude on the individual case (unverified)
This article is general information. Individual determinations are made by a qualified professional after a consultation, in light of individual circumstances. 四葉社会保険労務士事務所 can advise on the placement of child instructors, nursery teachers and the child development support manager, confirming the ratio of qualified staff and the full-time requirement, the idea of FTE and the design of the duty-roster list and shifts, managing the working hours the additional child-instructor allowance and the specialised support system/implementation allowances require, and preparing work rules and working-hour management. The designation application and change notifications are handled by a Gyoseishoshi (四葉行政書士事務所), confirming the property's use district by a real-estate company, and add-on calculation and NHIF billing by the establishment. 四葉社会保険労務士事務所 accepts work as an independent business entity, and where another professional is needed, we introduce them under a contract you conclude directly, separately; there is no referral fee. Frequently asked questions are collected in the FAQ. Written by Joji Uramatsu (Shakai Hoken Roumushi, Gyoseishoshi, Registered Real Estate Transaction Specialist).
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