Staffing standards and labor for disability-welfare providers
The 常勤換算 (full-time-equivalent conversion) used in the designation standards and the prescribed working hours set in your work rules are two different things. Lining up enough people to meet the standard does not make the arrangement stand up if the employment contracts, work rules and actual attendance do not follow. This page sets out the issues on the side that makes a compliant staffing arrangement work as employment. Explaining the designation requirements themselves and preparing the application documents are handled by 四葉行政書士事務所 under a separate contract.
How does 常勤換算 relate to the prescribed working hours in the work rules?
常勤換算 is the idea of converting part-time staff hours into “how many full-time staff this amounts to.” The denominator of that calculation is the prescribed working hours set for full-time staff at that provider. Because prescribed working hours are set in the work rules and employment contracts, a change to the work rules changes the full-time-equivalent figure even where the actual pattern of work is the same.
So even where the application documents show enough people, a gap between what the work rules provide and how work is actually performed can lead to questions at a later on-site inspection. Rather than treating compliance as a matter of the figures on the form, the point is to check that the work rules, the employment contracts and the attendance records are all written on the same assumptions.
How 常勤換算 is calculated, and how many staff must be placed, are issues on the designation-standards side. Please see Staffing standards for support workers and daily-living support staff (a column by 四葉行政書士事務所, in Japanese).
What is the difference between meeting the staffing standards and employing people properly under labor law?
They look to different laws. The staffing standards, as designation criteria under 障害者総合支援法 (the Act on Comprehensive Support for Persons with Disabilities), set out which roles must be filled and by how many people. How you employ those people is governed by the Labor Standards Act and other labor legislation, and coverage by social insurance by the Health Insurance Act, the Employees' Pension Insurance Act and others.
- Designation-standards side: roles, required numbers, full-time or part-time, qualification requirements
- Labor-legislation side: stating working conditions, working hours, breaks and days off, premium wages, annual paid leave
- Social-insurance side: criteria for a covered workplace, who becomes an insured person, filing deadlines
“Securing people who meet the standard” and “employing those people lawfully” are not enough on their own. When preparing to open, we recommend checking both side by side.
If the administrator also serves as サービス管理責任者, what should be watched on the labor side?
Whether concurrent service is permitted under the designation standards varies with the service category, the size of the provider and the practice of the designating authority. Here we list the points to check on the labor side on the assumption that concurrent service is permitted.
- How the scope of the duties undertaken is written in the employment contract and the notice of working conditions
- Whether the position and position allowance under the work rules correspond to the duties actually performed
- Whether working hours need to be recorded separately for each of the concurrent roles
- Whether the question of supervisory or managerial status (Labor Standards Act, Article 41, item 2) is being checked against the substance rather than the job title
Whether someone holds supervisory or managerial status is said to be judged on the substance of duties, authority and treatment rather than on the title of the position. Individual determinations are made by a qualified professional following consultation.
What happens if the staffing arrangement stated on the application and the actual shift roster diverge?
Even after designation, a change to the arrangement may require notification to the designating authority. That is a procedure on the designation-standards side. Alongside it, notifications for social insurance and employment insurance may also be required on the labor side. The two go to different places and have different deadlines, so the point is not to file one and consider the matter closed.
| When this happens | Designation-standards side (handled by 四葉行政書士事務所 under a separate contract) | Labor side (handled by this office) |
|---|---|---|
| A staff member is hired | Notification of change to the designating authority, if the arrangement changes | Notification of acquisition of insured status for health insurance and employees' pension, and for employment insurance |
| A staff member leaves | As above | Notification of loss of insured status, and issuing the separation certificate |
| The administrator or サービス管理責任者 changes | Notification of change to the designating authority | Changes to the employment contract and duties, and checking the position under the work rules |
| Working patterns change (full-time or part-time status, or number of hours) | Review of the arrangement where the full-time-equivalent figure is affected | Reissuing the notice of working conditions, and checking the social-insurance category of the insured person |
Whether a notification is required, and its deadline and form, vary with the service category and the designating authority. The table above is set out to show how responsibilities divide, and is not to be used as it stands to decide an individual case.
For staffing standards, should I consult an administrative scrivener or a Certified Social Insurance and Labor Consultant?
It divides according to what you want to ask.
- “How many people must be placed?” “How should the application be written?” — the designation-standards side. 四葉行政書士事務所 handles this under a separate contract
- “How should those people be employed?” “How should the work rules be revised?” — the labor side. This office handles this
It is quite all right if you cannot yet tell which it is. We listen to what you want to discuss and show you at the outset which office handles which part. The two offices are at the same address but are independent businesses. Contracts, invoices and payment details are also separate. You can engage only the part you need.
Why clients choose Yotsuba — and why the contracts are separate (in Japanese)
How much does it cost?
Because it varies with the scope of work and the size of the provider, we give you a quotation. It is billed separately from the fees of Yotsuba Real Estate Co., Ltd. and 四葉行政書士事務所.
The basis for this page
- Staffing standards = the designation standards (ministerial ordinances for each service category) under 障害者の日常生活及び社会生活を総合的に支援するための法律 (the Act on Comprehensive Support for the Daily and Social Life of Persons with Disabilities, Act No. 123 of 2005)
- Scope of supervisory and managerial status = Labor Standards Act (Act No. 49 of 1947), Article 41, item 2
- Stating working conditions = Labor Standards Act, Article 15, paragraph 1
- Social-insurance coverage and notifications = Health Insurance Act (Act No. 70 of 1922) and Employees' Pension Insurance Act (Act No. 115 of 1954)
- Employment-insurance notifications = Employment Insurance Act (Act No. 116 of 1974)
* The dates of last amendment of each statute, and the article numbers of the ministerial ordinances, have not been individually verified against primary sources as at the time this page was written (not verified). How 常勤換算 is calculated, and the deadlines and forms for notifications, vary with the service category and the designating authority. Please check the current treatment in the designating authority's guidelines, or we will explain it at a consultation.
This page is general information. Individual cases are explained after confirmation by a qualified professional. Preparing the designation application documents is handled by 四葉行政書士事務所 and real-estate transactions by Yotsuba Real Estate Co., Ltd., each under a separate contract. Tax filing and representation are the work of a tax accountant, registration that of a judicial scrivener, and contentious matters that of an attorney.
Last updated: 29 July 2026