Safe Staffing for Care Homes: How to Evidence CQC Regulation 18

"Do you have enough staff?" is the question behind many CQC findings. The answer an inspector needs is not yes or no, but evidence: how you decided what enough looks like, whether the rota met it, and what actually happened on the day.

What Regulation 18 says

Regulation 18 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 has two parts:

1. Sufficient numbers of suitably qualified, competent, skilled and experienced people must be deployed to meet the requirements of the regulations.
2. People employed must receive appropriate support, training, professional development, supervision and appraisal, be enabled to obtain further qualifications where appropriate, and, if they are registered professionals, be enabled to show their regulator that they continue to meet its standards.

The regulation does not set a staff-to-resident ratio. That is deliberate: the right numbers depend on the people you support. It also means the burden is on you to show how you decided and whether you delivered.

Evidence that numbers are sufficient

Decide what "enough" means

Record how you set staffing for each location and shift: the needs of the people you support, the layout of the building, and the skills each shift needs, such as a medication-trained member of staff on every medication round. Review it when needs change, and keep the review.

Show plan, rota and reality side by side

A staffing policy proves little on its own. The strongest evidence compares three things for the same period: what you planned, what you rostered, and who actually worked.

Where the three differ, show what you did about it: an agency shift booked, a manager working on the floor, or a shift reorganised, and the reason.

Track agency use and continuity

Heavy reliance on agency staff is not a breach in itself, but it raises questions about continuity of care and induction. Track the share of hours covered by agency staff, and keep evidence that agency workers were inducted and their training and checks confirmed.

Remember the notification duty

Under Regulation 18 of the Care Quality Commission (Registration) Regulations 2009, providers must notify CQC without delay of events that prevent, or appear likely to threaten, their ability to continue to provide services safely, and that includes an insufficient number of suitably qualified, skilled and experienced staff. A registered manager's planned absence of 28 days or more also needs notice to CQC under Regulation 14 of those Regulations.

Evidence that staff are supported

The second half of Regulation 18 is about the people already on the rota:

• Training: a matrix of mandatory training for each role, with completion and expiry dates, and what happens when training lapses.
• Induction: evidence that new care staff complete an induction, such as the Care Certificate, before working unsupervised.
• Supervision: regular supervision at a frequency you have set, with notes and actions.
• Appraisal: an annual appraisal for every member of staff.
• Professional registration: for nurses and other registered professionals, support to maintain their registration.

Night shifts and lone working

Night shifts and home care visits are where staffing evidence is thinnest, because fewer people are there to see what happened. Clock-in records and welfare check calls for staff working alone give you a record of who was on duty and that they were safe.

What good staffing records look like

Strong staffing evidence usually has the same features:

• Dated and specific: who worked which shift, on which unit, and when they arrived and left.
• Linked to need: a recorded reason for the staffing level on each shift, reviewed when needs change.
• Honest about gaps: shortfalls recorded with what was done, not hidden by a rota that was never updated.
• Joined up: training, supervision and checks for the same people who appear on the rota, so you can show that the staff who were there were the right staff.
• Easy to produce: retrievable in minutes for any date range, without rebuilding spreadsheets.

A quick self-check

• Can you show planned, rostered and actual staffing for every shift in the last month?
• Does every medication round have a trained, competency-assessed member of staff?
• Is mandatory training in date for everyone currently on the rota?
• Are supervision and appraisal up to date, and recorded?
• Do you know your agency share of hours this month?
• Would you know, the same day, if a shift fell below safe staffing?

How ProRota helps

Available in ProRota today: scheduling for every location, GPS clock-in and clock-out so you can show who actually worked, training and qualification records with expiry dates, and check calls for lone and night workers.

CQC Compliance adds required staffing and skill mix per location and shift, compared automatically with the rota and with who actually worked, plus supervision, appraisal and induction tracking. Read more about CQC's new sector frameworks, where safe staffing appears as a line of enquiry in the adult social care draft.