A domiciliary carer's day is a chain of short calls in different houses, and the minutes between them are work. Agencies that do not count them have been found to pay below the minimum wage, and HMRC has named and fined care employers for exactly this. The rules are not complicated, but they have to be applied to every carer, every day, which is where spreadsheets fail. This guide sets out what counts, how to calculate it, and how to stop estimating.
Time spent travelling between one client's home and the next during a run is working time. So is time spent waiting between calls when the carer cannot use the time as their own, for example a ten-minute gap on a street with nowhere to go. Travel from the office to the first call, where the carer has been required to attend the office, is working time too. The principle is simple: once the carer is at the employer's disposal, the clock is running until they are released.
Travel from home to the first call and from the last call back home is ordinary commuting and is not working time, unless the contract says otherwise. A genuine break, where the carer is free to do as they please for a set period, is not working time either, but a gap too short to be useful is not a break. Many agencies get into trouble by labelling every gap a break. If the carer cannot reasonably go home or do something of their own in it, it is paid.
The National Minimum Wage and National Living Wage are tested per pay reference period, usually the week or month. Total pay for the period is divided by total working hours, including travel and short waits. If the result is below the legal rate, the employer is in arrears whatever the contracted hourly rate says. A carer paid £12 an hour for contact time only, with 25% of their day spent travelling unpaid, is effectively on £9 an hour and the employer has a problem. Keep the calculation for each carer for each period; HMRC asks for it.
Flat allowance. A fixed number of minutes per call or per run, for example ten minutes between any two calls. Simple, but wrong both ways: rural runs are underpaid and tight urban runs are overpaid, and it does not survive a minimum wage check if the real minutes were higher.
Estimated from the map. Postcode-to-postcode driving or walking time, applied to each pair of consecutive calls. Fair in principle and usually accepted, provided the estimate is realistic for the time of day and the method is written down.
Measured from the day. The gap between the carer's check-out at one call and check-in at the next, less any genuine break. This is the only method that reflects what actually happened, and it is what a live rota system produces without anyone calculating anything.
Travel time is pay for the minutes. Mileage is reimbursement for the cost of the carer's own vehicle, and the two are often confused. Mileage can be paid tax-free up to the approved rate for business miles. It does not count towards the minimum wage calculation, and paying generous mileage does not excuse unpaid travel time. Record the miles between calls alongside the minutes, and pay both.
The cheapest travel minute is the one that never happens. Group calls into runs by area and by time, keep a carer in one neighbourhood for a run rather than crossing town, and plan double-ups so two carers do not both drive across the patch for one call. Our rota planning guide covers runs and continuity in detail. A rota that knows the travel time between every pair of calls can show you the cost of a decision before you make it.
Travel between calls is known at planning time. The rota shows travel time and distance between a carer's consecutive calls, and flags a call the carer cannot reach in time, so the run is fixed before it is published.
Measured from real check-ins. Carers check in and out at the door with GPS. The time between one check-out and the next check-in is recorded as travel, and the day's travel time, paid travel, mileage and waiting time are shown per carer per week.
Timesheets carry it. Contact time, travel time and mileage export together for payroll, so the minimum wage calculation is a report rather than a reconstruction.
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No, you may pay a different rate, but the overall average across the pay period must not fall below the minimum wage once travel is counted.
The minutes count the same way. Measured travel from check-out to check-in handles buses, walking and cars without needing a different rule for each.
If the carer has arrived for a planned call and has to wait or the call is cancelled on the doorstep, that time is at your disposal and is working time. Record it as a no-access call.
You can, but you must be able to show that it was at least the real time. If HMRC finds real travel was higher, the arrears are calculated on the real time.
HMRC can require arrears for up to six years and can impose a penalty on top. Keeping the per-period calculation is the protection.
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