Homecare Association response to the Fair Pay Agreements consultation (England)

We have responded to the Government's consultation on Fair Pay Agreements in England.

The Homecare Association supports the principle of fair pay agreements but that support depends on meaningful representation, commissioning and funding alignment, and realistic timelines. Without all three, the agreement will destabilise services rather than improve them.

On the negotiating body, we support a civil service secretariat but urge DHSC to invest in dedicated employer engagement support, multi-year funding, and independent analytical capacity. We recommend a 20-seat employer panel coordinated through the Care Provider Alliance.

We argue that commissioners must do more than simply give due regard to the agreement. Local authorities and NHS commissioners must formally sign off on affordability and implementation plans as a condition of ratification. We also call for a mandatory National Contract for Homecare to ensure commissioners fund the full cost of delivery.

On timelines, we recommend extending the first negotiation cycle to 9–12 months, with implementation dates set only after reviewing commissioning readiness and budget cycles. Backdating agreements would create serious financial risk.

On remit, we strongly advise keeping the first agreement narrow – focusing on a pay floor above the National Living Wage. We urge DHSC to defer wider terms, conditions, and training requirements to later cycles once the system has stabilised.

We also warn that without aligned commissioning, the agreement risks accelerating a shift towards false self-employment and unregulated services, undermining the very workers it aims to protect.