Practical Florida nurse registry licensing and compliance guidance from Scott Strachan, RN BSN, a nurse registry operator since 1997.
By Scott Strachan, RN BSN. Last reviewed September 2026. Statutes cited are from the 2026 Florida Statutes.
An omission letter is AHCA’s written request for missing or unclear information in your license application. A citation, or deficiency, is what a surveyor writes up when they find you out of compliance during an inspection. Both come with deadlines, and both are part of doing business. How you respond matters more than getting one.
This post is for new applicants and licensed Florida nurse registries. It covers the deadlines, what AHCA cites most often, how to handle a finding you disagree with, and why your written response matters more than most people realize.
We all put so much into this. It’s hard to be corrected, whether you believe you’re right or just didn’t realize you were wrong. An omission letter or a citation can feel like a slap in the face.
In reality, it’s a part of doing business and a part of improving. This regulatory framework exists to protect Floridians. It protects our clients and the caregivers we refer, and ultimately it protects us too. Most omissions and citations aren’t going to stop you from doing business. They’re a bump along the way.
| Omission letter | Citation (deficiency) | |
|---|---|---|
| When it happens | While AHCA reviews your application | After a survey or inspection |
| What it means | Something is missing or unclear | A surveyor found you out of compliance |
| Your deadline | 21 days to send the information | 30 days to correct; 10 days for a plan of correction if AHCA requires one |
| Where it’s cited | s. 408.806(3), F.S. | s. 408.811(4)-(5), F.S. |
What the law says. AHCA has 30 days after receiving your application to notify you of errors or omissions. You then have 21 days to respond, or your application is withdrawn and your fee is forfeited. After an inspection, deficiencies must be corrected within 30 calendar days of notice unless AHCA sets a different timeframe, and if AHCA requires a plan of correction, it’s due within 10 calendar days.
What we see in practice. With an omission letter, you generally get one chance to correct, so make your response complete the first time. Deficiencies are different. There’s no one-chance rule. You have a deadline, but some back-and-forth with AHCA is normal while you discuss a finding and send responses, and AHCA can tell you your response is insufficient. Aim for a response that addresses their concern and meets what’s required without exceeding it. Anything you commit to in a response becomes something you have to keep doing, so don’t take on more than the rule asks. For a new registry, remember that the initial survey is part of your application. Your application isn’t complete until the inspection is satisfactory, so survey findings on an initial application hold up your license until they’re resolved.
Inspection reports are public. You can look up any registry’s reports, including deficiencies, on AHCA’s inspection report search. Records go back to about 2008. Registries existed long before that, but older reports weren’t saved and displayed.
The problem is that it’s cumbersome to get a big-picture view one report at a time. With the help of AI, I reviewed nurse registry reports and pulled together the ten deficiency areas that come up most. AHCA doesn’t publish an official ranking, so treat this as a working list. It includes unannounced surveys as well as initial surveys, and it gives you a good idea of what AHCA is watching.
| # | Area | Tag | What to check |
|---|---|---|---|
| 1 | Alzheimer’s (ADRD) training | ZZ875 | Written information at registration, the 1-hour training within 30 days, and 2 more hours within 7 months for personal care |
| 2 | Communicable disease health statement | G0151 | A current statement in every caregiver file, dated within 6 months before the first referral |
| 3 | Emergency management plan updates | G0292, ZZ830 | An approved plan, submitted on time and updated every year |
| 4 | Caregiver registration files | G0150, G0152, G0252 | Application, contract, license or certificate verification, and proof you gave them the required rules and statutes |
| 5 | Administrator and alternate | G0160 | A qualified administrator and a written alternate designation |
| 6 | Hours of operation | G0175 | Office open 8 hours between 7 a.m. and 6 p.m., with the administrator or alternate available |
| 7 | Background screening | ZZ814, ZZ815, ZZ816 | Level 2 screening before client contact, a current Clearinghouse roster, and the signed attestation form |
| 8 | Access to files during a survey | G0174 | Records produced within 2 hours of the surveyor’s arrival |
| 9 | License number in advertising | G0102 | Your license number on your website, ads, and printed materials |
| 10 | Client records | G0200 | Complete clinical records wherever a nurse is referred |
Every item on this list is covered in my Startup & Compliance Package, from the policies and forms to the chart and file structure surveyors expect to see.
Two of the top items have a direct fix, both from companies I co-own:
Many offices don’t understand the Alzheimer’s disease and related disorders (ADRD) training requirement, and some don’t have proper training on file.
What the law says. Section 430.5025, F.S. covers nurse registries. Anyone who provides personal care or has regular contact with clients must complete a 1-hour training provided by the Department of Elder Affairs within 30 days. At a nurse registry, anyone who provides personal care must also complete 2 more hours within 7 months. Everyone employed, contracted, or referred before July 1, 2023 had to complete the training before July 1, 2026.
What that doesn’t mean. Not every course labeled “Alzheimer’s training” counts. Under s. 430.5025(5)(a), a provider can offer the 2-hour training without Department approval only if it’s approved by an applicable board or the Department of Health and registered with the electronic continuing education tracking system, or was approved by the Department before July 1, 2023. Some training providers are selling courses that may not be accepted.
What we see in practice. I recommend completing all ADRD training when a caregiver registers, before they’re active. C-E-U.com, a company I co-own, offers ADRD training for caregivers that meets Florida’s requirements.
AHCA professionals are real people too. Surveyors and reviewers have to know a wide range of license types, and those rules get complicated. You only have to know nurse registry regulations, and you should know them inside and out. That’s why you need to be the expert on your own license type.
When you disagree with a finding, start with five words: “Can you show me where?” Ask the surveyor to show you where the requirement is written. You’ll see exactly which rule they’re relying on, and if it doesn’t apply, you can explain why while you’re both looking at the actual text.
From the registry office: During an inspection, a surveyor pulled the chart of a hospice client who used a Hoyer lift to get out of bed. The surveyor asked whether two caregivers assisted with the lift. They didn’t. The surveyor insisted two people were required and said they were going to cite us. I was unsure of myself at the time and tried to explain and manage the situation. What ultimately saved me was asking, “Can you show me where?” The requirement the surveyor had in mind applied to nursing homes, not nurse registries, and there were no grounds for a citation.
Your best chance of resolving a disagreement is while the surveyor is still in your office, before anything is written up. If you aren’t making headway, you can ask to speak with their supervisor for clarification. You can email back and forth after you’re notified of a citation, but in my experience, by then it’s usually too late.
Formally, AHCA gives licensees the chance to contest findings before penalties are imposed. That’s a legal process, and it’s worth talking to an attorney if the stakes are high. In practice, I’ve accepted citations I absolutely disagreed with, because accepting them and describing the correction was the path of least resistance.
Here’s what most people miss: your response is public too. Anyone who looks up your registry, including future clients, referral sources, and competitors, can read what AHCA cited and what you said about it.
So don’t just respond. Shape your response with that audience in mind. If you disagree, say so respectfully and focus on what you did. For example: “While we respectfully disagree with this finding, here is what we did to address the surveyor’s concerns.”
If you’re a Startup & Compliance Package client, you don’t do this alone. The Path to Licensure portal includes my step-by-step omission letter guide, and we review your letter together before you respond. The package also includes my annotated notes on the regulation set AHCA surveyors use, plus the actual workbooks surveyors follow for both initial and relicensure surveys. They give you valuable insight into what you’ll be asked and what AHCA is looking for during a visit.
21 days from AHCA’s request. If you miss it, your application is withdrawn and your fee is forfeited.
30 calendar days after you’re notified, unless AHCA sets a different timeframe. If AHCA requires a plan of correction, it’s due within 10 calendar days.
Yes. Anyone can search a registry’s inspection reports and deficiencies on AHCA’s website, so write your responses knowing clients and competitors may read them.
Ask, “Can you show me where?” and review the exact requirement together while the surveyor is still in your office. If you can’t resolve it, ask to speak with their supervisor.
Usually not. Most are a bump along the way. For a new registry, though, initial survey findings must be resolved before your license is issued.
Yes. Under s. 430.5025, F.S., caregivers who provide personal care need the 1-hour Department of Elder Affairs training within 30 days and 2 more hours within 7 months.
Book a free 15-minute consultation. We’ll look at what AHCA is asking for and talk through your options. Call 239-766-8238.
This article provides general regulatory information. It is not legal, tax, or insurance advice.
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