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 2025 Florida Statutes.
A Florida companion or homemaker service is registered with AHCA, not licensed, and its caregivers may not provide hands-on personal care. A licensed nurse registry can refer independent CNAs, home health aides, and nurses who can. The move requires a license, an initial AHCA survey, and in most cases a rethink of how caregivers are engaged.
Most clients do require hands-on support, even if they don’t say so at first or don’t believe they need it. That leaves companion services open to liability, and it means missing the large number of Florida seniors who truly need full support from caregivers who can provide hands-on care. A nurse registry opens the door to those clients and to long-term care insurance work.
If you run a companion service, you’ve probably already felt the ceiling. This post covers why it’s there, what a nurse registry changes, and the regulatory hurdles that trip up operators who are otherwise ready.
What the law says. Florida defines a companion as someone who spends time with an elderly, handicapped, or convalescent person, accompanies them on outings, and may prepare meals. A homemaker handles household chores like housekeeping, meal preparation, and shopping. Both definitions end the same way: they may not provide hands-on personal care (F.S. 400.462(8) and (22)).
Personal care is defined as help with activities of daily living such as dressing, bathing, eating, and personal hygiene, plus help with transfers, walking, and medications as permitted by rule (F.S. 400.462(27)).
Put that in terms a family understands: it’s like hiring a babysitter and being told she isn’t allowed to pick up the baby. Your caregivers may be excellent, but the law draws a line at exactly the moment most families need help.
What we see in practice. Most families don’t call because Mom needs someone to talk to. They call because she can’t get in and out of the shower safely anymore, or because Dad came home from the hospital and needs help getting to the bathroom. A companion service has to turn that call away, or refer it out.
Many companion services cross that line anyway. Some do it quietly in the home; others put it right in their advertising, offering bathing, dressing, or “personal care” under a companion registration. Advertising alone is a problem: Florida law prohibits offering or advertising services that require licensure without holding the license (F.S. 408.812(1)). AHCA is aware of it, and as the law makes clear, the consequences can be severe.
Why the line matters. Crossing it is not a technicality. Under F.S. 408.812(2), performing services that require licensure without the proper license is unlicensed activity, and Florida law says unlicensed activity constitutes harm to clients and constitutes abuse and neglect as defined in s. 415.102. AHCA or a state attorney can seek an injunction, and a provider that keeps operating after AHCA notifies it to stop can be fined $1,000 per day (F.S. 408.812(4)). Hands-on personal care is a service that requires licensure, so a registered companion service that provides it is outside what its registration allows. A companion who helps a client into the shower “just this once” puts the whole business at risk.
From the registry office: At Abby Services, nearly 100 percent of our clients need hands-on support in some way, shape, or form. It is rare that a client doesn’t, or won’t eventually.
| Companion / homemaker service | Nurse registry | |
|---|---|---|
| AHCA status | Registration (F.S. 400.509) | License (F.S. 400.506) |
| Fee | $50 per biennium | $2,000 per biennium (Rule 59A-18.004) |
| Initial inspection | Not required (F.S. 408.806(7)(b)) | Required before licensure |
| Hands-on personal care | Not permitted | Through referred CNAs, HHAs, and nurses |
| Who can be referred | Companions, homemakers | RNs, LPNs, CNAs, HHAs, companions, homemakers |
| Caregiver relationship | Employed or contracted | Independent contractors compensated by fees (F.S. 400.462(25)) |
| Ongoing oversight | Light | Periodic unannounced surveys against AHCA G-Tags |
A companion registration takes an application and a $50 fee. There’s no initial survey and little ongoing oversight. That makes it easy to get into, and just as easy for referral sources to discount. Hospitals, case managers, and insurance carriers know the difference between a registered companion service and a licensed, surveyed nurse registry.
A nurse registry license tells referral sources something a registration can’t. The provider has been surveyed, its caregiver files have been reviewed, and its results are public on Florida Health Finder.
That matters most with the people who send you steady work: hospital discharge planners, rehab case managers, elder law attorneys, and care managers. They’re making referrals for clients with real care needs, and they want a provider who can handle the client as those needs grow.
What the law says. A Florida long-term care insurance policy with a home health care benefit may not require that a licensed home health agency provide services that a licensed nurse registry can provide, and may not limit benefits to Medicare-certified agencies or providers (F.S. 627.94071(5) and (9)). The same statute bars policies from excluding personal care provided by a home health aide (F.S. 627.94071(6)).
What that doesn’t mean. Payment still depends on the specific policy: its benefit definitions, eligibility triggers, elimination period, and documentation requirements.
What we see in practice. LTCI clients tend to need hands-on care, since that’s usually what triggers benefits in the first place. A companion service is generally shut out of that work. A licensed nurse registry can take it on, provided it handles the documentation carriers ask for.
From the registry office: In Florida, a nurse registry license and the statutes that govern our industry are essential when managing long-term care insurance.
Companion operators who make this move usually have the hard part figured out already. They know how to answer the phone at 9 p.m., recruit dependable caregivers, work with families, and market locally. A lot carries over:
What usually doesn’t carry over is the regulatory side. That’s where good operators get stuck.
Florida defines a nurse registry as a business that secures contracts for caregivers who are compensated by fees as independent contractors (F.S. 400.462(25)). Many companion services employ their caregivers. If yours does, you’ll need to decide how your business will be structured before you apply, and the language in your agreements, policies, and marketing has to match. This is a decision to make with your CPA and attorney, not one to back into.
The application falls under Chapter 408 Part II, F.S. 400.506, and Rule 59A-18. It requires an administrator and alternate administrator, an RN available for referral, proof of financial ability to operate, policies and procedures, and a comprehensive emergency management plan. Omissions are the most common source of delay. AHCA has 30 days to flag errors or omissions and 60 days after a complete application to approve or deny it (F.S. 408.806(3)).
Unlike a companion registration, a nurse registry license requires an initial inspection. Surveyors review your records, policies, and caregiver files against AHCA’s nurse registry G-Tags.
Caregiver files get more demanding once you’re referring licensed and certified caregivers: license and certification verification, health statements, required training, and background screening. Client files change too.
Copy that works for a companion service, like “our caregivers,” “our staff,” or “we schedule,” can create classification problems for a registry. Your website, contracts, and forms all need a review.
Getting licensed is the start, not the finish line. A nurse registry has to stay survey-ready every day, because AHCA can show up unannounced. The ongoing obligations include:
From the registry office: Most companion operators are loosely familiar with AHCA. What they usually aren’t prepared for is actually understanding and following the regulations that govern our industry, day in and day out.
See the full Path to Licensure for detail on each step.
No. Florida law says companions and homemakers may not provide hands-on personal care, which includes bathing, dressing, toileting, and transfers (F.S. 400.462).
No. Companion and homemaker services register with AHCA rather than obtain a license. The fee is $50 per biennium, and your registration number must appear in your advertising (F.S. 400.509).
Yes. Florida’s definition of a nurse registry includes companions and homemakers along with nurses, CNAs, and home health aides (F.S. 400.462(25) and 400.506(6)(a)). AHCA also confirms you don’t need to keep a separate companion registration once you hold a nurse registry license.
Florida law prohibits LTCI policies from requiring that a home health agency provide services a licensed nurse registry can provide. Payment still depends on the individual policy’s terms and documentation requirements.
The nurse registry model is built on referring independent contractors. How you restructure an existing workforce is a business, tax, and legal decision to make with your CPA and attorney before you apply.
A realistic timeline is 3 to 5 months, but it depends on the applicant. Part of it is in your hands: how quickly you prepare a complete application and answer any omissions. Part of it is in AHCA’s: the agency has 60 days to act on a complete application (F.S. 408.806(3)), and the initial survey has to be scheduled on top of that.
Book a free 15-minute intro call. We’ll talk through where you are and whether a nurse registry makes sense for your business.
Call 239-766-8238 to book your free intro call
This article is general regulatory information based on Florida statutes and rules as cited. It is not legal, tax, or insurance advice.
