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.
The Proof of Financial Ability to Operate (PFAO) is AHCA’s financial form for new nurse registries. It’s a budget and a business plan in one: what it will cost to open and run your registry for the first year, how much you expect to earn, and proof that you can cover it, with at least one month of operating expenses in reserve.
This post is for anyone preparing a Florida nurse registry application. It covers what the rule requires, the mistakes that most often bring an omission letter, how the registry model changes the numbers, and how much money to plan on.
Numbers intimidate me. I’ll say that up front. What helps me is structure, and AHCA’s PFAO form doesn’t give you much of it. It’s long, it isn’t well designed, and there are fields that should calculate automatically or carry forward from one schedule to the next, but don’t.
It also feels high stakes, because it is. You’ve paid a $2,000 application fee, and if AHCA finds a problem with your PFAO, you generally get one chance to fix it. That’s nerve-racking for anyone.
The good news: the PFAO is a projection, not a promise. AHCA isn’t holding you to these exact numbers. Reviewers want to see that you’ve thought it through and that you have the money to carry out your plan.
What the law says. Under section 408.810(8), F.S., applicants for initial licensure and change of ownership must provide satisfactory proof of financial ability to operate. Rule 59A-35.062, F.A.C. spells out the details:
What that doesn’t mean. The rule’s two-year projection requirement applies to other license types. The nurse registry form covers one year, which makes it a little less involved than what a home health agency files.
What we see in practice. When there’s a problem with your PFAO, it comes back as part of an omission letter. You have 21 days to respond under section 408.806(3)(b), F.S. Make your response complete the first time.
These are the problems that send a PFAO back:
From the registry office: I recently helped an applicant whose PFAO came back for two reasons. Florida’s minimum wage hadn’t gone up yet, but their caregiver pay assumptions sat right at the threshold, and the reviewer sent it back. The same applicant didn’t show their available funds in the format the reviewer wanted. To be honest, neither the instructions nor the rules make that format very clear.
You don’t have to have all the cash sitting in a bank account. You do have to show you have access to capital. The rule doesn’t list what counts as proof. The form itself does, on Schedule 1: proof of funding “may include audited financial statements, bank statements, financial institution commitment letters, lines of credit, etc.”
In practice, that usually looks like this:
| Source of funds | What to attach |
|---|---|
| Cash in the business account | A recent bank statement in the business’s name |
| Owner or investor money | Recent statements showing the money is available. Moving it into the business account before you apply makes this simpler. |
| Bank loan or line of credit | The lender’s commitment letter or the credit agreement |
| Parent or affiliated company | A letter from the parent company and its latest audited financial statements |
If your application is delayed, expect to send newer bank statements.
There’s no set number. What you need depends on the assumptions and commitments you put in your PFAO. Some costs are fixed, like rent and utilities. The biggest factor is how fast you project your registry will grow.
Everyone wants big growth. It isn’t always realistic, and it isn’t always preferable. If your PFAO shows rapid growth, you’ll need to show you have the cash to handle that growth. I recommend a conservative but realistic forecast. It’s your best guess, and you aren’t held to it.
As a general target, I think $20,000 to $25,000 is a good number to aim for. It gives you a reasonable runway to become profitable. For a breakdown of where that money goes, see How Much Does It Cost to Start a Nurse Registry in Florida?
Nurse registries are a strange beast, and plenty of people misunderstand them. That shows up on the PFAO. The form asks for gross revenue and what you expect to earn, but in a registry, caregivers are independent contractors. What they earn is theirs.
What we see in practice. Industry professionals coach registry owners not to think of caregiver earnings as the registry’s money. Your registry’s income is the referral fee clients pay on top of what the caregiver earns. Unfortunately, the PFAO doesn’t account for that. My advice is to accept it and give AHCA the financials in the format it asks for. The gross revenue the form requests includes caregiver earnings, even though caregivers are independent contractors and that money is theirs, not yours.
You have two good options: do it yourself with the right tools, or hire a financial professional. I’m most certainly not a financial professional. I built my own PFAO workbook because I needed the structure the AHCA form doesn’t give you. It does the math, carries numbers forward between schedules, flags common problems, and tells you what proof to attach for each line. Honestly, it’s what AHCA should have provided. Clients also get examples of real PFAOs that AHCA approved, with identifying information removed, so they can see what a finished one looks like. Both are included in my Startup & Compliance Package, and they can save DIY applicants a good bit of money.
If you’d rather have a professional handle it, I refer clients to Doug Walters of Walters & Associates CPAs. Doug and I covered this topic in depth on the podcast: PFAO: Proof of Financial Ability to Operate for Nurse Registries. You’re free to choose any financial professional you like.
From the registry office: When Doug joined me on The Nurse Registry Podcast, he was a wealth of information. His firm speaks AHCA’s language and has helped a large number of applicants with their PFAOs. A lot of their calls come from people who tried it on their own, got it sent back, and were either worried they wouldn’t pass or weren’t even sure what AHCA wanted. He also pointed out that there are exceptions to the one-correction limit. However, don’t plan on getting one.
No. Rule 59A-35.062 requires a CPA only for home health agencies, home medical equipment providers, and health care clinics. Many applicants still choose to work with one.
One year. Other license types file two years of projections, but the nurse registry form covers the first year of operation.
There’s no set amount. It depends on your costs and how fast you project growth. As a general target, $20,000 to $25,000 gives most new registries a reasonable runway.
Not necessarily. You need to show access to capital. The form lists bank statements, audited financial statements, financial institution commitment letters, and lines of credit as acceptable proof.
You’ll receive an omission letter and have 21 days to respond. You generally get one chance to correct it, so make your response complete.
On the PFAO, yes. The form asks for gross revenue, which includes what caregivers earn, so report it that way. Outside the form, that money belongs to the independent contractors. Your registry’s income is the referral fee.
Book a free 15-minute consultation. We’ll talk through where you are and whether my workbook or a financial professional is the better fit. Call 239-766-8238.
This article provides general regulatory information. It is not legal, tax, accounting, or insurance advice.
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