Proof of Financial Ability to Operate (PFAO) for Florida Nurse Registries

Practical Florida nurse registry licensing and compliance guidance from Scott Strachan, RN BSN, a nurse registry operator since 1997.

In This Article

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.

Why the PFAO feels high stakes

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 rule requires

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:

  • Nurse registries use their own form, AHCA Form 3110-7004A, Nurse Registry Proof of Financial Ability to Operate. You’ll find it with the application on AHCA’s Nurse Registries page.
  • You need contingency funding of at least one month’s average operating expense over your first year.
  • A CPA doesn’t have to prepare or sign it. The rule requires a CPA only for home health agencies, home medical equipment providers, and health care clinics.

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.

The mistakes I see most

These are the problems that send a PFAO back:

  • Caregiver pay below minimum wage. Reviewers check it. Florida’s minimum wage went up to $15 an hour on September 30, 2026, and it changes each September 30. Budget at or above the rate that will be in effect during your projection year, not just today’s rate.
  • Utilities budgeted at $0. Every office has utilities. A zero looks like you haven’t thought it through.
  • Flat revenue. Taking one annual number and dividing it by 12 isn’t realistic. A new registry starts slow and grows.
  • Proof of funds that doesn’t match Schedule 1. Your documents should show the same amounts you list as your sources of funds. If they show more, explain why.
  • Math that doesn’t carry forward. A number that appears on more than one schedule has to match everywhere it appears. The AHCA-provided form doesn’t do this for you. Mine does, which improves accuracy, limits mistakes, and ultimately helps you get approved. My PFAO workbook is included in my Startup & Compliance Package.

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.

How to prove you have the money

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.

How much money do you need?

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?

Why the registry model makes the PFAO confusing

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.

Getting help

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.

What the path looks like

  1. Decide on your office, services, and counties, since they drive your costs.
  2. Build a conservative first-year forecast with revenue that grows over time.
  3. Budget caregiver pay at or above Florida minimum wage and include every real expense.
  4. Line up your funding and gather current proof that matches Schedule 1.
  5. Write short notes explaining your assumptions.
  6. Check that every number that repeats across schedules matches, then submit with your application.

Frequently asked questions

Does a CPA have to sign a nurse registry PFAO?

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.

How many years of projections does a nurse registry PFAO need?

One year. Other license types file two years of projections, but the nurse registry form covers the first year of operation.

How much money do I need for a nurse registry PFAO?

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.

Do I need the money in a bank account?

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.

What happens if AHCA finds a problem with my PFAO?

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.

Should caregiver earnings count as registry revenue?

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.

Want a second set of eyes on your PFAO?

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.

Scott Strachan

Scott Strachan

Scott Strachan, RN BSN, has worked in Florida nurse registries since 1997, starting as an independently employed caregiver. He has been administrator of Abby Services, a Florida-licensed nurse registry in Fort Myers, since 2007 and an owner since 2016, and serves as Vice President of PCA Florida (Private Care Association). He hosts The Nurse Registry Podcast and founded Nurse Registry Consultant, LLC to help new and existing registries navigate AHCA licensure and compliance. Florida RN License #9224129.

Free 15-minute call

Book a Free Consultation

Pick a time that works for you. We'll talk through where you are and whether I'm the right fit.

Choose a Time

Prefer to talk now? Call 239-766-8238

New here?

Your account is created when you sign up for a service. Start by choosing the one that fits.

See services & get started Not sure yet? Book a free 15-minute consultation →