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 October 2026. Statutes cited are from the 2026 Florida Statutes.
Before you choose nurse registry software, ask whether it was built for registries or for agencies that employ caregivers, how it helps you follow the Department of Labor’s guidance on independent contractors, how money moves through it, whether it automates the notices Florida requires, and what training and support you’ll get. The answers matter more than the feature list.
This is for Florida nurse registry owners choosing software for the first time, and for established registries thinking about switching. These are some of the questions I’d ask any vendor, from someone who has used several.
It used to be that most, if not all, software was built for agencies. You could use it for your registry, but some areas never quite seemed right. Today there’s a handful of products built specifically for nurse registries that embrace independent contractor principles. Even then, the software won’t protect your model for you. For better or worse, it does what you tell it to do.
What the law says. Florida deems the caregivers a nurse registry refers to be independent contractors, not employees, “under any chapter” (s. 400.506(6)(d), F.S.), and a registry may not monitor, supervise, manage, or train them (s. 400.506(19), F.S.).
What that doesn’t mean. Florida law doesn’t bind federal agencies. The U.S. Department of Labor looks at how your registry actually operates, and its Field Assistance Bulletin 2018-4 describes the practices it looks at. Your software settings, task lists, and records are part of that picture.
From the registry office: Over the years, I’ve used three platforms: HomeTrak (now WellSky), Ally, and now CareLink. There is no perfect software. I compare registry software to handing someone the keys to a submarine. It may be able to do all kinds of amazing things, but if you don’t know how to do those things, the sub won’t go anywhere. I have yet to find a product that nails the training. It has always been up to me to learn it inside and out and apply it to my registry and to independent contractor principles.
And don’t skip reliability. Outages happen. Ask about their track record, how registries, caregivers, and clients are notified of interruptions, and what happens if the system is down when caregivers expect to be paid.
Those ten are a starting point. My full list has more than 60 questions, grouped and ordered from broad to granular: the company and the fit, cost, support and training, how money moves, the referral model feature by feature, Florida compliance, security and data, and your contract. It covers things a demo won’t show you, like how caregivers are notified of schedule changes, whether a prospect can sign before becoming active, and whether the vendor’s registries have been through a DOL audit. It’s how I walk the registries I work with through setting up their software to reinforce the independent contractor relationship, not quietly undermine it.
Ask whether it was built for registries, how it helps you follow FAB 2018-4, how money moves and who the processor works for, how Forms 1099 are handled, whether it automates Florida-required notices, and how support requests are tracked.
You can, but agency software is built around employing caregivers. You’ll need to rename its language and turn off features like assigning shifts, performance reviews, and hardwired skilled tasks, and some of that may not be possible.
By letting caregivers see and request open client opportunities, letting caregivers set their own rates and enter their own hours for the client to approve, and paying caregivers from client funds rather than the registry’s money.
Good registry software can generate, send, and log the written notice to a client’s physician within 48 hours after the contract is concluded that a CNA or HHA will be providing care, and the notice to the client, or the person they designated, when services end. Automated when the contract is signed and when the client is closed, they don’t get missed.
Yes. Through Hourly Review & Advisory, I review the platforms you’re considering or your current setup against the independent contractor model and Florida’s requirements.
This article provides general regulatory information. It is not legal, tax, or accounting advice.
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