What Belongs in an Independent Contractor Registration Folder?

For a Florida nurse registry, the independent contractor registration folder, commonly referred to as the personnel file, is the registry's record that the individual was properly registered and had the credentials required to be referred to a client. The registry must also maintain the contractor's application and related documentation for inspection by the Agency for Health Care Administration (AHCA). Although the exact documents vary somewhat depending on whether the contractor is an RN, LPN, CNA, HHA, homemaker, or companion, a well-organized registration folder should contain the following.

• Completed independent contractor application
• Identity verification
• License or certification verification
• Background screening
• Health statement: communicable disease
• Independent contractor agreement
• HIV/AIDS training
• Alzheimer's disease and related dementia training
• CPR certification
• Additional HHA documentation
• Complaint documentation

Practical tip: All field staff must be independent contractors and not employees.

The AHCA survey perspective

The important distinction is between having a document somewhere and being able to demonstrate that the contractor's registration file is complete.

AHCA's current nurse-registry survey guidance identifies Contractor Registration Folders (G0152) as an area surveyors review. The guidance directs surveyors to sample registration folders and verify the required information.

Florida law currently requires the nurse registry to maintain the file for three years after the date of the last file entry of patient-related or client-related information.

The goal is simple: A surveyor should be able to open the folder and quickly answer three questions:

1. Who is this person? Identity, application, education, and employment history.
2. Is this person qualified and eligible to be referred? License/certification, verification, screening, health statement, and required training.
3. Did the registry properly register this contractor? Contract, required disclosures/materials, documentation of the registration process, and complaint information when applicable.

A registration folder organized around those three questions is much easier to maintain, and much easier to defend during an AHCA survey.

Bottom line: The independent contractor registration folder should tell the complete registration story without becoming a dumping ground for unnecessary personnel documents. The registry should be able to demonstrate that the contractor met the applicable requirements before the first referral and that required credentials and documentation were kept current thereafter.

Practical tip: Make sure to enter the contractor's information into the Clearinghouse Roster within 5 business days.

Completed independent contractor application

The application is the foundation of the registration folder. Under s. 400.506, F.S., the application must include: full name, address, date of birth, Social Security number, educational background, employment history, applicable license or certification number, license or certification renewal information, when applicable, and HIV/AIDS education documentation.

The application must be maintained by the nurse registry and be available for AHCA inspection.

Practical tip: Make sure the application is complete, signed, and dated and that the employment history section is completed.

Identity verification

The registry's registration process should document verification of the contractor's identity.

Rule 59A-18.005 requires identification to be verified using the individual's current driver's license or other photo identification.

License or certification verification

• The registry must confirm a new independent contractor's license or certification with the appropriate issuing board or department. Go to the MQA portal at mqa-internet.doh.state.fl.us to look up licensure for RNs, LPNs, and CNAs.
• For home health aides, get a copy of the HHA's certificate demonstrating at least 40 hours of home health aide training.
• Homemaker/Companions: No specific documentation of qualifications required.

Practical tip: A printout or electronic documentation showing a clear and active license or certification is a practical way to demonstrate that verification occurred. You are not required to get a hard copy of the contractor's license.

Practical tip: Verification of licensure is required annually. Print out and place a copy of the license in the registration folder. Recommend setting a fixed date when all licenses are verified annually.

Background screening

The registration folder must contain evidence that the contractor has satisfied the Level 2 background screening requirements.

Florida law requires nurse registries to comply with the background screening requirements applicable to persons referred for contract. The registration folder should contain a copy of the Level 2 background screening.

Health statement: communicable disease

This is an item that can easily be overlooked. Before an independent contractor has contact with patients, Rule 59A-18.005(6) requires a statement from an appropriately qualified health care professional, dated within the previous six months, stating that the contractor is free from communicable diseases.

Practical tip: The six-month timing is particularly important. For example, a potential independent contractor's health statement is dated January 1, 2026. The contractor fills out an application on May 1, 2026. This is well within the six-month period. However, the contractor does not accept a client until August 1, 2026. This is not acceptable, as it exceeds the six-month requirement. The contractor will need to obtain another health statement.

Independent contractor agreement

The registration folder must contain evidence of a contract with the nurse registry.

The agreement should clearly establish the contractor relationship and address the contractor's responsibilities. The registry should also make sure its agreement is consistent with the statutory requirement that individuals referred by a nurse registry are independent contractors, not employees, and that the registry may not monitor, supervise, manage, or train them.

HIV/AIDS training

The application requirements include proof of the required HIV/AIDS education.

Alzheimer's disease and related dementia training

The registration folder must have proof that all Alzheimer's Disease and Related Dementia Training has been completed.

Practical tip:

• Initial one-hour training: Within 30 days after beginning work, contractors who provide personal care or have regular contact with clients must complete the Florida Department of Elder Affairs (DOEA) one-hour training.
• Additional two-hour training: Contractors who provide personal care for a nurse registry must complete an additional two hours of training.

CPR certification

Per state regulation, CPR certification may be obtained from the American Heart Association, the American Red Cross, or the Health and Safety Institute.

Practical tip: Online CPR certification is not acceptable, as certification also requires actual observed performance of the skill.

Additional HHA documentation

For a home health aide, the registration folder needs additional documentation.

Rule 59A-18.005 specifically requires evidence of completion of an HHA training course or Florida CNA certification.

The current Chapter 59A-18 rules also contain specific requirements for CNAs and HHAs under Rule 59A-18.0081, which was last amended effective January 11, 2024.

Complaint documentation

Rule 59A-18.005(8) requires the registry to establish a system for recording complaints involving individuals it refers. Complaint records and actions taken may be maintained in the contractor's registration file or in the registry's central complaint files.

If a complaint involves a violation of state law, the registry has specific responsibilities under s. 400.506(19), F.S.

Practical tip: If complaint documentation is maintained centrally rather than in the individual registration folder, the folder should still provide a clear way to identify that the registry's complaint process was followed when applicable.

Primary authorities: s. 400.506, F.S.; s. 400.512, F.S.; s. 408.809, F.S.; and Rules 59A-18.005, 59A-18.007, 59A-18.0081, and 59A-18.009, F.A.C.