It’s All About Control: How Nurse Registries Should Refer Training Without Crossing the Line

By Scott Strachan, RN, BSN – C-E-U.com

Operating a nurse registry means more than just connecting caregivers and clients. It also means staying compliant with strict Department of Labor guidance on how registries must operate as referral sources — not employers.

The Field Assistance Bulletin No. 2018-4 lays out six factors the Wage and Hour Division uses to evaluate whether a registry is acting as a true referral service or improperly taking on the role of an employer. When it comes to training and compliance, three factors matter most: Factor 1, Factor 4, and Factor 6.

Factor 1: Who Controls the Caregiver’s Work

• Safe Zone: Asking caregivers about their qualifications, licenses, or certifications in order to match them with clients.

• Red Flag: Dictating exactly how training must be completed, or requiring caregivers to take training through the registry itself.

👉 Best Practice: State that “caregivers must meet all required qualifications” without prescribing the exact path. Instead, provide a list of options where caregivers can complete the required courses.

Factor 4: Controlling the Caregiver’s Methods

• Safe Zone: Requiring that caregivers meet minimum state qualifications (like Alzheimer’s & Dementia training).

• Red Flag: Providing training directly, supervising in the home, or evaluating a caregiver’s performance.

👉 Best Practice: Refer caregivers to approved outside training resources rather than delivering training yourself. This keeps the registry from crossing into supervision or instruction.

Factor 6: Freedom to Work Elsewhere

• Safe Zone: Caregivers remain independent contractors, free to work for other clients and registries.

• Red Flag: Imposing restrictions that lock caregivers into one registry or one required training source.

👉 Best Practice: Provide a menu of options for meeting training requirements. This preserves independence and reinforces the contractor relationship.

Where C-E-U.com Fits In

Many registries maintain lists of approved or recommended training resources. Including C-E-U.com on that list benefits both caregivers and registries:

• Compliant: All courses are AHCA/DOEA-approved.

• Affordable: Among the lowest-cost options available.

• Convenient: 100% online, easy to access anytime.

• Survey-Ready: Certificates available instantly for AHCA review.

By offering choices, and pointing out C-E-U.com as the most affordable and convenient option, registries maintain compliance with Factors 1, 4, and 6 — while supporting caregivers and protecting themselves.

Key Takeaway

For nurse registries, it’s all about control. The more you dictate how a caregiver works, how they train, or who they can work for, the closer you come to an employer-employee relationship.

Stay compliant by requiring qualifications but leaving the how up to the caregiver. Give them options — and make sure one of those options is C-E-U.com, the easiest and least expensive choice.

📌 Alzheimer’s Disease and Related Dementia (ADRD) Training for Caregivers:
https://c-e-u.com/course/alzheimers-disease-and-related-dementia-adrd-training-for-caregivers/