Healthcare staffing

A staffing agency usually employs clinicians on W-2 and bills facilities. A nurse registry, as Florida defines it, refers independent contractors to patients or facilities and may not supervise them. A home health agency employs or directs staff to deliver care in the home under a plan of care, under its own license and, if certified, the Medicare Conditions of Participation. This framing is drawn from the cited statutes, not from a single official definition.

Not yet confirmed — check with the state licensing agency.

In practice: Medicare home health is covered in its own guide.

Source: Fla. Stat. 400.506 (nurse registries)

Last verified October 17, 2026

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A caregiver referred by a Florida nurse registry is an “independent contractor and not an employee of the nurse registry under any chapter” (400.506(6)(d)). Patients must be told this, and told the registry may not monitor, supervise, manage or train the caregiver ((6)(e), (19)).

Source: Fla. Stat. 400.506 (nurse registries)

Last verified October 17, 2026

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Registries may refer RNs, LPNs, CNAs, home health aides with documented training, and companions or homemakers, after verifying credentials and documenting freedom from communicable disease (400.506(6)(a)). CNAs and aides may be referred only when the patient is under a physician’s care, only for personal care, and the registry notifies the physician within 48 hours ((6)(b)).

Source: Fla. Stat. 400.506 (nurse registries)

Last verified October 17, 2026

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Where nurses go into patients’ homes, home care licensing can apply to the registry or staffing firm. In Oklahoma, “a nurse registry which provides home care services shall function and be licensed as a home care agency” (OAC 310:662-3-4(h)). In Florida, a registry must hold the nurse registry license (400.506), and a home infusion therapy provider “must be licensed as a home health agency or nurse registry” (400.464(3)).

In practice: Each state’s home health license is on the state home health license map.

Source: OAC 310:662 (OSDH copy, rules effective July 11, 2011)Fla. Stat. 400.506 (nurse registries)Fla. Stat. 400.464

Last verified October 17, 2026

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New Jersey’s health care service firm definition covers entities that “employ, place, or refer” workers into the homes of people with disabilities or adults 60 and over, so referral and placement-only models are included.

Not yet confirmed — check with the New Jersey Division of Consumer Affairs.

Source: Holland & Knight: NJ health care service firm registration (Sept 2026, secondary)

Last verified October 17, 2026

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The regulator differs by state: the health department in Minnesota, Pennsylvania, Connecticut, Washington, Indiana, Maine and Rhode Island; the labor department in Illinois and, from July 1, 2027, Nebraska; a licensing and inspections agency in Iowa. See the state table under How states differ.

Source: MDH: Supplemental nursing services agency FAQPennsylvania DOH: temporary health care services agenciesCT DPH: temporary nursing services agencyWAC 246-845-050 (Justia)IDOH: temporary healthcare staffing agency registry22 M.R.S. §2131216-RICR-40-10-10Illinois P.A. 102-0946 (HB 4666), enrolled textNeb. Rev. Stat. 48-4103Iowa Code ch. 135Q (2026)

Last verified October 17, 2026

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Several regimes are scoped to long-term care clients: Pennsylvania (nursing facilities, personal care homes, assisted living), Minnesota’s rate cap (nursing homes) and Massachusetts’ rates. Kentucky’s definition includes hospitals. A hospital-only staffing business may fall outside some laws, so scope is checked state by state.

Not yet confirmed — check with the state licensing agency.

Source: Pennsylvania DOH: temporary health care services agenciesMinn. Stat. 144A.742023 Ky. Acts ch. 61 (HB 502)

Last verified October 17, 2026

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Some laws name platforms expressly: Maine covers “online platforms or marketplaces” (22 M.R.S. §2131), Iowa registers technology platforms separately (135Q.3), and Nebraska’s 2027 law covers app-based platforms. Bills in Kansas (SB 228) and Minnesota (HF 1232, SF 1678) would do the same; their enactment was not confirmed.

Source: 22 M.R.S. §2131Iowa Code ch. 135Q (2026)Neb. Rev. Stat. 48-4103Kansas SB 228 (2025–26)Minnesota HF 1232 (2025)

Last verified October 17, 2026

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A recruiter that charges a placement fee and does not employ the worker can fall under general employment agency laws. New York licenses any employment agency, nurses’ registries included, and its fee definition is not limited to fees paid by job seekers (GBL §§171–172). California requires a $3,000 surety bond filed with the Secretary of State (Civ. Code 1812.503).

Source: NY General Business Law §171NY General Business Law §172Cal. Civ. Code 1812.503

Last verified October 17, 2026

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The hospital’s director of nursing service supervises and evaluates the clinical activities of all nursing personnel, whether employees, contracted, leased or volunteers, and “all licensed nurses who provide services in the hospital must adhere to the policies and procedures of the hospital” (42 CFR 482.23(b)(6)).

Source: 42 CFR 482.23 (Cornell LII)

Last verified October 17, 2026

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Orientation of agency nurses appears in state rules and survey findings, for example Indiana hospital surveys and California’s requirement that temporary agency RNs complete hospital and unit orientation. The federal regulation text read for this guide speaks of supervision and evaluation, not orientation.

Not yet confirmed — check with CMS.

Source: Indiana DOH hospital survey (2567)California SB 554 text

Last verified October 17, 2026

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Excluded parties “can receive no payment from Federal health care programs for any items or services they furnish, order, or prescribe”, and “anyone who hires an individual or entity on the LEIE may be subject to civil monetary penalties”. State Medicaid agencies must check the LEIE monthly.

In practice: Screening every placed clinician against the LEIE, and state Medicaid exclusion lists, protects both the agency and its clients.

Source: HHS OIG: Exclusions (LEIE)

Last verified October 17, 2026

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A civil money penalty applies to a person who “arranges or contracts (by employment or otherwise)” with an individual or entity they know or should know is excluded, for items or services payable by a federal health care program: up to $20,000 per item or service, plus up to 3 times the amount claimed, plus possible exclusion (42 U.S.C. 1320a-7a(a)(6)). Inflation-adjusted amounts are higher.

Source: 42 U.S.C. 1320a-7a (Cornell LII)

Last verified October 17, 2026

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OIG’s Updated Special Advisory Bulletin on the Effect of Exclusion, dated May 9, 2013, gives guidance on the scope and frequency of screening employees and contractors.

Source: HHS OIG: Special Advisory Bulletin and other guidance

Last verified October 17, 2026

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The employer completes Form I-9: Section 1 at hire, Section 2 within 3 business days (or at hire for jobs under 3 days), and keeps it 3 years after hire or 1 year after termination, whichever is later. The separate duty of “recruiters and referrers for a fee” is limited to agricultural associations, agricultural employers and farm labor contractors (8 CFR 274a.2).

In practice: A W-2 staffing agency is the employer and completes the I-9; for a direct-hire placement, the hiring client does.

Source: 8 CFR 274a.2 (Cornell LII)

Last verified October 17, 2026

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The Department of Labor announced a proposed independent contractor rule on February 26, 2026 (RIN 1235-AA46; comments closed April 28, 2026). It is no longer applying the 2024 rule in its investigations (FAB 2025-1). No final rule appears on its page.

Time-sensitive. A final rule may follow the proposal; recheck the DOL page and the Federal Register (reviewed October 17, 2026).

Source: U.S. DOL WHD: 2026 independent contractor rulemaking

Last verified October 17, 2026

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The IRS weighs behavioral control, financial control and the type of relationship; no single factor decides, and it looks at the entire relationship. Form SS-8 gets an IRS determination, which “may take at least six months”.

Source: IRS: Independent contractor (self-employed) or employee

Last verified October 17, 2026

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A Department of Labor joint-employer proposal (April 2026) under the FLSA, FMLA and MSPA sets four factors: power to hire or fire, substantial supervision of schedules or conditions, setting pay, and keeping records. Comments closed June 22, 2026; it was not final in the sources.

Not yet confirmed — check with the U.S. Department of Labor.

Time-sensitive. Proposed only; recheck the Federal Register for a final rule (reviewed October 17, 2026).

Source: CalChamber (secondary)National Law Review (secondary)

Last verified October 17, 2026

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A February 2026 NLRB final rule reinstated the 2020 standard, under which joint employment requires “substantial direct and immediate control” over essential terms of employment.

Not yet confirmed — check with the National Labor Relations Board.

Source: Sullivan & Cromwell (secondary)

Last verified October 17, 2026

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Most national staffing firms employ travel and per diem nurses on W-2. Because the facility directs daily work, it can be a joint employer for some purposes.

Not yet confirmed — check with the U.S. Department of Labor.

Source: Sheppard Mullin: joint employer (secondary)

Last verified October 17, 2026

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Under AB 5, RNs, LVNs, NPs, PAs, CRNAs, PTs and OTs are not on the exemption list, so the ABC test applies; bona fide staffing agency and business-to-business routes have structural requirements. A facility association flagged nurses supplied by nurse registries as an AB 5 risk area.

Not yet confirmed — check with the California Labor Commissioner.

Source: Hooper Lundy (secondary)CAHF AB 5 webinar slides

Last verified October 17, 2026

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Iowa deems a platform worker an independent contractor if the worker chooses shifts, where, when and how often, at their sole discretion (Iowa Code 135Q.1(7)). Florida declares registry-referred caregivers independent contractors by statute (400.506(6)(d)).

Source: Iowa Code ch. 135Q (2026)Fla. Stat. 400.506 (nurse registries)

Last verified October 17, 2026

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An agency may charge a nursing home no more than 150% of the weighted average wage rate for the employee classification and geographic group, plus a payroll-tax factor. The cap is all-in, including administrative and contract fees; wages include shift, weekend and overtime differentials. A nursing home paying agency staff’s actual travel and housing costs does not violate it (Minn. Stat. 144A.74). DHS computes the maximums each year; the MDH FAQ gives no figures.

In practice: A 2024 bill to raise the multiplier to 200% was introduced only; the statute reads 150%.

Source: Minn. Stat. 144A.74MDH: Supplemental nursing services agency FAQ

Last verified October 17, 2026

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101 CMR 345.00 sets maximum hourly rates that providers pay registered temporary nursing agencies, by health service area, with holiday rates capped at 150% of the standard maximum. Billing above the cap is an unfair or deceptive practice under c.93A (345.04(3)).

Source: 101 CMR 345.04 (Cornell LII)Massachusetts: temporary nursing agencies rates memo

Last verified October 17, 2026

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The latest table read (amendment effective January 21, 2022) lists RN maximums of about $69 to $71 an hour in nursing facilities and about $97 to $105 an hour in hospitals, weekday first shift. A rate update for dates of service on or after March 1, 2025 was proposed; whether and how it was adopted was not confirmed, so these figures may be superseded.

Not yet confirmed — check with the Massachusetts Executive Office of Health and Human Services.

Time-sensitive. The March 1, 2025 update may have replaced these rates; recheck 101 CMR 345.03 (reviewed October 17, 2026).

Source: 101 CMR 345.03 (Cornell LII)

Last verified October 17, 2026

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HB 2665 (2023) set maximum bill rates a temporary staffing agency may charge or receive, administered through OHA’s rate-setting program.

Source: OHA: temporary staffing agency rate settingOregon SB 1549 (2022), B-Engrossed

Last verified October 17, 2026

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OHA’s page is reported to list, for example, an RN (hospital) cap of $127.35 an hour, or $191.02 for holiday and overtime.

Not yet confirmed — check with the Oregon Health Authority.

Time-sensitive. OHA updates its caps; check the current figures on its page (reviewed October 17, 2026).

Source: OHA: temporary staffing agency rate setting

Last verified October 17, 2026

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For nursing facilities and assisted living residences, the agency rate “shall not exceed two hundred percent (200%) of the regional hourly wage” for each position, all charges included (216-RICR-40-10-10).

Source: 216-RICR-40-10-10

Last verified October 17, 2026

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A 130% billing ceiling appears only in introduced bill SB 2995 (2022); its enactment in that form was not confirmed, so Illinois is treated here as having no confirmed rate cap. Illinois does require bill-rate disclosure in facility contracts (510/14.3).

Not yet confirmed — check with the Illinois Department of Labor.

Source: Illinois SB 2995 (2022)Illinois P.A. 102-0946 (HB 4666), enrolled text

Last verified October 17, 2026

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Illinois requires quarterly reports of average charges, pay and labor-related costs by county and provider type (510/14(h)–(j)); Iowa quarterly reports of average charged and paid per category (135Q.2(4)); Maine an annual report with quarterly charge and wage averages (§2131(1-D)); Connecticut an annual cost report.

Source: Illinois P.A. 102-0946 (HB 4666), enrolled textIowa Code ch. 135Q (2026)22 M.R.S. §2131CT DPH: temporary nursing services agency

Last verified October 17, 2026

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An employment agency must post a $3,000 surety bond and file a copy with the Secretary of State, and may not operate without it; the section mentions no license (Civ. Code 1812.503). A “nurses’ registry” is “a person who engages in the business of obtaining and filling commitments for nursing service”; referrals other than private duty nursing follow the general employment agency chapters (Civ. Code 1812.524). No staffing-agency license was found. State page: California.

Source: Cal. Civ. Code 1812.503Cal. Civ. Code 1812.524

Last verified October 17, 2026

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From January 1, 2023, an agency may not provide temporary nursing services in Connecticut unless registered with DPH. The fee is $500 initially and $750 on renewal, due July 1. An annual cost report covers itemized revenues and costs, average nursing personnel, average fees by personnel and facility type, and the states of residence of personnel supplied. The codified statute section was not confirmed in this review. State page: Connecticut.

Source: CT DPH: temporary nursing services agency

Last verified October 17, 2026 · Effective January 1, 2023

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A nurse registry is exempt from home health agency licensure but must be licensed as a nurse registry, one license per operational site; the application fee is set by rule and capped at $2,000 per biennium (400.506(1)(a), (3)). Registries need level 2 background screening (9), keep records 3 years (10), and keep an emergency plan, with a $5,000 fine per failure (12). Nursing under physician direction needs a signed plan of treatment reviewed with the nurse at least every 2 months (13). One administrator may manage up to 5 registries under common control (18). State page: Florida.

Source: Fla. Stat. 400.506 (nurse registries)

Last verified October 17, 2026

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Nurse agencies are licensed under the Nurse Agency Licensing Act (225 ILCS 510), amended by P.A. 102-0946 effective July 1, 2022. Contracts with facilities go to the Department within 5 business days, and no less than 100% of the hourly rate must be paid to the nurse or CNA (510/14(a)(2)). Agencies file quarterly reports by provider type and county (510/14(h)–(j)). The civil penalty is $10,000 per occurrence, and underpaid employees recover the underpayment plus 5% (510/14.1(c)–(d)). New facility contracts must disclose the bill-rate schedule and all pay components (510/14.3). State page: Illinois.

In practice: A later act, P.A. 102-1124, amended Section 14 again; its changes are not reflected here.

Source: Illinois P.A. 102-0946 (HB 4666), enrolled text

Last verified October 17, 2026 · Effective July 1, 2022

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From July 1, 2023, an agency “engaged for hire in the business of providing or procuring temporary employment in healthcare facilities for healthcare personnel” registers with IDOH (HEA 1461). Registration costs $150, is annual, and may be renewed within 60 days of expiry. It requires ownership and structure information and a schedule of fees or charges; a price range per personnel type satisfies that. IDOH reads “temporary” as undefined duration or expected to last under two years. No rate cap was found. State page: Indiana.

Source: IDOH: temporary health care staffing agency guidance (Feb 22, 2024)IDOH: temporary healthcare staffing agency registry

Last verified October 17, 2026 · Effective July 1, 2023

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Law-firm summaries report a non-compete ban, a ban on poaching facility staff, Attorney General enforcement and 5-year record retention. The statute text (IC 16-52) was not read for this guide.

Not yet confirmed — check with the Indiana Department of Health.

Source: Hall Render (secondary)

Last verified October 17, 2026

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Agencies register annually at $500 per location; an unregistered agency may not contract with any Iowa health care entity (135Q.2(1)). Professional and general liability coverage of at least $1 million per occurrence and $3 million aggregate is required (135Q.2(2)(d)). Agencies report quarterly, for each Medicare or Medicaid entity, the average charged and paid per worker category (135Q.2(4)). Technology platforms register separately, also at $500 (135Q.3). State page: Iowa.

Source: Iowa Code ch. 135Q (2026)

Last verified October 17, 2026

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A KDADS memo of June 28, 2024 reportedly requires supplemental health care services agencies to register from July 1, 2024 at a $2,035 fee, each physical location separately, with quarterly reports, and states that registration “is not a license”. The statutory basis was not established; stand-alone registration bills did not pass. State page: Kansas.

Not yet confirmed — check with the Kansas Department for Aging and Disability Services.

Source: KDADS memo, June 28, 2024 (search summary)

Last verified October 17, 2026

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A “health care services agency” refers temporary direct care staff to assisted living communities, long-term care facilities or hospitals; temporary means undefined duration or under 24 continuous months (KRS 216.718(6), (9)). The agency documents licensing and training, carries professional and general liability insurance and workers’ compensation, holds a $10,000 employee dishonesty bond and keeps records 5 years; failure means denial, or revocation with a $25,000 penalty (KRS 216.722). Registration runs under 906 KAR 1:210. State page: Kentucky.

Source: 2023 Ky. Acts ch. 61 (HB 502)

Last verified October 17, 2026

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An entity that “primarily provides or procures” nurses, CNAs and other staff on a temporary basis in Maine registers annually, expressly including online platforms or marketplaces; licensed home health care providers are excluded. The CNA registry is checked before hire, and the Background Check Center is used for direct access workers. An annual report covers placements, average charges and wages by category. The fee is $1,000 initially and annually. Operating unregistered is a civil violation of $500 to $10,000 per day, and a violation is also one of the Unfair Trade Practices Act (22 M.R.S. §2131). State page: Maine.

Source: 22 M.R.S. §2131

Last verified October 17, 2026

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Temporary nursing service agencies register with DPH under M.G.L. c.111 §72Y and 105 CMR 157.000, which covers registration, renewal, denial and revocation, administrator and personnel requirements. Maximum rates are set under 101 CMR 345.00 (see Payment), and DPH may deny, revoke or refuse to renew a registration for charging above them. State page: Massachusetts.

Source: 105 CMR 157.000 (mass.gov)Massachusetts: temporary nursing agencies rates memo

Last verified October 17, 2026

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Supplemental nursing services agencies register with MDH (Minn. Stat. 144A.70–144A.74). The registration and renewal fee is $2,442, non-refundable (144A.71). Charges to nursing homes are capped (see Payment). State page: Minnesota.

Source: MDH: Supplemental nursing services agency FAQMinn. Stat. 144A.74

Last verified October 17, 2026

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LB 921 requires annual registration with the Department of Labor and covers app-based platforms. The fee is $1,500 per physical location, or $1,500 statewide for an agency with no Nebraska location. Non-competes in staffing agency contracts are barred. State page: Nebraska.

Time-sensitive. The law takes effect July 1, 2027; recheck the Department of Labor’s registration process before then.

Source: Neb. Rev. Stat. 48-4103Vensure: Nebraska health care staffing agency law (secondary)

Last verified October 17, 2026 · Effective July 1, 2027

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Entities that employ, place or refer workers for health care, personal care or companion services in the homes of people with disabilities or adults 60 and over, or at caregiving facilities, register as health care service firms, out-of-state firms included. Reported requirements: ownership disclosure, criminal-history certifications for principals, a $10,000 surety bond unless a net-worth waiver applies, $500 per primary location, and accreditation from a body recognized by NJ DHS within 12 months. P.L. 2026, c.45 (July 22, 2026) moved renewal to September 30. State page: New Jersey.

Not yet confirmed — check with the New Jersey Division of Consumer Affairs.

Time-sensitive. Firms that renewed for 2026–27 are extended to September 30, 2027; recheck the renewal cycle before then.

Source: Holland & Knight: NJ health care service firm registration (Sept 2026, secondary)N.J.A.C. 13:45B-13.3 (Justia)

Last verified October 17, 2026

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No one may operate an employment agency without a license (GBL §172), issued by the Commissioner of Labor or, for agencies in New York City, the city’s consumer affairs commissioner. An employment agency is anyone who “for a fee” procures employment, and the definition extends to nurses’ registries; a fee is anything of value, not only one paid by the job seeker. Temporary help firms are not mentioned (GBL §171). State page: New York.

Source: NY General Business Law §172NY General Business Law §171

Last verified October 17, 2026

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A temporary health care staffing agency registration law is reported as enacted in the SFY 2023–24 budget, including a bar on permanent-hire fees. The statute text was not read for this guide.

Not yet confirmed — check with the New York State Department of Health.

Source: LeadingAge NY (secondary)

Last verified October 17, 2026

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“A nurse registry which provides home care services shall function and be licensed as a home care agency” (OAC 310:662-3-4(h)). The home care agency license covers skilled or personal care provided to clients in their residence for a fee, renews annually and expires July 31 (310:662-1-2, 2-1). State page: Oklahoma.

Source: OAC 310:662 (OSDH copy, rules effective July 11, 2011)

Last verified October 17, 2026

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SB 1549 (2022) directed OHA to issue a renewable temporary staffing agency license; the Health Licensing Office administers the statutes and rules. HB 2665 (2023) set maximum bill rates (see Payment). State page: Oregon.

Source: Oregon SB 1549 (2022), B-EngrossedOregon HLO: temporary staffing agency statutesOHA: temporary staffing agency rate setting

Last verified October 17, 2026

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Act 128 of 2022 (signed November 3, 2022) covers agencies supplying RNs, LPNs, nurse aides or direct care staff to long-term care nursing facilities, personal care homes or assisted living residences. Owners and operators register annually and list each location. State page: Pennsylvania.

Source: Pennsylvania DOH: temporary health care services agenciesPA DOH: Act 128

Last verified October 17, 2026

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The Department’s interpretive guideline is reported to require an employee dishonesty or fidelity bond of $10,000 per covered employee. A $500 initial fee and $500 renewal are reported by secondary sources only.

Not yet confirmed — check with the Pennsylvania Department of Health.

Source: PA DOH: Act 128 (the interpretive guideline was moved; search summary)

Last verified October 17, 2026

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No one may “establish, conduct or maintain a nursing service agency” without a license. Each central office is licensed, and the agency keeps a licensed central office inside Rhode Island; licenses expire December 31. Accreditation is required within 24 months of initial licensure. The annual fee is $1,000 per licensee (§23-17.7.1-3(c)). The rule amendment in force has been effective since June 20, 2024. State page: Rhode Island.

Source: 216-RICR-40-10-10R.I. Gen. Laws §23-17.7.1-3

Last verified October 17, 2026

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An agency that staffs only hospitals and holds Joint Commission certification may be exempt from licensure (§23-17.7.1-15) but must still register and list each hospital it staffs, according to RIDOH guidance.

Not yet confirmed — check with the Rhode Island Department of Health.

Source: RIDOH nursing service agency guidance (search summary)

Last verified October 17, 2026

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This review found no Texas license or registration specific to nurse or health care staffing agencies. HB 4146 (2023) would have required annual registration with HHSC and was not shown to have been enacted; SB 1103 (2021) covers nurse aides, not agencies. Other Texas rules, including home health licensing, still apply. State page: Texas.

Not yet confirmed — check with the Texas Health and Human Services Commission.

Source: Texas HB 4146 (88R) bill analysisTexas SB 1103 (87R) enrolled

Last verified October 17, 2026

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This review found no Vermont statute specific to health care staffing agencies. COVID-era flexibilities covered individual out-of-state clinicians, not agencies, and a 2022 Attorney General settlement imposed hiring and termination protocols on one caregiver staffing agency by settlement, not statute. Other Vermont rules still apply. State page: Vermont.

Not yet confirmed — check with the Vermont Department of Disabilities, Aging and Independent Living.

Source: Vermont Attorney General: caregiver staffing agency settlement (2022)VTDigger: traveling health care workers law (secondary)

Last verified October 17, 2026

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No one may operate a business providing or referring health care personnel for temporary employment in health care facilities without first registering with DOH (ch. 18.52C RCW; WAC 246-845-050). State page: Washington.

Source: WAC 246-845-050 (Justia)

Last verified October 17, 2026

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SB 5547 (2023) requires disclosure of corporate ownership and annual reporting by facility type and county of average charges, wages, labor-related costs and placement distance, beginning in 2025 (RCW 18.52C.060). No non-compete provision was found in it.

Not yet confirmed — check with the Washington State Department of Health.

Source: WSHA summary (secondary)WHCA: 2025 nursing pool reporting (secondary)

Last verified October 17, 2026

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This review found no West Virginia statute specific to nurse staffing agencies. The Division of Labor registers employment agencies, but “only those agencies that make placements for individuals which are not on their own payroll are required to register”, so a temporary agency placing its own employees is exempt from that registration. Other West Virginia rules still apply. State page: West Virginia.

Not yet confirmed — check with the West Virginia Division of Labor.

Source: WV Division of Labor: employment agencies

Last verified October 17, 2026

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This review found no enacted Wisconsin statute licensing or registering health care staffing agencies. A hospital nurse staffing bill (ratios, not agencies) was reintroduced in February 2026. Other Wisconsin rules still apply. State page: Wisconsin.

Not yet confirmed — check with the Wisconsin Department of Health Services.

Source: nurse.org: Wisconsin nurse staffing bill (secondary)

Last verified October 17, 2026

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NCSBN states that “43 jurisdictions are currently part of the NLC”, and its map (file dated August 5, 2026) lists 43 jurisdictions that have enacted it. Guam, Massachusetts and the U.S. Virgin Islands are enacted with implementation dates to be determined; Guam is partially implemented. Massachusetts has enacted the compact but not implemented it.

Time-sensitive. Massachusetts’ implementation date is to be determined; recheck the NCSBN map (reviewed October 17, 2026).

In practice: State by state: Nurse Licensure Compact map.

Source: NCSBN: Nurse Licensure CompactNCSBN: NLC map (file dated Aug 5, 2026)

Last verified October 17, 2026

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A nurse who moves to another compact state must apply for licensure in the new primary state of residence within 60 days.

Source: NCSBN: Nurse Licensure Compact

Last verified October 17, 2026

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Pennsylvania fully implemented on July 7, 2025 and Connecticut on October 1, 2025. The dates were matched from the map’s text and secondary sources agree.

Not yet confirmed — check with NCSBN.

Source: NCSBN: NLC map (file dated Aug 5, 2026)Triage Staff: Pennsylvania implements the NLC (secondary)

Last verified October 17, 2026

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Not on the 43-jurisdiction list: Alaska, California, Hawaii, Illinois, Michigan, Minnesota, Nevada, New York, Oregon, the District of Columbia and Puerto Rico, among others. Placements there need a single-state license or a temporary permit.

Not yet confirmed — check with NCSBN and the state board of nursing.

Source: NCSBN: NLC map (file dated Aug 5, 2026)

Last verified October 17, 2026

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The APRN Compact takes effect once seven jurisdictions enact it. Secondary sources report five (Delaware, North Dakota, South Dakota, Utah, Wyoming), so it is not operational.

Not yet confirmed — check with NCSBN.

Time-sensitive. Recheck the enacting-state count as bills move (reviewed October 17, 2026).

Source: AMN Healthcare: APRN Compact guide, Aug 2026 (secondary)APRN Compact

Last verified October 17, 2026

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The cited regimes put the first decision on the model: W-2 staffing as employer of record, a registry or referral model only where a state authorizes it (Florida, for example), or direct-hire placement. Each brings different licensing, classification and fee rules. No single official checklist sets this order.

Not yet confirmed — check with each state’s licensing agency.

Source: Fla. Stat. 400.506 (nurse registries)NY General Business Law §171

Last verified October 17, 2026

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For each state, check for a health care staffing license or registration (for example Illinois, Minnesota, Massachusetts, Connecticut, New Jersey, Pennsylvania, Washington, Oregon, Rhode Island, Florida’s registry license, and Nebraska from July 1, 2027), any general employment agency license, and home care licensing where nurses go into homes.

Not yet confirmed — check with each state’s licensing agency.

Source: Illinois P.A. 102-0946 (HB 4666), enrolled textMinn. Stat. 144A.74CT DPH: temporary nursing services agencyPennsylvania DOH: temporary health care services agenciesOAC 310:662 (OSDH copy, rules effective July 11, 2011)

Last verified October 17, 2026

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Some states set amounts: Kentucky requires professional and general liability insurance, workers’ compensation and a $10,000 employee dishonesty bond (KRS 216.722); Iowa requires liability coverage of at least $1 million per occurrence and $3 million aggregate (135Q.2(2)(d)).

Source: 2023 Ky. Acts ch. 61 (HB 502)Iowa Code ch. 135Q (2026)

Last verified October 17, 2026

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State rules add screening duties: Florida registries need level 2 background screening (400.506(9)); Maine agencies check the CNA registry before hire and use the Background Check Center for direct access workers (§2131(1-A), (1-B)). Federal exclusion screening applies everywhere (see Federal rules).

Source: Fla. Stat. 400.506 (nurse registries)22 M.R.S. §2131HHS OIG: Exclusions (LEIE)

Last verified October 17, 2026

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Illinois voids non-competes with nurses and CNAs and bars “liquidated damages, conversion fees, employment fees, buy-out fees, placement fees, or other compensation” when the employee is hired permanently (510/14(g)). Kentucky bars buy-out and non-compete clauses and permanent-hire fees, except facility-paid fees reduced pro rata by time on the agency payroll (KRS 216.724(1)). Iowa bars noncompete clauses and conversion fees, with a narrow exception for workers the agency helped obtain U.S. work authorization (135Q.2(3)). Nebraska bars non-competes from July 1, 2027.

Source: Illinois P.A. 102-0946 (HB 4666), enrolled text2023 Ky. Acts ch. 61 (HB 502)Iowa Code ch. 135Q (2026)Neb. Rev. Stat. 48-4103

Last verified October 17, 2026

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Illinois bars recruiting on facility premises and requiring staff to recruit the facility’s permanent employees (510/14(f)); Kentucky bars soliciting the facility’s staff (KRS 216.724(1)(c)); Maine bars “predatory recruitment” (§2131(1-C)); Rhode Island bars recruiting a client’s employees and penalizing staff whom a client hires.

Source: Illinois P.A. 102-0946 (HB 4666), enrolled text2023 Ky. Acts ch. 61 (HB 502)22 M.R.S. §2131216-RICR-40-10-10

Last verified October 17, 2026

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Penalties are large: in Iowa an unregistered agency may not contract with any Iowa health care entity, and penalties rise from $5,000 to $25,000 and revocation (135Q.2(1), 135Q.4); in Maine $500 to $10,000 a day (§2131(4)); in Illinois $10,000 per occurrence (510/14.1(c)). A non-compliant Kentucky contract is void as an unfair trade practice (KRS 216.724(2)).

Source: Iowa Code ch. 135Q (2026)22 M.R.S. §2131Illinois P.A. 102-0946 (HB 4666), enrolled text2023 Ky. Acts ch. 61 (HB 502)

Last verified October 17, 2026

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Florida ties registry licensure to independent-contractor status and a duty not to supervise. Elsewhere, a registry placing 1099 nurses in homes risks reclassification as an employer and unlicensed home health practice, and Oklahoma licenses registries that provide home care as home care agencies.

Not yet confirmed — check with the state licensing agency.

Source: Fla. Stat. 400.506 (nurse registries)OAC 310:662 (OSDH copy, rules effective July 11, 2011)CAHF AB 5 webinar slides

Last verified October 17, 2026

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Rhode Island requires a licensed central office inside the state, so an out-of-state agency cannot simply register remotely (216-RICR-40-10-10).

Source: 216-RICR-40-10-10

Last verified October 17, 2026

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The FTC’s 2024 non-compete ban was set aside by a federal court on August 20, 2024 and removed from the CFR on February 12, 2026. State staffing laws are what restrict agency non-competes.

Not yet confirmed — check with the Federal Trade Commission.

Source: Trade Secrets Law: health care non-compete update, Q1 2026 (secondary)

Last verified October 17, 2026

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Connecticut’s homemaker-companion agency registration (C.G.S. ch. 400o, Department of Consumer Protection) covers non-medical services and excludes nursing care and medication administration; it does not cover nurse staffing.

Not yet confirmed — check with the Connecticut Department of Consumer Protection.

Source: C.G.S. ch. 400o (search summary)

Last verified October 17, 2026

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