Small operational choices that make a big difference
In the world of caregiver registries, staying compliant isn’t just about avoiding penalties—it’s about protecting the model itself.
The independent contractor (1099) approach offers flexibility, lower overhead, and a powerful way to match great caregivers with the families who need them. But it also comes with scrutiny. Regulators, auditors, and even clients are increasingly asking: Are you operating as a true registry—or just calling yourself one?
Here’s the truth: it's not one big decision that defines compliance. It’s the small, daily operational habits that make all the difference—and those habits must align with how a legitimate caregiver referral service is expected to function.
1. Let Clients Choose Their Caregivers
A caregiver registry should refer caregivers—not assign them.
When a client has final say in who provides their care, it reinforces that the registry is a matching service, not an employer. This distinction is central to maintaining 1099 classification. Make it easy for clients to view caregiver profiles, read reviews, and make informed choices. Many registry owners rely on 1099 software like Ally to streamline this process, ensuring transparency while supporting autonomy for both parties.
2. Avoid Controlling the Schedule
Suggest, don’t dictate.
Caregivers working through a registry should be able to set their own availability and accept referrals at their discretion. If you’re assigning shifts or expecting instant coverage, it starts to feel like employment. A good caregiver registry platform will allow caregivers to define their preferences and notify them when a client match is available—without crossing the line into managerial control.
3. Keep Payment Workflows Clean (and Legally Sound)
Payment handling is one of the most heavily scrutinized areas.
Holding client funds, paying caregivers before receiving client approval, or using pooled escrow accounts can all signal employment-like behavior. Registries should instead use a 1099 software solution that separates invoicing, approval, and payment. With Ally, for example, the client reviews hours submitted by the caregiver, then pays them directly—ensuring your workflows support a true caregiver referral service model and remain audit-proof.
4. Encourage (and Document) Independent Behavior
Independent contractors should operate… well, independently.
Encourage caregivers to use their own methods, bring their own supplies, and work for multiple clients or registries. These behaviors reinforce their independence, both in practice and on paper. It’s also important to document these behaviors where possible—especially if your registry ever faces worker classification questions. A digital audit trail from your registry software can serve as critical support.
5. Keep a Paper Trail
Auditors want documentation, not just good intentions.
To prove you’re operating as a legitimate caregiver registry, keep records showing:
- Clients selected their caregivers
- Caregivers submitted hours voluntarily
- Clients approved hours before payment
- No mandatory schedules were imposed
Without proof, even a compliant process can fall apart during an audit. That’s why leading caregiver registry software includes built-in tools for time tracking, approvals, and reporting—all with audit-readiness in mind.
6. Offer Support—Not Supervision
You can support caregivers without supervising them.
Registries can offer optional resources, onboarding guidance, and client communication tools—but should avoid training caregivers as if they’re employees. Instead, focus on providing value through education, not oversight. Keep the relationship professional and independent.
Final Thought:
Being a registry isn’t just a classification—it’s a mindset.
Every operational decision you make—from how referrals are managed to how payments flow—contributes to your compliance story. The difference between a true caregiver registry and a misclassified operation often comes down to consistency and documentation.
With the right daily habits—and the right 1099 caregiver registry software—you can keep your business protected, efficient, and thriving.
