Most discussion of Connecticut Public Act 26-50 is about homemaker-companion agencies. But section 1(d) reaches a different kind of business entirely: registries. If your operation supplies, refers, or places caregivers with consumers rather than employing them directly, the law still found you.
This article summarizes public sources. It is not legal advice.
What section 1(d) says
"Each registry... shall ensure that each individual such registry supplies or refers to or places with a consumer for the purpose of enabling such individual to provide to the consumer companion services or homemaker services... complies with the training requirements set forth in subsection (b) of this section before supplying or referring such individual to or placing such individual with a consumer."
"Registry" is a defined term under section 20-670 of the general statutes - the same statute that defines homemaker-companion agencies. The model is different (registries match independent caregivers with consumers rather than employing caregivers), but the training gate applies all the same.
The timing is the teeth
The operative word is "before." A registry must ensure compliance before it supplies, refers, or places the individual. This is not a 90-day window after placement, and it is not an annual attestation structure like the agency rule. It is a gate: untrained individuals do not get referred.
That makes the registry's practical question a verification question. Before a referral goes out, the registry needs to know the individual's training status against the subsection (b) requirements - the approved program list and its topics - and needs evidence to stand on.
What evidence looks like for a registry
The statute's proof mechanism throughout is the completion form prescribed by the DCP commissioner: agency or provider and worker signatures, programs completed, dates. For a registry, the natural practice is:
- Collect the individual's signed completion forms during onboarding, before any referral
- Check the programs and dates against the approved list's topics
- Track the recurring requirement - every program on the approved list at least once every two calendar years - so a referred worker does not quietly lapse while active in the registry's pool
- Re-check before placement, since the duty attaches to each act of supplying, referring, or placing
DCP published the approved program lists and the prescribed completion forms on September 30, 2026. Some topics on the lists are still marked "course materials are coming soon," and DCP reviews additional programs on a rolling basis - so the list a registry checks against will grow.
Why registries get missed in the coverage
The agency obligations are longer and come with the January 1, 2027 attestation deadline, so they absorb the attention. The registry rule is one sentence. But it is a sentence with a hard sequencing requirement, and registries operate on exactly the activity it regulates: referrals and placements.
There is also a fair reading question tucked into the text: subsection (d) points to the training requirements "set forth in subsection (b)" - the approved-list topics - rather than the full subsection (a) structure that binds agencies. Registries should read the statute with counsel and watch DCP's pages for any registry-specific guidance.
For consumers and families
If you hire through a registry, PA 26-50 gives you a clean question to ask: "How do you verify that the caregivers you refer meet Connecticut's training requirements before you refer them?" A registry with a real answer has a real process. That question works for agencies too - and it is the same standard the law applies.
Where Companza fits
Companza keeps one training record per worker: completions from any source, signed forms filed, due dates tracked. For organizations that need to know a person's status before a date or a referral, that record is the answer. Companza is a records platform, not a training provider, and not a state agency.
Sources
Frequently asked questions
Does PA 26-50 apply to caregiver registries?
Yes. Section 1(d) requires each registry to ensure that individuals it supplies, refers, or places with consumers for companion or homemaker services comply with the training requirements before the supply, referral, or placement.
When must a registry verify training?
Before supplying, referring, or placing the individual with a consumer. The statute makes compliance a precondition, not a follow-up.
What records can a registry rely on?
The completion form prescribed by the DCP commissioner, signed by both parties, listing programs and dates, checked against the approved program list's topics.
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