Under the 2001 Regulation of Care Act, any organisation providing care services must pay to register with the Care Commission, which was established last year to regulate and inspect Scottish care services.
But umbrella body Community Care Providers Scotland (CCPS) has warned that the "extraordinary" registration fee, believed to be around £2,000 per service, could cripple charities working in the care sector and has asked the Executive to clarify the terms on which the fee is charged.
"The nature of community care means that most services operate at a national level but sometimes have dozens of different services scattered around the country," said Annie Gunner, chief executive of CCPS. "What the Care Commission has yet to clarify is whether the fee structure will mean that charities are charged a separate fee for every service they provide, which will mean financial ruin for a lot of the smaller providers."
CCPS says that it could lead to people being herded back into institutionalised care, as charities would be unable to pay separate fees for each separate home-care service.
It also criticised the Executive for sending out the message that voluntary sector care services are dispensable, and says that the fee structure should reflect the fact that the voluntary sector provides over one-third of the care services in Scotland.
No official decision on fee levels has been made, but in its latest consultation document the Executive described the closure of smaller providers as an "unintended consequence" of the launch of the Care Commission.