The document states that the lack of inspections could see issues relating to the “safety and welfare” of people with disabilities arise; possible legal action which might be taken on foot of this; and “risk of damage to the reputation of the department”.
The register was drawn up as part of ongoing preparations to begin inspecting disability services.
Facilities for children with disabilities are the only state-funded children’s residential facilities not subject to any form of inspection.
According to documents obtained by the Irish Examiner, the department believes services for 9,000 people in 1,500 settings will have to be inspected, a higher figure than expected.
They will begin in 2013 and will be carried out by the Health Information and Quality Authority, which must recruit about 78 inspectors.
Many of the homes are run by charities, such as the Brothers of Charity, but others are HSE-run.
It was envisaged that the inspections would cost €10 million, but this estimate has been scaled back to €6.4m, which could be further reduced.
The move comes after much lobbying by the sector and a recommendation in the Ryan report more than two years ago that such residential homes be inspected by an independent body.