This question is easier to answer by explaining where you do not have any risk.
An agency does not have any risk in relation to debt transfer, on contractors who already have their operating structure in place and Provider selected. In these cases the agency should be able to demonstrate that this was the case and that no advice, direction or guidance was given by the Agency to the Contractor that influenced that choice. There are steps agencies should take to demonstrate this and detailed guidance is available to Members on this aspect.
Any other contractor can present a risk depending on the agency operating procedures. Therefore the risks primarily relate to any contractor who, is new to contracting and this is their first assignment or, is seeking guidance on their operating structure or provider.