Tennessee - Adult Companion Services — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-08-16
In Tennessee, Adult Companion Services provide non-medical supervision and socialization to help adults age safely in the community. These services are primarily delivered through the TennCare CHOICES program for seniors and adults with physical disabilities, and the Employment and Community First (ECF) CHOICES program for individuals with intellectual and developmental disabilities.
The single biggest structural barrier to entry for this service in Tennessee is the mandatory Managed Care Organization (MCO) contracting requirement. Tennessee operates its Medicaid Long-Term Services and Supports (LTSS) entirely through managed care. State credentialing and Medicaid enrollment alone do not grant a provider the ability to bill; applicants must be accepted into the closed or highly selective provider networks of TennCare's designated MCOs (BlueCare, UnitedHealthcare, or Wellpoint) to receive referrals and reimbursement.
1. Service Definition and Scope
Companion Care in Tennessee is defined as non-medical care, supervision, and socialization provided to a waiver participant. The service is designed to ensure the individual's safety and well-being while preventing institutionalization, but it strictly excludes hands-on medical or personal care tasks.
Providers must clearly distinguish companion services from personal care or homemaker services, as overlapping billing for the same time periods is prohibited under TennCare rules.
- Target Population: Adults aged 21 and older with physical disabilities or seniors aged 65 and older in CHOICES, and individuals with intellectual/developmental disabilities in ECF CHOICES.
- Covered Activities: Supervision, socialization, and light assistance with instrumental activities of daily living (IADLs) that are incidental to the primary companion role.
- Excluded Activities: Hands-on personal care (such as bathing, dressing, or toileting), medication administration, and any medical treatments.
- Setting Limitations: Companion Care cannot be provided to members living in an Assisted Care Living Facility (ACLF) or an Adult Care Home.
- Service Overlap: Companion services cannot be billed concurrently with Personal Care, Adult Day Care, or Respite services for the same member.
2. Regulatory and Oversight Agencies
Tennessee does not issue a specific facility or agency license for "Adult Companion Services." Instead, oversight is split between the state department responsible for credentialing Home and Community Based Services (HCBS) providers and the Medicaid authority that oversees the managed care plans.
Providers must interact with state agencies for credentialing and enrollment, but day-to-day oversight, authorization, and quality assurance are heavily delegated to the MCOs.
- Tennessee Department of Disability and Aging (DDA): Manages HCBS provider credentialing, quality oversight, and incident management (https://www.tn.gov/disability-and-aging.html).
- Bureau of TennCare: Administers the state Medicaid program, manages the MMIS, and oversees the MCO contracts (https://www.tn.gov/tenncare.html).
- BlueCare Tennessee: MCO managing CHOICES and ECF CHOICES benefits and provider networks (https://bluecare.bcbst.com).
- UnitedHealthcare Community Plan of Tennessee: MCO managing CHOICES and ECF CHOICES benefits and provider networks (https://www.uhc.com/communityplan/tennessee).
- Wellpoint Tennessee: MCO managing CHOICES and ECF CHOICES benefits and provider networks (https://www.wellpoint.com/tn/medicaid).
3. Gatekeeping Prerequisites: Who Can Even Apply
Tennessee's HCBS system is heavily gatekept by its managed care structure. While there is no Certificate of Need (CON) required for companion services, severe structural barriers exist before a provider can accept clients or bill for services.
An applicant cannot simply enroll in Medicaid and begin operating; they must pass through state credentialing and secure elusive MCO contracts, which are often subject to moratoria based on regional network adequacy.
- MCO Contracting Requirement: Providers must secure a network participation contract with at least one of the three TennCare MCOs (BlueCare, UHC, Wellpoint) to receive authorizations and reimbursement.
- Closed Network Moratoria: MCOs frequently close their networks to new HCBS providers based on regional adequacy; applicants must verify open enrollment windows with each MCO before investing in the credentialing process.
- DDA Credentialing Prerequisite: Providers must be fully credentialed by the Department of Disability and Aging (DDA) before any MCO will execute a network contract.
- Business Licensure Prerequisite: Applicants must hold a valid Tennessee State Business License and/or County Business License prior to submitting the DDA credentialing application.
4. Licensure and Certification Requirements
Because Tennessee does not license "Adult Companion Agencies" as a distinct category, providers are approved through the DDA HCBS Credentialing process. If an agency also intends to provide hands-on personal care, they must obtain a Personal Support Services Agency (PSSA) license.
The DDA credentialing process requires submission of a comprehensive application packet via email, detailing the agency's structure, tax status, and target service regions.
- DDA Credentialing Application: Must be submitted via email to DDA.Provider.Application@tn.gov, specifying the target regions (West, Middle, East, or Statewide).
- PSSA Licensure (Conditional): Issued by the TN Department of Mental Health and Substance Abuse Services (TDMHSAS) only if the agency also provides hands-on personal support services (https://www.tn.gov/behavioral-health.html).
- Required Disclosures: Submission of the DDA Disclosure Form detailing ownership, control interests, and any criminal history of the owners.
- Tax Documentation: Applicants must submit a W-9, IRS 147c letter, and a Substitute W-9 form with the credentialing packet.
- Processing Timeframe: DDA requires a minimum of 30 calendar days to process initial credentialing applications before providers can request a status update.
5. Medicaid Provider Enrollment
After obtaining DDA credentialing, providers must enroll in the state's Medicaid Management Information System (MMIS) to obtain a TennCare Medicaid ID. This is a prerequisite for MCO contracting.
Enrollment is conducted entirely online through the TennCare Provider Registration Portal (PDMS). Providers must maintain active enrollment and revalidate periodically to keep their MCO contracts valid.
- Enrollment Portal: Applications must be submitted through the TennCare Provider Registration Portal (PDMS) (https://pdms.tenncare.tn.gov/).
- NPI Requirement: The agency must obtain and register a Type 2 National Provider Identifier (NPI) specific to the organization.
- Application Fee: Providers are subject to the federal Medicaid institutional provider application fee (approximately $731 for 2024) unless waived or already paid to Medicare.
- Revalidation: TennCare requires all HCBS providers to revalidate their Medicaid enrollment every 5 years.
- Electronic Visit Verification (EVV): Providers must agree to integrate with TennCare's mandated EVV system for all in-home companion visits.
6. Staffing, Training and Background Checks
Direct support professionals (DSPs) providing companion care must meet strict background and training standards enforced by DDA and the MCOs. Agencies are responsible for maintaining these records in the employee's personnel file.
Staff cannot provide any billable services until all background checks have cleared and mandatory initial training is complete.
- Age Requirement: Companion care staff must be at least 18 years of age.
- Background Checks: Mandatory fingerprint-based criminal background checks must be processed through the Tennessee Bureau of Investigation (TBI).
- Registry Clearances: Staff must clear the Tennessee Department of Health Abuse Registry, the National Sex Offender Registry, and the Felony Offender Registry prior to hire.
- CPR and First Aid: All direct care staff must hold current, hands-on certification in basic First Aid and CPR.
- Abuse and Neglect Training: Mandatory training on recognizing and reporting abuse, neglect, and exploitation under Tennessee law must be completed upon hire and annually.
7. Documentation, Policies and Records
Providers must maintain comprehensive administrative and client records subject to unannounced audits by DDA, TennCare, and the MCOs. Documentation must prove that services were delivered exactly as authorized.
Failure to maintain accurate Electronic Visit Verification (EVV) data or incident reports can result in immediate claim recoupments or contract termination.
- Person-Centered Support Plan (PCSP): Services must be delivered and documented in strict accordance with the member's MCO-approved PCSP.
- EVV Compliance: Electronic Visit Verification records must capture the date, exact start and stop times, location of service, and the specific service code provided.
- Incident Reporting: Critical incidents (e.g., falls, suspected abuse) must be reported to DDA and the respective MCO within 24 hours of discovery.
- Record Retention: All financial, clinical, and personnel records must be retained for a minimum of 5 years from the date of service.
- Emergency Preparedness: Agencies must maintain and annually update a disaster and emergency response plan tailored to the needs of their waiver clients.
8. Billing, Rates and Claims
Companion care is billed directly to the member's MCO, not to TennCare fee-for-service. While TennCare establishes baseline rate methodologies, actual reimbursement is governed by the provider's contract with the MCO.
All services require prior authorization, and claims must match the EVV data exactly to avoid automated denials.
- Billing System: Claims are submitted to the specific MCO (BlueCare, UHC, or Wellpoint) clearinghouses, not the state MMIS.
- Service Codes: Companion care is typically billed using HCPCS code S5135 (Companion care, adult, per 15 minutes) or similar waiver-specific modifiers.
- Prior Authorization: 100% of companion services require prior authorization (PA) from the MCO before service delivery can begin.
- Timely Filing: Claims must generally be submitted within 120 days of the date of service, though specific limits are dictated by the MCO contract.
- EVV Claims Matching: MCO claims systems automatically cross-reference billed units against EVV check-in/check-out data; discrepancies result in automatic denials.
9. Approval Sequence and Timeline
The end-to-end process from business formation to billing can take 6 to 12 months. This timeline is heavily dependent on MCO contracting cycles and whether networks are open to new providers.
Providers must complete each step sequentially; MCOs will not review a contract application without proof of DDA credentialing and an active TennCare Medicaid ID.
- Step 1: Business Formation: Obtain TN State and County business licenses and secure an NPI (1 to 4 weeks).
- Step 2: DDA Credentialing: Submit the application packet to DDA and await approval (30 to 90 days).
- Step 3: TennCare Enrollment: Register via the PDMS portal to obtain a Medicaid ID (30 to 60 days).
- Step 4: MCO Contracting: Apply for network participation with BlueCare, UHC, and Wellpoint (90 to 180 days, contingent on open networks).
- Step 5: EVV Integration: Complete MCO-specific EVV training and system setup prior to accepting the first referral (2 to 4 weeks).
10. Common Denials and Survey Findings
DDA and MCO quality assurance teams conduct regular audits of HCBS providers. Deficiencies often stem from documentation gaps, unapproved service delivery, or staff qualification lapses.
Recoupment of funds is common when providers fail to strictly adhere to the authorized care plan or EVV requirements.
- EVV Non-Compliance: Claims denied or funds recouped due to missing EVV entries, excessive manual time entries, or times that do not match authorized schedules.
- Unapproved Staff: Citations for using staff who have not completed mandatory TBI background checks or CPR/First Aid training prior to their first shift.
- Scope Creep: Auditors citing providers for delivering and billing for hands-on personal care under the companion care billing code.
- Missing Signatures: Failure to obtain required member or guardian signatures on the Person-Centered Support Plan or daily service logs.
- Lapsed Credentialing: Failure to respond to DDA re-credentialing requests or TennCare revalidation, resulting in sudden termination of billing privileges.
11. Key Contacts and Resources
Navigating the Tennessee HCBS provider enrollment landscape requires coordination across multiple state agencies and private managed care organizations.
Providers should rely on the official portals and contact emails provided by DDA and the MCOs for the most current credentialing packets and network status updates.
- Tennessee Department of Disability and Aging (DDA): Provider Enrollment Coordinator, (615) 532-6530, DDA.Provider.Application@tn.gov, https://www.tn.gov/disability-and-aging.html
- TennCare Provider Registration Portal (PDMS): Official Medicaid enrollment system, https://pdms.tenncare.tn.gov/
- BlueCare Tennessee Provider Network: MCO contracting and resources, https://bluecare.bcbst.com/providers
- UnitedHealthcare Community Plan of TN: MCO contracting and resources, https://www.uhcprovider.com/en/health-plans-by-state/tennessee-health-plans/tn-comm-plan-home.html
- Wellpoint Tennessee Providers: MCO contracting and resources, https://provider.wellpoint.com/tennessee-provider/home
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