Tennessee - Adult Companion Services — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-09-10
Tennessee funds Companion Care primarily through the TennCare CHOICES and Employment and Community First (ECF) CHOICES managed care programs, requiring prospective agencies to first obtain provider credentialing through the Department of Intellectual and Developmental Disabilities (DIDD) before they can attempt to contract with the state's Managed Care Organizations (MCOs). The state does not issue a standalone "Adult Companion" license; instead, agencies typically operate under a Personal Support Services Agency (PSSA) license issued by the Department of Mental Health and Substance Abuse Services, or operate under direct DIDD credentialing for waiver-specific services.
Because Tennessee operates its long-term services and supports (LTSS) entirely through a managed care delivery system, obtaining a state license and Medicaid ID does not guarantee the ability to bill for services. Providers must successfully navigate MCO network adequacy reviews, meaning an application will only result in active billing if the regional MCOs determine there is a geographic need for additional Companion Care capacity.
1. Service Definition and Scope
In Tennessee's CHOICES and ECF CHOICES programs, Companion Care (often categorized alongside personal assistance or community integration services) provides non-medical supervision, socialization, and assistance to enable adults with physical disabilities or intellectual/developmental disabilities to remain safely in community settings. The service is designed to prevent institutionalization by offering oversight and engagement when primary caregivers are unavailable.
This service explicitly excludes medical or nursing care, and it cannot be billed concurrently with residential services like Supported Living or Medical Residential Services. It is authorized strictly according to the member's Person-Centered Support Plan (PCSP) developed by their MCO Care Coordinator.
- Service Name: Companion Care (under CHOICES) or Community Integration/Support (under ECF CHOICES).
- Scope of Activities: Non-medical supervision, socialization, assistance with light instrumental activities of daily living (IADLs), and community engagement.
- Exclusions: Cannot include hands-on nursing care, medication administration (unless specifically delegated under the Nurse Practice Act), or services already provided by a residential provider.
- Setting: Delivered in the member's private residence or in the community, not in licensed facilities like nursing homes or hospitals.
- Authorization: Must be explicitly detailed in the TennCare-approved PCSP.
2. Regulatory and Oversight Agencies
Oversight of Companion Care in Tennessee is divided between the state Medicaid agency, the disability services department, and the contracted MCOs. TennCare holds the ultimate authority over the Medicaid state plan and waivers, while DIDD handles the day-to-day quality monitoring and provider credentialing for HCBS.
Because services are administered through managed care, the MCOs act as the direct regulatory and payment authorities for enrolled providers, conducting their own credentialing, auditing, and network management.
- Division of TennCare: The single state Medicaid agency responsible for CHOICES and ECF CHOICES oversight (https://www.tn.gov/tenncare.html).
- Department of Intellectual and Developmental Disabilities (DIDD): Manages provider credentialing and quality assurance for HCBS waivers (https://www.tn.gov/didd.html).
- BlueCare Tennessee: One of the three MCOs administering TennCare LTSS (https://bluecare.bcbst.com/).
- UnitedHealthcare Community Plan: MCO administering TennCare LTSS (https://www.uhc.com/communityplan/tennessee).
- Wellpoint (formerly Amerigroup): MCO administering TennCare LTSS (https://www.wellpoint.com/tn/medicaid).
3. Gatekeeping Prerequisites: Who Can Even Apply
The absolute structural prerequisite for providing Companion Care in Tennessee is MCO network inclusion. Tennessee does not operate an open-network fee-for-service system for HCBS; providers must secure a contract with at least one of the three TennCare MCOs (BlueCare, UnitedHealthcare, or Wellpoint). If the MCOs declare their networks closed for Companion Care in a specific Grand Division (West, Middle, or East Tennessee) due to adequate capacity, new providers cannot enroll to bill for this service.
Additionally, to participate in ECF CHOICES or the 1915(c) waivers, an agency must first pass the DIDD Provider Credentialing process. DIDD only accepts new provider applications during specific open enrollment windows or when a specific service need is identified, acting as a secondary gatekeeper before MCO contracting.
- MCO Network Adequacy: Providers must submit a letter of intent to the MCOs; applications are rejected if the MCO determines no additional network capacity is needed.
- DIDD Credentialing Window: Agencies must apply for DIDD credentialing, which may be subject to targeted recruitment windows rather than rolling admissions.
- Licensure Prerequisite: If operating as a Personal Support Services Agency (PSSA), the agency must hold an active license from the Department of Mental Health and Substance Abuse Services before Medicaid enrollment.
- Business Registration: Must be registered and in good standing with the Tennessee Secretary of State.
4. Licensure and Certification Requirements
Tennessee does not have a specific "Adult Companion" license. Agencies providing in-home companion and personal care services typically must obtain a Personal Support Services Agency (PSSA) license, unless they are exclusively providing services under a DIDD waiver that exempts them through direct DIDD credentialing.
The DIDD credentialing process requires agencies to submit extensive documentation of their business structure, financial solvency, and operational policies. Providers must demonstrate compliance with the HCBS Settings Rule and pass a readiness review.
- PSSA License: Required for agencies providing personal support and companion services, issued by the state.
- DIDD Provider Application: Comprehensive application requiring policy manuals, organizational charts, and financial statements.
- HCBS Settings Rule Compliance: Providers must attest and demonstrate that their services integrate members into the broader community.
- Readiness Review: DIDD conducts a pre-approval review of the agency's policies, training curricula, and quality management plans.
- Insurance Requirements: Must maintain general liability, professional liability, and workers' compensation insurance as dictated by DIDD and MCO contracts.
5. Medicaid Provider Enrollment
Once licensed or credentialed by DIDD, providers must enroll in the TennCare Medicaid Management Information System (MMIS) to receive a Medicaid ID. This is done electronically through the TennCare Provider Registration portal.
Enrollment with TennCare is a prerequisite for MCO contracting, but it does not authorize the provider to bill. The provider must sign an abbreviated Medicaid agreement and then complete the full credentialing and contracting process with the individual MCOs.
- TennCare Provider Registration Portal: The electronic system used to apply for a Tennessee Medicaid ID (https://www.tn.gov/tenncare/providers/provider-registration.html).
- NPI Requirement: Providers must obtain a Type 2 (Organizational) National Provider Identifier from NPPES.
- Application Fee: Must pay the federal Medicaid/Medicare application fee (or provide proof of payment to Medicare/another state) unless exempt.
- Medicaid Agreement: Must sign the TennCare provider agreement acknowledging state and federal regulations.
- MCO Credentialing: After receiving a Medicaid ID, the provider must submit credentialing applications to BlueCare, UHC, and/or Wellpoint via the Council for Affordable Quality Healthcare (CAQH) or MCO-specific portals.
6. Staffing, Training and Background Checks
Tennessee enforces strict background check and training requirements for all staff providing direct contact services like Companion Care. Agencies are responsible for ensuring all checks are completed prior to the employee's first day of direct contact with a member.
Training must align with DIDD and TennCare requirements, including specific modules on abuse/neglect reporting, person-centered practices, and the specific needs of the population served.
- Abuse Registry Check: Staff must not be listed on the Tennessee Department of Health Abuse Registry.
- Sex Offender Registry: Staff must be cleared through the National Sexual Offender Registry and the Tennessee Sex Offender Registry.
- Criminal Background Check: Fingerprint-based criminal background checks are required for all direct support professionals.
- OIG Exclusion List: Agencies must verify staff are not excluded from Medicare/Medicaid participation via the federal OIG LEIE.
- Basic Training: Staff must complete training in CPR/First Aid, infection control, and incident management.
- Driver Requirements: Any staff transporting members must have a valid driver's license and automobile liability insurance.
7. Documentation, Policies and Records
Providers must maintain comprehensive records that align with the member's Person-Centered Support Plan (PCSP). Tennessee mandates the use of Electronic Visit Verification (EVV) for all in-home personal care and companion services to document the exact time, location, and duration of service delivery.
Agencies must also maintain robust incident management policies, reporting any critical incidents (such as abuse, neglect, or exploitation) directly to DIDD and the authorizing MCO within mandated timeframes.
- Electronic Visit Verification (EVV): Mandatory use of the state-approved EVV system or an MCO-approved alternate system to log all companion care shifts.
- Person-Centered Support Plan (PCSP): Services must be delivered and documented exactly as outlined in the MCO-approved PCSP.
- Service Notes: Daily documentation must describe the specific socialization or supervision activities provided and the member's response.
- Incident Reporting: Critical incidents must be reported to the MCO and DIDD within 24 hours of discovery.
- Record Retention: All clinical and billing records must be retained for a minimum of five years (or longer per MCO contract).
8. Billing, Rates and Claims
Companion Care is not billed directly to TennCare; all claims must be submitted to the member's assigned MCO (BlueCare, UHC, or Wellpoint). Rates are established by TennCare but administered through the MCO fee schedules.
Claims must match the EVV data and the prior authorization issued by the MCO. Any discrepancy between the authorized units, the EVV log, and the submitted claim will result in a denial.
- Billing Entity: Claims are submitted to the specific MCO (BlueCare, UHC, Wellpoint) managing the member's care.
- Prior Authorization: 100% of Companion Care services require prior authorization from the MCO before delivery.
- Procedure Codes: Typically billed using HCPCS codes such as S5135 (Companion care, per 15 minutes), subject to the specific waiver's coding matrix.
- EVV Integration: Claims will be denied if they are not supported by matching EVV data verifying the visit.
- Timely Filing: Claims must generally be submitted within 120 days of the date of service, though MCO contracts may specify different windows.
9. Approval Sequence and Timeline
Becoming a fully active Companion Care provider in Tennessee is a lengthy, multi-stage process due to the managed care structure. The process begins with state licensure or DIDD credentialing, moves to Medicaid enrollment, and concludes with MCO contracting.
Because MCOs only contract based on network need, a provider might complete DIDD credentialing and TennCare enrollment but wait months or be denied entirely at the MCO contracting stage if the network is closed.
- Step 1: Obtain PSSA license or complete DIDD Provider Credentialing (3-6 months).
- Step 2: Register in the TennCare Provider Registration portal to obtain a Medicaid ID (30-60 days).
- Step 3: Submit Letters of Intent to BlueCare, UHC, and Wellpoint to assess network need (30 days).
- Step 4: Complete MCO credentialing via CAQH if the Letter of Intent is accepted (90-120 days).
- Step 5: Sign MCO contracts and complete EVV system training before accepting referrals.
10. Common Denials and Survey Findings
Providers frequently face application denials at the MCO level due to closed networks or failure to demonstrate a unique geographic or cultural competency need. During audits, the most common recoupments stem from EVV non-compliance.
DIDD and MCO quality monitors frequently cite agencies for failing to maintain continuous background check clearances or for delivering services that deviate from the specific goals outlined in the PCSP.
- Network Closed Denials: MCOs rejecting applications because they already have enough Companion Care providers in the region.
- EVV Mismatches: Claims recouped because the billed time does not exactly match the GPS-stamped EVV log.
- Background Check Gaps: Citations for allowing staff to work before the fingerprint or abuse registry checks are fully cleared.
- PCSP Deviations: Providing and billing for services not explicitly authorized in the member's care plan.
- Training Deficiencies: Failure to document that staff completed required annual in-service training.
11. Key Contacts and Resources
Prospective providers must utilize the official portals and resources provided by TennCare, DIDD, and the three MCOs to navigate the enrollment and credentialing process.
Monitoring the DIDD and TennCare websites for announcements regarding open enrollment windows and policy updates is essential for maintaining compliance.
- TennCare Provider Registration: https://www.tn.gov/tenncare/providers/provider-registration.html
- DIDD Provider Credentialing: https://www.tn.gov/didd/providers/become-a-provider.html
- BlueCare Tennessee Provider Portal: https://bluecare.bcbst.com/providers
- UnitedHealthcare Community Plan of TN: https://www.uhcprovider.com/en/health-plans-by-state/tennessee-health-plans/tn-comm-plan-home.html
- Wellpoint Tennessee Providers: https://provider.wellpoint.com/tennessee-provider/home
- Tennessee Department of Health Abuse Registry: https://apps.health.tn.gov/AbuseRegistry/default.aspx
See all Tennessee services · Tennessee Medicaid consulting · book a consultation.