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Tennessee - Home Health Service — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-10

The Tennessee Health Facilities Commission (HFC) licenses Home Care Organizations to deliver intermittent skilled nursing, physical therapy, and home health aide services under Rule Chapter 1200-08-27. Applicants must secure a Certificate of Need (CON) from the HFC before submitting a licensure application, unless operating exclusively as a pediatric or EEOICPA provider.

TennCare reimburses these services through its managed care network. Agencies seeking to contract with TennCare Managed Care Organizations (MCOs) must obtain Medicare certification, a process that requires either a state survey or deeming through a recognized national accrediting body.

1. Service Definition and Scope

Tennessee Code Annotated § 68-11-201 defines a "home health service" as care provided by a licensed home care organization. The scope encompasses skilled nursing care, physical, occupational, or speech therapy, medical social services, home health aide services, and the provision of certain medical supplies and appliances.

The state distinguishes between intermittent care and private duty services. Intermittent care involves nursing or therapy visits normally lasting no more than two hours and occurring once per day, whereas private duty services involve extended skilled nursing under physician orders.

2. Regulatory and Oversight Agencies

The Tennessee Health Facilities Commission (HFC) is the independent state agency responsible for the Certificate of Need program, facility licensure, and acting as the CMS-designated State Surveying Agency. The HFC was formed by merging the former Health Services and Development Agency (HSDA) and the Department of Health’s Office of Health Care Facilities.

The Bureau of TennCare administers the state's Medicaid program and oversees the Managed Care Organizations (MCOs) that contract with licensed home health agencies. The Tennessee Department of Health (TDH) maintains the Joint Annual Reports (JARs) used for health planning data.

3. Gatekeeping Prerequisites: Who Can Even Apply

Tennessee strictly regulates market entry for home health agencies through its Certificate of Need (CON) program. An applicant cannot submit a licensure application to the HFC without first obtaining an approved CON, which requires proving a statistical need for new services in the proposed county based on the State Health Plan formula.

To serve Medicaid members, TennCare rules require home health agencies to become Medicare-certified before they can contract with TennCare MCOs. Furthermore, MCOs maintain closed or restricted networks and are under no obligation to contract with new home care organizations even if Medicare certification is achieved.

4. Licensure and Certification Requirements

Initial licensure requires submitting Form HF-3506 to the HFC along with the approved CON and the non-refundable application fee. The application mandates detailed disclosures regarding ownership, management contracts, and any history of adverse licensure actions or federal program exclusions.

Agencies must pass an initial state survey before admitting patients. The HFC Regional Office conducts this survey, and upon a successful recommendation, the application is presented to the Commission for formal ratification at its next scheduled meeting.

5. Medicaid Provider Enrollment

Providers must register electronically through the TennCare Provider Registration portal. Because TennCare operates under a managed care model, state-level registration is only the first step; agencies must subsequently secure contracts with the active MCOs in their service region.

Since private duty services do not qualify as Medicare-reimbursable, agencies applying to provide only private duty services cannot obtain the Medicare certification required to contract with TennCare MCOs for standard home health services.

6. Staffing, Training and Background Checks

Home care organizations must designate a qualified administrator responsible for daily operations. The licensure application requires the administrator to disclose any criminal convictions related to injury, harm, or financial mismanagement.

Agencies must implement policies ensuring all employees are informed of their legal obligations to report incidents of abuse or neglect. Staffing for specialized populations, such as pediatrics, requires documentation of adequately trained personnel and ongoing best-practice education.

7. Documentation, Policies and Records

Licensed agencies must submit Joint Annual Reports (JARs) to the Tennessee Department of Health. These reports serve as the state's primary data source for tracking home health utilization, patient volumes, and regional need.

Agencies must maintain comprehensive quality control and monitoring systems. This includes tracking patient readmissions to hospitals, managing transitions of care from acute facilities, and maintaining accreditation if utilizing deemed status.

8. Billing, Rates and Claims

Home health claims for Medicaid members are submitted directly to the member's assigned TennCare MCO, not to the state MMIS. Rates are negotiated between the provider and the MCO, subject to state fee schedule minimums where applicable.

Because Medicare certification is required, agencies must properly coordinate benefits. Medicare must be billed as the primary payer for dually eligible individuals receiving qualifying skilled intermittent care.

9. Approval Sequence and Timeline

The approval sequence begins with the Certificate of Need process, which can take several months. Once the CON is secured, the agency submits the HF-3506 licensure application and prepares for the initial state survey.

Agencies must request the survey 30 to 45 days before their target opening date. If the agency is unprepared on the survey date, rescheduling typically delays the process by 30 days or more. Final license issuance occurs 7 to 10 days after the Commission ratifies the survey results.

10. Common Denials and Survey Findings

Applications are frequently delayed or denied at the CON stage if the applicant cannot mathematically prove a need for services in the target county using TDH JAR data, or if they fail to secure letters of support from regional MCOs.

During the initial licensure survey, agencies often face delays if their policies and procedures are incomplete or if they admit patients prior to the official issuance of the license. Failure to disclose past disciplinary actions or federal exclusions on the application will result in immediate denial.

11. Key Contacts and Resources

The Tennessee Health Facilities Commission manages all CON and licensure inquiries. TennCare handles Medicaid enrollment and MCO oversight.

Prospective providers should regularly review the HFC website for updated application forms and the TDH website for the latest Joint Annual Report data used in CON applications.

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