Tennessee - Personal Emergency Response System — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-08-16

In Tennessee, Personal Emergency Response System (PERS) services provide 24-hour electronic monitoring and call-for-help devices to vulnerable adults living alone. This service is primarily funded through the TennCare CHOICES program for seniors and adults with physical disabilities, as well as the Employment and Community First (ECF) CHOICES program for individuals with intellectual and developmental disabilities.

The single biggest structural barrier to entry for a new PERS provider in Tennessee is the state's 100% managed care delivery system. Enrolling as a Medicaid provider with the state is merely a preliminary step; you cannot bill or receive clients unless you successfully secure network contracts with Tennessee's Managed Care Organizations (MCOs), which frequently utilize closed networks or moratoria for ancillary HCBS services based on regional network adequacy.

1. Service Definition and Scope

Under TennCare guidelines, PERS is defined as an electronic device that enables individuals at high risk of institutionalization to secure help in an emergency. The system connects to a 24-hour response center and includes a portable help button worn by the member.

The service scope encompasses the initial installation of the equipment, comprehensive instruction to the member on its use, monthly monitoring fees, and ongoing maintenance or replacement of malfunctioning units. It is not considered a habilitative service and is strictly limited to members who live alone or are alone for significant parts of the day.

• Target Population: Adults 21+ with physical disabilities and seniors 65+ enrolled in [CHOICES](https://www.tn.gov/tenncare/long-term-services-supports/choices.html).
• Covered Components: Initial installation, monthly monitoring, and equipment maintenance.
• Exclusions: Cannot be billed for members residing in 24-hour residential care settings or nursing facilities.
• Response Requirement: Must guarantee 24/7/365 response center availability to dispatch emergency services or designated responders.
• Equipment Standards: Devices must be tested monthly and replaced within 24 hours of a reported malfunction.

2. Regulatory and Oversight Agencies

The Division of TennCare is the single state Medicaid agency responsible for overall program administration and provider enrollment. However, day-to-day HCBS waiver operations and provider credentialing are heavily supported by the Department of Disability and Aging (DDA).

Because Tennessee operates under a managed care model, the actual oversight, authorization, and payment of PERS services are delegated to three Managed Care Organizations (MCOs). Providers must interact directly with these MCOs for credentialing, contracting, and compliance audits.

• State Medicaid Agency: Division of TennCare (https://www.tn.gov/tenncare.html) oversees the Medicaid Management Information System (MMIS) and state enrollment.
• HCBS Operating Agency: Department of Disability and Aging (DDA) (https://www.tn.gov/disability-and-aging.html) manages HCBS credentialing and quality assurance.
• Managed Care Organization: BlueCare Tennessee (https://bluecare.bcbst.com) administers CHOICES and ECF CHOICES benefits regionally.
• Managed Care Organization: UnitedHealthcare Community Plan of Tennessee (https://www.uhcprovider.com/en/health-plans-by-state/tennessee-health-plans/tn-comm-plan-home.html) contracts with HCBS providers for waiver services.
• Managed Care Organization: Wellpoint Tennessee (https://provider.wellpoint.com/tennessee-provider/home) serves as the third MCO managing LTSS and PERS authorizations.

3. Gatekeeping Prerequisites: Who Can Even Apply

Tennessee does not require a Certificate of Need (CON) for PERS providers, nor is there a specific state-issued medical facility license required prior to application. However, the absolute structural precondition blocking applicants is MCO Network Adequacy and Contracting.

If the three TennCare MCOs determine their current network of PERS providers is adequate for a specific region, they will enact a closed network or moratorium, outright rejecting new credentialing applications. A provider must verify open network status or secure a letter of need from an MCO before investing in the TennCare enrollment process.

• MCO Network Status: The primary gatekeeper; applicants must confirm that BlueCare, UHC, or Wellpoint are actively accepting new PERS providers in their target counties.
• Business Establishment: Must possess a valid Federal Employer Identification Number (EIN) and a registered National Provider Identifier (NPI) for the agency.
• Local Business License: Must hold a standard city or county business license in Tennessee, as no specific state health license exists for this service.
• Physical Location: Must maintain a verifiable business address to facilitate equipment deployment and maintenance.

4. Licensure and Certification Requirements

The Tennessee Department of Health does not issue a distinct Personal Emergency Response System License. Instead, PERS is treated as an unlicensed HCBS service that requires rigorous credentialing rather than traditional facility licensure.

To meet the certification standards outlined in the [MLTSS PROVIDER ENROLLMENT APPLICATION](https://provider.amerigroup.com/docs/gpp/TN_CAID_DIDDapplication.pdf?v=202310242127), providers must submit proof of extensive commercial insurance and pass the DDA/MCO credentialing review.

• State Licensure Exemption: Explicitly exempt from Tennessee Department of Health facility licensure; operates under general corporate/business registration.
• General Liability Insurance: Minimum coverage of $500,000 required by MCOs for HCBS enrollment.
• Automobile Liability Insurance: Minimum coverage of $1,500,000 required for staff deploying or maintaining equipment.
• Worker's Compensation: Minimum coverage of $750,000 required for agency employees.
• IRS Verification: Must provide an IRS Form 147C or SS-4 confirming the agency's EIN.

5. Medicaid Provider Enrollment

Before approaching the MCOs, an agency must enroll at the state level through the TennCare Provider Registration portal to obtain a Medicaid ID. This process verifies basic corporate integrity and assigns the provider to the state's MMIS.

As noted in [Tennessee Medicaid Provider Enrollment | Done For You](https://contractingproviders.com/services/medicaid-enrollment-assistance/tennessee), state enrollment grants billing rights with TennCare, but credentialing with the managed care plans is the practical requirement for serving patients.

• Enrollment Portal: Applications must be submitted through the TennCare Provider Registration portal (https://pdms.tenncare.tn.gov).
• Application Fee: Subject to the ACA institutional provider application fee unless waived by Medicare enrollment.
• Taxonomy Code: Must enroll using the appropriate HCBS taxonomy for Durable Medical Equipment or specific PERS taxonomy.
• Revalidation: Providers must revalidate their TennCare enrollment every 3 to 5 years to maintain active status.
• Electronic Funds Transfer: Must submit a voided check and EFT authorization for state-level registry, though MCOs will require separate EFT setups.

6. Staffing, Training and Background Checks

While PERS does not require licensed medical staff, the personnel installing the devices and the call center staff responding to alerts must meet strict state background check requirements.

According to [Tenn. Comp. R. & Regs. 1200-13-01-.05 - TENNCARE CHOICES PROGRAM](https://www.law.cornell.edu/regulations/tennessee/Tenn-Comp-R-Regs-1200-13-01-.05), all workers interacting with members must be screened against multiple registries to ensure member safety.

• Abuse Registry Check: Verification that no staff member's name appears on the Tennessee Department of Health Abuse Registry.
• Sex Offender Registry: Mandatory screening against both State and National Sexual Offender Registries.
• OIG Exclusion List: Verification that no staff or owners are excluded from Medicare, Medicaid, or any Federal health care programs.
• Call Center Staffing: Must maintain 24/7/365 awake staff at the response center capable of dispatching emergency services.
• Installer Training: Field staff must be trained on device installation, testing protocols, and instructing seniors on proper usage.

7. Documentation, Policies and Records

PERS providers must maintain comprehensive documentation to survive MCO audits and DDA quality reviews. This includes proof of service delivery, equipment maintenance, and emergency response logs.

Failure to maintain signed installation receipts or monthly testing logs is a primary cause for MCO clawbacks of monthly monitoring payments.

• Installation Receipts: Must obtain the member's or authorized representative's signature verifying receipt and instruction of the PERS unit.
• Responder Lists: Must maintain and update a list of the member's designated emergency responders at least twice a year.
• Testing Logs: Documentation of successful monthly testing of the PERS device for every active member.
• Maintenance Records: Logs proving that malfunctioning devices were replaced within the required 24-hour window.
• Incident Reporting: Policies aligning with DDA's Reportable Event Management system for documenting falls or emergency dispatches.

8. Billing, Rates and Claims

In Tennessee, PERS providers do not bill the state MMIS directly for services rendered. Instead, all claims are submitted to the specific MCO (BlueCare, UHC, or Wellpoint) that authorized the member's care plan.

Services are typically billed using standard HCPCS codes for installation and monthly monitoring. Prior authorization from the MCO care coordinator is an absolute requirement before any equipment is deployed.

• HCPCS Code S5160: Standard billing code for the initial installation and setup of the emergency response system.
• HCPCS Code S5161: Standard billing code for the ongoing monthly monitoring fee.
• Prior Authorization: No claims will be paid without an approved Service Agreement and prior authorization number from the MCO.
• Clearinghouse Submission: Claims are submitted via EDI (837P) or the respective MCO's secure provider portal.
• Timely Filing: Claims must typically be submitted within 120 days of the date of service, depending on the specific MCO contract terms.

9. Approval Sequence and Timeline

Becoming a fully active PERS provider in Tennessee is a multi-stage process that requires patience. Providers must sequence their applications correctly, as MCOs will not accept credentialing packets without a valid TennCare Medicaid ID.

The entire pipeline from business formation to signing the final MCO contract can take anywhere from 4 to 8 months, heavily dependent on MCO network need and application accuracy.

• Step 1 Business Setup: Obtain EIN, NPI, local business license, and required commercial insurance policies (Weeks 1-4).
• Step 2 TennCare Enrollment: Submit application via the TennCare Provider Registration portal to obtain a Medicaid ID (Weeks 4-12).
• Step 3 MCO Credentialing: Submit the MLTSS Provider Enrollment Application to BlueCare, UHC, and Wellpoint (Weeks 12-20).
• Step 4 MCO Contracting: Negotiate and sign the final network participation agreements with the MCOs (Weeks 20-24).
• Step 5 Care Coordinator Outreach: Market services to MCO care coordinators to begin receiving member referrals.

10. Common Denials and Survey Findings

The most frequent barrier to entry is an outright denial at the MCO credentialing stage due to a lack of network need. If the MCO already has enough PERS providers, they will not accept new applications regardless of the provider's qualifications.

For active providers, audit findings and payment clawbacks typically result from administrative negligence rather than equipment failure.

• Closed Network Denials: MCOs rejecting applications because their PERS provider network is currently full or under a moratorium.
• Insurance Deficiencies: Applications rejected because the provider failed to secure the specific $1.5M auto or $750k worker's comp minimums.
• Missing Signatures: Audit failures due to missing member signatures on the initial equipment receipt and training form.
• Lapsed Background Checks: Survey citations for failing to run annual OIG or abuse registry checks on call center or field staff.
• Unreported Malfunctions: Citations for failing to replace a broken PERS unit within the mandated 24-hour timeframe.

11. Key Contacts and Resources

Prospective providers should bookmark the primary state and MCO portals required for enrollment and compliance.

Utilizing the official [Provider Enrollment Frequently Asked Questions (FAQs)](https://www.tn.gov/tenncare/providers/provider-registration/provider-enrollment-frequently-asked-questions--faqs-.html) and DDA resources will ensure applications meet current state standards.

• TennCare Provider Registration: Official portal for state Medicaid enrollment (https://pdms.tenncare.tn.gov).
• DDA Provider Information: Resources for HCBS credentialing and compliance (https://www.tn.gov/disability-and-aging/provider-information.html).
• BlueCare Provider Network: Contracting and credentialing portal for BlueCare Tennessee (https://bluecare.bcbst.com/providers).
• UHC Community Plan Network: Provider resources for UnitedHealthcare Tennessee (https://www.uhcprovider.com/en/health-plans-by-state/tennessee-health-plans/tn-comm-plan-home.html).
• Wellpoint Provider Network: Contracting portal for Wellpoint Tennessee (https://provider.wellpoint.com/tennessee-provider/home).

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