Tennessee - Respite Care Services — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-08-16
In Tennessee, Respite Care Services provide short-term, temporary relief for unpaid primary caregivers of individuals enrolled in Medicaid Home and Community-Based Services (HCBS) waivers, such as TennCare CHOICES and Employment and Community First (ECF) CHOICES. The service ensures the member continues to receive necessary supervision and support in their home or a licensed facility while the primary caregiver steps away.
The single biggest structural barrier to entry for this service in Tennessee is the mandatory Managed Care Organization (MCO) contracting requirement. Tennessee operates a 100% managed care Medicaid system; enrolling with the state Medicaid agency (TennCare) does not grant you the ability to bill for services. Providers must secure active contracts with one or more of the state's three designated MCOs, which frequently enforce closed networks or moratoria based on regional network adequacy, blocking new providers from participating even if they are fully licensed and state-enrolled.
1. Service Definition and Scope
Respite care in Tennessee is defined as short-term relief provided to an unpaid primary caregiver. It is authorized under the TennCare CHOICES program for older adults and adults with physical disabilities, and the ECF CHOICES program for individuals with intellectual and developmental disabilities.
The service can be delivered in the member's primary residence or in an approved facility-based setting. It is strictly intended for caregiver relief and cannot be used as substitute childcare, nor can it be provided during hours the primary caregiver is engaged in employment.
- In-Home Respite: Delivered in the member's home by staff from a licensed Personal Support Services Agency (PSSA) or Home Care Organization.
- Facility-Based Respite: Delivered outside the home in licensed settings such as an Adult Day Care center or an Assisted Care Living Facility (ACLF).
- Duration Limits: Authorized in 15-minute increments or per diem rates, capped at a specific number of hours or days per calendar year as dictated by the member's Person-Centered Support Plan (PCSP).
- Excluded Providers: The service cannot be provided by the member's spouse, the primary caregiver themselves, or anyone living in the same residence unless specifically approved under a consumer-directed model.
- Target Populations: Elderly adults, adults with physical disabilities, and individuals with intellectual or developmental disabilities enrolled in specific TennCare waivers.
2. Regulatory and Oversight Agencies
Oversight of respite care in Tennessee is divided among the state Medicaid agency, the licensing commission, and the managed care plans. Providers must maintain compliance with all of these entities simultaneously.
Because Tennessee utilizes a managed care model, the day-to-day authorization, quality oversight, and reimbursement of respite services are handled directly by the MCOs rather than the state.
- Division of TennCare: The state Medicaid authority responsible for overarching waiver policy and the Provider Data Management System (PDMS) enrollment portal (https://www.tn.gov/tenncare.html).
- Health Facilities Commission (HFC): The state body that conducts surveys and issues the required facility or agency licenses, such as the PSSA license (https://www.tn.gov/hfc.html).
- Department of Disability and Aging (DDA) / DIDD: Credentials providers for ECF CHOICES and legacy IDD waivers before MCO contracting can occur (https://www.tn.gov/disability-and-aging.html).
- Wellpoint Tennessee: One of the three MCOs managing TennCare LTSS benefits (https://provider.wellpoint.com/tennessee-provider/home).
- BlueCare Tennessee: One of the three MCOs managing TennCare LTSS benefits (https://bluecare.bcbst.com/providers).
- UnitedHealthcare Community Plan of Tennessee: One of the three MCOs managing TennCare LTSS benefits (https://www.uhcprovider.com/en/health-plans-by-state/tennessee-health-plans/tn-comm-plan-home.html).
3. Gatekeeping Prerequisites: Who Can Even Apply
Tennessee does not allow providers to simply enroll in Medicaid and begin billing for respite care. The state's managed care framework imposes strict structural preconditions that must be cleared sequentially.
If a provider cannot secure an MCO contract due to network adequacy limits, their state license and TennCare enrollment are effectively useless for Medicaid billing.
- MCO Network Adequacy (Closed Networks): Providers must be accepted into the networks of Wellpoint, BlueCare, or UHC. MCOs frequently enact moratoria on new HCBS providers if they determine regional capacity is already met.
- HFC Licensure Prerequisite: An active license from the Health Facilities Commission (e.g., PSSA or Home Care Organization) must be obtained before a TennCare Medicaid enrollment application will be accepted.
- DIDD Credentialing: For providers wishing to serve the ECF CHOICES population, successful completion of the DIDD Provider Credentialing process is a mandatory prerequisite to MCO contracting.
- Type 2 NPI: The applicant must possess an active Type 2 National Provider Identifier (NPI) registered with an appropriate HCBS taxonomy code.
- Business Registration: The agency must be registered and in active good standing with the Tennessee Secretary of State.
4. Licensure and Certification Requirements
Tennessee does not issue a distinct "Respite Care License." Instead, agencies must hold a license appropriate to the setting where the service is delivered, issued by the Health Facilities Commission (HFC).
For in-home respite, the most common pathway is obtaining a Personal Support Services Agency (PSSA) license, which covers non-medical assistance and caregiver relief.
- Personal Support Services Agency (PSSA) License: The standard HFC license required for agencies providing non-medical in-home respite care.
- Home Care Organization (HCO) License: Required if the agency intends to provide skilled nursing or home health services in addition to basic respite.
- Facility Licenses: If providing respite outside the home, the provider must hold an Adult Day Care or Assisted Care Living Facility (ACLF) license.
- Initial State Survey: Licensure requires passing an initial on-site health, safety, and administrative survey conducted by HFC inspectors.
- Application Fees: Statutory application fees apply based on the facility type and must be submitted to the HFC along with the initial application packet.
5. Medicaid Provider Enrollment
Once licensed by the HFC, providers must enroll with the Division of TennCare to obtain a Medicaid Provider ID. This is done entirely online through the Provider Data Management System (PDMS).
Enrollment with TennCare establishes the provider's eligibility to participate in Medicaid but does not guarantee patient referrals or payment, which require the subsequent MCO contracting step.
- TennCare Provider Registration Portal: The centralized web-based system for submitting enrollment applications (https://www.tn.gov/tenncare/providers/provider-registration.html).
- IRS Documentation: Applications must include a W-9 and an IRS 147C letter; the legal business name must match these documents exactly.
- Proof of Licensure: A copy of the active HFC license (e.g., PSSA) must be uploaded with the enrollment application.
- Liability Insurance: Providers must submit proof of General Liability (minimum $500,000) and Automobile Liability (minimum $1,500,000 for ECF CHOICES).
- Medicaid ID Assignment: Upon approval, TennCare issues a Medicaid Provider ID, which is required to initiate the credentialing process with the MCOs.
- Revalidation: Providers must revalidate their TennCare enrollment every 5 years pursuant to federal regulations (42 CFR § 455.414).
6. Staffing, Training and Background Checks
Direct Support Professionals (DSPs) and respite workers must meet strict background and training standards outlined in Tenn. Comp. R. & Regs. 1200-13-01-.05 and DIDD provider manuals.
Agencies are responsible for maintaining continuous proof of clearance and training for all staff prior to any direct patient contact.
- Tennessee Abuse Registry: Mandatory clearance to ensure the worker's name does not appear on the state abuse registry.
- National Sex Offender Registry: Mandatory clearance required prior to hiring and verified annually.
- OIG Exclusion List: Verification that staff have not been excluded from participation in Medicare, Medicaid, or any Federal health care programs.
- Criminal Background Check: A TBI/FBI fingerprint-based criminal history check is required for all direct care staff.
- Basic Certifications: Mandatory current certification in CPR and First Aid before delivering any services.
- Program-Specific Training: Completion of DIDD or MCO-mandated training modules covering person-centered planning, incident reporting, and HCBS client rights.
7. Documentation, Policies and Records
Providers must maintain comprehensive records to satisfy HFC licensure surveyors, DIDD quality assurance teams, and MCO auditors. Missing documentation can lead to immediate claim recoupments.
Tennessee strictly enforces Electronic Visit Verification (EVV) for all in-home HCBS, including respite care, to combat fraud and ensure service delivery.
- Electronic Visit Verification (EVV): Mandatory use of the state-approved or MCO-integrated EVV system to log exact start and end times, location, and tasks for in-home respite shifts.
- Service Agreements: Signed documents detailing the authorized hours, specific tasks, and emergency protocols for each member.
- Incident Reporting Policy: Written protocols for reporting critical incidents to DIDD and the member's MCO within 24 hours of occurrence.
- Personnel Files: Must contain primary source proof of background checks, CPR/First Aid certifications, driver's licenses, and annual training logs.
- Caregiver Relief Logs: Documentation proving the primary caregiver was actually relieved and that respite was not used as substitute childcare.
8. Billing, Rates and Claims
Because TennCare is a managed care system, providers do not bill the state directly. Claims are submitted to the member's assigned MCO (Wellpoint, BlueCare, or UHC) according to their specific fee schedules.
Reimbursement rates are negotiated with the MCOs, though they generally follow a state-established minimum fee schedule for HCBS waivers.
- MCO Claims Submission: Claims must be routed through the respective MCO's provider portal or a designated clearinghouse (e.g., Availity).
- Billing Codes: Typically billed using HCPCS codes such as S5150 (unskilled in-home respite, per 15 minutes) or S5151 (per diem), depending on the authorization.
- Prior Authorization: Respite services must be explicitly authorized in the member's Person-Centered Support Plan (PCSP) by the MCO care coordinator before billing.
- EVV Integration: In-home respite claims will be automatically denied by the MCO if they are not matched to a compliant, verified EVV record.
- Timely Filing Limits: Dictated by the specific MCO contract, often requiring claim submission within 120 days of the date of service.
9. Approval Sequence and Timeline
Becoming a fully billable respite provider in Tennessee is a multi-stage process that typically takes 6 to 12 months. The sequence must be followed strictly, as each step requires the approval of the previous one.
Attempting to apply for TennCare enrollment without an HFC license, or applying to an MCO without a TennCare ID, will result in immediate rejection.
- Step 1: Business Formation and NPI: Register with the TN Secretary of State, obtain an EIN, and secure a Type 2 NPI (1-2 weeks).
- Step 2: HFC Licensure: Apply for a PSSA or HCO license and pass the initial state health and safety survey (3-6 months).
- Step 3: TennCare Enrollment: Submit the application through the Provider Registration portal to obtain a Medicaid ID (30-60 days).
- Step 4: DIDD Credentialing (If applicable): Complete the DIDD credentialing process for ECF CHOICES participation (60-90 days).
- Step 5: MCO Contracting: Apply to join the networks of Wellpoint, BlueCare, and UHC, subject to their network adequacy reviews (90-120 days).
10. Common Denials and Survey Findings
Applications and claims are frequently delayed or denied due to administrative errors or a failure to understand Tennessee's managed care landscape.
During HFC licensure surveys, agencies are most often cited for incomplete personnel files or failing to follow their own written policies.
- Closed MCO Networks: The most common barrier is applying to an MCO that is not currently accepting new respite providers in a specific region due to adequate capacity.
- Name Mismatches: TennCare enrollment applications are routinely rejected if the legal business name does not perfectly match the IRS 147C letter and W-9.
- EVV Non-Compliance: Claims denied by MCOs because the EVV data does not match the billed hours, lacks GPS verification, or was manually entered without justification.
- Lapsed Background Checks: HFC survey citations for allowing staff to provide care before TBI fingerprint results are fully cleared and documented.
- Inadequate Insurance: Application denial for failure to maintain the required $1,500,000 automobile liability or $500,000 general liability minimums.
11. Key Contacts and Resources
Providers should bookmark these official state and MCO resources for the most current manuals, fee schedules, and portal access.
Always refer to the specific MCO provider manuals for billing rules, as they supersede general state guidance in a managed care environment.
- TennCare Provider Registration: https://www.tn.gov/tenncare/providers/provider-registration.html
- Health Facilities Commission (Licensure): https://www.tn.gov/hfc/division-of-licensure-and-regulation.html
- Department of Disability and Aging (Provider Info): https://www.tn.gov/disability-and-aging/provider-information.html
- Wellpoint Tennessee Providers: https://provider.wellpoint.com/tennessee-provider/home
- BlueCare Tennessee Providers: https://bluecare.bcbst.com/providers
- UnitedHealthcare Community Plan TN: https://www.uhcprovider.com/en/health-plans-by-state/tennessee-health-plans/tn-comm-plan-home.html
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