Tennessee - Skilled Respite Service — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-09-10
TennCare CHOICES and Employment and Community First (ECF) CHOICES fund skilled respite care for members whose medical needs require a licensed practical nurse (LPN) or registered nurse (RN). Approval to bill for this service requires an agency to first hold a Home Care Organization license with a Home Health service designation from the Tennessee Health Facilities Commission, followed by credentialing with the specific Managed Care Organizations (MCOs) administering the waiver.
Standalone Medicaid enrollment does not guarantee patient volume or authorization, as Tennessee operates a fully managed long-term services and supports (MLTSS) system. Providers must secure active network contracts with BlueCare, UnitedHealthcare Community Plan, or Wellpoint to receive service authorizations and reimbursement for skilled respite delivery.
1. Service Definition and Scope
In Tennessee, skilled respite is defined as short-term nursing care provided to individuals unable to care for themselves, furnished on a short-term basis because of the absence or need for relief of those persons normally providing the care. It is delivered in the member's home or place of residence.
Because the care needs exceed what an unlicensed caregiver can provide, the service must be delivered by an RN or LPN operating under the scope of the Tennessee Nurse Practice Act. It is distinct from basic in-home respite, which is limited to 216 hours per year and delivered by unlicensed direct support professionals.
- Service Name: In-Home Respite Care (Skilled)
- Target Population: CHOICES Group 2 and Group 3 members, and ECF CHOICES members with complex medical needs
- Delivery Setting: The member's primary residence
- Staffing Requirement: Licensed Practical Nurse (LPN) or Registered Nurse (RN)
- Duration Limits: Typically authorized in 15-minute increments or per diem, subject to individual care plan caps
2. Regulatory and Oversight Agencies
Multiple state agencies govern the licensure, enrollment, and practice standards for skilled respite providers in Tennessee. The Health Facilities Commission handles facility and agency licensure, while TennCare oversees the Medicaid program.
Because TennCare operates under a managed care model, the actual day-to-day oversight, authorization, and quality monitoring are delegated to the contracted MCOs.
- Licensing Authority: Tennessee Health Facilities Commission (https://www.tn.gov/hfc.html)
- Medicaid Authority: Division of TennCare (https://www.tn.gov/tenncare.html)
- Nursing Regulation: Tennessee Board of Nursing (https://www.tn.gov/health/health-program-areas/health-professional-boards/nursing-board.html)
- Managed Care Plan: BlueCare Tennessee (https://bluecare.bcbst.com)
- Managed Care Plan: UnitedHealthcare Community Plan of Tennessee (https://www.uhccommunityplan.com/tn)
- Managed Care Plan: Wellpoint Tennessee (https://www.wellpoint.com/tn/medicaid)
3. Gatekeeping Prerequisites: Who Can Even Apply
Tennessee does not license a standalone 'skilled respite agency.' To provide this service, an entity must be licensed as a Home Care Organization (HCO) with a Home Health designation by the Health Facilities Commission. This requires a Certificate of Need (CON) or an exemption before a license application is even accepted.
Furthermore, because TennCare is a 100% managed care environment, holding a license and a Medicaid ID is insufficient to bill. Providers must pass MCO credentialing and secure a network contract, which is subject to network adequacy reviews by the MCOs.
- Prerequisite License: Home Care Organization (Home Health) license from the Health Facilities Commission
- Market Entry Gate: Certificate of Need (CON) approval or statutory exemption required prior to HCO licensure
- Network Contracting: Mandatory credentialing and contracting with at least one TennCare MCO (BlueCare, UHC, or Wellpoint)
- Operating History: No specific minimum operating history for initial licensure, but MCOs may require Medicare certification or accreditation for network entry
- Physical Location: Must maintain a physical administrative office within Tennessee or a border county
4. Licensure and Certification Requirements
Agencies must apply for a Home Care Organization license through the Health Facilities Commission. The process involves submitting a detailed application, policies and procedures, and passing an initial state survey.
The agency must designate a qualified administrator and a supervising registered nurse to oversee clinical operations and ensure compliance with state health regulations.
- Application Form: Application for License to Operate a Home Care Organization
- Initial Fee: Varies based on agency type, typically around $1,404 for Home Health
- Clinical Leadership: Must employ a Supervising Registered Nurse available during all operating hours
- Survey Requirement: Must pass an initial on-site health and safety survey by HFC surveyors
- Renewal Cycle: Licenses must be renewed annually with updated disclosures and fees
5. Medicaid Provider Enrollment
Once licensed, the agency must enroll as a Medicaid provider through the TennCare Provider Registration Portal. This step generates the Medicaid ID necessary for MCO credentialing.
Providers must complete the ACA-mandated screening processes, which for home health agencies typically falls under the moderate or high-risk category, requiring site visits and fingerprint-based background checks.
- Enrollment System: TennCare Provider Registration Portal (https://pdms.tenncare.tn.gov)
- Provider Type: Home Health Agency or HCBS Waiver Provider, depending on specific MCO billing configurations
- Application Fee: Subject to the federal CMS institutional provider application fee (approx. $709 for 2024) unless waived via Medicare enrollment
- Screening Risk Level: High risk for new home health agencies, requiring fingerprinting for owners with 5% or more interest
- Revalidation: Required every 3 to 5 years per CMS guidelines
6. Staffing, Training and Background Checks
Skilled respite must be delivered by nurses licensed by the Tennessee Board of Nursing or holding a multi-state compact license. The agency is responsible for verifying credentials prior to patient contact.
All staff must undergo rigorous background screening, including checks against the Tennessee Abuse Registry and national exclusion databases.
- Staff Qualifications: Active, unencumbered LPN or RN license valid in Tennessee
- Background Check: TBI/FBI fingerprint-based criminal history check required for all patient-facing staff
- Registry Checks: Mandatory screening against the Tennessee Department of Health Abuse Registry and National Sex Offender Registry
- OIG Exclusion: Monthly screening against the HHS-OIG List of Excluded Individuals/Entities (LEIE)
- Orientation: Must complete agency-specific orientation and TennCare-mandated HCBS settings training
7. Documentation, Policies and Records
Providers must maintain comprehensive clinical and administrative records. For skilled respite, this includes a physician's order, a nursing plan of care, and detailed shift notes.
Electronic Visit Verification (EVV) is mandatory for in-home personal care and respite services in Tennessee to comply with the 21st Century Cures Act.
- Care Plan: Services must be delivered strictly according to the MCO-approved Person-Centered Support Plan (PCSP)
- Clinical Records: Must include nursing assessments, medication administration records, and daily progress notes
- EVV Mandate: Must utilize the state-sponsored EVV system or an approved alternate vendor to log start and end times
- Retention Period: Records must be retained for a minimum of 5 years from the date of service or longer if required by MCO contract
- Incident Reporting: Critical incidents must be reported to the MCO and state within 24 hours of discovery
8. Billing, Rates and Claims
Billing for skilled respite is processed directly through the contracted MCOs, not the state MMIS. Providers must obtain prior authorization from the MCO before delivering services.
Rates are established by TennCare but administered by the MCOs. Claims must match the EVV data and the prior authorization exactly to avoid denial.
- Billing System: Claims are submitted to the respective MCO clearinghouses (Availity, etc.)
- Procedure Code: Typically billed using T1005 (Respite care services) with specific modifiers (e.g., TD for RN, TE for LPN) as defined by the MCO
- Prior Authorization: 100% of skilled respite hours require prior authorization from the member's MCO care coordinator
- Rate Structure: Reimbursed on a 15-minute unit basis; specific rates are published in the TennCare maximum reimbursement fee schedule
- Timely Filing: Generally 120 days from the date of service, but specific MCO contracts may dictate shorter windows
9. Approval Sequence and Timeline
The pathway to becoming a billable skilled respite provider is sequential and lengthy. It begins with corporate formation and CON approval (if applicable), followed by state licensure.
Only after the license is in hand can the agency enroll in TennCare, and only after TennCare enrollment can the agency apply for MCO network contracts.
- Step 1: Obtain Certificate of Need or exemption (3-6 months)
- Step 2: Submit Home Care Organization application to HFC (30-60 days for review)
- Step 3: Pass initial HFC licensure survey (scheduled within 60-90 days of application readiness)
- Step 4: Submit TennCare Provider Registration (30-60 days)
- Step 5: Complete MCO credentialing and contracting (90-120 days per MCO)
10. Common Denials and Survey Findings
Licensure applications are frequently delayed due to incomplete policies or failure to demonstrate compliance with the Home Care Organization rules during the initial survey.
On the billing side, claims are routinely denied if the EVV data does not perfectly match the billed units or if the service was provided outside the authorized date span.
- Licensure Denial: Failure to employ a qualified Supervising Registered Nurse at the time of application
- Survey Citation: Incomplete personnel files, specifically missing background checks or primary source license verification
- Credentialing Delay: Applying to MCOs before the TennCare Medicaid ID is fully active in the state system
- Claim Denial: EVV mismatch where the logged location or time does not align with the submitted claim
- Claim Denial: Exhaustion of authorized units on the member's Person-Centered Support Plan
11. Key Contacts and Resources
Providers should rely on the official state portals for the most current regulations, fee schedules, and provider manuals.
The MCO provider relations representatives are the primary point of contact for credentialing status and claims resolution.
- Health Facilities Commission: https://www.tn.gov/hfc.html
- TennCare Provider Registration: https://pdms.tenncare.tn.gov
- Tennessee Board of Nursing: https://www.tn.gov/health/health-program-areas/health-professional-boards/nursing-board.html
- BlueCare Provider Network: https://bluecare.bcbst.com/providers
- UnitedHealthcare Community Plan Providers: https://www.uhcprovider.com/en/health-plans-by-state/tennessee-health-plans/tn-comm-plan-home.html
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