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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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.


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