Tennessee - Transitional Assistance Services — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-09-10
The Division of TennCare funds Community Transition Services through the CHOICES and Employment and Community First (ECF) CHOICES managed care programs to cover one-time household set-up expenses when a member moves from a nursing facility or ICF/IID to a community setting. The service caps lifetime expenditures per member and strictly limits allowable purchases to essential furniture, utility deposits, and moving expenses required to establish a basic household.
Prospective providers cannot simply enroll in Medicaid and begin billing; they must first secure a network contract with one or more of TennCare's Managed Care Organizations (MCOs) or pass the Department of Intellectual and Developmental Disabilities (DIDD) credentialing process for ECF CHOICES. Because this service primarily involves the administrative purchasing and coordination of goods rather than direct clinical care, Tennessee does not issue a distinct facility or healthcare license for it, relying instead on MCO credentialing and DIDD provider agreements to regulate operators.
1. Service Definition and Scope
In Tennessee, Transitional Assistance Services are officially designated as Community Transition Services under the CHOICES and ECF CHOICES programs. This service provides financial assistance and coordination for individuals transitioning from institutional care (such as a nursing facility) to a community-based residence where they are directly responsible for their own living expenses.
The scope is strictly limited to non-recurring set-up expenses. It does not cover ongoing monthly rent, mortgage payments, food, or recreational items, and all purchases must be pre-approved in the member's Person-Centered Support Plan (PCSP).
- Covered Expense: Security deposits and first month's rent required to obtain a lease
- Covered Expense: Essential household furnishings including a bed, dining table, and chairs
- Covered Expense: Set-up fees or deposits for utility access (telephone, electricity, heating, water)
- Covered Expense: Services necessary for the individual's health and safety, such as pest eradication or one-time cleaning prior to occupancy
- Excluded Expense: Monthly rental or mortgage expenses, food, regular utility charges, and household appliances or items intended for diversion/recreation
- Service Cap: Expenditures are typically capped at a specific lifetime maximum per member (historically around $3,000, subject to current waiver limits)
2. Regulatory and Oversight Agencies
The Division of TennCare serves as the single state Medicaid agency and holds ultimate authority over the CHOICES and ECF CHOICES programs. TennCare delegates day-to-day operational oversight, provider credentialing, and quality monitoring to the Department of Intellectual and Developmental Disabilities (DIDD) for specific waivers, and to the contracted MCOs for the CHOICES program.
Providers must interact with both state agencies and the managed care entities to maintain compliance. The MCOs conduct regular audits of transition service claims to ensure all billed items match the approved PCSP and are supported by actual retail receipts.
- Division of TennCare: Administers the Medicaid program and sets statewide HCBS policy (https://www.tn.gov/tenncare.html)
- Department of Intellectual and Developmental Disabilities (DIDD): Serves as the credentialing authority for 1915(c) waivers and ECF CHOICES (https://www.tn.gov/didd.html)
- BlueCare Tennessee: Managed Care Organization administering CHOICES benefits (https://bluecare.bcbst.com)
- UnitedHealthcare Community Plan: Managed Care Organization administering CHOICES benefits (https://www.uhccommunityplan.com/tn)
- Wellpoint Tennessee: Managed Care Organization administering CHOICES benefits (https://www.wellpoint.com/tn/medicaid)
3. Gatekeeping Prerequisites: Who Can Even Apply
Tennessee utilizes a fully managed care delivery system for its HCBS programs, meaning provider enrollment is entirely dependent on MCO network needs. A provider cannot enroll in the TennCare Medicaid Management Information System (MMIS) for CHOICES without first securing a contract with BlueCare, UnitedHealthcare, or Wellpoint.
For ECF CHOICES, DIDD acts as the credentialing authority. Providers must submit a New Provider Credentialing Application to the DIDD Regional Provider Development Unit and prove compliance with the HCBS Settings Rule before they are permitted to sign a provider agreement.
- MCO Network Adequacy: MCOs maintain closed networks and will only issue contracts for Community Transition Services if they identify a regional shortage of providers
- DIDD Credentialing: ECF CHOICES applicants must pass the DIDD Regional Provider Development Unit's credentialing review before Medicaid enrollment
- HCBS Settings Rule Compliance: Applicants must complete an agency self-assessment proving their policies comport with the Settings Rule prior to approval
- Existing Provider Preference: MCOs heavily favor contracting this service out to existing, established HCBS providers or Area Agencies on Aging and Disability (AAADs) rather than standalone startup entities
- Business Registration: Must be registered and in good standing with the Tennessee Secretary of State
4. Licensure and Certification Requirements
The Tennessee Department of Health does not issue a specific facility or healthcare license for Community Transition Services, as it is an administrative and purchasing function rather than direct medical or personal care. Providers operate under their business license and their credentialed status with DIDD or the MCOs.
If an agency also provides direct care services (such as personal care or home health) alongside transition services, they must hold the appropriate Personal Support Services Agency (PSSA) or Home Care Organization license. Standalone transition service providers only need to meet the waiver's provider qualifications.
- State Licensure: No specific Department of Health license is required for standalone Community Transition Services
- DIDD Certification: Must maintain an active Provider Agreement with DIDD if serving ECF CHOICES members
- Local Business License: Must hold a valid city or county business license in the agency's primary operating location
- Insurance Requirements: Must maintain general liability and worker's compensation insurance as dictated by the MCO contracts
- Financial Solvency: Must demonstrate financial capacity to front the costs of transition purchases before receiving Medicaid reimbursement
5. Medicaid Provider Enrollment
Once credentialed by DIDD or approved for a contract by an MCO, the agency must enroll in Medicaid through the TennCare Provider Registration (TPR) portal. TennCare requires a unique National Provider Identifier (NPI) for each service type enrolled.
The enrollment process requires the submission of ownership disclosures, background check attestations, and the signed MCO or DIDD agreements. Providers cannot bill for any transition services until the TPR portal issues an active Medicaid ID.
- Enrollment Portal: TennCare Provider Registration (TPR) system (https://pdms.tenncare.tn.gov/Provider/Home/Home.aspx)
- NPI Requirement: Must obtain a Type 2 Organizational NPI specific to the HCBS services being provided
- Application Fee: Subject to the federal Medicaid institutional provider application fee unless waived by Medicare enrollment
- Ownership Disclosure: Must complete full CMS ownership and control interest disclosure forms
- Revalidation: Providers must revalidate their TennCare enrollment every five years
6. Staffing, Training and Background Checks
Staff coordinating Community Transition Services must meet basic educational and background requirements set by DIDD and the MCOs. Because staff may interact with vulnerable adults during the transition process, strict background screening is mandatory.
Agencies must maintain a roster of all employees involved in transition coordination and ensure they complete state-mandated training on abuse, neglect, and exploitation reporting.
- Background Checks: All staff must clear a Tennessee Bureau of Investigation (TBI) fingerprint-based background check
- Registry Checks: Mandatory screening against the Tennessee Department of Health Abuse Registry and the National Sex Offender Registry
- Staff Qualifications: Coordinators typically must hold a high school diploma or GED and have experience in social services or case management
- Mandatory Training: Completion of DIDD or MCO-approved training on the HCBS Settings Rule and person-centered practices
- Incident Reporting: Staff must be trained on Tennessee's mandatory reporting laws for abuse and neglect
7. Documentation, Policies and Records
Documentation is the most critical compliance element for Community Transition Services. Because the service reimburses for physical goods and deposits, providers must maintain a flawless paper trail of retail receipts, lease agreements, and utility invoices.
Every purchase must map directly back to an authorized line item in the member's Person-Centered Support Plan. MCOs will recoup funds if a provider cannot produce the original receipt for a billed item.
- Receipt Retention: Must keep original, itemized retail receipts for every piece of furniture, household good, or deposit purchased
- PCSP Alignment: All expenditures must be explicitly authorized in the member's approved Person-Centered Support Plan prior to purchase
- Delivery Verification: Must maintain signed delivery logs proving the member received the purchased items at their new community residence
- Settings Rule Policy: Must maintain agency policies demonstrating compliance with the federal HCBS Settings Rule
- Record Lifespan: All financial and service records must be retained for a minimum of five years from the date of service
8. Billing, Rates and Claims
Community Transition Services are billed directly to the member's assigned MCO (BlueCare, UHC, or Wellpoint) rather than to the state. Providers must use the specific HCPCS codes and modifiers outlined in their MCO contract.
Reimbursement is typically handled on a cost-reimbursement basis up to the authorized limit. Providers front the money for the deposits and furnishings, then submit the claim with attached receipts to the MCO for repayment.
- Billing System: Claims are submitted through the respective MCO's provider portal (e.g., Availity for Wellpoint/BlueCare)
- Reimbursement Model: Cost-reimbursement based on actual receipt values, not a flat fee-for-service rate
- Prior Authorization: Every transition service claim requires an active Prior Authorization (PA) number generated by the MCO care coordinator
- Claim Attachments: Invoices and receipts must often be uploaded as attachments to the electronic claim to prove the expenditure
- Timely Filing: Claims must generally be submitted within 120 days of the date of service, though MCO contracts may specify shorter windows
9. Approval Sequence and Timeline
The pathway to becoming a billing provider requires navigating MCO network management and state enrollment in a specific order. Attempting to enroll in TennCare before securing an MCO contract or DIDD credentialing will result in immediate rejection.
The entire process from initial MCO outreach to the first paid claim typically takes 4 to 8 months, depending heavily on how quickly the MCOs are processing new network additions.
- Step 1: Submit a letter of intent or network participation request to BlueCare, UHC, and Wellpoint
- Step 2: Complete the DIDD New Provider Credentialing Application (if targeting ECF CHOICES)
- Step 3: Receive network approval or DIDD credentialing approval
- Step 4: Submit the Medicaid enrollment application through the TennCare Provider Registration (TPR) portal
- Step 5: Execute the final MCO contracts and complete MCO-specific portal training
10. Common Denials and Survey Findings
Audits of Community Transition Services frequently result in recoupments due to poor financial documentation. Providers who treat the service cap as a flat grant rather than a strict cost-reimbursement limit will fail MCO audits.
State and MCO reviewers also look closely at the timing of purchases. Items bought before the transition plan is officially approved, or items that do not directly support community integration, are routinely denied.
- Missing Receipts: Recoupment of funds due to the provider's inability to produce itemized retail receipts for billed goods
- Unauthorized Purchases: Billing for items (like televisions or luxury goods) that were not explicitly approved in the PCSP
- Date Discrepancies: Purchasing items before the official authorization date or after the member's transition window has closed
- Settings Rule Violations: Failing to ensure the new residence meets HCBS Settings Rule requirements (e.g., member does not have a lease)
- Duplicate Billing: Attempting to bill for deposits that were already covered by another community grant or housing program
11. Key Contacts and Resources
Providers must maintain active communication with TennCare, DIDD, and the three managed care organizations. The state's official portals and provider manuals are the primary sources of truth for policy updates.
Prospective providers should regularly check the TennCare and DIDD websites for announcements regarding open enrollment windows or changes to the HCBS Settings Rule compliance process.
- Division of TennCare: https://www.tn.gov/tenncare.html
- Department of Intellectual and Developmental Disabilities (DIDD): https://www.tn.gov/didd.html
- TennCare Provider Registration (TPR): https://pdms.tenncare.tn.gov/Provider/Home/Home.aspx
- BlueCare Tennessee Provider Network: https://bluecare.bcbst.com/providers
- UnitedHealthcare Community Plan of Tennessee: https://www.uhcprovider.com/en/health-plans-by-state/tennessee-health-plans/tn-comm-plan-home.html
- Wellpoint Tennessee Providers: https://provider.wellpoint.com/tennessee-provider/home
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