Tennessee's home health care industry operates under a recently restructured regulatory framework with the new Health Facilities Commission overseeing licensure and certification. Agencies must navigate the state's comprehensive TennCare CHOICES program, adapt to enhanced EVV compliance requirements, and develop workforce strategies in a state with federal minimum wage and growing demand for home and community-based services.

Home Health Agency Requirements in Tennessee

In 2022, the Tennessee General Assembly passed Public Chapter 1119, creating the Tennessee Health Facilities Commission (HFC) as a new independent state agency. The Commission combines the former Health Services and Development Agency (HSDA) and the Department of Health's Office of Health Care Facilities (OHCF).

Health Facilities Commission Overview

The HFC encompasses multiple regulatory functions:

  • Certificate of Need (CON) Program
  • Licensure of health facilities
  • Nursing Home Civil Penalty Reinvestment Program
  • Clinical Laboratory Improvement Amendments (CLIA) Program
  • Trauma Care Advisory Council
  • Investigations of health facilities for state and federal compliance

November 2025 Relocation

As of November 24, 2025, the HFC consolidated into a single location:

  • Address: Andrew Jackson State Building, 502 Deaderick Street, 9th Floor, Nashville, TN 37243

Home Health Services Definition

Under HSDA Rule 0720-9-.01, home health services include:

  • Skilled nursing care
  • Physical, occupational, or speech therapy
  • Medical social services
  • Home health aide services
  • Provision of certain medical supplies and appliances

Licensure Applications

The HFC website provides applications for Initial licensure, Change of Ownership (CHOW), Renewal, Branch Office, Plans Review, and Trauma Licensure. Visit tn.gov/hfc for current forms and procedures.

Certified Nursing Assistant (CNA) Certification

Tennessee's CNA certification is administered through the Health Facilities Commission's Nurse Aide program. All candidates must complete a Tennessee Department of Health-approved Nurse Aide Training and Competency Evaluation Program (NATCEP).

Training Requirements

State-approved CNA training programs must provide:

  • Minimum 75 hours of instruction
  • At least 16 clinical hours for hands-on experience
  • Compliance with federal OBRA requirements and state Rule 1200-08-06

Programs are offered through high schools, community colleges (including Tennessee Colleges of Applied Technology - TCATs), vocational centers, and long-term care facilities.

Instructor Requirements

CNA courses must be taught by a Registered Nurse with:

  • At least two years of nursing experience
  • One year of long-term care (nursing home) experience

If the instructor lacks one year of long-term care experience, the program must contract with a coordinator from a local long-term care facility.

Additional Requirements

  • Criminal background check before patient contact
  • Physical examination clearance
  • Drug screening
  • TB skin test
  • Hepatitis B series
  • Current BLS/CPR certification (American Heart Association)

Certification Exam

Candidates must pass the National Nurse Aide Assessment Program (NNAAP) exam, which includes:

  • Written or oral test: Tests knowledge of caregiving principles
  • Skills assessment: Demonstrates practical competency

A passing score of 70% or higher on both sections is required for placement on the Tennessee Nurse Aide Registry. Candidates who score below 70% may retake the exam up to two additional times within a two-year period before retraining is required.

March 2025 Registry Update

As of March 28, 2025, all Nurse Aide Renewals and demographic changes have been moved to tn.tmutest.com. Phone assistance is available at 1-877-201-0758.

Certification Renewal

CNA certification is valid for 24 months. Renewal requirements include:

  • Verification of at least 8 hours of paid CNA work during the 24-month period
  • 12 hours per year of in-service training (for CNAs in Medicare/Medicaid-certified facilities)

Employer-Paid Training

Under federal law, Medicare/Medicaid-certified nursing facilities must cover training and testing costs for employed nurse aides. If hired within 12 months of completing training, facilities must reimburse costs on a prorated basis.

Program Costs

CNA program tuition typically ranges from $1,000 to $3,500, plus additional costs for textbooks, scrubs, and certification exam fees. Many schools offer financial aid, grants, scholarships, and payment plans.

Home Health Aide (HHA) Requirements

Home health aides in Tennessee must meet training requirements established by their employing agencies and applicable federal requirements for Medicare-certified agencies. HHAs work under nurse supervision providing personal care and basic health services.

Tennessee Medicaid and Home Care Services

Tennessee's Medicaid program, TennCare, provides home and community-based services primarily through the CHOICES program administered by the Division of TennCare.

TennCare CHOICES

The CHOICES program provides nursing facility services and home and community-based services (HCBS) for:

  • Seniors: Age 65 and older
  • Adults with Physical Disabilities: Age 21 and older

CHOICES Groups

CHOICES is organized into groups based on care needs and settings:

  • Group 2: Community-based services for those who meet nursing facility level of care
  • Group 3: At-risk populations who may need HCBS to prevent institutionalization

July 2025 Service Expansion

Effective July 1, 2025, TennCare expanded coverage for CHOICES Group 2 and Group 3 members to include:

  • Employment Services and Supports
  • Enabling Technology

These additions enhance self-sufficiency options for waiver participants.

Employment and Community First (ECF) CHOICES

ECF CHOICES serves individuals with intellectual and developmental disabilities (I/DD), providing employment-focused services and community-based supports.

2026 ECF CHOICES Expenditure Caps

For calendar year 2026:

  • Group 8 Adults: $513,625 annual expenditure cap
  • Group 6 (Exceptional Needs): $158,989 annual expenditure cap (combined with nursing facility cost)

2026 Financial Eligibility

For HCBS Waivers in Tennessee:

  • Income (Single): $2,982 per month
  • Assets (Single): $2,000
  • Look-Back Period: 60 months

How to Apply for CHOICES

  • Current TennCare members: Contact your TennCare health plan
  • New applicants: Contact your local Area Agency on Aging and Disability (AAAD) at 1-866-836-6678

2025-2026 Compliance Changes

Tennessee is implementing significant compliance enhancements for HCBS providers under IDD waivers:

  • Open-model EVV adoption requirements
  • Revised 1915(c) waiver notices
  • Increased emphasis on digital documentation
  • Rising compliance expectations for 2026

Providers must prepare for stronger operational accuracy requirements and enhanced oversight.

Electronic Visit Verification (EVV)

Tennessee has implemented Electronic Visit Verification (EVV) for personal care services and home health care services. TennCare is emphasizing open-model EVV adoption, allowing providers to choose from multiple approved EVV vendors while meeting state compliance requirements.

Medicare Home Health in Tennessee

Medicare-certified home health agencies in Tennessee must meet federal Conditions of Participation and operate under the Patient-Driven Groupings Model (PDGM) for reimbursement.

State Health Plan

In March 2024, the Tennessee Department of Health published the 2024-2026 State Health Plan with 8 recommendations to meet the healthcare needs of Tennesseans and improve health outcomes.

Tennessee Labor Laws for Home Care

Tennessee follows federal minimum wage and overtime standards, with no state-specific minimum wage requirement above the federal level.

Minimum Wage

Tennessee's minimum wage is $7.25 per hour, matching the federal minimum wage. The state has not enacted a higher state minimum wage.

Market Wages vs. Minimum Wage

Despite the $7.25 minimum wage, actual caregiver pay in Tennessee is significantly higher:

  • Average caregiver wage: $15.73 per hour (based on Indeed data, December 2025)
  • Typical range: $8.00 to $14.00 per hour depending on benefits, role, and experience
  • Many employers offer bonuses and incentives

Overtime Requirements

Tennessee follows federal FLSA standards:

  • Live-out employees: Must be paid 1.5x hourly rate for hours over 40 in a workweek
  • Live-in employees: Exempt from overtime requirements
  • Overtime not required for holiday work

Federal Home Care Worker Protections

The 2015 FLSA rule updates for home care workers apply in Tennessee, governing minimum wage, overtime pay, and record-keeping requirements. Rules vary based on whether workers are employed by agencies or private individuals, with exemptions for companionship and live-in domestic service workers in certain circumstances.

Record-Keeping

Employers must keep wage records on file for at least three years.

Workforce Challenges and Strategies

Tennessee agencies face workforce challenges shaped by the gap between minimum wage requirements and market wages, competition for healthcare workers, and enhanced compliance expectations.

Key Challenges

  • Wage Competition: Must pay above $7.25 minimum to attract workers (market rate ~$15.73)
  • Healthcare Competition: Hospitals, nursing homes, and other providers compete for CNAs
  • Rural Access: Rural counties have workforce shortages and travel challenges
  • Compliance Requirements: Enhanced EVV and documentation requirements for 2026
  • Training Costs: Programs range from $1,000 to $3,500

Recruitment Strategies

  • TCAT Partnerships: Work with Tennessee Colleges of Applied Technology offering CNA programs
  • High School Programs: Connect with career and technical education (CTE) health science pathways
  • Employer-Paid Training: Leverage federal requirements for Medicare/Medicaid facilities to cover training costs
  • AAAD Coordination: Partner with Area Agencies on Aging and Disability for referrals

Retention Strategies

  • Competitive Wages: Pay at or above the $15.73 market average to attract and retain workers
  • In-Service Training: Provide quality continuing education (12 hours/year required)
  • Career Advancement: Create pathways from HHA to CNA to LPN/RN
  • Compliance Support: Help staff adapt to enhanced EVV and documentation requirements
  • Recognition Programs: Acknowledge caregiver contributions

Technology Solutions

  • Open-model EVV systems meeting TennCare requirements
  • Digital documentation platforms for enhanced compliance
  • Mobile scheduling and communication apps
  • Online training platforms for in-service education

Resources for Tennessee Home Care Agencies

  • Tennessee Health Facilities Commission (HFC): Agency licensing and certification (tn.gov/hfc)
  • HFC Nurse Aide Program: CNA certification and registry
  • Nurse Aide Renewals: tn.tmutest.com (as of March 2025)
  • TennCare: CHOICES program information and waiver guidance
  • Area Agencies on Aging and Disability: 1-866-836-6678 for consumer referrals

The Bottom Line

Operating a home health or home care agency in Tennessee requires navigating the new Health Facilities Commission structure, understanding CNA certification requirements, and effectively managing TennCare CHOICES programs. While the state has no minimum wage above the federal $7.25/hour, market wages average $15.73/hour, requiring competitive compensation to attract workers. The July 2025 expansion of employment services and enabling technology for CHOICES members and the enhanced EVV compliance requirements for 2026 represent significant program developments agencies must address. Success in Tennessee requires competitive wages, strong relationships with TCATs and high school CTE programs, efficient compliance systems, and strategic use of employer-paid training benefits for Medicare/Medicaid-certified facilities.