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Tennessee · Home health vs home care · 0940-05-38, 0720-27 and Public Chapter 110
Tennessee licenses non-medical home care and home health through different state bodies. A Personal Support Services Agency (PSSA) is licensed by TDMHSAS, or by the Department of Disability and Aging when most clients have an intellectual or developmental disability. Home health is a Health Facilities Commission license that needs a certificate of need. Here is how they differ, where a PSSA has to stop, and what CMS’s 2026 home health moratorium does and does not touch.
Quick answer
Non-medical home care in Tennessee is licensed as a Personal Support Services Agency (PSSA). "To provide personal support services, an agency needs a license from either the Department of Mental Health and Substance Abuse Services or the Department of Intellectual and Developmental Disabilities." 0940-05-38-.04(1) Which one depends on who 50% or more of your clients are, and you need only one of the two. Public Chapter 110 (2015)
Home health is a different license: a home care organization providing home health services, licensed by the Health Facilities Commission, for skilled nursing, therapy, medical social services and home health aide services under a physician’s orders. 0720-27-.01(30) It needs a certificate of need, HFC and HFC’s fee is $1,404 a year, against TDMHSAS’s $810 per site for a PSSA. 0720-27-.02(2)(b) 0940-05-02-.05(1)
CMS halted Medicare enrollment of new home health agencies nationwide from May 13, 2026. QSO-26-11 By our reading that does not touch a PSSA, which is not a Medicare home health agency.
50%
Share of clients with an intellectual or developmental disability that moves the PSSA license to DDA
0940-05-38-.04(3)(b)| License | For | Source |
|---|---|---|
| PSSA license from TDMHSAS | Non-medical personal support where 50% or more of clients are aged, or have a mental illness or substance abuse diagnosis. | 0940-05-38-.04(3)(a) |
| PSSA license from DDA | The same services where 50% or more of clients have an intellectual or developmental disability, under DDA’s own chapter 0465-02-17. | 0940-05-38-.04(3)(b) |
| Home care organization license from HFC | Home health, home medical equipment, professional support or hospice services, even for one patient. | Public Chapter 858 (2024); HFC determination |
When a provider is a home care organization. A provider is operating a home care organization if it holds itself out as providing home health, home medical equipment or hospice services; contracts or agrees to deliver them; accepts physician orders for them; accepts responsibility for delivering them; or contracts with the state agency to provide professional support services. Public Chapter 858 (2024) Non-medical personal support is not in that definition, and a home care organization licensed by HFC is exempt from the PSSA license. 0940-05-38-.03(2)(g) By our reading, a licensed home health agency therefore does not need a PSSA license as well.
Each line is from the PSSA rules, HFC’s home health rules (Chapter 0720-27), TDMHSAS, HFC or CMS, linked in the cell. Lines marked "by our reading" are ours.
| PSSA (non-medical) | Home health (HFC) | |
|---|---|---|
| Who licenses | TDMHSAS’s Office of Licensure, under T.C.A. Title 33, Chapter 2, Part 4 (or DDA if 50% or more of clients have an intellectual or developmental disability). 0940-05-02-.01(1); 0940-05-38-.04(3) | The Health Facilities Commission (HFC), as a home care organization providing home health services, under Chapter 0720-27. 0720-27-.02(1) |
| What it covers | Self-care help, household help (housekeeping, laundry, meals, shopping, bill paying), help getting to community activities, and a registered nurse’s education services, in the client’s home. 0940-05-38-.01(1) | Services under orders recorded by a physician: skilled nursing, physical, occupational or speech therapy, medical social services and home health aide services. 0720-27-.01(30) |
| Clients | People who depend on personal support for major life activities but do not need nursing-level services for an acute illness or injury. 0940-05-38-.01(2) | Patients under a physician’s orders. 0720-27-.01(30) |
| Who runs it | One individual the licensee designates as responsible for operating the agency. The rules set no qualifications for that person. 0940-05-38-.05(4) | An administrator who is a physician, a registered nurse or trained in health service administration, with at least one year of supervisory or administrative experience in home health, hospice or related programs. 0720-27-.01(2) |
| Nurse | None required, unless you offer medication assistance (training by or under a registered nurse) or education services. 0940-05-38-.08(1)(b); .01(6) | Skilled nursing given by or under the supervision of a registered nurse who is available at all times during operating hours. 0720-27-.06(5)(a) |
| Caregivers | Documented competency in seven areas before working with clients, and job-related training every year; no hour minimum. 0940-05-38-.08(1) | Home health aides with 75 hours of training, including 16 hours of clinical training. 0720-27-.01(29) |
| Medication | Medication assistance: reminders and opening packaging. Since 2024, staff certified through a TDMHSAS-approved program may administer some medication in the client’s home. 0940-05-38-.01(9); Public Chapter 730 (2024) | Drugs and treatments given by appropriately licensed agency personnel, within the scope of their licenses. 0720-27-.06(4) |
| State fee | $810 per site, each year (TDMHSAS’s fee), non-refundable. 0940-05-02-.05(1) | $1,404 each year (HFC’s fee), with the application, not refundable. 0720-27-.02(2)(b) |
| Certificate of need | None found. Personal support services agencies are not on HFC’s list of institutions that need one. HFC, Certificate of Need Basics | Required before establishment, licensure or certification, with exceptions such as pediatric-only home health. HFC, Certificate of Need Basics |
| First inspection | An electronic desk audit; no fire or life safety inspection. TDMHSAS, steps 4-5 | An inspection by a surveyor; if deficiencies are noted, a plan of corrective action must be accepted. 0720-27-.02(2)(f) |
| Medicare | By our reading, not a Medicare home health agency; CMS’s 2026 moratorium memo does not mention non-medical home care. QSO-26-11 | Enrollment of new Medicare home health agencies is halted nationwide from May 13, 2026. QSO-26-11 |
Fees are the state’s: TDMHSAS’s for a PSSA and HFC’s for home health, paid to the state and separate from any CareRulebook price. The full PSSA process is on the Tennessee guide.
PSSA clients are people who depend on personal support but "does not require nursing level services to be provided in connection with an acute episode of illness or injury". 0940-05-38-.01(2) TDMHSAS’s PSSA slides then list tasks a PSSA may not do. PSSA slides, slides 25-27
TDMHSAS lists tasks not allowed under a PSSA license, including blood pressure monitoring, blood sugar checks, insulin injections, giving oral medications, prescription topical creams or pain patches, catheter and feeding tube care, measuring intake and output, taking vital signs and filling medication planners.
PSSA slides, slide 25Also not allowed: putting drops in eyes or ears, adjusting oxygen settings or IVs, changing dressings, enemas, catheter irrigation, emptying indwelling catheter or ostomy bags, positioning bed-bound clients to prevent contractures, tube feeding, ventilator management and applying ointments of any kind. For staff certified in medication administration, TDMHSAS says to ask the certification program whether any of these are allowed.
PSSA slides, slides 26-27Medication assistance means reminders and opening packaging. It does not include injections or any medication administration reserved for licensed nurses and others under Title 63, Chapter 7. Since Public Chapter 730 (2024), staff certified through a TDMHSAS-approved program may administer medication in the home to a client who cannot self-administer, but never intravenous, intramuscular or certain subcutaneous injectables.
0940-05-38-.01(9); Public Chapter 730 (2024)Adding a tube of medicine to a nebulizer is medication administration, not medication assistance, under the PSSA rules.
PSSA slides, slide 23A Hoyer lift or gait belt may be used, after training, to help with transfers into or out of bed, a chair, toilet or shower, but not as part of a therapy regimen.
0940-05-38-.06(1)(n)The PSSA rules name a registered nurse for education services (consultation about a chronic condition), for medication assistance training, and as one option for workers’ consultation. By our reading, none of these is hands-on nursing care.
0940-05-38-.01(6); .08(1)(b); .07(2)(g)By our reading, when a client needs one of these tasks, a PSSA arranges or refers for it (to a home health agency, a nurse or the client’s doctor) and keeps giving only the personal support it is licensed for. The services you offer, and the tasks your workers do not do, belong in your description of services, which is one of the 17 required policy items. 0940-05-38-.06(1)(a) CareRulebook’s manual covers them in Policy 2.1, and certified medication administration in Policy 2.12.
HFC’s home health rules define homemaker service as "A non-skilled service in the home to maintain independent living which does not require a physician’s order. An agency does not have to be licensed as a home care organization to provide such services." 0720-27-.01(31) That sentence is about HFC’s license only.
TDMHSAS’s PSSA rules count household help as a personal support service in its own right: "Household assistance with tasks such as housekeeping, laundry, meal planning, meal preparation, shopping, bill paying, and use of telecommunication devices". 0940-05-38-.01(1)(b) The PSSA exemption covers only "A person who provides only housekeeping services to a service recipient and no other assistance with major life activities". 0940-05-38-.03(2)(c) So by our reading a homemaker service that does laundry, meals or shopping for clients who meet the PSSA client definition (substantial limitations in two or more major life activities) needs a PSSA license, even though it needs no HFC license. Companionship on its own is named neither as a service nor as an exemption; ask TDMHSAS if that is your whole plan.
"Non-Medical Home Health". TDMHSAS’s Fact Sheet (rev. 10/27/2025) has a "Non-Medical Home Health" checkbox beside the Personal Support Services Agency box. No rule we saved defines a license category by that name. MH-4386, item 4 Ask your regional office which box applies before you file.
The statute, as rewritten by Public Chapter 110 in 2015, says TDMHSAS "shall also license personal support services for the aged as well as persons with mental illness", and DIDD, now the Department of Disability and Aging (DDA), licenses personal support services for people with intellectual or developmental disabilities. Public Chapter 110 (2015), section 1
The rules do not say how the 50% is counted (people, hours, or at application only). If your client mix is close to half, ask your TDMHSAS regional office before you apply.
The name sounds close to personal support, but it is a different service. HFC’s rules define professional support services as nursing, occupational, physical or speech therapy for people with intellectual or developmental disabilities under a contract with the state agency that pays for those services. 0720-35-.01(49) A home care organization providing professional support services must keep a contract with the Department of Intellectual and Developmental Disabilities (now DDA). 0720-35-.02(2)(b)
A provider that contracts with the state agency to provide professional support services is operating a home care organization under the 2024 definition, Public Chapter 858 (2024) and an organization authorized to provide only professional support services is an exception to the certificate of need requirement. HFC, Certificate of Need Basics
CareRulebook
CareRulebook’s Tennessee manual is built for a TDMHSAS-licensed PSSA: the 17 policy items and 8 personnel topics, your description of services and the tasks your workers do not do (Policy 2.1), and your client-mix attestation (Policy 1.3).
$199CareRulebook founding price for the first 50 Tennessee agencies, then $249. Not a TDMHSAS fee.
HFC’s guide lists "Home Care Organization (Home Health and Hospice)" among the institutions that need a certificate of need before establishment, licensure or certification, and home health among the services that need one before anyone starts them. HFC, Certificate of Need Basics A home health license covers "for the geographic areas specified by the certificate of need or at the time of the original licensing". 0720-27-.02(1)
We have not saved the certificate of need statute itself (T.C.A. 68-11-1601 and following) or HFC’s home health need standards, so this page does not cover how a certificate of need is decided. If your plan includes home health, start with HFC.
Federal · Medicare enrollment · from May 13, 2026
CMS’s memo QSO-26-11: "Effective May 13, 2026, CMS will halt the enrollment of new Hospice and HHA providers or HHA branch or practice locations." QSO-26-11
What it means, by our reading. The memo is about Medicare enrollment, not state licenses, and does not mention non-medical home care. A TDMHSAS PSSA is not a Medicare home health agency, so the moratorium does not affect it. For a planned home health agency, the certificate of need and HFC license come first, and Medicare enrollment of new agencies is closed while the moratorium lasts.
Find the line closest to what you will offer. Fees are the state’s, not CareRulebook prices. Lines marked "by our reading" are ours; check with the regulator before you apply.
| If you plan to offer | License | State fee | Source |
|---|---|---|---|
| Bathing, dressing, meals, laundry, shopping or outings for clients who are mostly older adults, or who have a mental illness or substance use diagnosis | PSSA license from TDMHSAS | $810 per site a year (TDMHSAS) | 0940-05-38-.04(3)(a)0940-05-02-.05(1) |
| The same services, where 50% or more of clients have an intellectual or developmental disability | PSSA license from DDA, under 0465-02-17 | DDA’s own fees (0465-02-02-.05, not saved) | 0940-05-38-.04(3)(b)0465-02-17-.02(5) |
| Only housekeeping, only transportation, or only deliveries | No PSSA license (exempt) | None | 0940-05-38-.03(2)(c), (d), (f) |
| Medication given by trained unlicensed staff, alongside personal support | PSSA license, with staff certified through a TDMHSAS-approved program | $810 (TDMHSAS); DDA’s class fee per worker | Public Chapter 730 (2024)PSSA slide 21 |
| Skilled nursing, therapy, medical social services or home health aide services under a physician’s orders | HFC home care organization license (home health), after a certificate of need | $1,404 a year (HFC); CON costs not covered here | 0720-27-.01(30)HFC, CON Basics |
| Mostly personal support, plus a few nursing tasks such as vital signs, insulin or dressing changes | Not under a PSSA license; by our reading, the HFC home health license | $1,404 a year (HFC) | PSSA slides 25-270720-27-.01(30) |
| Nursing or therapy for people with intellectual or developmental disabilities under a state contract | HFC home care organization license (professional support services); no certificate of need | HFC’s fee for 0720-35 (not covered here) | 0720-35-.01(49)HFC, CON Basics |
| Home health only for patients under 18, or only under the federal EEOICPA program | HFC home health license without a certificate of need; accreditation within two years | $1,404 a year (HFC) | HFC, CON Exemptions |
| Medicare-certified home health | HFC license and certificate of need, then Medicare enrollment, which is halted for new agencies from May 13, 2026 | $1,404 a year (HFC); Medicare costs not covered here | QSO-26-11HFC alert |
No. Non-medical home care (self-care help, household help and community access) is licensed as a Personal Support Services Agency by TDMHSAS, or by the Department of Disability and Aging if most clients have an intellectual or developmental disability. The Health Facilities Commission’s home care organization license is for home health, home medical equipment, professional support and hospice services.
"The Tennessee Department of Mental Health and Substance Abuse Services is authorized to license facilities and services operated for the provision of mental health, substance abuse, and personal support services in the State of Tennessee by T.C.A. Title 33, Chapter 2, Part 4."
No. Not by our reading. That line in the Health Facilities Commission’s home health rules is about HFC’s license only. TDMHSAS’s PSSA rules count household help (housekeeping, laundry, meals, shopping, bill paying, telephones) as a personal support service, and exempt only a person who provides housekeeping alone, with no other help with major life activities. A homemaker service that does more than housekeeping, for clients who meet the PSSA client definition (substantial limitations in two or more major life activities), needs a PSSA license.
"Household assistance with tasks such as housekeeping, laundry, meal planning, meal preparation, shopping, bill paying, and use of telecommunication devices;"
No. Not under the PSSA license. TDMHSAS lists tasks not allowed under a PSSA license, including taking vital signs, blood sugar checks, insulin injections, catheter care and dressing changes, and the rules describe PSSA clients as people who do not need nursing-level services for an acute illness or injury. The PSSA rules name a registered nurse only for education services, medication assistance training and as one option for workers’ consultation. Skilled nursing at home is a home health service under the Health Facilities Commission’s license, which needs a certificate of need.
"Taking/recording vitals - - blood pressure, pulse, temperature, respiration"
No. By our reading. CMS’s memo halts Medicare enrollment of new home health agencies and hospices from May 13, 2026, for six months, which CMS can extend. It does not mention state licenses or non-medical home care. A PSSA is licensed by TDMHSAS and is not a Medicare home health agency.
"Effective May 13, 2026, CMS will halt the enrollment of new Hospice and HHA providers or HHA branch or practice locations."
Different licenses from different state bodies. Non-medical home care (help with self-care, household tasks and getting to activities) is a Personal Support Services Agency (PSSA) license from TDMHSAS, or from the Department of Disability and Aging if 50% or more of clients have an intellectual or developmental disability. Home health (skilled nursing, therapy, medical social services and home health aide services under a physician’s orders) is a home care organization license from the Health Facilities Commission, which needs a certificate of need. TDMHSAS’s fee is $810 per site a year; HFC’s home health fee is $1,404 a year. Both are state fees, not CareRulebook prices.
Not for a non-medical PSSA, as far as we found: personal support services agencies are not on the Health Facilities Commission’s list of institutions that need one. A home care organization providing home health or hospice does need a certificate of need, with exceptions for home health limited to patients under 18 or to the federal EEOICPA program, and for organizations providing only professional support services.
No. Since Public Chapter 110 (2015), an agency serving both groups does not need a license from both departments. The licensing department is set by the larger population served or, for a new applicant, the larger population it expects to serve when it applies. You attest to your client mix when you apply and at every renewal, and then serve only clients who keep you within your licensed category.
By our reading of the PSSA rules, no: a home care organization licensed by the Health Facilities Commission is listed as exempt from the PSSA license. If your plan mixes both kinds of care, confirm with HFC and TDMHSAS before you apply.
Not under the PSSA license. TDMHSAS lists tasks not allowed under a PSSA license, including taking vital signs, blood sugar checks, insulin injections, catheter care and dressing changes, and PSSA clients are people who do not need nursing-level services for an acute illness or injury. The PSSA rules name a registered nurse only for education services, medication assistance training and as one option for workers’ consultation. Skilled nursing at home is a home health service under the Health Facilities Commission’s license.
Medicare enrollment of new home health agencies is halted nationwide from May 13, 2026, for six months, which CMS can extend for further six-month periods, with no exceptions for individual providers. Initial enrollment applications submitted during the moratorium are denied and must be resubmitted after it is lifted. The Health Facilities Commission points new home health certificate of need applicants to the moratorium. It does not affect a non-medical PSSA license.
TDMHSAS’s Fact Sheet (rev. 10/27/2025) has a "Non-Medical Home Health" checkbox beside the Personal Support Services Agency box. No rule we saved defines a license category by that name; the PSSA rules are the ones that cover non-medical care in the home. Ask your TDMHSAS regional office which box applies before you file.
No. CareRulebook’s Tennessee manual is for a TDMHSAS-licensed PSSA. Policy 2.1, Description of services, enrollment and termination criteria, and tasks workers do not do, sets out the services you offer and the tasks your workers do not do, and Policy 1.3 covers your client-mix attestation. It does not cover the DDA route or the Health Facilities Commission’s home health license.
TDMHSAS has proposed a rewrite of its licensure procedure rules, Chapter 0940-05-02 (hearing November 18, 2026), and has said PSSA medication administration rules are coming. Leave your email and we will tell you when a Tennessee change affects your policies.
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