Home Care vs Home Health in Tennessee 2026, What's the Difference?

These two terms get used interchangeably, especially by hospital discharge planners working fast. They are not the same service.

Home care is non-medical: help with bathing, meals, housekeeping, and companionship. No doctor's order needed. Usually paid privately or through TennCare's CHOICES program.

Home health is medical: skilled nursing, physical therapy, wound care. Requires a doctor's order, requires the patient to be homebound, and is usually covered at $0 by Medicare or TennCare.

The two are licensed under different agencies, follow different rules, and get billed in completely different ways. Many Tennessee families end up using both, home health for the first few weeks after a hospital discharge, then home care once the skilled need has resolved but ADL help is still needed.

This guide walks through what each service covers, what it costs in Tennessee, who pays, and how to find a properly licensed agency.

By Brevy Care Team · Last verified May 3, 2026

In This Guide

• Key Takeaways
• Home Care vs Home Health at a Glance
• What Home Care Covers in Tennessee
• What Home Health Covers in Tennessee
• Home Care vs Home Health Costs in Tennessee
• How Medicare Covers Home Health
• How TennCare Covers Both
• CHOICES Personal Care When Home Health Runs Out
• How to Find a Licensed Agency
• Red Flags to Watch For
• Frequently Asked Questions

Home Care vs Home Health at a Glance

A useful decision test: if a doctor wrote an order to "send out a nurse to check the wound" or "have therapy come twice a week for the next month," that's home health. If the question is "we need someone to help mom bathe and make meals every day for the foreseeable future," that's home care.

What Home Care Covers in Tennessee

Home care, sometimes called non-medical home care, personal support services, or in-home care, is the category of help that lets someone stay at home safely without needing to move to a facility.

In Tennessee, home care agencies are licensed as Personal Support Services Agencies (PSSAs) under Tenn. Comp. R. & Regs. 0940-05-38, with the regulator being the Tennessee Department of Mental Health and Substance Abuse Services (TDMHSAS) Office of Licensure. The statutory backbone is T.C.A. §33-2-421.

This is counterintuitive. Most families assume non-medical home care for seniors would be regulated by the Department of Disability and Aging (DDA, the agency that emerged in 2024 from the merger of TCAD and DIDD adult-services). It is not. PSSA licensure has always lived under TDMHSAS Title 33, the same statutory framework that licenses behavioral health programs, and the 2024 reorganization did not move it. Third-party guides that cite Chapter 0465-01 or DDA as the regulator are incorrect.

The four service categories a PSSA caregiver may provide under the rule:

• Self-care assistance: eating, dressing, toileting, bathing, mobility, transfer assistance
• Household assistance: housekeeping, laundry, meal planning, meal preparation, shopping, bill paying, telecommunications
• Personal assistance: community access, transportation, social and recreational activities
• Education services: an RN-led consultation to the recipient or a primary family caregiver about a chronic condition

What PSSA caregivers may NOT do. The rule's own definition of "service recipient" is someone who needs personal support but not nursing-level care. A PSSA worker may give medication reminders (cuing, "it's time for your blood pressure pill") but may not administer prescription medications, may not give injections, may not change wound dressings, may not manage IV therapy or catheters, and may not perform any task that requires a nursing license. Anything that crosses that line moves the service into home health.

Personnel requirements under 0940-05-38-.07: caregivers must be at least 18, have completed criminal background checks every two years (or within 10 days of being hired), have annual checks of the TN Abuse Registry and Sex Offender Registry, have documented training matched to the recipient's needs, have a five-year work history with three personal references, and have annual performance evaluations. Agencies are required to carry liability insurance.

Exemptions from PSSA licensure. Seven categories of providers don't need a PSSA license: individual workers serving only one client outside a business arrangement, family caregivers, housekeeping-only services, transportation-only services, homeless shelter workers, delivery providers, and HFC-licensed home care organizations. That last one matters: if a Tennessee home care company already holds an HFC license under Chapter 0720-35 ("Professional Support Services"), it does not also need a TDMHSAS PSSA license. Many large agencies that operate both home health and non-medical home care under one corporate roof go the dual-HFC-license route. From a consumer perspective, the substantive scope is similar; what matters is verifying the license is current.

What Home Health Covers in Tennessee

Home health is the category of care that requires a clinical license. In Tennessee, home health agencies (HHAs) are licensed by the Tennessee Health Facilities Commission (HFC) under Tenn. Comp. R. & Regs. 0720-27.

Until July 2022, home health rules were at Tenn. Comp. R. & Regs. 1200-08-26 under the TN Department of Health Board for Licensing Health Care Facilities (BLHCF). Public Chapter 1119 of 2022 created HFC and migrated home health, hospice, nursing home, and assisted-living licensure into the new commission's Title 0720 series. Third-party guides still citing 1200-08-26 are using pre-2022 chapter numbers, verify the current 0720-27 citation if you're checking against an outside source.

What an HHA provides:

• Skilled nursing: wound care, IV therapy, injections, medication administration, catheter care, ostomy management, diabetic education, pain management
• Physical therapy: gait training, balance, strengthening, post-surgical mobility
• Occupational therapy: ADL retraining, adaptive equipment, energy conservation, post-stroke recovery
• Speech-language pathology: swallow therapy, aphasia rehab, cognitive-communication
• Medical social work: care planning, community resource navigation, transition planning
• Home health aide hours under registered-nurse supervision, paired with the skilled services above, not standalone

All HHA services are provided under a physician's plan of care. The home-health-aide role inside an HHA is materially different from a non-medical caregiver inside a PSSA. The HHA aide works under an RN-supervised plan; the PSSA caregiver works under PSSA training rules without nurse oversight. The job title "home health aide" is used in both settings, which is the single biggest source of confusion in this category.

Medicare certification is separate from state license. A Tennessee HHA may hold a state HFC license alone (operating private-pay or TennCare-only) or may also be Medicare-certified, which adds federal Conditions of Participation under 42 CFR Part 484 on top of state rules. Medicare-certified HHAs handle both Medicare and most TennCare home health work. CMS surveys for Medicare certification are conducted by HFC's survey arm under contract with CMS.

Hospice is a third license, not the same as home health. End-of-life palliative care is regulated under HFC Chapter 0720-28 (in-home hospice) or 0720-23 (residential hospice), with federal Medicare hospice rules at 42 CFR Part 418. Home health is a restorative skilled-care benefit; hospice is a palliative end-of-life benefit with a six-month-or-less life-expectancy certification. They are not interchangeable, and an agency licensed for one is not automatically licensed for the other.

Home Care vs Home Health Costs in Tennessee

For most Tennessee families, home health is covered by Medicare or TennCare at $0 out-of-pocket if the patient qualifies, so the cost question really only applies to non-medical home care.

Source: CareScout 2025 Cost of Care Survey, with Tennessee figures synthesized from CareScout state tables and metro-level agency price-shopping. The 2025 report merged the older "homemaker" and "home health aide" categories into a single "non-medical caregiver" line at the $35/hr national median (a 3% increase from 2024). Tennessee runs about 15-25% below the national median, which translates to roughly $15,000-$25,000 per year in savings at full-time hours compared to high-cost states.

Live-in home care in Tennessee is typically priced at $4,500-$7,000 per month flat ($54,000-$84,000/year). Federal Fair Labor Standards Act rules at 29 CFR Part 552 allow sleep time, meal time, and "complete freedom" periods to be excluded from compensable hours by mutual agreement; live-in workers are exempt from federal overtime under FLSA §13(b)(21) but remain entitled to federal minimum wage ($7.25/hr; Tennessee has no separate state minimum wage).

A 2025-2026 federal labor rule worth flagging. On July 25, 2025, the U.S. Department of Labor issued Field Assistance Bulletin 2025-4, which suspended enforcement of the 2013 home care third-party-employer rule. A July 2025 DOL notice of proposed rulemaking proposed rescinding the 2013 rule entirely; the comment period closed September 2, 2025. As of May 2026 the final rule has not been issued. If finalized, the rescission would restore pre-2013 companionship and live-in exemptions for third-party home care agency employees, which could shift the labor-cost math for live-in services in Tennessee. This is a "watch this space" item, not settled law.

A note on direct-hire. Hiring a caregiver through Craigslist or word-of-mouth as an independent contractor is meaningfully cheaper per hour, but the family becomes the legal employer of record, responsible for payroll tax withholding, workers' compensation insurance, and liability for any injury or theft. For most families, an agency arrangement is the safer default; the higher hourly rate buys legal protections and replacement-caregiver coverage.

How Medicare Covers Home Health

Medicare's home health benefit is the most-misrepresented section of in-home care. Three things to know up front.

1. Medicare home health is not custodial care. It pays only for intermittent skilled care for homebound patients. It does not pay for help bathing, meal prep, or companionship, that's home care, which Medicare doesn't cover at all.

2. The cost is $0 for covered services, with no deductible and no copay. Durable medical equipment ordered as part of the plan of care has the standard 20% Part B coinsurance.

3. Five eligibility tests all must be met:

Medicare home health is recertifiable as long as the eligibility criteria still apply.

Medicare does NOT cover at home: 24-hour care, meal delivery, homemaker services unrelated to a skilled care plan, custodial care alone (bathing/dressing without a skilled need), groceries, or transportation. If those are the only needs, Medicare is the wrong payer, look at private-pay home care, TennCare CHOICES, or a Medicare Advantage plan with supplemental in-home benefits.

Medicare Advantage equivalence. MA plans must cover at least the same home-health benefit as Original Medicare; some plans offer additional in-home support services as supplemental benefits, but those vary plan-to-plan. Check the specific Evidence of Coverage.

How TennCare Covers Both

TennCare's coverage of in-home services depends on the member's age and benefit package.

Adults age 21+ in standard TennCare (Pkg B/E). Home health is a covered State Plan benefit, but with some of the strictest hour caps in the country:

• Skilled nursing: less than 8 hours per visit, maximum 1 visit per day, 27 hours per week (or 30 hours per week for members at Level 2 nursing-facility level of care under §1115 demonstration authority).
• Home health aide hours under nurse supervision: 8 hours/day, 2 visits/day, with a combined nursing-plus-aide ceiling of 35 hours/week (or 40 hours/week at Level 2 LOC).
• No personal care, no homemaker services, no companion care as State Plan benefits for adults. Those aren't covered through standard TennCare at all, they require a CHOICES, ECF CHOICES, or Katie Beckett HCBS pathway (covered in the next section).
• Private duty nursing for adults 21+ is restricted to ventilator-dependent or life-sustaining-technology cases, capped at 16 hours/day after age 21.

Children under 21 (Pkg A). EPSDT applies. Any medically necessary home health is covered without the adult cap, and PDN is not restricted to ventilator-only cases. The federal EPSDT mandate is one of the few areas where pediatric Medicaid is meaningfully more generous than adult Medicaid.

Prior authorization. TennCare's three MCOs (BlueCare Tennessee, UnitedHealthcare Community Plan TN, Wellpoint Tennessee) administer the home health benefit through their provider networks. Standard PA decisions are due within 14 days; expedited (urgent) decisions within 72 hours, per 42 CFR §438.210. Tenn. Code §71-5-197 adds a 24-hour PA response standard as a state-law backstop.

Provider network. Most Medicare-certified HHAs in Tennessee participate with all three TennCare MCOs. To confirm, use the MCO's online provider directory after your member has been assigned, or call the MCO member services line.

CHOICES Personal Care When Home Health Runs Out

When standard TennCare home health can't keep up with what a member needs at home, most often when the issue is ongoing ADL help rather than a short-term skilled need, the answer is one of three home and community based services (HCBS) pathways.

TennCare CHOICES Group 2 is the main one for most adults. It's the HCBS option for adults who would otherwise meet nursing-facility level of care but who choose to live at home or in an assisted living facility.

CHOICES Group 2 includes:

• Personal Care Visits, up to 2,580 hours/year (maximum 2 visits/day, 4 hours/visit, 4 hours between visits)
• Attendant Care, 1,080 hours/year (1,400 hours if homemaker bundled)
• Adult Day Services, 2,080 hours/year
• In-Home Respite, 216 hours/year
• Inpatient Respite, 9 days/year
• Home-Delivered Meals, 1 per day
• Home Modifications, $6,000 per project, $10,000/year, $20,000 lifetime
• Personal Emergency Response System (PERS)
• Pest Control, 9 treatments/year
• Assistive Technology ($900/year) and Enabling Technology ($5,000/year, made permanent effective 7/1/2025)
• Employment Services and Supports (added 7/1/2025)

The CHOICES Group 2 cost-neutrality cap is $294.87 per day, $107,627.55 per year (effective 1/1/2026). Services are managed by an MCO Care Coordinator who authorizes hours within that cap based on the member's care plan and acuity.

CHOICES Group 3 is a smaller at-risk package for adults who don't yet meet full nursing-facility LOC but are at risk of placement. The annual ceiling is roughly $18,000/year in services and supports. Same service array as Group 2, just bounded by a lower expenditure ceiling.

ECF CHOICES serves younger adults (under 65) with intellectual or developmental disabilities, with its own service catalog including Personal Assistance, Community Living Supports, and Family Caregiver Stipends.

Consumer Direction. Across CHOICES groups and ECF CHOICES, members can elect to direct their own services and become the employer of record for their caregiver. Consumer Direct Care Network Tennessee (CDTN) acts as the Fiscal Employer Agent, handling W-2 payroll, electronic visit verification, background checks, and biweekly direct deposit. Eligible employees include adult children, siblings, parents of an adult member, friends, and other relatives. Spouses, court-appointed conservators, legal guardians, and powers of attorney serving as the member's CD Representative are not eligible to be paid as the caregiver. Typical 2026 caregiver wage range is $11-$15/hour. (For the full paid-family-caregiver pathway, see How to Get Paid as a Family Caregiver in Tennessee.)

Not sure which pathway your parent qualifies for? TennCare's home health, CHOICES Group 2, ECF CHOICES, and Katie Beckett each have different eligibility rules, different services, and different waiting lists. Brevy's care advisors can walk through the situation and point you at the right starting place, at no cost.

How to Find a Licensed Agency

The first thing to verify is which license the agency actually holds, because that tells you what services they can legally provide.

For home health (medical): check the Tennessee Health Facilities Commission's county-level directory at tn.gov/hfc/certificate-of-need-information/hfc-toolbox/county-licensed-home-health-and-hospice-agencies-.html. HFC publishes four lists by county: standard home health licensed counties, EEOICPA exemption, pediatric exemption, and hospice. There are roughly 300-400 licensed HHAs statewide.

For Medicare certification status of a home health agency, check Medicare.gov Care Compare, every Medicare-certified HHA has a 5-star quality rating, recent CMS-2567 deficiency reports, and patient-experience survey results.

For non-medical home care (PSSA): check the TDMHSAS Office of Licensure provider list at tn.gov/behavioral-health/licensing.html. The interface is less polished than HFC's, but the licensure data is authoritative. Some Tennessee agencies operate under HFC's parallel "Professional Support Services" license at Chapter 0720-35 instead, those will appear in HFC's directories rather than TDMHSAS's.

Questions to ask any agency before you sign:

• What is your state license number, and under which chapter, 0720-27 (HFC home health), 0720-35 (HFC professional support services), or 0940-05-38 (TDMHSAS PSSA)?
• Are you Medicare-certified? Medicaid-enrolled? Which TennCare MCOs do you contract with?
• Are your caregivers W-2 employees of the agency (not 1099 contractors)?
• What's your background-check and drug-screening protocol?
• What are your training requirements, agency-internal, state-required, or both?
• What's your minimum-hour requirement per visit? (Most TN agencies require 3-4 hour minimums.)
• How is supervision handled? How often does an RN visit (for HHA) or supervisor check in (for PSSA)?
• What's your caregiver-continuity policy, same caregiver each visit, or rotating staff?
• Do you have 24/7 on-call backup, or only business hours?
• Can I see the written care plan, and how often is it reviewed?
• What's the exit clause if the relationship isn't working?

Inspection and complaint history. Tennessee HFC posts inspection and survey records for HHAs. PSSA complaint records are available through TDMHSAS Office of Licensure. Ask the agency directly for any complaints in the last 24 months and how they were resolved, and verify the answer against the state record.

Red Flags to Watch For

• The agency cannot or will not produce its license document. A current, active license under 0720-27, 0720-35, or 0940-05-38 should be available in seconds.
• Caregivers are paid as 1099 contractors instead of W-2 employees. That signals the agency is shifting tax and liability burden onto the worker (or onto you).
• No formal background check, or "background check" run only at hire and never repeated. State rules require biennial criminal-background screening for PSSAs at minimum.
• High-pressure long-term contract with no exit clause. A reputable agency lets you cancel with notice.
• Refuses to share the supervision schedule or written care plan. Both are required by state rules.
• Caregiver turnover above 50% per year. Some turnover is normal in this industry; well above 50% is a red flag for working conditions and care continuity.
• Refuses to put rates and overtime policy in writing. Especially for live-in care given the unsettled FLSA situation.

Frequently Asked Questions

Find personalized help comparing Tennessee home care and home health options at brevy.com.