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

Home care vs home health in Tennessee is one of the most-confused distinctions in eldercare: these two terms get used interchangeably, especially by hospital discharge planners working fast. They are not the same service, and the difference decides who may legally do the work and who pays.

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. Medicare does not cover it when it is the only care needed.1,2

Home health is medical: skilled nursing, physical therapy, wound care. It requires a doctor's order, requires the patient to be homebound, and for covered services the patient generally pays $0 under Medicare or TennCare.3,2

The two are licensed under different agencies, follow different rules, and get billed in completely different ways. Many Tennessee families use 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 covers, what it costs in Tennessee, who pays, and how to find a properly licensed agency.

In This Guide

• Key Takeaways
• Home Care vs Home Health in Tennessee 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 in Tennessee at a Glance

A useful decision test: if a doctor wrote an order to send a nurse to check a wound or have therapy come twice a week for a month, that's home health. If the need is 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, also called non-medical home care, personal support services, or in-home care, is the help that lets someone stay home safely without moving to a facility.1

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

This is counterintuitive. Most families assume non-medical home care for seniors falls under the Department of Disability and Aging (DDA, formed in 2024 from the TCAD and DIDD adult-services merger). It does not. PSSA licensure has always lived under TDMHSAS Title 33, and the 2024 reorganization did not move it. Third-party guides citing Chapter 0465-01 or DDA as the regulator are wrong.

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

• Self-care assistance: eating, dressing, toileting, bathing, mobility, transfers
• Household assistance: housekeeping, laundry, meal prep, shopping, bill paying
• Personal assistance: community access, transportation, social and recreational activities
• Education services: an RN-led consultation about a chronic condition

What PSSA caregivers may NOT do. The rule defines a "service recipient" as someone who needs personal support but not nursing-level care. A PSSA worker may give medication reminders (cuing) but may not administer prescription medications, give injections, change wound dressings, manage IV therapy or catheters, or perform any task requiring 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, pass criminal background checks every two years (or within 10 days of hire), clear annual checks of the TN Abuse Registry and Sex Offender Registry, carry documented training matched to the recipient's needs, and have annual performance evaluations. Agencies must carry liability insurance.

One exemption that matters for consumers: 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 run both home health and non-medical home care under one corporate roof go the dual-HFC-license route. The substantive scope is similar either way; what matters is verifying the license is current.1

What Home Health Covers in Tennessee

Home health is the 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. 0720-27.3

Until July 2022, home health rules were at Tenn. Comp. R. & Regs. 1200-08-26 under the TN Department of Health. 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.

What an HHA provides:

• Skilled nursing: wound care, IV therapy, injections, medication administration, catheter and ostomy care
• Physical, occupational, and speech-language therapy: gait and strength training, ADL retraining, swallow therapy, post-stroke recovery
• 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, while 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 (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.3

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). Home health is a restorative skilled-care benefit; hospice is a palliative end-of-life benefit. 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 cost really only applies to non-medical home care.2

Source: CareScout 2025 Cost of Care Survey; Tennessee figures are 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 that national median, roughly $15,000-$25,000 per year in savings at full-time hours versus high-cost states.1

Live-in home care in Tennessee is typically priced at $4,500-$7,000 per month flat ($54,000-$84,000/year). Under federal Fair Labor Standards Act rules at 29 CFR Part 552, live-in workers are exempt from federal overtime (FLSA §13(b)(21)) but remain entitled to the federal $7.25/hr minimum wage; Tennessee has no separate state minimum wage.1

A 2025-2026 federal labor rule worth flagging. On July 25, 2025, the U.S. Department of Labor issued Field Assistance Bulletin 2025-4, suspending enforcement of the 2013 home care third-party-employer rule, and a July 2025 proposed rule would rescind that rule entirely. As of mid-2026 no final rule has issued. If finalized, the rescission would restore pre-2013 companionship and live-in exemptions for agency employees and could shift the labor-cost math for live-in care in Tennessee. Treat it as a watch item, not settled law.1

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

How Medicare Covers Home Health

Medicare's home health benefit is the most-misrepresented part of in-home care. Three things up front.2

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 is home care, which Medicare does not 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 is paid at 80%, leaving the standard 20% Part B coinsurance.2

3. Five eligibility tests all must be met (each grounded in the federal home health rule at 42 CFR §409.42 and 42 U.S.C. §1395x(m), and the CMS CY 2026 final rule):2,3

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.2

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

How TennCare Covers Both

TennCare's in-home coverage depends on the member's age and benefit package.4

Adults age 21+ in standard TennCare (Benefit Package B). Package B is the package for an adult 21 or older who does not have Medicare and is not getting long-term care. Home health is one of the Medicaid services it covers, delivered through the member's managed care organization (MCO), but the adult home health benefit is hour-capped, and several in-home services that families assume are covered are not in Package B at all:

• Personal care, adult day services, and home modifications are not Package B benefits. Those are CHOICES and ECF CHOICES services, expressly excluded from Package B, so they require a CHOICES, ECF CHOICES, or Katie Beckett home and community based services (HCBS) pathway (covered in the next section), which means enrolling in a long-term-care benefit package such as E, J, K, or L.
• Private duty nursing for adults 21+ is limited to services needed to support ventilator equipment or other life-sustaining medical technology.
• The exact weekly and daily hour limits on adult skilled-nursing and home-health-aide visits are set by TennCare's coverage policy and administered visit-by-visit by the MCO; confirm the current limits with your member's plan before relying on a specific number.

Children under 21. Under the federal EPSDT mandate, any medically necessary home health is covered without the adult limits, and private duty nursing is not restricted to ventilator-only cases. EPSDT is one of the few areas where pediatric Medicaid is meaningfully more generous than adult Medicaid.4

Prior authorization and appeals. TennCare's three MCOs (BlueCare Tennessee, UnitedHealthcare Community Plan TN, Wellpoint Tennessee) administer the home health benefit through their provider networks. If a service is denied, the member has 60 days to file a TennCare medical appeal after finding out there is a problem (standard decisions usually within 90 days of filing; expedited appeals in about a week).4

Provider network. Most Medicare-certified HHAs in Tennessee participate with all three TennCare MCOs. To confirm, use the MCO's online provider directory or call its 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, usually because 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.5

CHOICES Group 2 covers a home and community based services array that includes personal care, attendant care, in-home and inpatient respite, adult day services, home-delivered meals, a personal emergency response system, assistive and enabling technology, minor home modifications, and care coordination. The specific annual unit limit for each service is published in the TennCare CHOICES Member Benefit Table and is authorized by an MCO Care Coordinator based on the member's care plan and acuity.5

What bounds the whole package is a single dollar ceiling: the CHOICES Group 2 individual cost-neutrality cap, set to the average daily cost of nursing facility reimbursement. Effective January 1, 2026, that cap is $294.87 per day, $107,627.55 per year. If a member's plan of care would cost more than the cap, the member generally must receive care through Group 1 (a nursing facility) instead.5

CHOICES Group 3 is a smaller at-risk package for adults who don't yet meet full nursing-facility level of care but are at risk of placement. Its annual HCBS expenditure cap is $18,000 per year, excluding the cost of minor home modifications. Same service array as Group 2, just bounded by a lower expenditure ceiling.5

ECF CHOICES is an employment-first program for younger adults (under 65) with intellectual or developmental disabilities. Its catalog includes Personal Assistance (limited to 215 hours per month), Community Integration Support Services, Independent Living Skills Training, and a Family Caregiver Stipend in lieu of Supportive Home Care.6

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 payroll, tax withholding, electronic visit verification (the CareAttend mobile app), worker enrollment, and direct deposit. Eligible workers include adult children, siblings, parents of an adult member, friends, neighbors, and other relatives. A member's spouse, court-appointed conservator, legal guardian, or CD representative is not eligible to be paid as the caregiver. Under the TennCare-approved CDTN rate schedule (revised July 30, 2025), the member sets each worker's wage up to a service-specific maximum, roughly $16 to $19 per hour for personal care and respite (for example, a Personal Care Visit maximum of $19.16/hour and a Respite maximum of $18.93/hour). CDTN routes by managed care plan: UnitedHealthcare 1-888-444-3109, Wellpoint 1-888-398-0664, BlueCare Tennessee 1-888-450-3240. (For the full paid-family-caregiver pathway, see How to Get Paid as a Family Caregiver in Tennessee.)7

How to Find a Licensed Agency

First, verify which license the agency 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 of licensed home health and hospice agencies (roughly 300-400 licensed HHAs statewide).3

For Medicare certification status, check Medicare.gov Care Compare, where every Medicare-certified HHA carries a star rating, recent deficiency reports, and patient-experience results.

For non-medical home care (PSSA): check the TDMHSAS Office of Licensure provider list at tn.gov/behavioral-health/licensing.html. Some Tennessee agencies operate under HFC's parallel Professional Support Services license at Chapter 0720-35 instead, and those 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 or Medicaid-enrolled, and which TennCare MCOs do you contract with?
• Are your caregivers W-2 employees of the agency (not 1099 contractors)?
• What is your background-check protocol, and what is your minimum-hour requirement per visit? (Most TN agencies require 3-4 hour minimums.)
• How is supervision handled, and what is your caregiver-continuity policy: same caregiver each visit, or rotating staff?
• Do you have 24/7 on-call backup, and can I see the written care plan and its review schedule?

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 shifts tax and liability burden onto the worker (or onto you).
• No formal background check, or one 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, or a refusal to share the supervision schedule or written care plan. Both documents are required by state rules.
• Caregiver turnover above 50% per year, or a refusal to put rates and overtime policy in writing, which matters most for live-in care given the unsettled FLSA situation.1

Learn More

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

The information on Brevy.com is for educational purposes only and is not a substitute for professional legal, financial, or medical advice. Rules vary by state and program and change frequently. Always verify with the relevant agency or a qualified professional. Brevy is not a law firm, financial advisor, or healthcare provider.