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, Medicare also requires the patient to be homebound, and for covered services the patient generally pays $0 under Medicare or TennCare.3,2,4

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, with statutory backbone at T.C.A. §33-2-421. The rule says an agency needs a license from either the Tennessee Department of Mental Health and Substance Abuse Services (TDMHSAS) or the Department of Intellectual and Developmental Disabilities (DIDD). TDMHSAS's Office of Licensure inspects PSSAs and keeps the statewide files on them.1

That two-department wording matters when you check a license. An agency licensed by either department may provide personal support services to people with physical or other disabilities, so ask which department issued the license and check it with that department.1

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: also part of the rule's definition, delivered in the person's home

What PSSA caregivers may NOT do. The rule defines a "service recipient" as someone who depends on personal support services but does not require nursing-level services in connection with an acute episode of illness or injury. On medication it's precise: a PSSA worker may give medication reminders and open medication packaging, but may not give injections or any form of medication administration reserved for people licensed under Title 63, Chapter 7. Care that needs a nurse moves the service into home health.1

Personnel requirements under 0940-05-38-.07: caregivers must be at least 18, submit to a criminal background check every two years (or within 10 days of hire), be checked against the Tennessee Abuse Registry and Sexual Offender Registry annually and before any direct contact with a client, carry documented training specific to the recipient's needs, and have annual performance evaluations. Each personnel file must also hold a five-year work history and references from at least three people.1

Ask for the consumer notice. Before service begins, T.C.A. §33-2-421(c) requires the agency to give you a written notice saying whether it is the caregiver's employer or contractor, and what it will pay: wages, overtime past 40 hours a week, taxes, Social Security, workers' compensation, and unemployment.1

One exemption that matters for consumers: a home care organization licensed by HFC under T.C.A. Title 68, Chapter 11, Part 2 does not also need a PSSA license. That includes agencies holding HFC's Professional Support Services license under Chapter 0720-35, HFC's parallel pathway for non-medical home care. Whichever license the agency holds, verify it's current.1,3

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 Department of Health's Board for Licensing Health Care Facilities. Public Chapter 1119 of 2022 moved home care organization licensure to HFC, and the renumbering into HFC's Title 0720 series took effect July 1, 2022. Third-party guides still citing 1200-08-26 are using pre-2022 chapter numbers.3

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 the PSSA rule's training requirements, not a nurse's plan of care. The job title "home health aide" is used in both settings, which is the single biggest source of confusion in this category.3

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. Many agencies hold both.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.3

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.2,4

Source: CareScout 2025 Cost of Care Survey, Median Cost Data Tables. CareScout publishes one Tennessee row, not per-metro figures, so it gives no separate figure for Nashville, Memphis, Knoxville, Chattanooga, or the Tri-Cities; get written quotes from local agencies. The 2025 survey merged the older "homemaker" and "home health aide" categories into a single "non-medical caregiver" line, so a 2024 homemaker figure and this 2025 figure aren't a year-over-year series. Nationally, CareScout reports the median rose 3% year over year to $35 an hour.1

Live-in home care pricing varies by agency, so compare written quotes. The Department of Labor's Fact Sheet 79B says live-in domestic workers must be paid at least the federal minimum wage, currently $7.25 an hour, for all hours worked. Meal, sleep, and off-duty time can be excluded by agreement, but time interrupted by a call to duty counts as hours worked, and live-in workers may be exempt from federal overtime. Tennessee has no state minimum wage statute, so the federal floor applies.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 proposed rule published July 2, 2025 would rescind that rule entirely. Until a final rule issues, the suspension stays in effect. 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. A caregiver you hire yourself who serves only one person, isn't in a business arrangement to serve others, and doesn't hold themselves out to the public as being in the business, is exempt from PSSA licensure. So none of the PSSA protections apply on their own: no required background and registry checks, and no consumer notice setting out who pays wages, overtime, taxes, Social Security, workers' compensation, and unemployment. If you hire directly, settle those questions with the caregiver in writing.1

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 when that is the only care needed. While a nurse or therapist is visiting, though, a home health aide's covered help can include bathing, grooming, help with walking, and feeding, so ask the agency for aide hours.2

2. The cost is $0 for covered services, with no deductible and no copay. Durable medical equipment is the exception: Medicare pays 80% of the approved amount, and you pay 20% after the Part B deductible.2

3. Four eligibility tests all must be met (the federal home health rule is 42 CFR §409.42):2,3,6

The physician or allowed practitioner reviews the plan of care periodically, and coverage holds only while all of these conditions are still met.6

Medicare does NOT cover at home: 24-hour care, meal delivery, homemaker services such as shopping and cleaning that are unrelated to the care plan, or custodial care alone (bathing/dressing without a skilled need). If those are the only needs, Medicare is the wrong payer, look at private-pay home care, TennCare CHOICES, or whether a Medicare Advantage plan offers extra in-home benefits.2,6

Medicare Advantage equivalence. MA plans must cover all medically necessary Part A and Part B services that Original Medicare covers, and that includes home health. MA plans may require prior authorization before covering certain services, which Original Medicare generally does not, so ask the plan before home health starts. Most plans also offer extra benefits Original Medicare doesn't, such as routine dental, vision, hearing, and fitness; check the plan's own coverage documents for any in-home support.7

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 has hour limits, 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 for an adult they require enrolling in CHOICES or ECF CHOICES (covered in the next section), which means a long-term-care benefit package such as E, J, K, or L.4 Katie Beckett is a separate home and community based services (HCBS) pathway.8
• Private duty nursing for adults 21+ is limited to services needed to support ventilator equipment or other life-sustaining medical technology.4
• Adult home health hours are limited. Home health nursing care for adults 21+ is limited to 8 hours a day and 27 hours a week (30 for someone who qualifies for Level 2 nursing facility care). Home health aide and nursing services combined are limited to 8 hours a day and 35 hours a week (40 for Level 2).4

Children under 21. Under the federal EPSDT mandate, medically necessary services to treat a condition found through screening must be furnished to a child even when the state plan doesn't cover them for adults, so a child isn't held to the adult home health hours or the ventilator-only private duty nursing rule when more is medically necessary. On in-home care, that makes the child benefit meaningfully more generous than the adult one.4,5

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).4,3

Provider network. Which MCO networks an agency contracts with varies by agency, so ask before you start care. To confirm, use the MCO's online provider directory or call its member services line.3

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 TennCare's long-term services and supports programs that pay for home and community based services (HCBS), such as CHOICES, ECF CHOICES, and Katie Beckett.8

TennCare CHOICES Group 2 is the main one for most adults. It provides home and community based services in place of nursing facility care, at home or in a community-based residential alternative.8

CHOICES Group 2 covers a home and community based services array that includes personal care (up to 2,580 hours a year), adult day care (up to 2,080 hours a year), in-home respite (up to 216 hours a year), inpatient respite (up to 9 days a year), home-delivered meals (up to one a day), a personal emergency response system, assistive technology (up to $900 a year), enabling technology (up to $5,000 a year), minor home modifications, pest control, and community transportation. Those per-service limits are published in TennCare's Appendix A: CHOICES Benefit Table.8

What bounds the whole package is the Group 2 Individual Cost Neutrality Cap: the average cost of the level of nursing facility care the member would otherwise qualify for, counting home health and private duty nursing along with CHOICES services. Effective January 1, 2026, TennCare puts the average cost of Medicaid nursing facility reimbursement at $294.87 per day, $107,627.55 per year. A member who would qualify for enhanced respiratory care gets a higher cap: $173,010 a year at the tracheal suctioning rate, or $249,977.55 at the chronic ventilator rate. TennCare won't enroll someone in Group 2 unless the MCO or AAAD finds their needs can be met safely in the community within the cap, and a member whose needs no longer can be may be moved to nursing facility care. That decision can be appealed.8

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 excludes minor home modifications, and the two governments publish different figures for it: TennCare's own policy refers to an $18,000 cap, while CMS's approved terms set $19,764 per calendar year and let the state adjust it for provider rate increases. Ask the MCO which figure it's applying. Same service array as Group 2, bounded by that lower ceiling.8

ECF CHOICES is TennCare's managed-care benefit for Tennesseans with an intellectual or developmental disability, built around integrated employment and independent community living. Its catalog includes Personal Assistance (limited to 215 hours per month), Community Integration Support Services, and Independent Living Skills Training. The Family Caregiver Stipend, paid in lieu of Supportive Home Care, is offered only in the Essential Family Supports group (Group 4).9

Consumer Direction. In CHOICES, members can elect to direct their own services and become the employer of the people who provide their care, hiring, training, and scheduling workers themselves. Consumer Direct Care Network Tennessee (CDTN) is the Fiscal Employer Agent and supports members through the CareAttend electronic visit verification mobile app. Members can hire family members, friends, neighbors, or other acquaintances, but under the CMS-approved terms a spouse cannot be the paid worker, and neither can the member's consumer-direction representative; confirm any other limits with the MCO Coordinator before hiring. Under the TennCare-approved CDTN rate schedule, the member sets each worker's wage up to a service-specific maximum: $19.16 an hour for a Personal Care Visit and $18.93 an hour for Respite. The amount charged to the member's budget is higher, because it includes employer taxes. 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.)9

ECF CHOICES has its own consumer-direction option, including budget authority, in which a fiscal employer agent handles the financial administration and provides supports broker assistance. The wage maximums above are CHOICES rates, so confirm ECF CHOICES hiring rules and wage limits with the MCO.9

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. HFC doesn't publish a statewide total; adding up the county lists gives a rough range of 300-400 licensed HHAs, an estimate rather than an official count.3

For Medicare certification status, ask the agency directly, then look it up on Medicare.gov's Care Compare tool.

For non-medical home care (PSSA): check the license with the department that issued it. TDMHSAS's Office of Licensure (tn.gov/behavioral-health/licensing.html) keeps the statewide PSSA files, and the rule also lets DIDD license PSSAs.1 Some Tennessee agencies operate under HFC's parallel Professional Support Services license at Chapter 0720-35 instead; for those, check the license with HFC.3

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 (PSSA, licensed by TDMHSAS or DIDD)?
• Are you Medicare-certified or Medicaid-enrolled, and which TennCare MCOs do you contract with?
• Can I see your written consumer notice, which must say whether you employ the caregiver or contract with them?
• How do you meet the registry-check requirement (every year and before any direct contact), and what does the documented training for my parent's caregiver cover?1
• Will you confirm in writing that the caregiver gives medication reminders only? Administering medication is outside a PSSA's scope.1
• How is supervision handled, and will the same caregiver come each visit?

Inspection and complaint history. For HHAs, complaints and inspection-report requests go through HFC. For PSSAs, TDMHSAS's Office of Licensure investigates licensed and unlicensed providers and keeps the statewide files. Ask the agency directly about any recent complaints and how they were resolved, and check the answer with the state.3,1

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.
• A consumer notice that is vague about who pays. Whether the agency calls itself the caregiver's employer or a contractor, the notice must say what it will pay: wages, overtime past 40 hours a week, taxes, Social Security, workers' compensation, and unemployment. If any of those is missing, ask who covers it before service starts.1
• No formal background check, or one run only at hire and never repeated. PSSA rules require a criminal background check every two years and a check of the Tennessee Abuse Registry and Sexual Offender Registry every year.1
• A refusal to say who supervises the caregiver day to day. For a PSSA, the written consumer notice must name who handles supervision.1
• No written consumer notice before service starts, or a refusal to put rates and overtime policy in writing. Tennessee law requires the notice, and overtime terms matter 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.