Ownership: Tennessee limits who may employ physicians: T.C.A. 63-6-204 permits employment by licensed hospitals and their affiliates, physician professional corporations and physician groups, medical school faculty practice plans, FQHCs, rural health clinics, employers treating their own employees and a few other listed settings, and requires that employers not interfere with medical judgment.
Certificate of need: Tennessee has an active CON program run by the Health Facilities Commission.
Nurse practitioners: AANP classifies Tennessee as restricted practice: NPs must practice under physician supervision (T.C.A. 63-7) and may prescribe Schedule II to IV drugs only within formulary limits or after consulting the supervising physician.
Who can own a medical clinic in Tennessee
Tennessee limits who may employ physicians: T.C.A. 63-6-204 permits employment by licensed hospitals and their affiliates, physician professional corporations and physician groups, medical school faculty practice plans, FQHCs, rural health clinics, employers treating their own employees and a few other listed settings, and requires that employers not interfere with medical judgment. A general business owned by non-physicians is not on that list, so lay-owned practices typically use a physician-owned PC or PLLC with an MSO.
Sources: law.justia.com
Business entity and registration
Physicians usually form a medical professional corporation or medical professional LLC, owned by licensed physicians (and certain permitted professional combinations), filed with the Tennessee Secretary of State; Board of Medical Examiners rule 0880-02-.20 says MPLLC articles filed with the Secretary of State are treated as filed with the Board.
Sources: law.cornell.edu, sos.tn.gov
Certificate of need in Tennessee
Tennessee has an active CON program run by the Health Facilities Commission. It covers hospitals, ambulatory surgical treatment centers, outpatient diagnostic centers, nursing homes, home care and hospice, rehab facilities and opioid treatment programs, plus services such as cardiac catheterization and linear accelerators; MRI and PET need a CON in counties of 175,000 or fewer residents. Premises used only as a physician's professional practice office are excluded, and NCSL reports ASCs are scheduled to be exempted in December 2027 under 2024 legislation.
Licenses, registrations and state agencies
The Tennessee Health Facilities Commission licenses 21 types of health care facilities, including hospitals, nursing homes and ambulatory surgical treatment centers, and also runs CON; ordinary physician offices are not licensed health care institutions. Pain management clinics need a separate license from the Department of Health with a pain management specialist physician as medical director, and medical spas must register with the Board of Medical Examiners.
Sources: tn.gov, tn.gov, law.justia.com
Tennessee-specific requirements to know
Pain management clinics must be licensed, keep a qualified pain management specialist as medical director, and stop operating if a replacement director is not approved after the department is notified within 10 business days. Prescribers must enroll in and use the Controlled Substance Monitoring Database (CSMD) under T.C.A. 53-10-305 and 53-10-310. Medical spa registration with the Board of Medical Examiners is renewed every 12 months.
Sources: law.justia.com, pdmpassist.org, law.cornell.edu
Agencies you will deal with
- Medical board: Tennessee Board of Medical Examiners
- Board of nursing: Board of nursing
- Board of pharmacy: Board of pharmacy
- Business registration: Tennessee Secretary of State, Division of Business and Charitable Organizations
- Facility licensing: Tennessee Health Facilities Commission
- Medicaid enrollment: TennCare
Nurse practitioners and physician assistants
Nurse practitioners: AANP classifies Tennessee as restricted practice: NPs must practice under physician supervision (T.C.A. 63-7) and may prescribe Schedule II to IV drugs only within formulary limits or after consulting the supervising physician.
Sources: storage.aanp.org
Physician assistants: Under Board rule 0880-02-.18, Tennessee PAs practice under a supervising physician with jointly signed written protocols updated every two years, physician review of at least 20% of charts every 30 days (plus all controlled substance prescriptions within set deadlines) and physician visits to remote sites at least every 30 days.
Sources: law.cornell.edu
Med spas, injectables and IV therapy in Tennessee
Any medical spa offering cosmetic medical services must register annually with the Tennessee Board of Medical Examiners (rule 0880-02-.24), naming an MD or DO with an active Tennessee license and practice as medical director or supervising physician who attests to responsibility for the services and to the signage and advertising rules in T.C.A. 63-1-153. Operating without current registration is unprofessional conduct by the supervising physician.
Sources: law.cornell.edu
Planning an aesthetic or IV business? See how to start a med spa and how to start an IV therapy business.
Step-by-step checklist in Tennessee
- Choose your structure and check ownership rules. Decide who will own the practice and confirm it fits Tennessee’s corporate practice of medicine rules. Tennessee limits who may employ physicians: T.C.A. 63-6-204 permits employment by licensed hospitals and their affiliates, physician professional corporations and physician groups, medical school faculty practice plans, FQHCs, rural health clinics, employers treating their own employees and a few other listed settings, and requires that employers not interfere with medical judgment.
- Form the entity with the Tennessee Secretary of State, Division of Business and Charitable Organizations. Physicians usually form a medical professional corporation or medical professional LLC, owned by licensed physicians (and certain permitted professional combinations), filed with the Tennessee Secretary of State; Board of Medical Examiners rule 0880-02-.20 says MPLLC articles filed with the Secretary of State are treated as filed with the Board.
- Get federal numbers. Apply for an EIN from the IRS, then a Type 2 NPI for the practice and Type 1 NPIs for each clinician through NPPES.
- Confirm licenses with the Tennessee Board of Medical Examiners. Every physician needs a Tennessee license. Check the board’s rules for any practice registrations, supervision agreements or office requirements before opening.
- Check certificate of need and facility licensing. Tennessee has an active CON program run by the Health Facilities Commission.
- Register to prescribe. Register with the DEA for controlled substances and complete any Tennessee controlled substance registration and prescription monitoring program enrollment. Pain management clinics must be licensed, keep a qualified pain management specialist as medical director, and stop operating if a replacement director is not approved after the department is notified within 10 business days.
- Set up lab, safety and privacy basics. Get a CLIA certificate if you will run any lab tests, including waived tests, and put HIPAA privacy and security and OSHA policies in place.
- Enroll with Medicare, Medicaid and insurers. Enroll in Medicare through PECOS, enroll with TennCare and start commercial credentialing early, because payer enrollment often takes months.
- Plan staffing around NP and PA rules. AANP classifies Tennessee as restricted practice: NPs must practice under physician supervision (T.C.A. 63-7) and may prescribe Schedule II to IV drugs only within formulary limits or after consulting the supervising physician.
- Launch your marketing before opening day. Claim your Google Business Profile, publish a website with online booking and start ads and content four to eight weeks before you open, so the schedule is not empty on day one.
The national steps are explained in more detail in our guide to how to start a medical clinic, and costs are broken down in how much it costs to start a clinic.
Marketing a new clinic in Tennessee
New clinics usually fail on cash flow before they fail on care. The fastest fix is patients booked before opening day: a complete Google Business Profile, a website with online booking, local search ads and a few weeks of social content showing the team and the space. We run that launch for new clinics and keep it going once the doors open.
Plan your Tennessee launch with us →
Sources
- https://law.justia.com/codes/tennessee/title-63/chapter-6/part-2/section-63-6-204/
- https://www.law.cornell.edu/regulations/tennessee/Tenn-Comp-R-Regs-0880-02-.20
- https://sos.tn.gov/businesses
- https://www.tn.gov/hfc/certificate-of-need-information/certificate-of-need-basics.html
- https://www.ncsl.org/health/certificate-of-need-state-laws
- https://storage.aanp.org/www/documents/no-index/state-fact-sheets/tennessee.pdf
- https://www.law.cornell.edu/regulations/tennessee/Tenn-Comp-R-Regs-0880-02-.18
- https://www.tn.gov/hfc/division-of-licensure-and-regulation.html
- https://law.justia.com/codes/tennessee/title-63/chapter-1/part-3/section-63-1-306/
- https://www.law.cornell.edu/regulations/tennessee/Tenn-Comp-R-Regs-0880-02-.24
- https://www.pdmpassist.org/pdf/state_summaries/Tennessee_Summary_Profile.pdf