Tennessee: Ownership and Oversight
Strict CPOM (statute + AG opinion). Physician-only entity ownership with a short PA exception, plus some of the most prescriptive oversight mechanics in the country: fixed chart-review percentages, site-visit clocks, and controlled-substance review deadlines.
Who the statute actually covers
- MPC / MPLLC owner (Rules 0880-02-.20, 1050-02-.19): physicians licensed under T.C.A. Title 63, ch. 6 (MD) or ch. 9 (DO), and entities owned by them. "Physician" does not include PAs, APRNs, or chiropractors.
- "Supervision, control and responsibility" (T.C.A. § 63-6-204(b)): the standard the AG used to leave a narrow, risky gray area for non-professional-entity structures.
- "Endorsed" PA (T.C.A. § 63-19-106, 2022): a PA with at least 6,000 documented postgraduate clinical hours who moves from detailed protocols to a lighter collaborative agreement.
1. Who can own what
| Entity / Path | Who may own | Key limits |
|---|---|---|
| Medical PC / PLLC | Physicians (Title 63 ch. 6 or 9) and physician-owned entities only. | T.C.A. § 48-101-610; § 48-249-1109. |
| PA co-ownership | PAs may co-own an MPC/MPLLC only with physicians, except radiologists, pathologists, and anesthesiologists. | A PA cannot solely own an entity providing medical services (AG Op. 07-116). |
| NP / APRN / RN | Not lawful to own and operate a PC/PLLC providing medical services (AG Op. 07-116). | Narrow non-professional-entity gray area under § 63-6-204(b). Treat as high-risk. |
| Physician-for-hire supervision | A physician may not be employed or contracted by an NP or PA solely to supply required supervision (AG Op. 07-116). | The medspa/franchise fact pattern regulators look for. |
| Lay / MSO | Not permitted in the professional entity. | Board may notify the AG and pursue judicial dissolution. |
2. Collaborative and supervisory oversight
| Role | Agreement required | Oversight mechanics | Path to independence |
|---|---|---|---|
| PA | Non-endorsed PA: jointly developed written protocols. Endorsed PA (6,000+ hours): collaborative agreement (T.C.A. § 63-19-106). | No numeric ratio. Chart review: 100% within 10 days of any controlled substance prescription; at least 20% of all charts every 30 days; enhanced review for at least 6 months on any specialty change. Remote site visit every 30 days. PA Schedule II/III opioids capped at a nonrefillable 30-day course. | Endorsement lightens paperwork; collaborating physician requirement itself is permanent. |
| NP / APRN | Written protocols with a supervising physician in the same area of medicine, kept at each site, updated at least every 2 years (Rule 0880-06-.02). CSMD supervisory confirmation for controlled substances; joint-name prescription pads. | No numeric ratio. Chart review: 20% every 30 days; personal review and chart certification within 30 days for controlled-substance encounters, reviewed every 10 business days. Site visit every 30 days. | None. TN has no APRN full practice authority pathway. |
3. Primary authorities
- T.C.A. § 48-101-610; § 48-249-1109; Rules 0880-02-.20 and 1050-02-.19.
- Tenn. Att'y Gen. Op. 07-116 (Aug. 2007).
- T.C.A. § 63-19-106 (2022).
- Rule 0880-06-.02; § 63-6-204.
Practical read: Tennessee is where loose supervision models go to die. The 20% chart review, 30-day site visit, and 10-day controlled substance review are audit math: a physician who signs on with too many clinicians cannot physically comply, and the AG has already rejected both NP-owned medical entities and physicians hired only to sign. Build the compliance calendar before signing the deal.
General education, not legal advice.