ACLF Memory Care Licensing Tennessee — Secured Unit Rules and Standards

Tennessee Doesn't Issue a "Memory Care" License

This is the first and most important thing families need to understand: there is no standalone memory care license in Tennessee. The phrase "memory care" is a marketing term, not a regulatory category. What facilities call their "memory care wing" or "memory care community" is actually a secured unit operating under a broader facility license.

The Health Facilities Commission (HFC) licenses senior living facilities under several distinct categories, and memory care services can be delivered within Assisted-Care Living Facilities (ACLFs), Residential Homes for the Aged (RHAs), and, as special care units, within Skilled Nursing Facilities (SNFs). RHAs can admit residents with early-stage dementia under specific conditions and may operate secured units subject to their licensing requirements.

Understanding which license type a facility holds tells you what care they can legally provide, what they cannot do, and at what point your parent may need to transfer out.

ACLF Rules for Secured Memory Care Units

Assisted-Care Living Facilities are governed by HFC Chapter 0720-26. They serve aged individuals who need help with activities of daily living but don't require continuous skilled nursing. An ACLF can perform limited medical services under the supervision of a licensed nurse on premises or on-call.

To operate a secured unit — defined as a distinct part of the facility where residents are intentionally denied egress for safety reasons — an ACLF must meet specific structural and operational requirements:

Physical separateness. The secured unit must be a physically identifiable, structurally distinct area — an entire wing, floor, or separate building. It can't be a hallway with a locked door at one end. The unit must be separated from the rest of the facility by magnetically locked doors that automatically release when the fire alarm activates or power fails.

Interdisciplinary admission team. A marketing representative cannot admit someone to a secured unit. Tennessee regulations require a formal evaluation before admission by a team consisting of at least a physician, a registered nurse, and a family member or patient advocate. This team must certify that the facility can meet the resident's specific behavioral and medical needs.

Quarterly re-evaluations. Once admitted, the resident's physical and cognitive status must be re-evaluated by the interdisciplinary team at least every three months. The question at each review: is continued placement in the secured unit still appropriate?

Therapeutic outdoor access. The unit must provide direct, barrier-free access to a secured outdoor courtyard where residents can walk safely without elopement risk. The area must support emergency evacuations.

Staff training mandates. All direct-care staff assigned to a secured dementia unit must complete 40 hours of specialized classroom instruction covering dementia behaviors, communication techniques, and stress reduction — beyond the standard state-approved nurse aide training. All facility staff must participate in annual in-service dementia training.

24/7 awake staffing. At least one awake attendant must be physically present in the secured unit at all times — day, evening, and overnight.

Family support groups. Secured units must organize and facilitate a support group for families of residents, meeting at least quarterly.

Residential Homes for the Aged (RHAs)

RHAs, governed by HFC Chapter 0720-21, provide a lower intensity of care than ACLFs. They offer domiciliary care — meals, housekeeping, personal supervision — but cannot directly administer medications or provide technical nursing care unless those services are contracted out to an independent, licensed home health agency.

Residents with early-stage dementia may be admitted to an RHA, but only after a comprehensive evaluation by an interdisciplinary team confirms the facility can meet their needs. RHAs may operate secured units for eligible residents, subject to their licensing requirements. The regulation also requires that RHA residents be capable of evacuating the building within 13 minutes — a standard that excludes many people with moderate-to-advanced dementia.

As a care setting for dementia, RHAs work for a narrow window: when a parent's cognitive decline is mild enough to meet the facility's admission and evacuation requirements, but they can no longer manage independently. Once behaviors like nighttime wandering, combativeness, or severe confusion emerge, the RHA may no longer be an appropriate setting.

What ACLFs Cannot Do

Understanding the boundaries of the ACLF license is critical for planning care transitions. ACLFs are prohibited from admitting or retaining residents who:

• Require continuous skilled nursing care
• Have active stage III or IV pressure ulcers
• Require physical or chemical restraints
• Cannot assist with self-preservation (meaning they can't participate at all in their own evacuation during an emergency)

If a non-ambulatory person is admitted, they must be capable of self-transferring from a bed to a wheelchair. Once a resident's dementia advances to the point where they need continuous medical monitoring, the ACLF must discharge them to a licensed skilled nursing facility.

This means the ACLF memory care unit is a mid-stage solution. It works well for the period when a parent needs a secured environment and dementia-trained staff but doesn't yet need round-the-clock nursing. When the disease progresses past that point, a nursing facility becomes the legally required next step.

The Dementia Disclosure Requirement

Under T.C.A. § 68-11-1404, any healthcare facility that markets itself as providing specialized Alzheimer's or dementia care must give prospective residents or their legal representatives a detailed written disclosure before admission. This disclosure must cover:

• The program's overall philosophy and mission
• The specific criteria and assessment tools used for admission, transfer, and discharge
• Staffing patterns, ratios, and dementia training credentials
• The frequency, duration, and types of therapeutic activities offered daily
• Physical environment, safety features, and security protocols
• The complete fee structure, including any additional charges for dementia-stage progression

If a facility refuses to provide this disclosure or gives you a vague brochure instead of specific operational details, that's a regulatory red flag. They're required by state law to give you this information before you sign anything.

How to Verify a Facility's License

The HFC maintains a public facility search tool at tn.gov/hfc. You can look up any senior living facility by name or location and verify its license type (ACLF, RHA, or SNF), bed count, and active status. This is the first step in due diligence — before you tour, before you ask about pricing, before you compare options.

Beyond the license check, request the facility's most recent CMS Statement of Deficiencies (Form CMS-2567) and Plan of Correction. Facilities are required to make these available. A legislative audit found that over half of Tennessee's licensed facilities were overdue for their mandatory 15-month inspections, so the most recent survey may be dated — but it's still the best regulatory snapshot available.

For the complete facility evaluation framework — including a scored checklist covering licensing, staffing, clinical capacity, and contract terms — our Tennessee Dementia & Memory Care Guide includes tools specifically designed for families comparing memory care options across the state.

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