Health Facilities Commission withdraws plan to charge CNA applicants after federal guidance; short-term contract approved

Fiscal Review ยท November 5, 2025

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Summary

The Health Facilities Commission told the Fiscal Review Committee it will not pass a $25 application fee to certified nurse aide applicants after CMS told the agency the fee would be prohibited. The agency requested a short-term contract to pay vendor costs and said TennCare will continue to provide federal matching funds.

Logan Grant, executive director of the Health Facilities Commission, told the Fiscal Review Committee that the commission had planned to pass a $25 application fee to certified nurse aide (CNA) applicants but withdrew that plan after the Tennessee Nursing Home Association and Tennessee Health Care Association raised concerns about a federal prohibition.

"We were notified by the Nursing Home Association, Tennessee Health Care Association, that there's a federal prohibition against that," Grant said, and the Centers for Medicare & Medicaid Services (CMS) confirmed the federal prohibition.

John Carr, director of administration for the Health Facilities Commission, said the commission now seeks approval for a short-term contract (up to one year) to pay the vendor because the vendor had bid on the project anticipating fees would be charged to applicants. The commission also plans a competitive RFP to consolidate the short-term contract and a longer-term solution.

Carr said TennCare pays 50% federal funds and 50% state funds for the contract and that TennCare confirmed access to federal funds should not be impacted by the change in applicant fees.

Representative Bridal asked for clarification and was told there will be no fees imposed on CNA applicants going forward under the federal requirement.

The committee approved the short-term contract and directed the agency to proceed with the RFP and related actions.

Why it matters: The CNA registry is a federally related program; the commission changed course after federal guidance, and the committee approved temporary funding to cover vendor costs while the state seeks a consolidated long-term contract.

What to watch: The Health Facilities Commission said it will issue an RFP for a consolidated contract and coordinate with TennCare on funding and federal requirements.