Navigating TN Jurisprudence for PTs and PTAs

Learning Outcomes

After this course, participants will be able to:

• Identify at least 3 sources of rules and laws governing physical therapy practice in Tennessee. 
• Explain how to access the most recent Tennessee Physical Therapy Practice Act and apply the clinical scope of practice in Tennessee.
• List the key supervision requirements for physical therapist assistants, PT/PTA students, and physical therapy aides.
• Examine the Tennessee Practice Act to determine requirements for physical therapists and physical therapist assistants to maintain and renew their licenses, including continuing competence requirements.  

Sources of Law Governing PT Practice in Tennessee

Overview of Regulatory Hierarchy

Why Jurisprudence Matters: Protecting the Public and the Profession

Jurisprudence, in the context of physical therapy practice, is the study and application of the laws, rules, and professional standards that govern what you can and cannot do as a licensed practitioner. For many clinicians, the word "jurisprudence" calls to mind law school coursework or abstract legal theory — neither of which seems particularly relevant when you are fitting a patient for a walker or progressing a post-operative shoulder through a range-of-motion protocol. But this perception misses something important. Every clinical decision you make occurs within a legal and regulatory framework that defines the boundaries of your authority, shapes your professional relationships, and ultimately determines whether your license remains intact. Understanding that framework is not a bureaucratic inconvenience; it is a core professional competency.

The purpose of this regulatory framework is twofold. First, it exists to protect the public. Patients seeking physical therapy are often in vulnerable circumstances — they are in pain, recovering from surgery, managing a chronic condition, or working through a disability. They are not in a position to independently evaluate your clinical qualifications, verify your training, or assess whether your interventions meet an acceptable standard of care. The law steps into that gap. Licensure requirements, scope-of-practice definitions, and disciplinary procedures collectively ensure that only qualified individuals provide physical therapy services and that those individuals can be held accountable when they cause harm. Second, the regulatory framework protects the profession itself. Clear, enforceable standards elevate physical therapy in the eyes of other healthcare disciplines, payers, and the public. They reinforce that physical therapy is a science-based profession with rigorous expectations — not an unregulated wellness service.

The Layered Framework of Laws, Rules, and Policies

The rules governing your practice in Tennessee do not come from a single document or a single authority. They exist in layers, each building upon the one beneath it, and each carrying a different kind of legal weight. At the broadest level, federal law establishes baseline standards that apply across all fifty states. Beneath that, the Tennessee General Assembly has enacted statutes specifically addressing physical therapy practice. Those statutes delegate authority to an administrative agency — the Tennessee Board of Physical Therapy — which then promulgates rules that fill in the operational details the legislature left unspecified. The Board also issues policy statements that interpret how those rules apply to particular practice situations. Finally, professional organizations like the American Physical Therapy Association (APTA) publish standards and guidelines that, while not legally binding in the same way as statutes or rules, establish the professional benchmark against which your conduct will often be measured.

Think of this structure as a pyramid. Federal law sits at the apex. State statutes occupy the next tier. Administrative rules follow. Board policy statements and professional standards occupy the lower tiers — highly practical and directly applicable to day-to-day decision-making, but subordinate to the legal authority above them. As a licensed physical therapist or physical therapist assistant practicing in Tennessee, you are simultaneously accountable to all of these layers. Ignorance of any one of them is not a defense in a disciplinary proceeding; it is simply a risk you have chosen to carry.

How Federal Law Intersects with State Regulation

Before turning to Tennessee-specific sources, it is essential to understand where federal law enters the picture. Three bodies of federal law are particularly significant for physical therapy practice.

The first is Medicare and Medicaid. These federal programs are administered by the Centers for Medicare and Medicaid Services (CMS) and establish conditions of participation, documentation requirements, billing rules, and supervision standards that apply whenever you treat a Medicare or Medicaid beneficiary. CMS supervision requirements for physical therapist assistants, for example, may differ from what Tennessee's own rules specify — and when that occurs, the more restrictive standard generally governs. Federal anti-fraud and abuse laws, including the False Claims Act and the Stark Law, also operate in this space and carry consequences far more severe than a state board reprimand.

The second is the Americans with Disabilities Act (ADA). The ADA imposes obligations on physical therapy practices as places of public accommodation, including requirements related to facility accessibility, the provision of services to patients with disabilities, and the handling of requests for reasonable modifications. Physical therapists who also serve as employers must understand the ADA's employment provisions as well.

The third is the Health Insurance Portability and Accountability Act (HIPAA). HIPAA's Privacy Rule and Security Rule govern how you create, store, access, transmit, and dispose of protected health information. These federal requirements apply regardless of what Tennessee law says on the subject, and they establish both civil and criminal penalties for violations. HIPAA compliance is not optional, and it is not delegable — you are personally responsible for understanding and following the rules that apply to your handling of patient information, even if your employer has designated a privacy officer to manage compliance at the organizational level.

The Four Primary Sources of Rules and Laws

Source 1 — Tennessee Code Annotated (TCA), Title 63, Chapter 13: The Statutory Foundation

The Tennessee Code Annotated is the official compilation of all laws enacted by the Tennessee General Assembly. Title 63 addresses health professions generally, and Chapter 13 is devoted specifically to physical therapy. This is the Practice Act — the foundational statute that authorizes the existence of physical therapy as a licensed profession in Tennessee, establishes the Tennessee Board of Physical Therapy, and defines the essential parameters of lawful practice.

Chapter 13 addresses a range of critically important subjects. It provides the legal definition of physical therapy and delineates the scope of practice for both physical therapists and physical therapist assistants. It specifies the requirements for initial licensure, including education, examination, and character standards. It addresses license renewal, continuing competence requirements, and the consequences of practicing without a valid license. It grants the Board the authority to investigate complaints and impose discipline, and it enumerates the grounds on which a license may be suspended, revoked, or otherwise sanctioned. In short, TCA Title 63, Chapter 13 is the legal document that makes your license real — and it is the document that can take that license away.

Statutes enacted by the legislature carry the highest legal authority of any Tennessee-specific source. No administrative rule, Board policy, or professional guideline can contradict or override a provision of the Practice Act. When you read the statute, you are reading the law as the people's elected representatives have written it. Amendments to the statute require legislative action — a process that is deliberate and often slow. For this reason, statutory language tends to be broad and principle-based, leaving the operational details to be addressed through administrative rulemaking.

Source 2 — Tennessee Rules and Regulations, Chapter 1150-01: Administrative Rules

Because the legislature cannot anticipate every situation that will arise in clinical practice, the Practice Act delegates authority to the Tennessee Board of Physical Therapy to promulgate administrative rules. These rules are codified in the Tennessee Rules and Regulations, Chapter 1150-01, and they carry the full force of law. Violating a Board rule is legally equivalent to violating a statute — the consequences in a disciplinary proceeding are the same.

Chapter 1150-01 is where you will find the operational specifics that govern your daily practice. It addresses topics such as the required supervision ratio between physical therapists and physical therapist assistants, the standards for delegation to support personnel, the specifics of continuing education requirements for license renewal, the procedures for telehealth practice, and the standards applicable to various practice settings. While the statute tells you that supervision of PTAs is required, the rules tell you precisely what that supervision must look like. While the statute establishes that continuing education is a condition of renewal, the rules specify how many hours are required, what categories of education qualify, and how documentation must be maintained.

Administrative rules are promulgated through a formal rulemaking process that includes public notice and an opportunity for comment. Once adopted, they remain in effect unless amended or repealed through that same process. However, rules are revised more frequently than statutes, and it is entirely possible for Chapter 1150-01 to look meaningfully different from one renewal cycle to the next. This is one reason why staying current with the regulatory landscape is an ongoing professional obligation, not a one-time task.

Source 3 — Tennessee Board of Physical Therapy Policy Statements

Even carefully written administrative rules cannot address every nuance that arises in practice. The Tennessee Board of Physical Therapy issues policy statements to fill these interpretive gaps — to clarify how the Practice Act and the administrative rules apply to specific practice scenarios that clinicians regularly encounter. Policy statements do not create new law, but they represent the Board's official interpretation of existing law, and that interpretation carries significant practical weight.

Consider the significance of this. If a Board policy statement clarifies that a particular activity falls within the scope of practice of a physical therapist assistant under specified conditions, and you perform that activity under those conditions, you have a reasonable basis to defend your conduct if it is ever called into question. Conversely, if a policy statement indicates that the Board views a particular activity as outside the permissible scope of practice, continuing to perform that activity — even if you believe the statute or rules are ambiguous on the point — exposes you to meaningful disciplinary risk. Policy statements are, in a practical sense, the Board speaking directly to practitioners about how it intends to apply the law.

Policy statements are available through the Board's official resources and should be reviewed as part of any comprehensive effort to understand your regulatory obligations. Because they are interpretive rather than legislative, they can be revised or rescinded by Board action without the formal rulemaking process required for administrative rules — which means they can also change more quickly. Monitoring them is an important part of staying current with the Board's expectations.

Source 4 — Professional Standards: APTA Guide to Physical Therapist Practice and Standards of Practice

The fourth source of rules governing your practice differs in character from the first three. The APTA Guide to Physical Therapist Practice and the APTA Standards of Practice for Physical Therapy are not laws. They are not enacted by a legislature, promulgated by a regulatory board, or enforced through a licensing system. They represent the profession's own articulation of what competent, ethical physical therapy practice looks like — and that distinction matters.

It matters first because professional standards establish the clinical and professional benchmark against which your conduct will be measured in a variety of contexts. If a patient files a complaint against you, if a malpractice claim is initiated, or if a disciplinary proceeding is convened, the question of whether your practice met an acceptable standard of care will frequently be evaluated by reference to these documents. Expert witnesses will be asked whether your actions were consistent with what a reasonably competent physical therapist would do — and the APTA's published standards will inform that analysis. Compliance with professional standards is therefore not merely aspirational; it is protective.

It matters second because professional standards often reflect best practices that have not yet been codified into law. The regulatory process is slow and deliberate by design. Professional standards can evolve more rapidly in response to emerging evidence, new practice models, and changing patient populations. As a result, the standards published by the APTA may describe expectations that are more current and more clinically sophisticated than what the statute or administrative rules expressly require. Holding yourself to professional standards — not merely legal minimums — is the hallmark of a practitioner who is genuinely committed to quality care, and not simply to regulatory compliance.

Note that the APTA Code of Ethics, while closely related to these professional standards, is addressed in a separate course text course. The distinction between ethical obligations and legal obligations is itself an important area of study, and it will receive the dedicated attention it deserves.

How These Sources Interact

When Sources Conflict, Which Governs?

In an ideal regulatory environment, statutes, administrative rules, Board policy statements, and professional standards would all align perfectly, pointing in the same direction on every question that arises in practice. In reality, the relationship among these sources is sometimes more complicated. Apparent conflicts can arise — and knowing how to resolve them is an essential component of regulatory literacy.

The general principle is straightforward: a higher authority governs over a lower authority. A provision of the Tennessee Code Annotated takes precedence over an inconsistent administrative rule. An administrative rule takes precedence over an inconsistent Board policy statement. A Board policy statement takes precedence over professional standards that point in a different direction. This hierarchy exists because each source derives its authority from the one above it. The Board can promulgate rules only because the legislature authorized it to do so — and it can only promulgate rules that are consistent with that legislative authorization. If a rule conflicts with the statute it is supposed to implement, the rule is invalid.

In practice, genuine conflicts among these sources are relatively rare. More common is ambiguity — situations where the applicable legal source does not clearly address the question at hand. In those situations, lower-level sources provide important interpretive guidance. A Board policy statement may clarify how an ambiguous statutory provision should be read. Professional standards may fill in clinical details that the administrative rules do not specify. When you encounter ambiguity, the safest course of action is to read the relevant sources together, work from the most authoritative toward the least authoritative, and — when genuine uncertainty remains — contact the Board directly for guidance before proceeding. Documenting that you sought and received such guidance is itself a protective practice.

There is one additional dimension to this analysis worth noting: the relationship between federal and state law. As discussed earlier, federal programs like Medicare impose their own requirements. Where a federal requirement is more restrictive than Tennessee law, the federal standard governs for patients covered by that federal program. Where Tennessee law is more restrictive than a federal standard, Tennessee law governs for all licensees operating in the state, regardless of payer. Understanding which framework is more restrictive in any given situation requires careful analysis — and when the stakes are high, consultation with a healthcare attorney may be warranted.

The Role of the Tennessee Board of Physical Therapy

The Tennessee Board of Physical Therapy is the administrative agency charged with regulating physical therapy practice in the state. It is not an arm of the APTA. It is not a professional membership organization. It is a governmental body, created by the legislature, exercising delegated governmental authority — and that distinction should shape how you understand its role in your professional life.

The Board is composed of licensed physical therapists, physical therapist assistants, and at least one public member appointed to represent consumer interests. This composition reflects the dual purpose of the Board's work: to bring professional expertise to the regulatory process while maintaining accountability to the public the profession serves. Board members are appointed by the Governor and serve terms prescribed by statute. They are not paid employees of the state; they are practitioners and citizens who volunteer their time and expertise to this regulatory function.

The Board's authority is broad. It establishes the standards for licensure and examines applicants for compliance with those standards. It promulgates and amends the administrative rules that govern practice. It issues policy statements and interpretive guidance. And critically, it investigates complaints against licensees and has the authority to impose a full range of disciplinary sanctions — including public reprimand, probation, suspension, and revocation of licensure. In serious cases involving criminal conduct or fraud, the Board may refer matters to law enforcement or coordinate with other regulatory agencies. The Board's disciplinary decisions are public records, and they carry lasting professional consequences. Understanding the Board's authority is not a reason for anxiety; it is a reason for informed, deliberate professional conduct.

How to Stay Current: Monitoring Board Meeting Minutes and Regulatory Updates

The regulatory landscape governing physical therapy practice in Tennessee is not static. Rules are amended. Policy statements are issued, revised, or withdrawn. The Board receives and acts on complaints, and those actions sometimes generate guidance that affects how all practitioners should approach their work. Staying current with these developments is a professional obligation — not a passive one.

The most direct way to stay informed is to monitor the official resources of the Tennessee Board of Physical Therapy. The Board holds regular meetings, and the minutes of those meetings are public records that document the Board's discussions, decisions, and any guidance it issues. Reviewing these minutes is one of the most reliable ways to understand how the Board is currently thinking about specific practice questions. The Board's website also publishes the current text of the administrative rules, current policy statements, and information about any proposed rulemaking — including opportunities to submit public comment before new rules take effect.

Additionally, the Tennessee Physical Therapy Association (TPTA) regularly monitors regulatory developments and communicates relevant updates to its members. APTA's state advocacy resources and regulatory tracking tools offer another layer of information, particularly regarding federal developments that intersect with state practice. Continuing education courses on jurisprudence — including this one — fulfill a required component of license renewal precisely because the legislature and the Board recognize that staying current is an ongoing necessity, not a one-time accomplishment.

As a practical matter, consider building regulatory monitoring into your professional routine. Bookmark the Board's website. Subscribe to any available notifications of regulatory updates. When you read about a disciplinary action affecting another licensee, take a moment to understand what conduct triggered the action and what it means for your own practice. The goal is not to practice in a state of legal anxiety, but to practice with the awareness and intentionality of a professional who understands the rules of the field they have chosen to work in.

Physical Therapy Practice in Tennessee

Practicing physical therapy means more than delivering skilled clinical care — it means operating within a web of legal and ethical obligations that extend well beyond the treatment room. From protecting vulnerable patients to maintaining the integrity of the profession itself, Tennessee PTs and PTAs are held to clear standards of conduct under both state and federal law.

Whistleblowing

A whistleblower is someone who reports activity that is illegal, unethical, or otherwise contrary to professional or organizational standards — typically from within the workplace. As a PT or PTA, you have a clear ethical obligation to report such conduct when you encounter it, whether that involves a colleague's unsafe practice, billing fraud, patient abuse, or violations of professional boundaries. Who you report to will depend on the nature of the issue and may include your direct supervisor, your facility's compliance officer, your state licensing board, or a state or federal agency. It is normal to feel hesitant — many clinicians worry about retaliation, including strained relationships with colleagues, negative performance reviews, or job loss. Those concerns are valid, but legal protections exist at multiple levels. In Tennessee, the primary protection is the Tennessee Public Protection Act (TPPA), which prohibits employers from terminating employees solely for refusing to participate in or remain silent about illegal activities. PTs working in settings that bill Medicare or Medicaid have additional protection under both the Tennessee False Claims Act and the Tennessee Medicaid False Claims Act, which shield employees from retaliation for reporting fraudulent billing practices. Those working in long-term care should also be aware of T.C.A. § 68-11-903, which specifically protects employees who report violations of nursing home residents' rights. At the federal level, OSHA protects workers who report unsafe conditions, and the False Claims Act provides both protection against retaliation and potential financial recovery for those who report fraud against the government. Most healthcare employers also maintain internal anti-retaliation policies as part of their compliance programs.

The professional and ethical standard is clear: if you witness something wrong in your clinical environment, you are expected to speak up and take appropriate action. Silence can be construed as complicity — and in some circumstances, may itself carry professional or legal consequences.

Mandatory Reporting: Child Abuse

Under Tennessee Code Annotated §37-1-403(I), every person in Tennessee is a mandated reporter. Anyone with reasonable cause to believe a child is being abused or neglected is legally required to report it immediately to the Tennessee Department of Children's Services or local law enforcement. Reporters may remain anonymous.

Duty to Report Abuse, Neglect, or Exploitation of Adults

Under T.C.A. §71-6-103(b), any person — including but not limited to physicians, nurses, social workers, department personnel, coroners, medical examiners, alternate care facility employees, and caretakers — who has reasonable cause to suspect that an adult has suffered abuse, neglect, or exploitation must report it or ensure that a report is made. This duty to report persists even if the adult has died and includes reporting the circumstances surrounding the death.

Sexual Harassment

State and federal laws prohibit sexual harassment in the workplace. PTs and PTAs are expected to be familiar with both levels of applicable law.

Discrimination

Federal and state discrimination laws carry direct implications for how PTs and PTAs interact with patients, students, and colleagues. Our professional code of conduct expressly prohibits discrimination — and the law reinforces that obligation.

Protected categories include: age, race, disability, religion, national origin, sexual orientation, gender, and marital status.

In clinical practice, this means that every patient is entitled to equitable access to care and respectful treatment, regardless of their background or identity. Discriminatory conduct — whether in patient admission, clinical decision-making, or professional interactions — can expose you, your employer, and your facility to both ethical sanctions and legal liability. Familiarity with your state practice act and your facility's non-discrimination policies is essential.

Background Checks

Under Public Chapter 1084, healthcare facilities, emergency medical services providers, and individual health professionals are legally required to conduct background checks before hiring any person who will provide direct patient care and has not previously undergone one. These checks must include the state sex offender registry, the state abuse registry, and the abuse registries for any state in which the prospective employee has resided during the past seven years.

Changing Your Name on Your License

Each person holding a license who has had a change of address shall file in writing with the Board their current mailing address, giving both old and new addresses. Such notification must be received in the Board's administrative office no later than thirty (30) days after the change is effective and must reference the individual's name, profession, and license number. Licensees shall complete the change of address process through the electronic license portal within 30 days of the address change.

Please note: Updating your name with the Tennessee licensure board does not automatically update your records with APTA or TPTA. To update your name in APTA membership records, contact APTA Membership Services at 800-999-2782. You do not need to contact TPTA separately, as APTA and TPTA share membership information.

Changing Your Address on Your License

Each person holding a license who has had a change of address shall file in writing with the Board their current mailing address, giving both old and new addresses. Such notification must be received in the Board's administrative office no later than thirty (30) days after the change is effective and must reference the individual's name, profession, and license number. Licensees shall complete the change of address process through the electronic license portal within 30 days of the address change.

Tennessee Physical Therapy Practice Act

Finding the Law: Citation and History

The Tennessee Physical Therapy Practice Act is found in Title 63, Chapter 13, Parts 1, 3, and 4 of the Tennessee Code Annotated. Officially, the chapter is known and may be cited as the "Occupational and Physical Therapy Practice Act." That name reflects an important piece of legislative history. Originally, this title encompassed both the Occupational and Physical Therapy Practice Acts, resulting in some regulatory overlap between the two professions. That changed with the passage of Public Chapter 115 of the Public Acts of 2007, which replaced the combined Board of Occupational Therapy and Physical Therapy Examiners — and its two committees — with separate Boards of Occupational Therapy and Physical Therapy. While the chapter title retained its original language, the regulatory structures governing each profession now operate independently. The current edition of the Practice Act is available through the Tennessee Board of Physical Therapy's website, which also lists any rules adopted or amended between complete editions. Practitioners are well advised to consult that resource periodically, as rules can be amended between legislative sessions.

Legislative Intent: The Statute's Stated Purpose

The legislature has explicitly stated its purpose. The Act exists to protect the public health, safety, and welfare, and to provide for state administrative control, supervision, licensure, and regulation of the practice of physical therapy and occupational therapy. More specifically, it is the General Assembly's intent that only individuals who meet and maintain prescribed standards of competence and conduct may engage in the practice of physical therapy or occupational therapy as authorized by the chapter. That statement of intent is not merely prefatory language. It is the lens through which every other provision in the statute should be read. When a specific provision is ambiguous, courts and regulators will interpret it in light of that stated purpose. Reading the statute with that intent in mind transforms it from an intimidating legal document into a coherent framework you can actually use.

The Role of Part 1: General Provisions

Part 1 — the General Provisions — lays the foundation upon which everything else in the statute rests. It answers the threshold questions a reader must resolve before any of the more specific provisions can be correctly understood: What is this law trying to accomplish? What do the key terms mean? Who is in charge of enforcement, and what authority do they have? And who, if anyone, is exempt from the statute's reach?

Experienced readers of legislation know to begin with the general provisions precisely because they supply the interpretive tools needed to make sense of what follows. A term used in Part 3 governing licensure, or in Part 4 governing disciplinary proceedings, will carry the meaning assigned to it in Part 1's definitions section — not the meaning a reader might assume from everyday usage. A scope-of-practice question that arises in clinical practice cannot be answered correctly without first understanding what the statute means by "practice of physical therapy" and what the statute expressly excludes from that definition. In this sense, Part 1 is not merely introductory. It is foundational.

Scope Limitations Established in Part 1

Part 1 also establishes two important boundaries on the scope of physical therapy practice that every practitioner must understand from the outset, because they operate as constraints on everything the more specific provisions authorize.

The first boundary addresses the relationship between physical therapy and other licensed professions. Nothing in Chapter 13 shall be construed as allowing physical therapists to practice medicine, osteopathy, podiatry, chiropractic, or nursing. This provision does not diminish the scope of physical therapy practice; it clarifies that physical therapy licensure confers no authority to practice in those separately regulated domains. A physical therapist who performs an act that falls within the exclusive scope of medical practice, for example, cannot look to the Physical Therapy Practice Act as legal authority for doing so.

The second boundary addresses the referral requirement and a specific technical exclusion. Except as provided in § 63-13-303, the scope of physical therapy practice operates under the written or oral referral of a licensed doctor of medicine, chiropractic, dentistry, podiatry, or osteopathy, or a nurse practitioner or physician assistant pursuant to § 63-6-204(b). The reference to § 63-13-303 is significant; it signals that the referral requirement is not absolute, and that Part 3 creates a defined exception that practitioners must understand separately. Additionally, the scope of physical therapy practice expressly excludes the performance of treatment in which the physical therapist or physical therapist assistant uses direct thrust to move a patient's spine joint beyond its normal range of motion without exceeding the limits of anatomical integrity. This exclusion has direct clinical relevance and is not subject to any exception within the statute.

The Definitions Section: Why Precision Matters

One of the most practically significant features of Part 1 is its definitions section. Legal definitions are not the same as dictionary definitions, and the distinctions matter enormously in a regulatory context. When the Practice Act uses a defined term, it means precisely what the statute says it means — nothing more, nothing less — regardless of how that term might be used in ordinary conversation or in other professional contexts. Misunderstanding a defined term can lead a practitioner to draw incorrect conclusions about what they are authorized to do, what obligations they owe, or what conduct is prohibited.

Consider a few of the definitions that have direct operational significance for physical therapists and physical therapist assistants practicing in Tennessee.

Competence is defined as the application of knowledge, skills, and behaviors required to function effectively, safely, ethically, and legally within the context of the patient's role and environment. This definition is notable for what it includes beyond clinical skill. Functioning legally and ethically is expressly part of competence under Tennessee law — not a separate professional aspiration, but a component of the statutory standard itself.

Physical therapist and physiotherapist are defined together as a person licensed pursuant to Chapter 13 to practice physical therapy. The equivalence of these two terms is worth noting, as both are recognized designations under Tennessee law.

A physical therapist assistant is defined as a person who meets the requirements of the chapter for licensure as a physical therapist assistant and who performs physical therapy procedures and related tasks that have been selected and delegated only by the supervising physical therapist. Two elements of this definition deserve attention. First, the physical therapist assistant's scope of activity is defined in relation to delegation — the PTA does not independently select the procedures they perform. Second, that delegation authority rests exclusively with the supervising physical therapist, not with any other provider or supervisor.

Physical therapy is defined as the care and services provided by or under the direction and supervision of a physical therapist who is licensed pursuant to Chapter 13. This definition establishes that the concept of "physical therapy" is not limited to what the physical therapist personally performs; it includes care provided under the PT's direction and supervision, which has direct implications for how assistive personnel function within a physical therapy practice.

The practice of physical therapy is defined with considerable specificity, and that specificity matters. Whether by in-person encounter or via telehealth as authorized by § 63-1-155, the practice of physical therapy encompasses: examining, evaluating, and testing individuals with mechanical, physiological, and developmental impairments or other health and movement-related conditions to determine a treatment diagnosis, prognosis, and plan of intervention; alleviating impairments and functional limitations by designing, implementing, and modifying therapeutic interventions including therapeutic exercise, functional training, manual therapy, therapeutic massage, assistive and adaptive equipment, airway clearance techniques, debridement and wound care, physical agents or modalities, dry needling, and patient-related instruction; reducing the risk of injury and disability through promotion and maintenance of fitness, health, and quality of life in all age populations; and engaging in administration, consultation, education, and research. Practitioners should read this definition carefully. Dry needling, for example, appears expressly within the statutory definition of the practice of physical therapy — a fact that has significance both for what Tennessee-licensed physical therapists are authorized to do and for how the separately defined term "dry needling" operates within the regulatory scheme.

Dry needling is a skilled intervention that uses a thin filiform needle to penetrate the skin and stimulate underlying neural, muscular, and connective tissues for the management of neuromusculoskeletal conditions, pain, and movement impairments. This statutory definition establishes the boundaries of the technique as recognized under Tennessee law.

The definitions addressing physical therapy assistive personnel establish two distinct categories, and the distinction between them has supervisory and operational significance. "Other assistive personnel" means trained or educated health care personnel who perform specific designated tasks related to physical therapy under the supervision of a physical therapist, and who may be identified by the title specific to their training or education at the supervising physical therapist's discretion, provided they are properly credentialed and not prohibited by any other law. "Physical therapy aide" — a term that encompasses "aide," "technician," and "transporter" — means a person trained by and under the direction of a physical therapist who performs designated and supervised routine physical therapy tasks. The distinction between these two categories reflects different levels of external training, different credentialing considerations, and, as the rules and regulations further specify, potentially different supervisory requirements.

The definitions of supervision and on-site supervision establish different standards that apply in different practice contexts. Supervision of the physical therapist assistant means the supervising physical therapist will be readily available to the physical therapist assistant being supervised.

When the physical therapist assistant is practicing in an offsite setting, the supervising physical therapist will be immediately accessible by telecommunications, patient conferences will be regularly scheduled and documented, and supervisory visits will be made as further outlined in the rules and regulations.

On-site supervision, by contrast, requires that the supervising physical therapist or physical therapist assistant be continuously on-site and present in the department or facility where assistive personnel is performing services, be immediately available to assist the person being supervised, and maintain continued involvement in appropriate aspects of each treatment session in which a component of treatment is delegated to assistive personnel. These are meaningfully different standards, and applying the wrong one to a given practice situation can create both regulatory exposure and patient safety risk.

Finally, the definitions of restricted physical therapy license and restricted physical therapist assistant license serve notice that licensure in Tennessee is not simply an on-or-off condition. A restricted physical therapy license is one on which the committee has placed restrictions or conditions — or both — as to scope of practice, place of practice, supervision of practice, duration of licensed status, or type of condition of patient to whom the licensee may provide services. A restricted physical therapist assistant license is one on which the committee has placed any restrictions due to action imposed by the committee. Practitioners who hold or supervise individuals holding restricted licenses must understand precisely what those restrictions require.

A thorough understanding of Part 1 — its stated purpose, its carefully drawn definitions, and its express scope limitations — is not optional background reading. It is the essential foundation upon which every other provision of the Practice Act rests. The definitions supplied in § 63-13-103 will appear, often without elaboration, throughout Parts 3 and 4. The scope limitations established in § 63-13-104 operate as constraints that no other provision in the statute overrides, except where the statute itself creates a specific exception. And the legislative intent articulated in § 63-13-102 provides the interpretive compass that should guide any practitioner working through an ambiguous or novel question under the Act. With that foundation in place, the more specific provisions governing licensure, practice, and professional discipline become considerably more accessible — and considerably more useful.

Practice of Physical Therapy/Scope of Practice 63-13-303 (What we can do): 

The practice of physical therapy means providing physical therapy services, whether through an in-person encounter or via telehealth, telemedicine, or provider-based telemedicine, and may include:

• Examining, evaluating, and testing individuals with mechanical, physiological, and developmental impairments, functional limitations and disabilities, or other health and movement-related conditions to determine a physical therapy treatment, diagnosis, prognosis, a plan of therapeutic intervention, and to assess the ongoing effect of an intervention.
• Alleviating impairments and functional limitations by designing, implementing, and modifying therapeutic interventions that include, but are not limited to, therapeutic exercise, functional training, manual therapy, therapeutic massage, assistive and adaptive orthotic, prosthetic, protective and supportive equipment, airway clearance techniques, debridement and wound care, physical agents or modalities, dry needling, mechanical and electrotherapeutic modalities, and patient-related instruction.
• Reducing the risk of injury, impairments, functional limitation, and disability, including the promotion and maintenance of fitness, health, and quality of life in all age populations
• Engaging in administration, consultation, education, and research.
• Under Tennessee law (63-1-172), licensed physical therapists can independently refer or order physical therapy services for children as part of their Individualized Education Program (IEP) in school settings. As outlined in Chapter 13 of Title 63, physical therapists may make these referrals within their professional scope of practice and are recognized under federal Medicaid regulations (42 C.F.R. 440.110(a)(1)) as “licensed practitioners of the healing arts.” A physical therapist’s signature on the IEP serves as valid documentation of the referral, as long as the child has been appropriately evaluated and assessed by the therapist. This law supports the ability of physical therapists to initiate school-based services without needing a physician’s referral.

Direct Access (What we can do with some limitations noted)

The practice of physical therapy generally requires a written or oral referral from a referring practitioner (63-13-104): 

• Doctor of medicine, chiropractic, dentistry, podiatry, or osteopathy.
• Nurse practitioner or physician assistant

. However, a licensed physical therapist may (63-13-303):

• Conduct an initial patient visit without a referral.

• Provide physical assessments or exercise recommendations to an asymptomatic person without a referral.

• In emergency situations where emergency medical care is necessary, including minor emergencies, assist a person to the best of their ability without a referral. After providing assistance, the physical therapist must refer the person to the appropriate healthcare practitioner as needed.

• Treat a patient without a referral, within the scope of physical therapy, if the following conditions are met:

  • The physical therapist has notified the patient's physician.

  • If no progress is made within 30 days of the initial visit, the physical therapist must stop treatment and refer the patient to a qualified healthcare practitioner.

  • The physical therapist must consult the patient's healthcare practitioner if treatment continues beyond 90 days.

  • If the patient was previously diagnosed with chronic, neuromuscular, or developmental conditions, and the treatment is for symptoms related to those conditions, the 30-day and 90-day rules do not apply.

  • A physical therapist must refer patients to appropriate healthcare practitioners if symptoms or conditions arise that require services beyond the physical therapist's scope of practice, if progress is not being made, or if physical therapy treatment is contraindicated.

It is considered unprofessional conduct for a physical therapist to initiate or continue physical therapy services for a patient in a manner that violates the above.  

Exclusions from Physical Therapy Scope (63-13-104)

Physical therapy does not include the following practices:

• Medicine
• Osteopathy
• Podiatry
• Chiropractic
• Nursing

The scope of physical therapy practice does not permit treatment techniques that involve applying a direct thrust to a patient’s spinal joint with the intent of moving it beyond its normal range of motion, even if the maneuver remains within the limits of anatomical integrity.

Acceptance of Barter as Payment for Healthcare Services (63-1-166)

In Tennessee, healthcare professionals can accept goods or services as payment for their medical care, instead of money. This is often called "bartering."

Here's when it's allowed:

• The patient receiving the care does not have health insurance, as specifically defined by state law (Section 56-7-109).
• This direct exchange type is permitted even if other laws seem to prevent it.

Important Note for Providers:

If a healthcare provider accepts bartered goods or services, they must report this income to their licensing board each year using the required federal tax forms.

Parental Consent Required for Treatment of Minors- Exceptions - Penalties -Civil actions. (63-1-176)

Under Tennessee law, non-physician healthcare providers such as physical therapists must obtain parental consent before treating a minor, unless specific exceptions apply. A "minor" is defined as anyone under 18, except those who are emancipated, in the military, in need of emergency care, or are custodial parents themselves. Healthcare providers may not evaluate, diagnose, and treat minors without securing consent from a parent or legal guardian. Violating this requirement is considered unlawful and can lead to disciplinary actions by licensing boards, including suspension or revocation of a license. Parents may also file civil lawsuits to seek damages and other legal remedies. Courts must notify the appropriate regulatory authority if a provider is found to have knowingly violated the law, and legal actions must be initiated within the timeframes established by law.

Supervision of Students and Assistive Personnel (63-13-311)

The supervision of PTAs and assistive personnel is an essential part of our work.  Many issues before the board pertain to supervision or the lack thereof.  Note: We will review the more detailed supervision rules in the rules section under Supervision a little later.  

Physical therapists are responsible for the patient care provided by physical therapist assistants, assistive personnel, and students on clinical affiliations under their supervision. They can delegate specific tasks or procedures to these individuals as long as they are within the scope of their education or training.

Physical therapist assistants must always be supervised by a licensed physical therapist.

Physical therapy aides, other assistive personnel, and clinical students must always perform patient care activities under the onsite supervision of a licensed physical therapist or physical therapist assistant.

Physical therapist students and physical therapist assistant students must always be supervised by a physical therapist in accordance with the guidelines established by the state licensing board.  

Board of Physical Therapy (63-13-318)

The state board of physical therapy was established to oversee and regulate the profession.

The board is made up of five members, all state residents, appointed by the governor:

• Three members must be licensed physical therapists with at least 5 years of experience in the practice or teaching of physical therapy immediately before their appointment.
• One member must be a licensed physical therapist assistant with at least 5 years of experience in performing physical therapy procedures and related tasks, or in teaching a physical therapist assistant program, immediately before their appointment.
• One member must be a public representative — someone who is not engaged in the practice of physical therapy and has no professional or business connection to the healthcare industry.

Selection process and Diversity of members

The governor may appoint physical therapist and physical therapist assistant members from lists of candidates submitted by interested physical therapy groups, including the Tennessee Physical Therapy Association. The governor must also consult with these groups to identify qualified people for the positions.

When making appointments, the governor must try to:

• Include at least one member who is 55 years or older.
• Ensure the board’s gender balance reflects that of the state’s population.

Organization, Meetings, and Support

• The board meets annually to select a chair and a secretary and hold meetings as needed.
• For the board to make decisions, at least three members must be present. This is called a quorum.

• The board receives administrative, investigative, and clerical support from the division.

Compensation
Board members:

• are reimbursed for actual expenses incurred while performing their official board duties.
• are paid $100 per day for official board business.
• Have their travel covered under state travel regulations.

Terms, Vacancies, and Removals

• Regular appointments to the board last three years, and members continue to serve until a new appointment is made. If a position becomes vacant, the governor will appoint someone to fill the remainder of that term.

• The governor may remove a member—at the board’s request—for misconduct, inability to perform duties, or neglect of responsibilities.

Board Powers (63-13-304)

The Board of Physical Therapy has the power and authority to:

• Evaluate the qualifications of applicants for licensure and provide for the examination of physical therapists and physical therapist assistants.

• Set passing scores for the examination.

• Issue licenses to those who meet the qualifications outlined in this chapter.

• Regulate the practice of physical therapy by interpreting and enforcing this chapter, including taking disciplinary action.

• Adopt and revise rules as necessary and appropriate, consistent with this chapter, to fulfill its obligations. Once lawfully adopted, these rules have the effect of law.

• Establish requirements for assessing licensees' continuing competence.

• Set all license and registration fees.

The Board of Physical Therapy shall establish minimum competency requirements that a physical therapist must demonstrate in order to practice dry needling.

Exemptions From Licensure (63-13-305)

The following persons are exempt from licensure as a physical therapist or physical therapist assistant under this chapter:

• A person pursuing a degree in physical therapy or as a physical therapist assistant in a board-approved education program, fulfilling supervised clinical education requirements.

• A physical therapist or physical therapist assistant practicing in the United States Armed Services, United States Public Health Service, or Veterans Administration, as per federal regulations for state licensure of healthcare providers.

• A physical therapist or physical therapist assistant licensed in another U.S. jurisdiction, or a foreign-educated or internationally trained physical therapist credentialed in another country who is performing physical therapy as part of teaching or participating in an educational seminar for up to 60 days in a calendar year.

• A physical therapist or physical therapist assistant licensed in another U.S. jurisdiction temporarily performs physical therapy for members of established athletic teams, athletic corporations, or performing arts companies that are training, competing, or performing in Tennessee. The person must agree to use the Secretary of State for service of process as per Title 20, Chapter 2, Part 2.

• The practice of dry needling by a licensed physical therapist does not constitute the practice of acupuncture.

• Nothing in this chapter restricts persons licensed under any other state law from performing physical agent modalities for which they have received education and training.

License Renewal/Retirement/Inactive Status and Exemption from Continuing Education Requirements (63-13-308)

• Tennessee-licensed physical therapists (PTs) and physical therapist assistants (PTAs) must renew their licenses as specified by the regulations to practice in Tennessee. Failure to renew by the expiration date will result in the loss of the privilege to practice in the state.

• A physical therapist or PTA licensed in another jurisdiction that is a Physical Therapy Licensure Compact member can apply for compact privileges in Tennessee, provided they meet the requirements outlined in § 63-13-402, which will be discussed later in the course.

• Retired licensees are not required to register as long as they file an affidavit, provided by the board, stating the retirement date and any other necessary information. If a retired person wishes to return to practice, they must apply for licensure again and meet the continuing education requirements set by the board, unless exceptions are granted for good and sufficient reasons as determined by the board.

• A licensee can place their license in inactive status by submitting the appropriate forms and paying a biennial fee. To return to active practice, they must apply for re-licensure and fulfill the continuing education requirements set by the board, with potential exceptions as determined by the board.

Reinstatement of License, Failure to Renew License (63-13-309)

Reinstatement of a Lapsed License

If you miss the renewal deadline, you must pay the renewal fee, a late renewal penalty fee, and a reinstatement fee as set by the board’s rules.

Reinstatement After More Than Three Years

If your license has lapsed for more than three (3) consecutive years, you must reapply for a new license and pay the required fees.

You must also demonstrate your competency in physical therapy, which may involve:

• Serving an internship under a restricted license,
• Taking remedial courses,
• Or a combination of these, as determined by the board.
• The board may also require you to take an examination.

Administrative Revocation for Failure to Renew

If you fail to renew your license and pay the biennial renewal fee within sixty (60) days after it’s due, your license will be administratively revoked without further notice or hearing.

If your license is administratively revoked, you can apply in writing to the board for reinstatement. If you show good cause, the board may reinstate your license upon payment of all required fees.

Denial, Suspension, or Revocation of Licenses (63-13-312)

The board has the authority to deny, suspend, or revoke the license of a licensee who is guilty of violating any provisions of this practice act or is guilty of the following acts or offenses:

• Practicing physical therapy in violation of the laws or board rules.
• Practicing beyond the scope of physical therapy.
• Making false or misleading statements or being guilty of fraud in obtaining a license or practicing.
• Providing substandard care due to ignorance, incompetence, or negligence, whether or not the patient was harmed.
• Providing substandard care as a physical therapist assistant, including performing tasks that go beyond what the supervising physical therapist has assigned, even if no actual harm to the patient occurs.
• Failing to properly supervise or delegate duties that exceed the scope of practice for assistive personnel.
• Being convicted of a felony or any crime involving moral turpitude, including a guilty verdict or a plea of no contest.
• Practicing under the influence of controlled substances, drugs, chemicals, or alcohol.
• Facing disciplinary action in another state or territory for acts that would be grounds for discipline in this state.
• Engaging in sexual misconduct, including:
  • Having or soliciting sexual relationships with patients.
  • Making sexual advances or engaging in sexual conduct with patients.
  • Intentionally viewing a disrobed patient inappropriately during treatment.
• Participating in or accepting unearned fees or commissions for services not provided.
• Failing to adhere to professional ethics.
• Charging unreasonable or fraudulent fees for services.
• Making deceptive or fraudulent representations in the practice of physical therapy.
• Being judged mentally incompetent by a court.
• Aiding or abetting an unlicensed person in performing activities requiring a license.
• Failing to report violations of the chapter by other licensees or individuals.
• Interfering with or refusing to cooperate in an investigation or disciplinary proceeding, including threatening or harassing patients or witnesses.
• Failing to maintain patient confidentiality without prior written consent unless required by law.
• Failing to maintain adequate patient records, including evaluation, diagnosis, treatment plan, and discharge plan.
• Promoting unnecessary devices or treatments for financial gain.
• Providing unwarranted treatment or continuing treatment beyond the point of reasonable benefit.
• Violating or attempting to violate any provisions of the chapter, board orders, or any criminal statute.
• Engaging in fee-splitting or paying commissions for referrals.
• Acting inconsistently with generally accepted standards of physical therapy practice.
• Practicing with a mental or physical condition that impairs the ability to practice safely and skillfully.

Disciplinary Actions of the Board (3-13-313)

The board has the authority to take the following disciplinary actions, either individually or in combination, upon proof of any violation of this chapter:

• Deny an application for a license, whether the application is made through reciprocity or otherwise.
• Permanently or temporarily withhold the issuance of a license.
• Suspend, limit, or restrict a previously issued license for a duration and in a manner determined by the board.
• Issue a letter of reprimand.
• Reprimand or discipline an applicant or licensee in other ways, including informal settlements and letters of warning, as the board deems appropriate.
• Revoke a license.
• Refuse to issue or renew a license.
• Impose civil penalties for violations of this chapter. Additionally, the board may assess and collect reasonable costs incurred during a disciplinary hearing when action is taken against a person's license.

Administrative Procedure of Disciplinary Actions (63-13-314)

• Disciplinary Proceedings: Any disciplinary action against a licensee will follow the procedures outlined in the Uniform Administrative Procedures Act, found in Title 4, Chapter 5.

• Board’s Jurisdiction: The board has the authority to modify or refuse to modify any of its orders related to disciplinary actions if requested by any party involved.

Penalties (63-13-315)

Class B Misdemeanor

A person commits a Class B misdemeanor if they engage in an activity that requires a physical therapy license without obtaining the required license, violate any provision of this chapter, or use words, titles, or representations that imply they are licensed to practice physical therapy. This includes using any title or description incorporating terms or abbreviations restricted under §§ 63-13-103 and 63-13-310.

Investigation 

The board can authorize an investigation to determine if someone is unlawfully practicing physical therapy.

• Injunctive Relief: The board, through the attorney general's office, can seek a court order to stop anyone from violating this chapter. This legal action is in addition to any other penalties and remedies this chapter provides.

• Civil Penalty: A person who helps or requires someone else to violate this chapter or its rules, allows their license to be used by someone else, or acts with the intent to violate or evade this chapter or rules can be fined up to $1,000 for each violation.

Peer Assistance Program, Fees (63-13-316)

Instead of a disciplinary proceeding, the board may permit a licensee to actively participate in a board-approved peer assistance program.   This is more of a private way to address certain violations. 

Some of the circumstances that would qualify for a peer assistance program would be:

• The board has evidence that the licensee is impaired.
• The licensee has not been convicted of a felony relating to a controlled substance in the United States.
• The licensee enters into a written agreement with the board for a restricted license and complies with all the terms of the agreement, including making progress in the program and adhering to any limitations on the licensee's practice.
• The licensee signed a waiver allowing the peer assistance program to release information to the board if the licensee does not comply with the requirements of this section or is unable to practice with reasonable skill or safety.

The board will establish fees for this section.

Unlawful Use of Titles or Designations Indicating Licensure (63-13-310)

For professional identification and compliance with state law, licensed physical therapists in Tennessee must use the designation “PT” or “DPT,” as appropriate to their educational credentials, in connection with their name or place of business. It is unlawful for any individual or business to use terms such as “physical therapy,” “physical therapist,” “physiotherapy,” “doctor of physical therapy,” or related abbreviations (e.g., PT, DPT, RPT, LPT) unless the services are being provided by or under the direction of a physical therapist licensed under Tennessee law. This includes marketing, signage, or billing practices that imply the provision of physical therapy services.

Importantly, these regulations do not restrict professionals licensed under other Tennessee laws from practicing within their own scope of practice—provided they do not represent themselves as physical therapists or physical therapist assistants. Licensed physical therapist assistants must use the credential “PTA” to denote their licensure. No one may use the title “physical therapist assistant” or the abbreviation “PTA” unless they are properly licensed under this part.

Disclosures to Patient, Confidentiality, Complaints, and Display of Licensure (63-13-317)

The physical therapist must inform the patient of any financial arrangements associated with the referral process and disclose any financial interest in products endorsed or recommended to patients in writing. The licensee is also responsible for ensuring that the patient is informed of the freedom of choice regarding services and products.

Importantly, information regarding the physical therapist-patient relationship is confidential and may not be disclosed to any third party not involved in that patient's care without the patient's prior written consent. Physical therapist-patient confidentiality does not extend to cases in which the physical therapist must report information as required by law.

Any person may submit a complaint regarding any licensee or anyone potentially violating this chapter. Confidentiality shall be maintained subject to the law.

The department is to keep all information relating to complaints filed against licensees confidential until the information becomes public record as required by law. 

Each licensee must display a copy of their license or a current renewal verification at their place of employment, in a location accessible to the public.

Case Studies Involving HIPAA violations

Tennessee law under TCA 63-13-317 establishes that physical therapist-patient information is confidential and may not be disclosed without the patient's prior written consent. This obligation exists alongside — and does not replace — the federal confidentiality requirements established under the Health Insurance Portability and Accountability Act (HIPAA), which governs the use and disclosure of protected health information by all healthcare providers. A full treatment of HIPAA's Privacy Rule, Security Rule, and breach notification requirements is addressed in the companion ethics course. However, the following two enforcement actions — one a federal criminal prosecution involving a Tennessee hospital, and one a federal civil settlement with a physical therapy practice — illustrate what is at stake when patient confidentiality obligations are violated. Together they demonstrate that these consequences are not limited to large health systems or distant industries. They reach individual healthcare workers, and they reach physical therapy practices directly.

Case Study 1. Selling Patient Information for Financial Gain

United States v. Dandridge et al. — Methodist Le Bonheur Healthcare, Memphis, Tennessee (2022–2024)- What Happened

Between November 2017 and December 2020, five employees of Methodist Le Bonheur Healthcare in Memphis — most of whom worked in financial department roles — were paid by an outside individual, Roderick Harvey, to provide him with the names and phone numbers of patients who had been involved in motor vehicle accidents. Harvey then sold that information to third parties, including personal injury attorneys and chiropractors. Approximately 90 patients' personally identifiable information was disclosed without their knowledge or consent.

A federal grand jury indicted the five former employees for conspiring with Harvey to unlawfully disclose patient information in violation of HIPAA. Harvey was separately charged with obtaining patient information with the intent to sell it for personal financial gain — the most serious category of criminal HIPAA violation. Harvey was ultimately sentenced to five years of probation, one year of home detention, and ordered to pay a $50,000 fine. Each of the five former employees pleaded guilty, with each violation carrying a maximum penalty of one year of imprisonment, a $50,000 fine, and one year of supervised release.

Why This Matters to Physical Therapists

This case is directly relevant to physical therapy practice because the information was sold specifically to chiropractors and personal injury attorneys — professionals who operate in the same referral ecosystem as physical therapists. The financial incentives that drove this scheme are not unique to hospital billing departments; they exist in any setting where patient contact information has commercial value to third parties.

This case also illustrates that HIPAA criminal liability is not reserved for hackers or identity thieves. It attaches to any member of a healthcare workforce — clinical or administrative — who knowingly discloses patient information for purposes the patient has not authorized. Methodist Le Bonheur Healthcare had HIPAA privacy training in place and terminated the employees immediately upon discovering the unauthorized access. The hospital cooperated fully with the investigation. Institutional compliance programs do not insulate individuals from personal criminal liability.

As a physical therapist or physical therapist assistant, sharing a patient's name, contact information, diagnosis, or appointment status with any party not involved in that patient's care — without a valid written authorization or a specific legal obligation to disclose — is a potential violation of both TCA 63-13-317 and federal law. The Board may pursue disciplinary action independently of any federal enforcement proceeding arising from the same conduct.

Case Study 2: Patient Testimonials, Social Media, and Website Disclosures

Complete P.T., Pool & Land Physical Therapy, Inc. — HHS OCR Settlement, 2016 ($25,000)-What Happened

Complete P.T., Pool & Land Physical Therapy, Inc., a physical therapy practice located in the Los Angeles area, agreed to settle violations of the HIPAA Privacy Rules with the U.S. Department of Health and Human Services Office for Civil Rights. The settlement is an admission of civil liability, requiring payment of $25,000, adoption and implementation of a corrective action plan, and annual reporting of compliance efforts for a one-year period.

OCR received a complaint alleging that Complete P.T. had impermissibly disclosed numerous individuals' protected health information when it posted patient testimonials, including full names and full face photographic images, to its website without obtaining valid, HIPAA-compliant authorizations. OCR's investigation found that Complete P.T. failed to reasonably safeguard PHI, impermissibly disclosed PHI without authorization, and failed to implement policies and procedures to ensure written authorizations were obtained from patients before their information was used in marketing materials.

As part of the corrective action plan, Complete P.T. was required to remove all PHI from its website and affiliated web domains for which valid patient authorizations had not been obtained, provide additional HIPAA training to all staff, and submit documentation to OCR confirming compliance.

OCR Director Jocelyn Samuels stated: "The HIPAA Privacy Rule gives individuals important controls over whether and how their protected health information is used and disclosed for marketing purposes. All covered entities, including physical therapy providers, must ensure that they have adequate policies and procedures to obtain an individual's authorization for such purposes, including for posting on a website and/or social media pages, and a valid authorization form."

Why This Matters to Physical Therapists

This case is the only HIPAA enforcement action by OCR against a physical therapy provider currently published in HHS's resolution agreement database — making it directly and specifically relevant to every PT and PTA in practice today.

The scenario it describes is not unusual. Physical therapy practices regularly collect patient success stories, before-and-after photographs, and written testimonials to use in marketing materials, on websites, and on social media. The instinct to celebrate patient outcomes is natural — and sharing those stories can genuinely help prospective patients make informed decisions about care. But a patient's name, photograph, diagnosis, and treatment history are all protected health information under HIPAA. Posting them publicly without a valid, HIPAA-compliant written authorization is a federal privacy violation, regardless of whether the patient verbally agreed, seemed happy to participate, or never complained.

This obligation connects directly to the advertising rules in Chapter 1150-01-.13, which prohibit communicating personally identifiable patient information without obtaining explicit patient consent and require that all advertising content be truthful and non-deceptive. A testimonial posted without proper authorization violates both federal HIPAA requirements and the Board's own advertising standards — creating dual exposure to OCR enforcement and state disciplinary action from the same act.

The practical lesson is straightforward: before any patient's name, photograph, video, story, or identifying information appears on your website, social media account, marketing materials, or any other public-facing platform, a written, HIPAA-compliant authorization must be obtained, signed, and retained. A verbal agreement is not sufficient. A release signed for one purpose — such as participation in a research study — does not authorize use in marketing. Consult your facility's privacy officer or legal counsel if you are uncertain whether an existing authorization covers a specific intended use.

Physical Therapy Licensure Compact

What is the Compact?  

The state of Tennessee has enacted the Physical Therapy Licensure Compact (Tennessee Code Annotated 63-13-401 et seq.), joining a growing number of states in a formal interstate agreement designed to make it easier for licensed physical therapists and physical therapist assistants to practice across state lines. The Compact's primary goal is to improve public access to physical therapy services while allowing individual states to protect the health and safety of their residents.

It is important to understand what the Compact is not. It does not create a single national license, and it does not reduce any state's authority to regulate the profession within its borders. Instead, it creates a system of mutual recognition — member states agree to honor each other's licenses under specific conditions, allowing qualified licensees to practice in other member states without having to go through a full, separate licensure process in each one. A key principle embedded throughout the Compact is that physical therapy practice occurs in the state where the patient or client is located at the time of the encounter. Regardless of where a PT or PTA is physically located — or where their home license was issued — the laws and regulations of the state where the patient is receiving services govern that practice.

The Compact also serves several other important objectives. It encourages cooperation among member states in regulating multi-state physical therapy practice, supports spouses of relocating military members, and enhances the exchange of licensure, investigative, and disciplinary information between member states. These objectives reflect a recognition that the modern physical therapy workforce — including travel therapists and telehealth providers — increasingly operates across state lines, and that the regulatory framework should support rather than obstruct that reality.

The Compact is overseen by the Physical Therapy Compact Commission, a governing body made up of one delegate from each member state. That delegate is selected by the state's physical therapy licensing board and must be a current board member — either a physical therapist, physical therapist assistant, public member, or board administrator. The Commission's responsibilities include establishing bylaws, setting the fiscal year, maintaining financial records, and creating uniform rules to implement and administer the Compact. Those rules carry the force of law and are binding on all member states. The Commission meets at least once annually, and all meetings are open to the public with minutes recorded. Specific committees or the Executive Board may meet privately under defined circumstances outlined in the Compact.

The Executive Board consists of nine members — seven voting members elected from the Commission's membership, and two non-voting ex officio members representing the national physical therapy professional association and the organization of physical therapy licensing boards, respectively. The Executive Board prepares the budget, maintains the Commission's financial records, monitors Compact compliance among member states, and establishes committees as needed to ensure proper Compact administration. 

To join the Compact, a state must meet several baseline requirements. It must participate in the Commission's shared data system, have a process for receiving and investigating complaints, report disciplinary actions to the Commission, conduct FBI criminal background checks on licensure applicants — including biometric fingerprint-based checks — use a nationally recognized licensure examination, and require continuing competence for license renewal. These standards ensure that every member state operates at a consistent level of public protection, which is what makes the mutual recognition system reliable and credible. 

At the center of the Compact's infrastructure is a shared data system — a central database containing licensure, disciplinary, and investigative information on all licensees in member states. This system ensures that a disciplinary action taken in one state follows a licensee across state lines. The Commission is required to promptly notify all member states when adverse action is taken against any licensee. General disciplinary information is available to all member states, while investigative information is shared only with states where the licensee currently holds a license or is applying for one.

Growth of the Compact

The PT Compact was officially enacted on April 25, 2017, when the tenth state joined — marking the threshold required to bring the Commission into effect. Tennessee began issuing compact privileges on July 9, 2018. As of early 2025, more than 34 states plus Washington D.C. are actively issuing compact privileges, with additional states having enacted legislation that has not yet taken effect, as those states work through the implementation process. States that have enacted the Compact legislation may not be actively issuing or accepting compact privileges for some time, as they must first meet all of the Commission's participation requirements. Additional states continue to introduce legislation to join. For the most current and complete picture of which states are active, which have enacted legislation, and which have legislation in progress, visit the PT Compact Commission's interactive map at ptcompact.org.

Compact Privilege: What It Is and What It Requires

The compact privilege is the authorization a remote state grants to allow a licensee from another member state to practice within its borders as a physical therapist or physical therapist assistant under that state's laws and rules. Your home state is the member state where you permanently reside. A remote state is any other member state where you want to practice using the compact privilege rather than obtaining a full separate license.

To be eligible for and maintain the compact privilege, you must meet all of the following requirements at the same time. You must hold a current, active license in your home state. You must have no encumbrances — meaning no limitations of any kind — on any state license. You must have had no adverse action taken against any license or compact privilege within the past two years. You must notify the Commission that you are seeking the compact privilege in a specific remote state. You must pay all applicable fees, including any charged by the remote state. You must meet any jurisprudence requirements set by the remote state, which may include demonstrating knowledge of that state's physical therapy laws and rules. And you must report any adverse action taken against you by a non-member state to the Commission within 30 days of that action.

Your compact privilege is directly tied to your home state license — it is not a standalone credential. It remains valid only as long as your home state license remains valid and unencumbered. If your home state license is encumbered or subject to adverse action, you immediately lose the compact privilege in every remote state. You cannot regain compact privileges until your home state license is fully restored and two years have passed from the date of the adverse action. The same two-year waiting period applies if your compact privilege is removed in any remote state — and in that situation, you lose compact privileges in all remote states, not just the one where the action occurred.

When practicing in a remote state, you are practicing under that state's laws and regulations — not your home state's. This is a critical point. The compact privilege does not carry your home state's practice standards into the remote state. You are responsible for knowing and following the rules of every state in which you practice, and the remote state has full authority to regulate your conduct within its borders, remove your compact privilege, impose fines, and take any other action necessary to protect its citizens.

Verifying Compact Privilege Status

Whether you are an employer, a colleague, or a patient, it is important to know how to confirm that a PT or PTA is authorized to practice in Tennessee under a compact privilege. To verify whether a physical therapist or physical therapist assistant holds a valid compact privilege to practice in Tennessee, visit the PT Compact Commission's verification webpage at ptcompact.org. This resource allows you to confirm a licensee's current compact privilege status in any active member state. Relying on verbal confirmation alone is not sufficient — always verify through the official Commission data system.

Active Duty Military Personnel or Their Spouses 

The Compact recognizes that military families face unique challenges in maintaining professional licensure. Service members and their spouses may be required to relocate frequently and with little notice, making the standard definition of "home state" — the state of primary residence — impractical.

To address this, a licensee who is active-duty military or the spouse of an active-duty military member may choose from three options when designating their home state. They may designate their home of record, their Permanent Change of Station (PCS) location, or their current state of residence if it differs from both the home of record and the PCS state. Supporting military spouses is one of the Compact's six stated objectives, and this flexibility reflects a practical commitment to that goal. It allows military-connected licensees to maintain a stable regulatory home base from which to carry compact privileges into remote states, regardless of how often or how quickly their duty station changes.

Adverse Actions: Who Has Authority and How Investigations Work

Understanding disciplinary authority under the Compact is essential for any practitioner operating across state lines. The Compact draws a clear line between what a home state can do and what a remote state can do.

Home State Authority:

Your home state has exclusive authority to impose disciplinary action against the license it issued. No remote state can suspend or revoke your home state license — that power belongs solely to the state that granted it. That said, a home state may act on investigative information gathered by a remote state, provided it follows its own established disciplinary procedures. Information crosses state lines freely to support accountability, but your home state's procedural protections remain in place.

The Compact also allows member states to offer an alternative to formal discipline — a non-disciplinary monitoring or remediation program, such as one addressing substance abuse. If a state permits this and requires that participation remain confidential under its laws, the Compact honors that confidentiality. However, any licensee participating in such a program in lieu of formal discipline must agree not to practice in any other member state during the program without first obtaining authorization from that state.

Remote State Authority:

While a remote state cannot touch your home state license, it has meaningful authority within its own borders. It may remove your compact privilege, impose fines, and take other necessary actions to protect its residents. It may also issue subpoenas requiring witnesses to appear or evidence to be produced — and those subpoenas must be enforced by courts in other party states. The state issuing the subpoena is responsible for covering any associated witness fees and travel expenses. If state law permits, a remote state may also recover from the licensee the costs of investigating and resolving a case that results in adverse action.

Joint Investigations:

Member states are not limited to investigating conduct that occurs within their own borders. Any member state may participate with other member states in joint investigations of licensees, and all member states are required to share investigative, litigation, and compliance materials in support of any joint or individual investigation conducted under the Compact. This sharing obligation is mandatory, not optional. As a practitioner, this means that conduct in one state may be investigated and acted upon by licensing boards in other states where you hold a license or compact privilege. The Compact is designed so that no state border becomes a barrier to professional accountability.

How the Compact's Rules Are Made

The Commission has the authority to create rules that are legally binding on all member states. Understanding how those rules are made — and how they can be challenged — is part of being an informed practitioner under the Compact.

The standard rulemaking process is transparent and open to public participation. At least thirty days before a rule is voted on, the Commission must publish a notice that includes the proposed rule's full text, the reason for it, the date and location of the meeting where it will be considered, and instructions for submitting comments. Any person may submit written comments, and those comments are made available to the public. If at least twenty-five individuals, a government agency, or an association with at least twenty-five members requests a public hearing, the Commission must hold one. All hearings are recorded and available upon request. A final rule requires a majority vote of all Commission members to pass.

There is an important check on the Commission's authority. If a majority of member state legislatures formally reject a rule within four years of its adoption, that rule loses force and effect in all member states. This ensures that the Commission remains accountable to the states it serves.

In genuine emergencies — situations involving an imminent threat to public health or safety, risk of financial loss, or a federally imposed deadline — the Commission may adopt a rule without advance notice or a public hearing. However, the standard rulemaking process must then be applied retroactively within ninety days of the emergency rule taking effect.

When States Fail to Comply, Withdraw, or Disagree

The Compact includes a clear process for addressing situations where a member state fails to meet its obligations. The Commission must first provide written notice of the problem and offer remedial support and technical assistance. Termination from the Compact is a last resort, available only after all other options have been exhausted, and requires an affirmative vote of a majority of member states. A terminated state remains financially responsible for all obligations incurred up to and including the date of termination.

A member state may also voluntarily leave the Compact by repealing its enacting statute. However, withdrawal does not take effect until six months after that repeal, giving licensees and other states time to adjust. Even after withdrawal, the departing state's licensing board must continue to comply with investigative and adverse action reporting obligations that arose before withdrawal took effect.

When disputes arise between member states — or between member and non-member states — the Commission is required to attempt to resolve them. It must establish procedures for both mediation and binding dispute resolution. If a state remains in default after those efforts, the Commission may pursue legal action in federal court, seeking both injunctive relief and damages. The prevailing party in any such action is entitled to recover attorney's fees and litigation costs.

For the practicing clinician, this framework may seem distant from daily patient care. But it carries a direct message: the compact privilege you hold is backed by a legally enforceable interstate agreement. The system that grants you the ability to practice across state lines is one with real obligations, real consequences, and real accountability — for states and for licensees alike.

Rules of the Tennessee Board of Physical Therapy Chapter: 1150-01 General Rules Governing the Practice of Physical Therapy

Regulations

The Tennessee Board of Physical Therapy is tasked with creating and enforcing the specific regulations that govern the profession statewide. In this context, a regulation is an official rule designed to ensure that the practice of physical therapy aligns with the state's legal requirements. These governing principles are primarily found in Chapter 1150-01. While this body of regulations was originally established in 1978, it is regularly updated to reflect modern standards, with the most recent revisions taking effect in December 2025.

Before diving into the specifics, it is essential to understand the "language" used by the Tennessee Board of Physical Therapy. These definitions ensure everyone is on the same page regarding roles, locations, and legal actions.

Key Definitions 

The following terms and acronyms are used throughout the state regulations governing physical therapy. 

The following terms and acronyms are used throughout the state regulations governing physical therapy.

Regulatory Bodies & Organizations

The Act: The state law governing occupational and physical therapy in Tennessee (Title 63, Chapter 13 of the Tennessee Code Annotated).

Board: The Board of Physical Therapy.

Department: The Tennessee Department of Health.

Division: The Division of Health Related Boards (HRB) within the Department of Health.

Board Administrative Office: Located at 665 Mainstream Drive, Nashville, TN 37243.

Board Designee: Any person who has received a written delegation of authority from the Board to perform Board functions, subject to review and ratification by the full Board where provided by these rules.

HRB: The acronym for Health Related Boards.

Professional Organizations & Education

APTA: American Physical Therapy Association.

APTATN: American Physical Therapy Association of Tennessee (formerly known as the Tennessee Physical Therapy Association).

CAPTE: Commission on Accreditation of Physical Therapy Education, the agency that accredits PT/PTA schools.

FSBPT: Federation of State Boards of Physical Therapy.

Recognized Educational Institution: Any school accredited by CAPTE and approved by the Board.

Examination Service: The testing service whose examination has been adopted by the Board.

NPTE: National Physical Therapy Examinations.

Guide to Physical Therapist Practice: The APTA document adopted by the Board to describe standard PT practice.

Licensure & Application

Applicant: Any individual seeking licensure by the Board who has submitted an official application and paid the application fee.

License: The official document issued to an applicant who has successfully completed the licensure process. The license takes the form of an "artistically designed" license as well as other versions bearing an expiration date.

Licensee: Any person duly licensed by the Board to engage in the practice of physical therapy.

Good Moral Character: The quality of being well regarded in personal behavior and professional ethics.

Closed File: An administrative action that renders an incomplete or denied file inactive.

Restriction: Any action deemed appropriate by the Board to be required of a disciplined licensee during any period of probation, suspension, or revocation with leave to apply; or as a prerequisite to the lifting of probation or suspension; or any action deemed appropriate by the Board to be required of an applicant for licensure.

Written Evidence: Includes, but is not limited to, written verification from supervisors or other professional colleagues familiar with the applicant's work.

Personnel Categories & Supervision

Licensed Physical Therapist (PT): Any person who has met the qualifications for licensed physical therapist and holds a current, unsuspended, and unrevoked license lawfully issued by the Board.

Licensed Physical Therapist Assistant (PTA): Any person who has met the qualifications for licensed physical therapist assistant and holds a current, unsuspended, and unrevoked license lawfully issued by the Board. PTAs perform physical therapy procedures and related interventions that have been selected and delegated only by the supervising physical therapist.

Clinical Student: A student enrolled in a CAPTE-approved developing program, a CAPTE-accredited physical therapy program, or a regionally accredited post-professional physical therapist program.

Internationally Educated / Foreign Trained: An individual who has graduated from a PT or PTA program outside the United States and its jurisdictions that may or may not be accredited by CAPTE.

FEPT / FEPTA: Acronyms for Foreign Educated Physical Therapists (FEPT) and Physical Therapist Assistants (FEPTA) who are graduates of a non-CAPTE-accredited program outside of the USA.

Foreign Credentialing Commission for Physical Therapy (FCCPT): The agency that reviews international educational credentials.

Recognized Credentialing Agency: An agency approved by the Board that evaluates the educational credentials of international graduates who have not attended CAPTE-accredited or Board-approved schools of physical therapy.

Physical Therapy Assistive Personnel:

Physical Therapy Aide: Aides, technicians, and transporters trained by and under the direction of physical therapists who perform designated and supervised routine physical therapy tasks.

Other Assistive Personnel: Other trained or educated healthcare personnel not defined as a PTA or aide who perform specific designated tasks related to physical therapy under the supervision of a PT and/or PTA. At the discretion of the supervising PT and/or PTA, and if properly credentialed and not prohibited by any other law, these individuals may be identified by the title specific to their training or education.

Volunteer Personnel: Uncompensated individuals who are limited to observation of physical therapy functions and are prohibited from the delivery of physical therapy services.

Practice & Clinical Definitions

Physical Therapy Treatment Diagnosis: Both the process and the end result of evaluating information obtained from the examination and/or consultation, which the physical therapist then organizes into defined clusters, syndromes, or categories to help determine the most appropriate intervention strategies.

Manual Therapy Techniques: A continuum of skilled movements to joints and/or related soft tissues at varying speeds and amplitudes, which physical therapists and/or physical therapist assistants may administer.

Telemedicine: The use of real-time audio, video, or other electronic media and telecommunication technology that enables interaction between a physical therapist or physical therapist assistant and a patient for the purpose of diagnosis, consultation, or treatment at a distant site where there may be no in-person exchange between a healthcare provider and a patient; or store-and-forward telemedicine services.

Consultation: A meeting conducted either face-to-face or by some other medium such as, but not limited to, telephone, facsimile, mail, or electronic means, wherein two or more health professionals discuss the examination, evaluation, diagnosis, prognosis, and treatment of a particular case.

Continuing Competence: The ongoing application of professional knowledge, skills, and abilities that relate to occupational performance objectives in the range of possible encounters defined by that individual's scope of practice and practice setting.

General Definitions & Legalities

Advertising: Includes, but is not limited to, business solicitations, with or without limiting qualifications, in a card, sign, or device issued to a person; in a sign or marking in or on any building; or in any newspaper, magazine, directory, or other printed matter. Advertising also includes business solicitations communicated by individual, radio, video, internet, or television broadcasting or any other means designed to secure public attention.

Use of a Title or Description: To hold oneself out to the public as having a particular status, including but not limited to, by the use of signs, mailboxes, address plates, stationery, announcements, advertising, the internet, business cards, or other means of professional identification.

Fee: Money, gifts, services, or anything of value offered or received as compensation in return for rendering services; also, the required fees pursuant to these rules.

Person: Any individual, firm, corporation, partnership, organization, or political entity.

Relative: A parent, foster parent, parent-in-law, child, spouse, brother, foster brother, sister, foster sister, grandparent, grandchild, son-in-law, brother-in-law, daughter-in-law, sister-in-law, or other family member who resides in the same household.

He/She / Him/Her: When "he" appears in the text of these rules, the word represents both the feminine and masculine genders.

Scope of Practice and Supervision (1150-01-.02)

Access to Care: Referral Requirements

Generally, physical therapy must be performed under the written or oral referral of a licensed MD, Chiropractor, Dentist, Podiatrist, Osteopath, Nurse Practitioner, or Physician Assistant.

Exceptions to the Referral Requirement:

• Initial Visits: A PT may conduct an initial evaluation without a referral.

• Asymptomatic Persons: A PT may provide physical assessments or instructions, including a recommendation of exercise, to an asymptomatic person without a referral.

• Emergency Circumstances: A licensed physical therapist can assist without a referral in emergencies, including minor ones. After providing help, the therapist must refer the person to the appropriate healthcare practitioner if further care is needed.

  • For this rule, “emergency circumstances” refer to situations requiring immediate medical care. This includes cases where a patient experiences the sudden onset of a medical condition with acute symptoms—such as severe pain—where delaying treatment could reasonably be expected to result in:

    • Placing the patient’s health in serious jeopardy;

    • Serious impairment of bodily functions; or

    • Serious dysfunction of any bodily organ or part.

Treating Without a Referral (Direct Access Rules): A PT can treat a patient without a referral if they follow these steps:

1. Notification: Inform the patient’s physician that treatment has begun.

2. The 30-Day Rule: If no clinical progress is made within 30 days, the PT must stop treatment and refer the patient to a qualified practitioner.

3. The 90-Day Rule: Treatment cannot exceed 90 days without the patient’s healthcare practitioner's consultation.

4. Chronic Condition Exception: The 30 and 90-day limits do not apply if the patient has a previously diagnosed chronic, neuromuscular, or developmental condition and is being treated for symptoms of that condition.

Mandatory Referral: At any point in care, a physical therapist is obligated to refer a patient to another healthcare provider if:

• The patient shows symptoms or conditions outside the physical therapist's scope of practice,
• Reasonable therapeutic progress is not being achieved or 
• Physical therapy is contraindicated.

Practice of Physical Therapy

The terms “physical therapy” and “physiotherapy” mean the same thing and can be used interchangeably. 

The practice of physical therapy in the state of Tennessee includes the following: 

Assessment and Diagnosis: Physical therapists examine, evaluate, and test individuals with mechanical, physiological, and developmental impairments, functional limitations, disabilities, or other movement-related conditions in order to determine a physical therapy treatment diagnosis, prognosis, a plan of therapeutic intervention, and to assess the ongoing effectiveness of the intervention.

Therapeutic Interventions: Physical therapists design, implement, and modify therapeutic interventions to alleviate impairments and functional limitations. These interventions include, but are not limited to: therapeutic exercise; functional training; manual therapy; therapeutic massage; assistive and adaptive orthotic, prosthetic, protective, and supportive equipment; airway clearance techniques; debridement and wound care; physical agents or modalities; dry needling; mechanical and electrotherapeutic modalities including patient-related instruction; and electrophysiologic studies (motor and sensory nerve conduction, and somatosensory evoked potentials).

Injury Prevention and Health Promotion: Physical therapists work to reduce the risk of injury, impairments, functional limitations, and disabilities. They also promote and maintain fitness, health, and quality of life across all age groups.

Professional Roles: Physical therapists engage in administration, consultation, education, and research.

Manual Therapy Techniques: These are passive interventions where therapists use their hands to apply skilled movements designed to:

• Modulate pain
• Increase joint range of motion
• Reduce or eliminate soft tissue swelling, inflammation, or restriction
• Induce relaxation
• Improve contractile and noncontractile tissue extensibility
• Improve pulmonary function

These techniques involve applying graded forces without exceeding the joint's normal range of motion and may be applied to all joints of the body as deemed appropriate.

Special Electromyography Guidelines:

• Invasive Kinesiologic Electromyography: May only be performed in a university academic setting as part of a research project approved by the educational institution's Internal Review Board, without a referral.
• Diagnostic Electromyography: Must be performed by a licensed physical therapist who meets specific requirements.
• Referral for Electromyography: Diagnostic and invasive electromyography may only be performed with a referral from an allopathic physician, osteopathic physician, dentist, podiatrist, nurse practitioner, or physician assistant licensed under the relevant Tennessee statutes.

Substandard Care

As practitioners, we must avoid actions that compromise patient welfare or professional integrity. Substandard care includes, but is not limited to:

• Inappropriate Utilization: Overutilizing services beyond what is clinically necessary, or failing to provide essential care.

• Unwarranted Intervention: Providing treatment that is not supported by the patient’s specific condition or diagnosis.

• Diminishing Returns: Continuing treatment beyond the point where the patient achieves reasonable benefit.

• Patient Abandonment: Abandoning the care of a patient without informing the patient of further care options.

• Failure to Follow Standards: Failing to practice in accordance with the standards set forth in the Guide to Physical Therapist Practice.

Scope of Practice Limitations

The practice of physical therapy (or "physiotherapy") is distinct from other medical disciplines. Nothing in these rules authorizes a PT, PTA, or any other person to practice medicine, chiropractic, osteopathy, podiatry, nursing, or to practice as a physician assistant.

Professional Guidelines

The Board officially adopts the  APTA Guide to Physical Therapist Practice. All practitioners are expected to adhere to the most current version of this guide.

Universal Precautions for Preventing HIV Transmission

The Board officially adopts the Centers for Disease Control and Prevention (CDC) guidelines for Standard Precautions to prevent the transmission of HIV and other infectious agents.

All licensed personnel must adhere to the protocols outlined in the 2007 Guidelines for Isolation Precautions: Preventing Transmission of Infectious Agents in Healthcare Settings, as published by the Healthcare Infection Control Practices Advisory Committee (HICPAC). It is important to note that if the CDC updates these guidelines, the Board also adopts those updates.

In simple terms, these guidelines outline how we protect patients and healthcare providers from infections by consistently using standard precautions with every patient, every time.

Supervision of Personnel and Students

Licensed Physical Therapist Assistants (PTAs)

All services performed by a licensed PTA must be conducted under the supervision of a licensed and practicing physical therapist in Tennessee. Supervision is defined by the following requirements:

• Evaluations and Planning: The PT must perform the initial patient evaluation and develop a written treatment plan that includes therapeutic goals, service frequency, and duration.

• Ongoing Assessment: The PT must perform and document re-evaluations, assessments, and modifications in the treatment plan at least every 30 days. For patients seen longer than 60 days, the PT must personally inspect the actual act of therapy services rendered at least every 60 days.

• Proximity and Communication: A PT may not supervise a PTA providing services at a site more than 60 miles or one hour away. The supervising PT must be available via telephone or other means at all times while the PTA is delivering care.

• Discharge: The PT is responsible for performing the final evaluation and writing the discharge summary.

• Shared Accountability: Both the PT and the PTA are equally accountable for adhering to these provisions.

Physical Therapy Assistive Personnel and Aides

A physical therapist may utilize aides and other assistive personnel for tasks that do not require clinical decision-making or professional problem-solving.

• Aide Supervision: Physical therapy aides must work under direct on-site supervision by a licensed PT or PTA.

• Other Assistive Personnel: Personnel such as nationally certified exercise physiologists, certified athletic trainers, or massage therapists may perform delegated tasks consistent with their training and education. These tasks must be performed under the on-site supervision of a PT, who must then co-sign all related documentation in the patient records.

Defining "On-Site Supervision": The supervising PT or PTA must:

1. Be continuously on-site and present in the department or facility where assistive personnel are performing services

2. Be immediately available to assist the person being supervised in the services being performed

3. Maintain continued involvement in appropriate aspects of each treatment session in which a component of treatment is delegated to assistive personnel

Supervision Ratios and Limits

A physical therapist may concurrently supervise:

• Up to three full-time physical therapist assistants.

• Up to two full-time assistive personnel or aides.

Volunteers and Students

• Volunteers: PTs and PTAs must provide direct on-site supervision for volunteers. Volunteers are strictly prohibited from providing physical therapy to patients.

• PT Clinical Students: Must be supervised on-site by a PT at all times. Per APTA guidelines, clinical instructors should have at least one year of licensed clinical experience.

• PTA Clinical Students: Must be supervised on-site by a PTA at all times. Per APTA guidelines, clinical instructors should have at least one year of licensed clinical experience.

Necessity of Licensure and Professional Identification (1150-01-.03)

Mandatory Licensure

As you know, before practicing physical therapy in Tennessee, you must hold a current state license.

Physical therapy is categorized as one of the "healing arts," and its practice is restricted to those credentialed by the Board or expressly exempted by state law (T.C.A. § 63-1-123).

Protected Titles and Representations

It is unlawful for any unlicensed person to represent themselves as a Physical Therapist (PT) or Physical Therapist Assistant (PTA). This prohibition applies to all forms of professional identification, including but not limited to:

• Signage and address plates

• Stationery and calling cards

• Internet profiles and social media

• Telephone listings and advertisements

Authorized Use of Credentials

Licensees in good standing (those with active, non-suspended licenses) have the legal right to use the following titles and acronyms:

• Physical Therapist (P.T.)

• Doctor of Physical Therapy (D.P.T.)

• Physical Therapist Assistant (P.T.A.)

Advertising Requirements

To prevent misleading the public, any licensee publishing an "advertisement" must include one of the authorized titles listed above.

Warning: Failure to include your professional title in advertisements is considered an omission of a material fact. This makes the advertisement "misleading and deceptive" and may subject the licensee to disciplinary action.

Qualifications for Licensure, Procedures, Fees, and Examinations (1150-01-.04 through 1150-01-.08)

A note to the reader: If you are taking this course, you most likely already hold a Tennessee PT or PTA license. The following sections on licensure qualifications, application procedures, fees, and examinations are included because the Tennessee Board of Physical Therapy requires that current licensees be familiar with the full scope of the rules governing the profession — including those that applied when you were first licensed and those that apply to new applicants today. This knowledge is also valuable if you ever supervise students, assist colleagues seeking licensure, or are asked a scope-of-practice question about what it means to be a licensed practitioner in Tennessee.

Qualifications for Licensure (1150-01-.04)

Licensure by Examination

To obtain a Tennessee PT or PTA license by examination, an applicant must meet three basic requirements: demonstrate good moral character, graduate from a CAPTE-accredited physical therapy or physical therapist assistant program, and pass the Board's licensing examination.

Licensure by Reciprocity

Applicants who are already licensed in another U.S. state may apply for a Tennessee license by reciprocity. They must hold a current, unrestricted license and meet credential requirements that vary depending on when they were first licensed elsewhere:

• July 1995 to present: Must be of good moral character, hold a degree from a CAPTE-accredited program, have all prior licensure verified, and have passed the licensing exam at the current criterion-referenced passing point.
• December 29, 1981, through July 1995: Same requirements as above, but the minimum acceptable exam score is a converted score of 75, based on 1.5 standard deviations below the national mean — applied to both individual parts and the total score.
• July 1, 1976, through December 28, 1981: Same as above, but the educational program may have been approved by either CAPTE or the American Medical Association.

Internationally Educated Applicants

Physical therapists and PTAs who completed their education outside the United States have additional requirements beyond the standard examination or reciprocity criteria. They must submit one of the following directly to the Board's administrative office:

• A valid, error-free Type 1 Comprehensive Credential Evaluation Certificate from the Foreign Credentialing Commission on Physical Therapy (FCCPT), confirming their education is substantially equivalent to a CAPTE-approved curriculum. Note that the FCCPT's "Visa Credential Verification Certificate" does not fulfill this requirement. Applicants who are ineligible to take the TOEFL iBT must submit all other components of the Type 1 Certificate directly to the Board; or
• An equivalent certification from another Board-approved credentialing agency that evaluates the curriculum in the same manner as the FCCPT and reaches the same conclusion regarding equivalency.

All internationally educated applicants must also provide proof of U.S. or Canadian citizenship, or documentation showing they are legally authorized to live and work in the United States. Acceptable documents include notarized copies of birth certificates, naturalization papers, or current visa status.

Supervised Clinical Practice Requirements for Foreign-educated Physical Therapists  (1150-01-.04)

After the Board has reviewed and approved an applicant's credentials, internationally educated applicants must complete a Board-approved supervised clinical practice period before they can be fully licensed.

The basics:

• 480 total hours, completed at a pace of no fewer than 10 and no more than 40 hours per week.
• The supervising physical therapist must complete and submit the Board's evaluation form at the end of the supervisory period.
• If the Board determines the period was not successfully completed, the applicant may be required to complete additional supervised hours, additional coursework, or an oral examination.

Who cannot serve as a supervisor? To protect the integrity of the process, the following individuals are not acceptable supervisors: parents (including foster parents and in-laws), spouses or former spouses, siblings, children, stepchildren, cousins, in-laws (present or former), aunts, uncles, grandparents, grandchildren, current or former employees of the applicant, the applicant's present or former physical therapist, present or former romantic partners, and anyone sharing the applicant's household.

One exception: a supervisor who receives payment only for the actual hours spent supervising is not considered an "employee" under this rule.

Electrophysiologic Studies 

Diagnostic Electromyography (EMG): To perform invasive needle studies for the diagnosis of muscle and nerve disease, a Physical Therapist must hold a current ECS (Electrophysiology Clinical Specialist) certification from the American Board of Physical Therapy Specialties and submit documented evidence of this certification to the Board's administrative office prior to performing these studies.

Surface and Kinesiologic Studies: For studies involving motor/sensory conduction, somatosensory evoked potentials, or kinesiologic needle studies, a Physical Therapist must demonstrate a "theoretical background and technical skills" for safe and competent performance and submit documented evidence of this background to the Board's administrative office.

Supervision Standards: Supervision of any applicant conducting the above studies must remain consistent with sound medical practice.

Board Determination: The qualification of any applicant for licensure as a PT or PTA is determined by a majority vote of the Board of Physical Therapy.

Procedures for Licensure (1150-01-.05)

The licensure process is straightforward when you know what to expect. Here is what every applicant must do:

• Apply: Submit a complete application through the Board's authorized online licensure system, or request a paper application from the Board's administrative office. Applications are accepted year-round.
• Be honest: Answer every question on the application completely and truthfully. All required documents must be in order before submitting.
• Pay fees: Submit the nonrefundable application fee, the State regulatory fee, and the reciprocity fee (if applicable) at the time of application.
• Submit a photo: Include a passport-style photograph taken within the past 12 months.
• Provide transcripts: Your degree-granting institution must send your official transcript directly to the Board's administrative office. The transcript must show the degree was conferred, carry the institution's official seal, and match the name on your application. The institution must have been CAPTE-accredited at the time your degree was granted.
• Letter of recommendation: Submit an original letter from a PT or PTA licensed in the United States confirming your good moral character. This letter cannot come from a relative.
• Disclose your history: You are required to disclose any of the following: criminal convictions (other than minor traffic violations); any prior denial, discipline, or restriction of licensure by any state or country; and any civil suit judgments or settlements in which you were a named defendant.
• Criminal background check: A background check must be submitted directly from the Board's designated vendor to the administrative office.
• No resumes: Personal resumes will not be accepted or reviewed.
• Pay the license fee on time: Once notified that your license fee is due, you have 30 days to pay. Failure to do so will result in your application file being closed.

For licensure by examination: Passing the required examination is a prerequisite for a license to be issued.

For licensure by reciprocity: Passing examination scores must be submitted directly from the examining service to the Board, and verification of licensure from every state in which you are or have ever been licensed must be submitted directly to the Board as well.

For internationally educated applicants: In addition to the above, you must have your education evaluated by a Board-approved credentialing agency, provide proof of work authorization, submit a verification of licensure from each jurisdiction where you have been licensed, and have all non-English documents translated and certified.

Fees (1150-01-.06)

The Board’s statutes authorize certain fees, which are set as follows:

• Duplicate (replacement) license – Paid when requesting a replacement for a lost or destroyed “artistically designed” license or renewal certificate.

• Endorsement/Verification fee – Paid when requesting the Board to endorse you to another state or to verify your license.

• Reinstatement fee – Paid to reactivate an administratively revoked license for failure to renew.

• License fee – A nonrefundable fee paid before the “artistically designed” license is issued.

• Provisional license/application fee – A nonrefundable fee for applicants or licensees seeking a provisional license.

• Renewal fee – Paid by all license holders, including those reactivating a retired or lapsed license.

• Late renewal fee – Paid when a license is renewed late, but before it has been administratively revoked.

• Reciprocity fee – Paid in addition to the application fee.

• State regulatory fee – Paid by all individuals at the time of application and with each renewal.

The Board sets, reviews, and changes all fees as needed. Payment must be sent to the Board's administrative office by certified check, personal check, money order, or electronically through the Board's authorized licensure system. Checks and money orders are to be made payable to the Board of Physical Therapy.

For the complete fee schedule, see Rule 1150-01-.06.

Application Review, Approval, and Denial (1150-01-.07)

Once submitted, applications are reviewed for completeness. This initial review may be handled by the Board's Unit Director, with the Board ratifying any licensure actions taken.

If your application is incomplete, you will be notified and will not be eligible to sit for the exam until everything is in order. The Board may also request additional information before making an eligibility decision.

If your application is denied, you will be notified by certified mail. The letter will include the specific reasons for denial and the legal authority behind it. Depending on the basis for denial, you may have the right to request a contested case hearing under the Tennessee Administrative Procedures Act. Any appeal request must be made in writing within 30 days of receiving the denial notice.

Providing false or incomplete information on your application can result in denial of the right to sit for the exam — or, if you are already licensed, suspension or revocation of that license.

An application is considered abandoned and closed if it is not completed within 12 months of initial review, or if the applicant does not sit for the exam within 6 months of receiving an eligibility notification. Starting over requires a new application and new fees.

Examinations (1150-01-.08)

Since most licensees taking this course have already passed the NPTE, this section is presented as a brief overview for reference. The full examination rules are available in Chapter 1150-01-.08.

Tennessee uses the National Physical Therapy Examination (NPTE), administered by the Federation of State Boards of Physical Therapy (FSBPT). All educational requirements must be completed before an applicant is eligible to sit for the exam. Applications are submitted directly to the FSBPT at www.fsbpt.org.

The passing score is a scaled score of 600 on a 200–800 scale. Results are not available at the test site and are mailed within 10 working days of the Board receiving score reports.

If an applicant does not pass, they may retake the exam. After two failed attempts in any state, a minimum three-month waiting period is required before reapplying. After two or more failures, the applicant must also submit proof of 10 hours of additional clinical training and 10 hours of additional coursework before the Board will approve another attempt. This requirement applies after each subsequent failure as well.

Applicants who are approved to test but do not sit for the exam within 12 months of their eligibility will have their applications closed and must restart the process.

Renewal of a License (1150-01-.09)

Renewal Due Date and Responsibility 

The deadline for license renewal is the expiration date specified on the current renewal certificate. The preferred method of renewal is through the Board's authorized online licensure system. While the Board may provide notifications, the responsibility for maintaining an active license rests solely with the practitioner. Failure to receive a notice does not excuse a licensee from meeting renewal requirements or deadlines.

Methods of Renewal

To maintain eligibility for renewal, the following must be submitted to the Division of Health Related Boards on or before the expiration date:

• A completed and signed renewal application form;
• Payment of the renewal and State regulatory fees; and
• A signed statement attesting to the completion of all required continuing competence activities. All supporting documentation must be uploaded to the designated vendor platform in accordance with the standards for continuing competence.

Non-Compliance

Licensees who fail to comply with renewal rules or who receive notification of failure to timely renew will have their licenses processed pursuant to standard administrative procedures. Providing false or untrue information on a signed renewal form may result in formal disciplinary action.

Reinstatement of an Expired License

To reinstate a license that has already expired, an individual must pay both the reinstatement fee and the standard renewal fee and submit proof of completing the necessary continuing competence requirements. Renewal issuance decisions may be handled administratively or may be reviewed by a Board member or authorized designee..

Provisional License (1150-01-.10)

A provisional license shall be issued for an internationally educated applicant who has complied with all licensure qualifications except the supervised clinical practice period.

A provisional license may also be issued to a physical therapist or PTA whose license has been retired or expired for greater than three years and whose license is presently unencumbered with respect to disciplinary action.

An applicant seeking a provisional license shall pay the nonrefundable Provisional License/Application fee and, if applicable, the State Regulatory fee, Reinstatement fee, and Reciprocity fee.

Duration of License

• For internationally educated applicants, provisional licenses are valid for no less than 12 weeks and no more than 48 weeks. The provisional license may not be renewed.
• For physical therapists or PTAs whose licenses have been retired or expired for greater than three years, provisional licenses are valid for a period of time as determined by the Board. The provisional license may not be renewed.

Supervision of a Provisional Licensee

A physical therapist with a provisional license must work under the direct on-site supervision of a licensed physical therapist who possesses an active, unencumbered Tennessee license and has completed a minimum of one year of licensed clinical experience.

A PTA with a provisional license must work under the direct on-site supervision of a PT or PTA who possesses an active, unencumbered Tennessee license and has completed a minimum of one year of licensed clinical experience.

Retirement and Reactivation of a License (1150-01-.11)

Conversion to Retired Status

A practitioner holding a current license who does not intend to practice as a physical therapist or PTA in Tennessee may apply to convert their active license to inactive ("retired") status. Once retired, the individual is no longer required to pay the biennial renewal fee.

Application Process for Retirement

A person holding an active license may request retired status through one of the following methods:

• Affidavit of Retirement: The licensee may obtain an affidavit of retirement form from the Board’s administrative office. This completed form must affirm that the licensee will not practice or imply that they hold an active Tennessee license. This includes a commitment not to use any titles, letters, or figures that suggest they are currently licensed to practice within the state.

• Written Request: Alternatively, a licensee may submit a signed and notarized letter to the Board. This letter must explicitly state the request for retirement and include a statement confirming that the licensee understands they may not practice or represent themselves as an active PT or PTA while in retired status.

Reactivation of a Retired License

Individuals wishing to return to active practice must complete the following steps to reactivate their license:

• Written Request: Submit a written request for licensure reactivation to the Board's administrative office, including a statement describing all relevant experience and education gained during the period of retirement or inactivity

• Fees: Pay the current licensure renewal and state regulatory fees. If the request for reactivation is made less than 1 year after the initial retirement date, the applicant must also pay the reinstatement fee.

• Continuing Competence: Provide evidence of meeting all continuing competence requirements as specified in the Board’s rules.

Review and Determination

Applications for reactivation are processed in the same way as initial licensure applications. 

Continuing Competence (1150-01-.12)

Overview and Purpose

The Board requires all physical therapists and physical therapist assistants to participate in a minimum number of planned learning experiences to ensure safe and effective practice. These activities must be completed during the twenty-four months preceding the licensure renewal month. The content must directly relate to physical therapy, including areas such as intervention, examination, research, documentation, education, management, leadership, or other relevant content areas.

Requirements for Initial Licensure

For those approved for initial licensure by examination, completing the initial licensure requirements serves as proof of competence for the first renewal period. However, new licensees must still complete four hours of ethics and jurisprudence education during this initial term.

Biennial Hour Requirements

Licensees are required to complete thirty hours of continuing competence every twenty-four months.

• Physical Therapists: At least twenty hours must be obtained through Class I activities. Up to ten hours may be obtained through Class II activities.

• Physical Therapist Assistants: At least twenty hours must be obtained through Class I activities. Up to ten hours may be obtained through Class II activities.

All thirty hours may be completed through Class I activities if the licensee chooses.

Ethics and Jurisprudence Education

Four of the required Class I hours must be dedicated to ethics and jurisprudence courses every renewal cycle. The APTA Tennessee (APTATN) is the sole authority for approving these courses. To be valid, these courses must be at least two hours in length and provide education in the following areas:

Ethics:

• The APTA Code of Ethics for Physical Therapists and Physical Therapist Assistants
• Model for ethical decision-making
• Case analysis

Jurisprudence:

• The Occupational and Physical Therapy Practice Act (T.C.A., Title 63, Chapter 13, Parts 1 and 3)
• General Rules Governing the Practice of Physical Therapy (Chapter 1150-01)
• Board of Physical Therapy Policy Statements
• Licensure process
• Scope of practice
• Licensure renewal
• Disclosures to patients
• Offenses that may lead to disciplinary action
• Supervision of Physical Therapist Assistants
• Supervision of Physical Therapy assistive personnel
• Supervision of others (students, volunteers)

Class I: Acceptable Activities and Evidence

The following activities qualify as Class I continuing competence credit:

Peer Review of Practice

• External Peer Review: Reviews performed by a recognized entity such as the APTA qualify for 20 hours per review, limited to one review per 24-month period.
• Internal Peer Review: Reviews conducted within a licensee's own organization qualify for 2 hours per review, with a maximum of two reviews per 24-month period.

Educational Events and University Credit

• Courses and Symposia: Workshops, seminars, and symposia provided or approved by the APTA or its academies/sections (state chapters of the APTA are not considered approved providers), FSBPT, APTATN, or accredited PT and PTA educational programs. Relevant formats are defined by the Board's Continuing Education Policy Statement.
• University Courses: 12 hours of continuing competence credit for every semester credit hour completed at an accredited university.
• Presenting: Participating as a presenter in approved continuing education courses, workshops, seminars, or symposia earns credit based on contact hours, not to exceed 20 hours per topic. Approved entities include the APTA or its sections, FSBPT, APTATN, and accredited Tennessee PT or PTA schools.
• Adjunct Teaching: Teaching a credit-bearing PT or PTA course as an adjunct responsibility earns credit based on contact hours, up to a maximum of 20 hours. If the same course is taught multiple times, the hours may only be counted once.

Academic and Clinical Milestones

• Advanced Degrees: Obtaining an advanced degree from an accredited university qualifies for 26 hours of credit, recognized only in the 24-month period in which the degree is awarded.
• Residencies and Fellowships: Participating in an accredited clinical residency or fellowship program earns 5 hours of credit for each week of the program, with a maximum of 26 hours per program.
• Clinical Specialization: Certification or recertification by the American Board of Physical Therapy Specialties (ABPTS) qualifies for 26 hours of credit, recognized only in the 24-month period in which certification or recertification is awarded. Certification by organizations other than the ABPTS may be recognized for up to 26 hours, with the final amount determined by the Board.

Research and Scholarship

• Authorship: Serving as an author for a scientific poster, platform presentation, or published article undergoing peer review earns 10 hours of credit per event. A maximum of two events may be claimed every 24 months.

FSBPT Approved Activities: Activities approved by the FSBPT also qualify as Class I credit.

The Board or its designee retains the right to determine whether any submitted course complies with the requirements of this rule.

Class II: Acceptable Activities and Evidence

Class II activities include various professional development experiences that contribute to ongoing proficiency. The following are recognized for credit, subject to specific limitations noted for each 24-month renewal period:

Professional Reading and Academic Engagement.

Practitioners may earn credit through independent study or attendance at less formal educational gatherings.

• Self-Instruction: Reading professional literature earns a maximum of 1 hour of credit per renewal cycle.

• Scientific Sessions: Attendance at scientific poster sessions, lectures, panels, or symposia that do not meet Class I criteria earns one hour of credit per hour of activity, with a two-hour maximum per renewal cycle.

Clinical Instruction and Mentorship. Credit is awarded for supporting the development of students and fellow professionals.

• Student Instruction: Serving as a clinical instructor for an accredited physical therapist or physical therapist assistant program earns one hour of credit for every sixteen contact hours with students.

• Residency and Mentorship: Acting as a clinical instructor for a resident or as a mentor in a formal, non-academic mentorship program also earns one hour of credit for every sixteen contact hours.

Collaborative Learning and In-Service Training. Engagement with peers and workplace-based education provides additional opportunities for credit.

• Study Groups: Participating in a physical therapy study group with two or more licensees qualifies for a maximum of 1 hour of credit per renewal cycle.

• In-Service Programs: Attending or presenting in-service programs earns one hour of credit for every eight contact hours. This category is limited to a total of four hours of credit every twenty-four months.

Professional Service and Advocacy. Contributing to the governance and representation of the profession is recognized as a valid competence activity.

• Professional Leadership: Serving as a representative to the APTA House of Delegates or as a member of a professional board, committee, or task force qualifies for a maximum of four hours of credit per renewal cycle.

• Regulatory Participation: Attending a regulatory board meeting earns a maximum of one hour of credit toward Class II requirements.

• Association Membership: Maintaining an active membership in the American Physical Therapy Association counts for a maximum of one hour of credit per renewal cycle.

Unacceptable Activities for Continuing Compliance

The Board does not recognize the following activities for continuing competence credit:

• Regulatory and Safety Training: Attendance at courses regarding the regulations of the United States Occupational Safety and Health Administration (OSHA) or the Tennessee Division of Occupational Safety and Health (TOSHA) is not accepted. Additionally, training in cardiopulmonary resuscitation (CPR) and general safety protocols does not qualify for credit.

• Administrative and Business Meetings: Participation in non-educational business meetings conducted at annual association, chapter, or organization gatherings is excluded.

• Recreational and Social Events: Credit is not granted for entertainment or recreational meetings and activities.

• Exhibit Hall Attendance: Time spent visiting commercial or clinical exhibits is considered an unacceptable activity for continuing competence credit.

Documentation of Compliance

Each licensee must retain completion certificates, transcripts, and syllabi for all continuing competence requirements for a period of 5 years from the date the requirements were completed. This documentation must be produced for inspection if requested in writing by the Board during its verification process, and must be uploaded into the licensee's own CE broker account.

Acceptable Evidence for Submission

The following examples illustrate the types of documentation that must be maintained and uploaded:

• A signed peer review report, an official program or course outline, or a copy of a publication that clearly shows objectives and content were related to physical therapy, states the number of contact hours, and identifies the licensee's responsibility in teaching or authorship.
• A CEU certificate or verification of home study completion identifying the sponsoring entity; a copy of a final grade report for university credit courses; a specialization certificate; proof of attendance with a copy of the program for other Class I or Class II activities; or documentation of self-instruction from professional literature.

Provider Obligations

Organizations that sponsor or provide continuing education units are also required to maintain records of all offered activities for at least 5 years.

Disciplinary Action

Licensees who fail to complete the required competence activities or who provide false certification of completion may be subject to disciplinary action

Reinstatement and Reactivation of Licenses

The requirements for restoring a license to active status depend on how long the license has been inactive or expired.

Inactivity of Three Years or Less. An individual whose license has expired or been retired for three years or less must submit the appropriate application for reinstatement or reactivation along with documentation of continuing competence. All qualifying activities must have been initiated and completed within the two years immediately preceding the application submission.

Inactivity of More Than Three Years. An individual whose license has expired or been retired for more than three years must submit the required application along with documentation of continuing competence completed within the previous two years. In these cases, the Board may also require additional education, a period of supervised clinical practice, successful completion of examinations, or the issuance of a provisional license.

Hardship Waivers and Extensions

In instances involving documented illness, disability, or other undue hardship, the Board may waive continuing competence requirements or extend the deadline for their completion.

To be considered, a licensee must submit a written request supported by appropriate documentation before the end of the twenty-four-month period in which the continuing competence requirements were not met.

Advertising (1150-01-.13)

Because the public may lack specialized knowledge regarding physical therapy services, the choice of a practitioner carries significant consequences. Unrestricted advertising poses a risk of deception; therefore, physical therapists must take special care to avoid misleading the public. The benefits of advertising depend entirely on its reliability and accuracy. Because advertising is a calculated rather than spontaneous act, reasonable regulation ensures that the information provided is useful, meaningful, and relevant to the public interest.

Definitions

• Advertisement: Any informational communication designed to attract public attention to the practice of a physical therapist licensed in Tennessee.

• Licensee: Any person, partnership, or corporation holding a valid license to practice physical therapy in Tennessee.

• Material Fact: Any fact that an ordinary, reasonable, and prudent person would need to know or rely upon in order to make an informed decision when choosing a physical therapist.

• Bait and Switch Advertising: An alluring but insincere offer to provide a service or product that the advertiser does not actually intend to sell. The purpose is to attract consumers with an appealing offer, only to switch them to a different service, typically for a higher fee or on terms more advantageous to the advertiser.

• Discounted Fee: A fee offered or charged for a product or service that is less than the amount usually charged. Services expressly offered free of charge are not classified as discounted fees.

Advertising Fees and Services

• Fixed Fees: Practitioners may advertise fixed fees for any service. It is presumed that an advertised fixed fee includes all professionally recognized components required to complete the service according to accepted standards, unless otherwise stated.

• Range of Fees: When advertising a fee range, the licensee must disclose the factors used to determine the final cost to prevent public deception.

• Discount Fees: Licensees may advertise discounts only if the fee is truly lower than their customary charge and the quality and components of the service remain identical to those provided at the regular price.

• Related Services and Additional Fees: Any advertisement must clearly identify related services that may be required in conjunction with the advertised service if those additional services incur further costs.

• Duration of Advertised Fees: Fees stated in an advertisement must be honored for the entire period specified, whether or not services are completed within that timeframe. If no expiration date is provided, the fee must be honored for 30 days from the last publication date or until the next scheduled publication, whichever is later.

Prohibited Advertising Content and Unethical Conduct

Any licensee who engages in the following acts or omissions in their advertisements is considered to be practicing unethical conduct and is subject to disciplinary action.

• Claims of professional superiority that cannot be substantiated;
• The misleading use of an unearned or non-health degree;
• Promotion of services that the licensee knows or should know are beyond their ability to perform;
• Communication techniques that intimidate or exert undue pressure on prospective patients;
• Unfair or excessive appeals to a person's anxiety;
• Use of unverifiable personal testimonials regarding the quality or competency of services;
• Utilization of past performance data to predict future results in a way that creates unjustified expectations;
• Communication of personally identifiable patient information without obtaining explicit patient consent;
• Any misrepresentation of a material fact;
• Knowing suppression, omission, or concealment of any material fact or law that would render the advertisement deceptive;
• Statements about the benefits of therapeutic procedures involving significant risks without including a realistic assessment of safety and efficacy, available alternatives, and a description of the benefits of those alternatives where necessary to prevent deception;
• Any communication creating an unjustified expectation about potential treatment results;
• Failure to comply with the rules governing advertisement of fees, services, or advertising records;
• Use of bait and switch tactics (the Board may require the licensee to furnish data on sales at advertised fees if such tactics are suspected);
• Misrepresentation of credentials, training, experience, or ability;
• Failure to include the corporation, partnership, or individual licensee's name, address, and telephone number in any advertisement. Any entity advertising by trade name or failing to list all licensees at a particular location must: (1) provide a list of all practicing licensees upon request, and (2) maintain and conspicuously display a directory of all practitioners in the office;
• Failure to disclose that compensation was provided to media representatives in exchange for an advertisement or article, unless the nature of the medium makes the fact of compensation apparent;
• Use of the name of a departed licensee in advertisements or on office signs more than thirty days after their departure (this does not apply to retired or deceased former associates, provided their status is clearly disclosed); and
• Directly or indirectly offering, giving, receiving, or agreeing to receive any fee or consideration to or from a third party for the referral of a patient.

Advertising Records and Responsibility

Every licensee who serves as a principal, partner, or officer of a firm identified in an advertisement bears joint and several responsibility for its form and content. This extends to any licensed professional employees acting as agents for the entity. It is legally presumed that any advertisement has been reviewed and approved by the licensee named within it.

Retention of Records

Licensees must maintain a comprehensive archive of all promotional communications for a period of two years following the final date of broadcast or publication. This includes recordings of electronic media advertisements and copies of print or other forms of advertisement. These records must be made available for review upon request by the Board or its designee.

Substantiation of Claims

At the time any advertisement is placed, the licensee must possess and rely upon objective information that substantiates the truthfulness of all assertions, representations, and omissions of material fact.

Severability

The sections, clauses, sentences, and parts of these rules are considered severable and are not matters of mutual essential inducement. If any specific portion of these rules is rescinded or found to be ineffective, the remaining provisions shall remain in force.

Should a court adjudge any single part of these rules to be unconstitutional or invalid, that judgment will not affect, impair, or invalidate the rest of the regulation. The impact of such a ruling shall be confined strictly to the specific provision in question, and the invalidity of a provision in one instance does not affect its validity or applicability in any other instance.

Think of severability as the legal equivalent of a "safety net." It ensures that if one tiny part of the agreement breaks, the whole thing doesn't come crashing down — like a strand of modern Christmas lights where one burned-out bulb doesn't darken the rest of the strand.

Code of Ethics (1150-01-.14)

The Board officially adopts the current Code of Ethics issued by the American Physical Therapy Association (APTA) for all licensed physical therapists and physical therapist assistants. This code is incorporated into these rules as if fully set out within this text. The Board further adopts any future amendments or updates to the Code of Ethics as they are released by the APTA to ensure that professional conduct remains aligned with national standards.

Disciplinary Actions, Civil Penalties, Assessment of Costs, and Screening Panels (1150-01-.15)

Think of this section as the "Graduated Scale of Consequences." When a PT or PTA breaks the rules, the Board has a toolkit of disciplinary actions, ranging from a gentle warning to a career-ending revocation.

Upon a finding by the Board that a PT or PTA has violated any provision, the Board may impose any of the following actions separately or in any combination deemed appropriate to the offense:

Here is the breakdown of those penalties from least to most severe:

The Six Levels of Discipline

(a) Advisory Censure — A written action issued for minor or near-infractions. It is advisory in nature and does not constitute a formal disciplinary action.

(b) Formal Censure or Reprimand — A written action issued for one-time and less severe violations. This is a formal disciplinary action.

(c) Probation — A formal disciplinary action that places the licensee under close scrutiny for a fixed period of time. This action may be combined with conditions that must be met before probation will be lifted and/or that restrict the individual's activities during the probationary period.

(d) Licensure Suspension — A formal disciplinary action that suspends an individual's right to practice for a fixed period of time. It contemplates the individual's reentry into practice under the previously issued license.

(e) Licensure Revocation — The most severe form of disciplinary action, which removes an individual from the practice of the profession and terminates the licensure previously issued. It relegates the violator to the status held prior to application for licensure. The Board may, in its discretion, allow reinstatement of a revoked license upon conditions and after a period of time it deems appropriate. No petition for reinstatement and no new application from a person whose license was revoked shall be considered prior to the expiration of at least one year, unless otherwise stated in the Board's revocation order.

(f) Conditions — Any action deemed appropriate by the Board to be required of a disciplined licensee in any of the following circumstances:

• During any period of probation or suspension;
• During any period of revocation, after which the licensee may petition for an order of compliance to reinstate the revoked license;
• As a prerequisite to the lifting of probation or suspension, or as a prerequisite to reinstatement of a revoked license, or
• As a stand-alone requirement in any disciplinary order.

Civil Penalties

The Board may assess civil penalties according to the following schedule:

Type A Civil Penalty: May be imposed for willful and knowing violations of the Practice Act that create an imminent, substantial threat to the health, safety, and welfare of an individual patient or the public. Willfully and knowingly practicing without a license is one such violation. Amount: $500–$1,000.

Type B Civil Penalty: May be imposed for violations that directly impact the care of patients or the public. Amount: $100–$500.

Type C Civil Penalty: May be imposed for violations that are neither directly detrimental to patients or the public nor directly impact their care, but have only an indirect relationship to patient care or the public. Amount: $50–$100.

In assessing civil penalties, the Board may consider: the deterrent effect on the violator; the circumstances leading to the violation; the severity of the violation and the risk of harm to the public; the economic benefits gained by the violator; and the public interest.

Order of Compliance

An Order of Compliance is the "graduation certificate" of the disciplinary process. Even when a period of suspension or probation has technically expired on the calendar, no discipline is automatically lifted. The licensee must prove to the Board that all required conditions were met, and the Board must officially sign off.

An Order of Compliance is a necessary adjunct to each previously issued disciplinary order containing probation, suspension, or other conditions limiting the licensee's ability to practice. It is available only when the petitioner has completely complied with all conditions of the previously issued disciplinary order, including payment of civil penalties, completion of required continuing education, and payment of administrative costs.

The Board may consider a petition at its last meeting before the expiration of the discipline, provided all conditions have been met. At its discretion, the Board may require the petitioner to appear in person before granting the order. No disciplinary sanction is lifted until the licensee petitions for and receives such order, which becomes effective on the original expiration date of the discipline or the date of the petition, whichever is later.

Circumstances for Petition: The Board entertains petitions for an Order of Compliance in three specific scenarios:

1. When the petitioner can prove compliance with all terms of the previously issued order and is seeking an order reflecting that compliance, or
2. When the petitioner can prove compliance and is seeking to lift a previously ordered suspension or probation, or
3. When the petitioner can prove compliance and is seeking reinstatement of a previously revoked license.

Submission Procedures: The petitioner must submit a Petition for Order of Compliance to the Board's Administrative Office containing: a copy of the original disciplinary order; a statement specifying which provision of the rule the petitioner is relying upon; and documentation proving full compliance with all terms or conditions. If compliance relies on the testimony of individuals, the petitioner must include signed statements from each individual attesting, under oath, to compliance; the Board's consultant and administrative staff may require such statements to be notarized. No additional documentation or testimony will be considered after the initial submission.

Administrative staff and consultants will review the petition to either certify compliance for Board presentation or deny the petition if the proof is insufficient. If denied, the licensee may file for a declaratory order as authorized by law.

Order Modifications

This procedure allows a licensee to request changes to the disciplinary portion of an order only when they can prove that compliance with specific terms is impossible. It is not a substitute for an appeal or reconsideration, and cannot be used to challenge findings of fact, conclusions of law, or to seek a lesser penalty.

For purposes of this rule, "impossible" does not mean compliance that is merely inconvenient, impractical, or financially difficult.

Modification Procedures: The petitioner must submit a written request to the Board's administrative office containing: a copy of the original order; a detailed statement explaining why compliance is impossible; and supporting documentation with signed and notarized statements from any individuals providing testimony.

The Board's consultant and staff will make an initial determination. If impossibility is certified, the matter is forwarded for Board presentation. If denied, the petitioner is notified of the specific deficiencies in their proof. As with Orders of Compliance, if denied, the petitioner may seek a declaratory order.

Standardized Petition Form Elements

Both the Petition for Order of Compliance and the Petition for Order Modification require:

• Petitioner's name, mailing address, email address, and telephone number
• Attorney information, if applicable
• A clear selection of the specific relief requested
• A signed and dated representation that all attached documentation is true and accurate

Screening Panels

A screening panel is an alternative pathway in the disciplinary process. Rather than going straight to a formal Board hearing, a screening panel offers an opportunity for a more informal resolution of a complaint or potential disciplinary matter.

Who serves on a screening panel? Screening panels are established under T.C.A. § 63-1-138 and operate alongside — not instead of — the full Board. They share authority with Board members to conduct informal hearings and make settlement recommendations. Any panel made up of two or more people must elect a chairperson before conducting any official business.

How does the process work? During an informal hearing, the panel reviews the situation and may recommend settlement terms. It is important to understand that nothing decided at this level is automatically final. A proposed settlement only becomes binding when all three of the following conditions are met:

• A majority of the screening panel approves the proposed settlement;
• Both the Department of Health and the licensee agree to the terms; and
• The full Board ratifies the agreement.

In other words, all parties must be on board before anything is finalized.

What about confidentiality? Screening panel activities are confidential. They are not considered official agency meetings under Tennessee's open meetings law, which means the public does not have access to what takes place during these proceedings. Panel members also have deliberative privilege and the same legal immunity as the Board itself — they cannot be deposed or subpoenaed to testify about matters discussed during screening panel proceedings.

One important note for licensees: Participation in an informal screening panel hearing is voluntary for the licensee. You cannot be compelled to take part. However, if both you and the state agree to participate, it can offer a less adversarial path toward resolving a complaint. As with any disciplinary proceeding, consulting with legal counsel before participating is strongly encouraged.

Duplicate (Replacement) License (1150-01-.16)

A license holder whose "artistically designed" license has been lost or destroyed may be issued a new license upon receipt of a request to the Board's administrative office. The request must be accompanied by the required replacement license fee.

A license holder whose renewal certificate has been lost or destroyed may similarly be issued a new license upon receipt of a request to the Board's administrative office, accompanied by the required fee.

Mandatory Release of Client Records

Upon request from a client or the client's authorized representative, any individual licensed by this Board must provide either a complete copy of the client's records or a summary of those records maintained by the provider.

It is the provider's option whether to provide copies of the full records or a summary. All record requests must be honored in a timely manner. The person requesting the records is responsible for paying any reasonable costs the provider charges for copying and mailing.

Board Meetings, Officers, Consultants, Records, Complaints, and Declaratory Orders (1150-01-.19)

Purpose of the Board

The Board is responsible for regulating the practice of physical therapy.

Board Meetings

• Meeting Schedule: The Board decides when and where to meet, but at least one meeting is required annually.
• Special Meetings: Can be called by the Chair or at the request of two Board members, with adequate notification to all members.
• Quorum: Three members of the Board are needed to constitute a quorum.
• Public Access: All Board meetings are open to the public.
• Non-Board Members: Can address the Board only if recognized by the chairperson.

Board Officers

• Chair: Presides over all Board meetings.
• Secretary: Presides in the absence of the Chair and, along with the Board’s Unit Director, handles Board correspondence.

Responsibilities of the Board

• Adopting and revising rules and regulations.
• Adopting and administering examinations.
• Denying, withholding, or approving licenses and renewing them.
• Appointing designees to assist in duties.
• Conducting hearings.

Conflict of Interest

Any Board member with a personal, private, or financial interest in a matter before the Board must disclose it in writing and not vote on it.

Board Consultant

The Board may select a consultant vested with the authority to: recommend whether and what type of disciplinary actions should be instituted as a result of complaints or investigations; recommend whether and under what terms a complaint case might be settled (any proposed settlement must be ratified by the full Board to become effective); and undertake other matters authorized by a majority vote of the Board.

Records and Complaints

• Communications: All requests, applications, notices, and correspondence must be directed to the Board's administrative office.
• Board Decisions: Requests requiring a Board decision must be received 14 days before a scheduled meeting, or they will be deferred to the next meeting.
• Public Records: All records, except those made confidential by law, are open for inspection at the Board's administrative office. Copies are available upon payment of copying costs.
• Complaints: Complaints against a licensed practitioner may only become public information pursuant to T.C.A. § 63-1-117.

Declaratory Orders

The Board adopts Rule 1200-10-01-.11 of the Division of Health Related Boards as its rule governing the declaratory order process. All declaratory order petitions involving statutes, rules, or orders within the Board's jurisdiction shall be addressed by the Board. Declaratory Order Petition forms are available from the Board's administrative office.

Consumer Right-to-Know Requirements (1150-01-.20)

Malpractice

You are required to report any malpractice cases. However, if the payment amount from a malpractice judgment, award, or settlement is below $10,000, it does not need to be reported under the "Health Care Consumer Right-To-Know Act of 1998." If the amount exceeds $10,000, it must be reported to consumers.

Criminal Conviction Reporting Requirements

Any felony conviction must be reported. 

Any misdemeanor conviction involving the following elements must be reported:

• Sexual offenses
• Alcohol or drug-related offenses
• Physical injury or threats of injury to any person
• Abuse or neglect of a minor, spouse, or elderly person
• Fraud or theft

If a misdemeanor conviction that has been reported is later expunged, you must submit a copy of the expungement order signed by the judge to the Department. Only then will the conviction be removed from your profile.

Professional Peer Assistance (1150-01-.21)

As an alternative to disciplinary action or as part of disciplinary action, the Board may approve and utilize a professional assistance program for situations regarding licensee substance abuse, chemical abuse, or lapses in professional and/or ethical judgments. Information on those referred by the board and who are entering the program is confidential.

Dry Needling (1150-01-.22)

Educational Requirements

To perform dry needling, a physical therapist must receive all of the educational instruction described below. All educational instruction must be obtained in person and may not be obtained online or through video conferencing.

Mandatory Training Areas

• 50 hours of instruction in the following areas (usually covered during physical therapy school):
  • Musculoskeletal and Neuromuscular Systems
  • Anatomical basis of pain mechanisms, chronic pain, and referred pain
  • Trigger Points
  • Universal Precautions
•  24 hours of specific dry needling instruction covering all six of the following areas:
  • Dry needling technique
  • Dry needling indications and contraindications
  • Documentation of dry needling
  • Management of adverse effects
  • Practical psychomotor competency
  • OSHA’s Bloodborne Pathogens Protocol

Course Approval

Each instructional course must specify the anatomical regions covered and whether the course is introductory or advanced. Courses must be pre-approved or approved by the Board or its consultant, or the Board may delegate the approval process to recognized health-related organizations or accredited physical therapy educational institutions.

Newly Licensed Therapists

A newly licensed physical therapist shall not practice dry needling for at least one (1) year from the date of initial licensure, unless the practitioner can demonstrate compliance with the training requirements through their pre-licensure educational coursework.

Out-of-State Training

Physical therapists who completed the 24 hours of dry needling-specific instruction in another state or country must provide upon request or audit the same documentation to the Board as is required of a course provider.

Delegation

Dry needling can only be performed by a licensed physical therapist and cannot be delegated to a physical therapist assistant, students, or support personnel.

Documentation

Physical therapists must provide written documentation of their dry-needling training upon request by the Board.

Patient Information

Physical therapists must provide all patients receiving dry needling with information that includes a definition and description of the practice, as well as the risks, benefits, and potential side effects associated with dry needling.

Telemedicine (1150-01-.23)

This is a new rule, effective December 29, 2025.

Telemedicine offers exciting opportunities to expand access to physical therapy services, but it comes with its own set of rules and responsibilities. This section walks you through what you need to know before delivering care through a virtual platform.

Establishing a Provider-Patient Relationship

A provider-patient relationship through telemedicine is formed when both you and your patient mutually agree to communicate and engage in care — with the exception of emergency situations, where that formality is not required. The patient's consent can be either expressed (clearly stated) or implied (understood through their actions and participation).

It is important to understand that simply receiving a patient's health information does not automatically create a provider-patient relationship. Your professional responsibilities begin only when you actively undertake to evaluate, diagnose, or treat the patient — or when you meaningfully participate in that process.

Scope of Practice

Practicing via telemedicine does not expand or change your scope of practice. The same rules that govern your in-person practice under Tennessee Code Annotated, Title 63, Chapter 13, and Chapter 1150-01-.02 apply equally when you are working remotely. This rule does not create any new standards of care — it simply extends your existing obligations to a virtual setting.

Standard of Care

The standard of care in telemedicine is identical to the standard expected in a face-to-face clinical encounter. Providing services remotely is not a reason to lower your clinical expectations or professional judgment. Your patients deserve the same quality of care regardless of how the visit is delivered.

Patient Identity and Communication

Before and during telemedicine sessions, you are responsible for taking several steps to protect your patient and ensure effective communication. At the start of your relationship with a telemedicine patient, you need to:

• Confirm the patient's identity at the beginning of each session;
• Collect alternative contact information for the patient in case technology fails or an emergency arises;
• Provide the patient with alternative ways to reach you, so they are never left without access to their provider;
• Share your emergency contact protocols with the patient so they know how to reach you or get help if something goes wrong during a session;
• Protect patient information by using only secure communication platforms and channels; and
• Obtain written, informed consent from the patient — or from the person legally authorized to make healthcare decisions on their behalf — before providing any telemedicine services.

These steps are not just administrative formalities. They are the foundation of a safe, professional, and legally sound telemedicine practice.

Compliance with Laws and Regulations

Practicing physical therapy through telemedicine carries the same legal obligations as in-person care. To practice telemedicine in Tennessee, you must:

• Hold an active Tennessee license or current compact privileges in Tennessee in good standing;
• Be legally authorized to practice in any other jurisdiction where your patient is physically located or lives;
• Follow all Board rules, regulations, and current standards of care; and
• Comply with all applicable state and federal laws, including privacy and telehealth regulations.

If you are considering adding telemedicine to your practice, take the time to review your licensure status in any state where your patients may be located. Treating a patient across state lines without proper authorization is a violation of both Tennessee law and the laws of the patient's home state.

Policy Statements

The Board of Physical Therapy is also responsible for issuing policy statements.  A policy statement is an authoritative guide to the meaning of an applicable guideline. The Board's website lists numerous policies, some of which date back more than 15 years.  Below is a sample of some policy statements related to PT.  For an up-to-date list, click here.  

FSBPT License Verification Report Position Statement 

Several states are no longer sending state license verifications to the Tennessee Board of Physical Therapy as required by Rule 1150-01-.05(3)(b).

To address this, and consistent with T.C.A. 63-13-304, the Tennessee Board of Physical Therapy is temporarily allowing the use of the FSBPT (Federation of State Boards of Physical Therapy) score/license verification report to confirm an applicant’s licensure across all states.

This is a short-term measure and will remain in place until a formal rule change is made.

Direct Access Policy 2023

These recent changes were discussed in 63-13-303, which outlines exceptions for referrals and governs direct access to physical therapy services. An amendment on April 4, 2023, allows a physical therapist to treat a patient without a referral, adhering to the scope of practice of physical therapy and specific conditions. However, this condition was added: 

• If, based on clinical evidence, the physical therapist determines no progress in the patient's condition within thirty (30) days after the initial visit, the physical therapist discontinues services and refers the patient to a qualifying healthcare practitioner.

The Board of Physical Therapy emphasizes that, according to 63-13-303, a physical therapist treating a patient without a referral must discontinue services and refer the patient to an appropriate healthcare practitioner after thirty (30) days if no progress is observed.

Approved and Pre-Approved Dry Needling Courses

All physical therapists in Tennessee who wish to practice dry needling must complete specific coursework that meets specific prerequisites. Those are further described in 1150-01-.22(b). Courses in dry needling must be approved by the Board. As mentioned earlier, they will be reauthorized every two years. Please refer to the Board for a list of the most up-to-date providers. 

Criminal Convictions 

Anyone applying for a license as a physical therapist or physical therapist assistant with one or more criminal convictions may be required to meet with the Board before a license is granted. The following individuals must appear before the Board prior to being issued a license:

1. Any applicant with a felony conviction.
2. Any applicant with multiple misdemeanor convictions.
3. Any applicant convicted of a Class A or B misdemeanor within five (5) years of the application date.

The following individuals do not need to appear before the Board before a license is issued:

1. Applicants convicted of nothing more serious than a Class C misdemeanor (or its equivalent in other states).
2. Applicants convicted of only one misdemeanor that occurred more than five (5) years before the application date.

The Board’s administrator, in consultation with a Board member, consultant, or attorney, can grant temporary authorization and decide if the applicant needs to appear before the Board. This policy was adopted by the Board of Physical Therapy on February 17, 2012.

Patient Referrals for Physical Therapy

The Tennessee Board of Physical Therapy has established the following policy regarding patient referrals for physical therapy:

Jointly developed protocols may include referring patients for physical therapy, provided the referrals are within the skill and competence of the physician assistant, orthopedic physician assistant, or advanced practice nurse, and align with the supervising physician's usual scope of practice.

When physical therapy referrals are included in such protocols, any referrals made by a physician assistant, orthopedic physician assistant, or advanced practice nurse are considered to be referrals from the supervising physician. This complies with Tennessee Code Annotated Sections 63-13-109 and 63-13-303, which require that "The practice of physical therapy shall be under the written or oral referral of a licensed doctor of medicine or osteopathy."

Physical Therapy Discharge Evaluations/Plans/Summaries

Physical therapists often face situations where patients are discharged from a facility without prior notice to the physical therapy department. When a patient’s discharge is outside the physical therapist's control, completing a formal discharge evaluation may not be feasible, and producing a formal discharge summary can be logistically challenging.

However, to comply with TCA 63-13-312(20), the physical therapy section of the medical record must include the following:

• Patient identification
• Physical therapy evaluation
• Physical therapy treatment diagnosis
• Plan of care, including desired outcomes
• Treatment record
• Results of interventions
• Discharge plan

Despite challenges, a discharge evaluation, plan, or summary is required for every physical therapy record.

This policy was adopted by the Board of Physical Therapy on August 11, 2006, and amended and ratified on November 14, 2008.

Educational Equivalency for Foreign-Trained Therapists

This is addressed at length in Rule 1150-01-.04(3). 

The Tennessee Board of Physical Therapy has established guidelines for determining if foreign-trained Physical Therapists meet the necessary educational requirements to practice in Tennessee. These guidelines ensure that the applicant’s education is equivalent to a first professional degree from a CAPTE-approved Physical Therapy program in the U.S. However, the Board has the final say on whether the education is equivalent, even if a credentialing agency approves it. The Board also considers the standards set by the National Federation of State Boards of Physical Therapy.

Requirements for Foreign-Trained Physical Therapists:

1. English Proficiency: Proof of English proficiency by passing the TOEFL, TWE, or TSE exams as required by Rule 1150-1-.04.

2. Education Equivalency: Verification of the applicant’s education through one of the Board's approved credentialing agencies, meeting the following criteria:

   A) Minimum Education:

   • At least 150 semester hours.

   B) General Educational Requirements (60 semester hours minimum):

   • Courses required with a minimum grade of “C”:
     • Humanities: At least one course.
     • Physical Sciences: One course in Physics and one in Chemistry.
     • Biological Sciences: One-semester course.
     • Social Sciences: At least one course.
     • Behavioral Sciences: One-semester course in Psychology.
     • Mathematics: At least one course.

   C) Professional Educational Requirements (90 semester hours minimum):

   • Basic Sciences (must include courses in):
     • Human Anatomy and Physiology specific to Physical Therapy.
     • Neurological Sciences.
     • Kinesiology/Functional Anatomy.
     • Abnormal or Developmental Psychology.
     • Pathology.
   • Clinical Sciences (must include courses in):
     • Neurology, Orthopedics, Pediatrics, Geriatrics.
     • Integumentary, Musculoskeletal, Neuromuscular, Cardiopulmonary, and Metabolic Assessment and Treatment.
   • Clinical Education: Two clinical affiliations totaling a minimum of 800 hours.

   D) Related Professional Courses:

   • Content must include topics such as professional behaviors, administration, community health, research, medical terminology, communication, ethics, legal aspects, cultural competency, emergency procedures, and consultation.

   Note: CLEP credits will only be accepted for general education requirements.

These guidelines were originally adopted on November 6, 1998, ratified on November 14, 2008, and adopted by the Board on August 21, 2009.

Home Health Aides

Monitoring home health aides by physical therapy practitioners is not in itself a violation of the Physical Therapy Practice Act and Rules if no other ethical or practice violations are present. 

The Board of Occupational and Physical Therapy Examiners, Committee of Physical Therapy, adopted the following policy statement on February 11, 2005.

Multidisciplinary Health Screenings

The board has determined that conducting health screenings in areas outside of a licensed professional’s scope of practice poses a risk to public safety. Any licensee who performs such screenings may face disciplinary action by the board or be at risk of malpractice litigation.

This resolution was originally adopted by the Board of Occupational and Physical Therapy on September 14, 1998, and ratified by the Board of Physical Therapy on November 14, 2008

Called to Active Military Duty

The policy statement on active military duty was created to support licensed professionals serving in the military who may face challenges renewing their licenses or completing continuing education due to deployment. This policy ensures that military personnel are given flexibility and consideration when they cannot meet these requirements on time because of their service. 

Procedures:

1. Any licensed professional who was actively licensed with Health Related Boards before being called to active duty and couldn’t renew their license due to military deployment must notify the appropriate board office in writing.
2. The licensee must submit a letter explaining that the reason for the late renewal was active duty service in the U.S. Military. This letter should include the dates of service and proof of active duty.
3. Once the board receives the notification and proof of service, the licensee will be allowed to renew their license without any late fees or penalties.
4. All documentation, including proof of active service, will be added to the licensee's permanent file.

Additional Points:

• If the license has expired for one year or less, the licensee will not be required to complete continuing education for renewal.
• If the license has expired for over a year, the licensee must complete half of the required continuing education to renew it.

This ensures that military personnel have a fair and manageable process for maintaining their professional licenses during and after service.

Continuing Competency

Physical Therapists and Physical Therapist Assistants in Tennessee must demonstrate continuing competence by earning a minimum of 30 hours of continuing education (CE) within the 24 months before their license renewal month. This applies to both Physical Therapists and Physical Therapist Assistants. Failure to meet this requirement may result in disciplinary action.

If a licensee falls short of the required CE hours, the Board will send a notification to the licensee's last known address, allowing 90 days to resolve the deficiency without penalty. If the issue is not resolved within this grace period, disciplinary measures will follow, depending on how many hours are missing:

• If at least 8 CE hours are completed:

  1. A civil penalty of $100 per missing hour must be paid within 30 days of notification.
  2. The licensee must complete and submit the missing hours with proof of attendance.

• If less than 8 CE hours are completed:

  1. A civil penalty of $100 per missing hour must be paid within 30 days of notification.
  2. The licensee must complete and submit the missing hours with proof of attendance.
  3. The license will be suspended for at least 45 days and remain suspended until all missing CE hours are submitted.

Licensees found non-compliant will face a follow-up audit and cannot count previously submitted hours towards future CE requirements. Ignoring Board requests for documentation or failing to resolve the deficiency may result in further disciplinary action.

The Board of Physical Therapy amended and ratified this policy on February 9, 2017.

Fingerstick Techniques

The Tennessee Board of Physical Therapy policy is that performing fingerstick techniques (such as glucometer or coumadin readings) is within the scope of practice for licensed physical therapists and physical therapist assistants in Tennessee, as long as these activities are necessary during physical therapy treatment under Tennessee Code Annotated § 63-13-301.

However, this policy does not remove the responsibility to refer patients to the appropriate healthcare providers, as required by Tennessee Code Annotated § 63-13-302. This policy was adopted to protect patients, improve care, and guide licensees.

Adopted by the Board on August 20, 2010.

Lapsed License Policy

The Tennessee Board of Physical Therapy has established the following procedures for reinstating an expired license for Physical Therapists and Physical Therapist Assistants:

1. Cease Practice and Contact the Board:
   Upon realizing their license has expired, the individual must immediately stop practicing and contact the Board’s administrative office to request a reinstatement application.

2. Complete and Submit Application:
   The individual must complete the reinstatement application, provide a detailed work history since the license expired, sign, notarize, and return it to the Board’s administrative office along with the required documents and fees.

3. Reinstatement for Less Than 30 Days Expired:
   If the license has expired for less than 30 days, the Board’s administrator may reinstate it upon receiving the completed application, documentation (including continuing education proof), and fee payment. Preferential treatment will not be given; applications are reviewed in the order received.

4. Reinstatement for 30 Days to Less Than 6 Months Expired:
   If the individual has practiced for over 30 days but less than six months on an expired license, they will be presented with an Agreed Citation. This citation imposes a $250 fine for each month worked beyond the 30-day grace period. The license will only be reinstated once the citation is signed and the fine is paid.

   • The Agreed Citation will be reported on the Department of Health’s website, the monthly disciplinary action report, and to federal databanks like the National Practitioner Data Bank (NPDB).
   • This option is only available for licenses lapsed for less than six months.

5. Refusal or 6 Months or Longer Expired:
   If the licensee refuses to sign the citation or has practiced on an expired license for six months or longer, the matter will be referred to the Office of Investigations and Office of General Counsel for formal disciplinary action. If proven, the minimum penalties include:

   • A formal, reportable reprimand on the license.
   • Civil penalties exceeding $250 per month for each month worked beyond the 30-day grace period.
   • Payment of costs for investigation and prosecution.
   • Any other remedies deemed appropriate by the Board.

6. Reinstatement During Disciplinary Action:
   If the matter is referred for formal disciplinary action, the Board’s administrative office can reinstate the license upon receiving a completed reinstatement application, supporting documentation, and fee payment. Applications will be processed in the order they are received, without preferential treatment.

   For those who declined the Agreed Citation, their application will be considered received 60 days after the citation was initially sent.

The Board of Physical Therapy amended and ratified this policy on May 27, 2016.

 Release of Medical Records 

Effective June 18, 2005, the statute regarding the release of medical records (T.C.A. § 63-2-101) was amended to include requirements for releasing records to the TennCare Office of Inspector General and the Medicaid Fraud Control Unit. The new statutory provisions are as follows:

1. T.C.A. § 63-2-101 (i):
   Healthcare providers must make medical records available for inspection and copying by the Office of Inspector General and the Medicaid Fraud Control Unit upon request, no later than the close of business on the next business day. The provider must provide a compelling reason if records cannot be produced. Records cannot be removed from the provider’s office without consent unless there is a reasonable belief that the records may be altered or destroyed.

2. T.C.A. § 63-2-101 (j):
   Upon the provider's request, an authorized agent of the requesting agency must sign a document acknowledging receipt of the records. Similarly, upon the agency's request, an authorized agent of the provider must sign a document acknowledging the return of specific records.

3. T.C.A. § 63-2-101 (k):
   Providers are protected from civil or criminal liability for releasing patient information in response to a request from the Office of Inspector General or the Medicaid Fraud Control Unit.

This amendment ensures compliance with investigations by the TennCare Office of Inspector General and the Medicaid Fraud Control Unit while protecting healthcare providers.

Summary of Key Regulatory Updates

Online Learning: The previous 10-hour limit on online/asynchronous Continuing Education (CE) has been removed. PTs can now complete all CE hours online.

Reciprocity:  The Board no longer automatically recognizes courses approved by other state APTA chapters. All courses must be approved by the TN Board or APTA Tennessee.

Ethics & Jurisprudence: Content standards for Ethics courses were updated. PTs must ensure they take the newly approved 2026 versions of these courses with the latest APTA Code of Ethics update to stay compliant.

Attorney General 

In addition to the federal Attorney General, each state has an Attorney General. The Attorney General is the chief law officer of the state.  He or she gives advice and opinions to the governor and to the executive and administrative departments or agencies.  Those opinions are entitled to respectful consideration, but the Attorney General's opinions have no control over the state of the law discussed in the opinion. Opinions published before the year 2000 are not available for digital viewing.  Those from 2000 and later may be found here.  To request an opinion in its entirety, call (615) 741-2518.  I have placed a few applicable to therapists below, but I have found none in the past few years for physical therapists. 

Different Health Care Professionals to be Members or Holders of Financial Rights of the Same PLLC

Why does this matter to PT practice? 

Understanding Attorney General Opinion No. 26-002 is essential for any physical therapist considering a multi-disciplinary business model, as it clarifies the strict boundaries of the Corporate Practice of Medicine and the Professional Limited Liability Company (LLC) statutes in Tennessee. While the opinion specifically addresses the eligibility of physicians, PAs, and nurses to co-own a single entity, its importance to physical therapists lies in its exclusionary nature: it confirms that the Tennessee General Assembly has not yet granted physical therapists the automatic right to form a "cross-combination" PLLC with other medical providers. For the PT entrepreneur, this means that unless the Board of Physical Therapy issues a specific regulatory bypass, you are generally restricted to a "single-profession" PLLC model. Ignoring this distinction can lead to your business entity being declared void under Tenn. Code Ann. § 48-249-1109(d), potentially exposing you to personal liability and professional discipline for unauthorized practice structures.

Opinion 21-16 COVID-19 Vaccination as a Condition of Employment Imposed by Private Employers 

The question for the Attorney General was whether a private employer can require its employees to be vaccinated against COVID-19 as a condition of employment.  The opinion states that in Tennessee, private employers have the authority to mandate COVID-19 vaccination as a condition of employment. However, the ability to enforce such a requirement may be influenced by federal law, collective bargaining agreements, and other employment-related contractual obligations. It's essential to consider each private employment situation's specific details and circumstances. Certain exceptions, such as those for medical reasons, may apply based on relevant legal and contractual considerations. Please see the entire opinion on the website for a full analysis.  

Opinion 83-172: Use of Electronic Muscle Exercisers

This first opinion was issued in 1983. It deals with rules and regulations regarding the operation of electronic muscle exercisers and an operator's licensing requirements and qualifications. There were no rules or regulations governing those requirements for those devices then, but under certain circumstances, the equipment must only be operated by a licensed physical therapist.

Opinion 95-033: Advertising and Treatment by Massage Therapists

This opinion was issued in 1995, and the question presented to the Attorney General was, “May a massage therapist in Tennessee lawfully advertise that he or she ‘treats’ one or more conditions?”  The answer was no.  The Attorney General expressed that treating any condition through massage constitutes therapeutic massage, and only licensed physical therapists and certain other healthcare professionals may lawfully engage in therapeutic massage. 

Opinion 05-171: Physical and Occupational Therapy Reimbursements under the Medical Fee Schedule

This opinion is dated 2005.  The question was, "Does the method of reimbursing physical and occupational therapy facilities under the medical fee schedule as prescribed by the rules and regulations violate the equal protection provisions of the Tennessee Constitution?"  The Attorney General's answer was no, pursuant to various other rules and regulations cited in that opinion.

Opinion 07-55: Performance of Spinal Manipulation

In 2007, this landmark opinion was issued.  "Under current law, may physical therapists legally perform spinal manipulation as that term is defined in Tennessee code, annotated 63-43-101?"  The opinion said no.  No personal license under Title 63, including physical therapists, may perform spinal manipulation or spinal adjustment.  In this case, the chiropractors received an opinion that protected one of their practice techniques.

Opinion 12-27: Authority of Physical Therapy Board

In 2012, these questions were presented to the Attorney General regarding the Physical Therapy Board's ability to take action against chiropractors who offered “physical therapy” or used the term “physical therapy” in their practices.  This Attorney General opinion favored physical therapists, stating that the Board could file for injunctive relief and impose civil penalties. 

Tennessee Board of Physical Therapy Meetings 

Please refer to the Board meeting minutes for this discussion.

Understanding how the Tennessee Board of Physical Therapy conducts its business is an important component of jurisprudence education. Board meetings are open to the public, and once minutes are ratified, they become public records — meaning any licensee can review them. Staying informed about Board activity is part of being a responsible, engaged professional.

An administrative hearing is a proceeding before an administrative agency that may consist of argument, trial, or both. The use of procedural rules is more relaxed than in a court hearing. If you ever find yourself in a situation where you must appear before the Board, it may be in your best interest to seek legal counsel as you proceed.

Meeting Overview

The November 7, 2025, Board meeting is the most recent meeting for which minutes are available on the Board's website at the time of this course update. The meeting was held virtually via WebEx, with 5 board members present along with key staff, including legal counsel, investigators, and representatives from APTA-TN and TnPAP. at the Poplar Conference Room, 665 Mainstream Drive, Nashville, TN 37243. The meeting was called to order at 9:00 AM CST by Board Chair David Harris with a quorum present.

Minutes & Legal Report

The previous meeting's minutes were approved with a minor spelling correction. At the time of this meeting, there were no contested cases or appeals pending.

Disciplinary Activity

PTs under monitoring (4 total): 2 on probation with terms, 2 on suspension.

PTAs under monitoring (6 total): 2 on reprimand with terms, 1 on probation, 2 on suspension, 1 revoked or surrendered.

Several consent orders were addressed, illustrating the Board's role in evaluating whether proposed discipline is proportional:

• Two consent orders were ratified (with typographical corrections).
• One consent order was denied because the Board found the proposed action disproportionate to the conduct; the Board instead directed probation and a TnPAP evaluation.
• One order of compliance was ratified, formally clearing a licensee who had satisfied all prior disciplinary conditions.

Complaints Report

As of this meeting, 27 open complaints were on file, with 8 closed so far in 2025.

Fiscal Report

The Fiscal Director presented a preliminary revenue and expenditure report for the Fiscal Year ending June 30, 2025. Total expenditures were approximately $608,090, and Board fee revenue was approximately $519,531, resulting in a change in position of approximately -$148,559. The reserve balance stood at approximately $158,964.

Applicant Review

The Board reviewed a licensure applicant whose background check revealed a 2019 criminal matter involving statutory rape. After hearing the applicant's statement, the Board voted to conditionally grant licensure, subject to proof of satisfied court requirements within 60 days and completion of a TnPAP evaluation on Boundaries and Sexual Misconduct. One Board member recused himself; all others voted yes. This case illustrates that the Board takes public protection seriously while providing an accountable pathway to licensure.

TnPAP Report (July–September 2025)

One PT was under non-regulatory monitoring. There were no new referrals, agreements, or discharges during this period.

Licensure Statistics (as of October 31, 2025):

The Administrative Report presented the following active license totals:

• Physical Therapists: 7,789
• Physical Therapist Assistants: 4,365

Licensing activities from August 1 – October 31, 2025:

Course Approvals (Dry Needling and Continuing Education):

The Board approved the following courses with the corrections noted. This serves as a reminder that all dry needling courses must be Board-approved before they can be used for continuing competence credit:

• Beneath the Surface: Applied Anatomy for Dry Needling Through Cada — Course Number 6319 — Approved with corrections
• Dry Needling 2 — Course Number 6358 — Approved with corrections
• MT–O: Evidence-Based Orthopedic Diagnostic Evaluation — Course Number P00068 — Approved with corrections
• Dry Needling Level 1 — Course Number P00069 — Approved with corrections

Scope of Practice Inquiry

The Board received an inquiry about whether LENS Neurofeedback falls within the PT scope of practice in Tennessee. The Board was unable to confirm it does and requested more information, referring the matter to T.C.A. § 63-13-103(17). Takeaway: When uncertain about a modality or service, contact the Board before incorporating it into your practice.

CE Waiver

One PTA was granted a waiver of live CE requirements for the 2023–2025 renewal cycle based on hardship, per Rule 1150-01-.12(10).

Administrative Actions

• 2027 meeting dates were approved (February, May, August, and November).
• The Board Chair and Board Secretary were both re-elected unanimously.
• The meeting adjourned at 11:10 AM. Minutes were ratified at the February 20, 2026 Board meeting.

Why This Matters

Reading Board meeting minutes is one of the most practical ways to understand how the rules you are learning in this course are applied in the real world. The minutes show you:

• What types of conduct lead to disciplinary action;
• How the Board weighs proportionality in discipline;
• What the Board is watching in terms of scope of practice questions;
• How course approval decisions are made; and
• The volume and nature of complaints being filed against licensees.

You are encouraged to review the Board meeting minutes regularly as part of your professional development. They are public records, available on the Tennessee Department of Health website.

Detailed information about disciplinary actions and general licensure verification may be found on the Tennessee Department of Health Website. 

Legislative Updates 

To stay updated on the latest legislative updates, please visit this page.   

PC.741 SB1874/HB1853 — This one directly mentions physical therapists. It clarifies what constitutes "home health services," and specifically states that home health service does not include physical, occupational, or speech therapy services provided by a licensed healthcare professional under title 63, chapter 13 or 17, when provided in the room or residence of an assisted-care living facility resident. This is relevant to PTs working in those settings.

PC.831 SB1766/HB1882 — Requires healthcare providers (which would include PTs) to provide patients a full copy of their medical records within 10 working days of a written request, rather than the option to provide a summary.

PC.893 SB1720/HB2451 — Affects how PTs can advertise. It requires healthcare practitioners to only advertise the profession, title, or designation associated with their actual educational degree.

PC.921 SB2850/HB2900 — Requires verification of U.S. citizenship or lawful presence for professional license applicants, which would apply to PT licensure.

PC.924 SB0734/HB0628 — Allows licensing boards to enter executive session to discuss a licensee's health conditions confidentially, which would apply to the PT licensing board.

PC.944 SB2588/HB2097 — Requires state health-related boards (including those governing PTs) to issue advisory opinions upon request.

PC.1043 SB2151/HB2861 — Prohibits healthcare practitioners, including PTs, from coercing patients regarding vaccinations or misrepresenting vaccination requirements.

PC.1061 SB2749/HB2936 — Requires parental consent for healthcare services to minors, which would apply to PTs treating pediatric patients.

Public Chapter 1061- A physical therapist in Tennessee must obtain consent from a parent before providing care to a minor. Failure to do so could result in disciplinary action from the Board of Physical Therapy and a civil lawsuit from the parent.

Public Chapter 831- Public Chapter No. 831, which took effect on July 1, 2024, amends Tennessee law to create a strict timeline and format for providing patient records. Upon receiving a written request from a patient, a patient's authorized representative, or an attorney with a durable power of attorney for health care, a healthcare provider must provide a copy of the patient's medical records within ten (10) working days. The provider must give a full copy of the medical records. While the provider can also create a summary of the records, providing only a summary does not satisfy this legal requirement.

Public Chapter 551-This public chapter extends the Physical Therapy Licensure Compact to June 30, 2028, and took effect on March 19, 2020.

Public Chapter 594-This chapter was the Department of Health's Accountability Act.  It allows all health-related boards to take action against a licensee who has been disciplined by another state. It expands allowable actions beyond a summary suspension.  The act also states that notification of health practitioner law changes can be done by the online posting of those law changes by the respective boards. That notification must remain online for at least two years following the change in law.  This went into effect on March 20, 2020

Public Chapter 738- Chapter 738 states that before authorizing public records destruction, the public record request coordinator must be contacted to ensure that those records are not subject to any pending public records request.  Therefore, this act does not allow for any destruction of public records if it is known that those records are needed for a pending inquiry.  The regular schedule of records destruction can still occur as long as there is no knowledge by the records custodian of a pending request.  This went into effect on June 22, 2020

Public Chapter 790- This chapter makes several changes to the statutes regarding physical therapists.  The statute now includes the term "physiotherapist," and a definition of "competence" has been added.  The new statute clarifies that a physical therapist will only be licensed under this chapter if he or she holds a degree from a physical therapy program accredited by a national accreditation agency recognized by the United States Department of Education and the board.  The age requirement has been deleted. The statute also changed to allow a physical therapist to conduct an initial patient visit without a referral, instead of just an initial evaluation.  The physical therapist may now treat a patient without a referral if it is within the scope of practice and the following occurs:  

• The patient's physician is notified.
• The physical therapist must refer the patient to a healthcare practitioner who qualifies as a referring practitioner if the physical therapist determines no progress has been made in regard to the patient's condition within 30 days after the initial visit.  
• Therapy services cannot continue beyond 90 days without the patient's healthcare practitioner being consulted.  
• The 30 and 90-day time frame windows do not apply if the patient was diagnosed by a licensed physician with chronic, neuromuscular, or developmental conditions and the treatment is for symptoms associated with those conditions.
• The physical therapist must refer the patient to an appropriate healthcare practitioner for the following reasons:  
  • Patient's symptoms or conditions beyond their scope of practice
  • Reasonable therapeutic progress is not being made
  • Physical therapy is contraindicated

It is considered unprofessional conduct to initiate physical therapy services in violation of the conditions discussed in this statute.   

Applications will be active for 12 months, and no more than six attempts can be made to pass the examination.  

A physical therapist (or PT assistant) licensed in the PT Licensure Compact member state is eligible to become a licensee for compact privileges in Tennessee.

Finally, additional grounds for license denial, suspension, revocation, and discipline were created.  Now included in the statute are: 

1. A licensee acting in a manner inconsistent with generally accepted standards of physical therapy practice
2. Practicing physical therapy with a mental or physical condition that impairs the ability of the licensee to practice with skill and safety. 

This went into effect on July 15, 2020

Public Chapter 4-Deals with telehealth and reimbursement. An amended Telehealth Statute 63-1-155 was enacted on August 20, 2020. 

This public chapter covers telehealth services and their reimbursement. Most of the legislation focuses on insurance and payment for these services. However, Section 9 of the chapter explains what telehealth means and which healthcare providers can offer it.

In Section 9, "telehealth," "telemedicine," and "provider-based telemedicine" are defined as the use of real-time audio, video, or other electronic tools that allow healthcare providers and patients to interact remotely for diagnosis, consultation, or treatment. This includes situations without face-to-face meetings and "store-and-forward" services, in which medical information is sent electronically for later review.

Until April 1, 2022, all licensed healthcare providers under Title 63, licensed alcohol and drug counselors under Title 68, and crisis service providers working at licensed facilities under Title 33 are considered eligible to offer telehealth services. After April 1, 2022, this definition will only include individuals with a valid license under the same titles. Telehealth services cannot be used in pain management clinics or to treat chronic non-cancer-related pain. Veterinarians are also not allowed to use telehealth services.

A patient-provider relationship through telehealth is established by mutual agreement and communication. Telehealth does not change the standard of care, meaning healthcare providers are held to the same expectations as if treating the patient in person. Lastly, the board cannot create rules for telehealth that are stricter than those already permitted by the provider's licensing regulations.

Frequently Asked Questions

The Board provides a frequently asked questions page and recommends it as another resource for practicing PTs and PTAs in Tennessee.  You can access it here.  A few of the questions not already covered in this course to are included below:

Q: How to file a complaint against a physician: 

A: To file a complaint against a physician, follow these steps:

1. Contact the Health-Related Boards’ Office of Investigations:
   • Phone: Call 1-800-852-2187 to speak directly with the office and report the issue.
2. Submit an Allegation Report Form:
   • Visit the Office of Investigation webpage to access the Allegation Report form.
   • Fill out the form with the necessary details about your complaint.

Make sure to include all relevant information and documentation to support your complaint, such as medical records or witness statements, if applicable. Once submitted, the office will review the case and take appropriate action if necessary.

Q: How do I verify the status of a Tennessee license?

A: To verify the status of a Tennessee healthcare practitioner or facility license, you can use the following resources:

1. For Individuals:

   • Visit the Individual License Verification website.
   • Enter the required information to search for the healthcare practitioner’s license status.

2. For Facilities:

   • Go to the Facility License Verification page.
   • You can search for licensed healthcare facilities in Tennessee by entering the appropriate details.

Q: I would prefer to receive all information from the Board electronically. Can I change my contact preferences? 

A:

• Electronic Communication: You have the option to "opt in" to receive all communications from the Board electronically.

• Address on File: Even if you choose electronic communication, you must maintain a current mailing and practice address with the Board at all times.

• Notification of Changes: You are required to notify the Board of any change to the information in your licensure file, including your addresses, within thirty (30) days of the change.

These tools allow you to confirm the current licensure status, disciplinary actions, and any other relevant credentials of practitioners and facilities in Tennessee.

Q: How does a licensed PT or PTA renew their license in Tennessee?

A: To renew online, go to this link 

Special Populations: Resident Rights, Elder Abuse, and Pediatrics

While mandatory reporting obligations and the duty to protect vulnerable patients were introduced earlier in this course — particularly in the context of whistleblowing and Tennessee's reporting statutes — the populations discussed in this section warrant a closer and more focused examination. Pediatric patients, elderly residents, and individuals in long-term care settings face unique legal and ethical considerations beyond general reporting requirements.

Understanding the specific rights, protections, and professional responsibilities that apply to these groups is an essential part of practicing physical therapy safely and ethically in Tennessee.

Resident Rights

The 1987 Nursing Home Reform Law established critical protections for long-term care residents, though these rights broadly apply across settings. Providers participating in Medicare/Medicaid must uphold resident dignity, self-determination, and well-being. The overarching right is to receive services enabling the highest possible physical, mental, and psychosocial health per an individualized care plan developed with patient and family involvement whenever practical. This landmark legislation obligates facilities to actively promote and safeguard rights through person-centered care planning and an environment fostering choice, inclusion, and purposeful living. While originating in long-term care, these principles today help shape contemporary practice expectations for empowering patients and optimizing quality of life across the healthcare continuum.

The Right to Be Fully Informed 

Individuals have the right to full disclosure regarding services, associated charges, governing rules and regulations, and a written copy of their rights. They must receive contact information for resources like the state ombudsman and applicable survey agencies. Facilities should provide access to survey reports and any plans for correcting deficiencies. Patients/residents deserve advance notice of room or roommate changes, along with appropriate assistance for sensory impairments. Importantly, they have the universal right to obtain all information in an understandable language or format, whether Spanish, Braille, or other accommodations tailored to their needs. Care settings must ensure transparent communication and cognizance of rights, including through translation or accessible means for diverse populations.

Right to Complain

Individuals have a right to present grievances without fear of reprisal and a prompt effort by the community to resolve those grievances. They have a right to complain to the Ombudsman and file a complaint with a state survey or any other certification agency.

Right to Participate in One's Own Care

They have a right to participate in their care. That includes receiving adequate and appropriate care, being informed of any change in medical condition, and participating in their care planning, treatment, and discharge. They have a right to refuse medication, treatment, therapy, and restraints (chemical or physical). They have a right to review their medical record, and they have a right to be free from charges for services that might otherwise be covered by an insurance provider. 

Right to Privacy and Confidentiality

This right included private and unrestricted communication with anyone of their choice during treatment and care. The communication could be regarding medical, personal, or financial affairs.

Rights During Transfers and Discharges

This right is very specific to long-term care. Individuals need to know that whatever that transfer is, it's necessary to meet their welfare. Maybe they've improved, and now they no longer need care. It might be needed to protect other individuals, including the safety of other residents or staff, or they haven't paid their bill, quite honestly. Individuals are to receive a thirty-day notice that includes the reason, effective date, and location.

Right to be Treated with Dignity, Respect, Freedom, and Self-Determination

Individuals have a right to be treated with consideration, respect, and dignity and be free from abuse. 

Right to Visits (or refuse visits) 

Individuals have a right to visits, and that could be from anybody, including their physician, a representative from the state survey, the ombudsman, relatives, friends, other individuals, or organizations who might be providing social or legal services.

Right to Make Independent Choices

This goes back to autonomy, right? This right can include what they wear or how they spend their free time. It includes the right to choose their own physician and accommodations, participate in community activities, and manage their financial affairs.

Again, this is very specific to long-term care. However, I think it applies to any setting our patients might be in.

Your Role

So what's your role? Your role is to

• Know the rights of your patients wherever you're working.
• Respect their dignity and their privacy, 24 hours a day, seven days a week. That means knocking on the door before you enter and asking permission.
• Speak to individuals respectfully and in a positive manner
• Let them make choices about their care, giving them that informed consent we discussed.
• Respect their right to refuse therapy, to refuse care, medications, a specific diet, activity, or whatever that happens to be.
• Listen to them and their family members who might have concerns about their rights, treatment, and/or their plan of care. Refer individuals who may have questions or concerns to the appropriate person. 

Elder Abuse

Elder abuse is a growing geriatric concern. There are ethical issues related to this. We need to look beyond just protective services records. We need to look at financial, medical, social, and long-term care areas for any sort of breakdown, possible difficulties, and solutions.

Key definitions:

• Elder: 65 years or older
• Elder abuse: An act or omission by someone in a trusted relationship that harms or threatens an older adult's health/welfare
• Caregiver: Anyone with custody or control over an elder

Estimates suggest that 10-15% of elders experience abuse. While there is no single victim profile, 90% of perpetrators are known to the victim, mirroring child abuse dynamics. As therapists work closely with seniors and caretakers, we are well-positioned to detect and address signs of abuse through appropriate reporting and interdisciplinary collaboration. Education and advocacy regarding this often hidden issue are crucial.

Forms of Abuse

• Physical abuse
• Sexual abuse
• Emotional abuse
• Neglect
• Abandonment
• Financial exploitation
• Self-neglect

Elder Abuse Indicators

• Physical Abuse. Sprains, dislocations, fractures, or broken bones. Burns, internal injuries, abrasions, and bruising. Injuries are unexplained, or explanations are implausible. 
• Sexual Abuse. Fear of being touched/inappropriate modesty on evaluation. Inner thigh/breast bruising, tenderness. 
• Emotional Abuse. Depression, sleep, appetite disturbances, decreased social contact, loss of interest in self, apathy, and suicidal ideation: Evasiveness, anxiety, and hostility. 
• Neglect and Self-Neglect. Inadequate, dirty, or inappropriate clothing, malnutrition, dehydration, odor, poor hygiene, and pressure sores. Misuse/disregard/absence of medicines, medical assistive devices, and medical regimens. 
• Self-Neglect. Eccentric or idiosyncratic behavior, self-imposed isolation, marked indifference. 
• Financial Abuse. Fear, vague answers, and anxiety when asked about personal finances. Disparity between assets, appearance, and general condition. Failure to purchase medicines, medical assistive devices, seek medical care, or follow medical regimens. 

Some potential signs of elder abuse include depression, fear of being touched, and eccentric behavior. Importantly, many elder abuse indicators are very similar to bullying warning signs across age groups. As therapists, we must pay attention to these red flags wherever they occur and report them. Our skills in building trust, observation, and intervention enable us to identify concerning behaviors among vulnerable individuals at any age. 

Elder Justice Act

You have a duty to report any suspected acts involving resident mistreatment, neglect, abuse, crimes, misappropriation of resident property, or injuries of unknown source. The facility must report any reasonable suspicion of a crime against a resident or patient to: the Secretary of the U.S. Department of Health and Human Services (HHS), and the law enforcement authorities in the political subdivision where the facility is located. 

There are very specific timeframes for reporting any elder abuse. If the events cause suspicion of a crime—suspicion is the key—we don't have to prove that elder abuse occurred. If we suspect it may have occurred, we have to report it.

• If the incident results in “serious bodily injury,” the facility must report it to HHS and law enforcement authorities immediately, but not later than two hours after forming the suspicion.  
• Do not result in “serious bodily injury.” The facility must report to HHS and law enforcement authorities no later than 24 hours after forming the suspicion.

Serious bodily injury is an injury  

• involving extreme physical pain or substantial risk of death;  
• involving protracted loss or impairment of the function of a bodily member, organ, or mental faculty, or
• requiring medical intervention such as surgery, hospitalization, or physical rehabilitation

Pediatrics and Your Role

Physical therapists practicing in Tennessee who work with pediatric populations must adhere to both state and federal mandates designed to protect the safety and well-being of minors. Under Tennessee Code Annotated (TCA) § 37-1-605, all healthcare professionals — including physical therapists — are designated as mandatory reporters of suspected child abuse or neglect. This means that any PT who, in the course of their professional duties, has reasonable cause to suspect that a child has been subjected to abuse, neglect, or endangerment is legally obligated to report that suspicion to the Tennessee Department of Children's Services (DCS) or local law enforcement. Failure to report is considered a Class A misdemeanor under Tennessee law.

In addition to mandatory reporting obligations, physical therapists working with minors in Tennessee must obtain informed consent from a parent or legal guardian before initiating an evaluation or treatment. Because minors lack the legal capacity to consent to medical treatment on their own, the responsibility falls on the licensed PT to verify that the consenting adult holds appropriate legal authority over the child's healthcare decisions. This is particularly important in cases involving divorced or separated parents, foster care situations, or cases where guardianship may be shared or contested.

Physical therapists employed in school-based settings in Tennessee are subject to additional layers of regulation under the Individuals with Disabilities Education Act (IDEA) and Tennessee's state special education guidelines. When PT services are included in a student's Individualized Education Program (IEP), the therapist must serve as a collaborative member of the IEP team and deliver services in accordance with the least restrictive environment (LRE) principle. Tennessee's State Board of Physical Therapy also requires that all licensees maintain compliance with professional boundaries and ethical standards outlined in their practice act, ensuring that pediatric patients receive care that is both clinically appropriate and legally sound.

Conclusion

The practice of physical therapy in Tennessee is governed by a layered framework of laws, rules, and professional standards that every licensed PT and PTA is personally responsible for understanding and following. From the foundational statutes of the Tennessee Code Annotated and the operational rules of Chapter 1150-01, to Board policy statements and APTA professional standards, each layer of this regulatory structure exists for a single, overriding purpose: to protect the public and to ensure that only qualified, competent, and ethical practitioners are entrusted with patient care. Ignorance of these requirements is not a defense — it is a risk with real consequences, up to and including the permanent loss of your license.

Equally important is the understanding that legal and ethical obligations extend beyond the treatment room. As demonstrated by the enforcement actions discussed in this course — including the criminal prosecution of Methodist Le Bonheur Healthcare employees for selling patient contact information to personal injury attorneys and chiropractors, and the federal settlement with Complete P.T. for posting patient testimonials and photographs online without valid authorizations — patient confidentiality obligations carry real legal consequences at both the state and federal level, in every setting, and for physical therapy providers specifically.. Patient privacy, informed consent, proper supervision, accurate documentation, mandatory reporting of abuse and neglect, and adherence to the scope of practice are not merely bureaucratic checkboxes; they are the daily expression of your commitment to safe, ethical, and patient-centered care. The rights of patients — whether rooted in the 1987 Nursing Home Reform Law, HIPAA, or Tennessee's own practice act — must be actively upheld, not simply acknowledged.

Malpractice liability and elder abuse reporting obligations remind us that our professional duties carry legal weight. Negligence does not require intent — it requires only that your conduct fell below the standard of care expected of a competent clinician. Thorough documentation, evidence-based clinical decision-making, and clear communication with patients and colleagues remain among your strongest protections against liability and disciplinary action.

Finally, staying current is not optional. The regulatory landscape governing physical therapy in Tennessee is not static. Rules are amended, policy statements are issued and revised, and legislative updates reshape the boundaries of practice. Monitoring Board meeting minutes, joining professional listservs, completing the required 30 hours of continuing competence every two years — including 4 hours dedicated to ethics and jurisprudence — and going directly to the licensing board with questions are all concrete steps every licensee should take as an ongoing professional habit. Your license is yours to protect. Know your laws, practice within your scope, uphold your patients' rights, and never stop learning.

References

Rules of the Tennessee Board of Physical Therapy, Chapter 1150‑1: General rules governing the practice of physical therapy (as currently compiled). (2026, Feb 23). Retrieved from https://www.tn.gov/health/health-program-areas/health-professional-boards/pt-board/pt-board/statutes-and-rules.html

Tennessee Board of Physical Therapy. (n.d.). Frequently asked questions. Tennessee Department of Health. Retrieved Feb 23, 2026, from https://www.tn.gov/health/health-program-areas/health-professional-boards/pt-board/pt-board/frequently-asked-questions.html

Tennessee Board of Physical Therapy. Meeting minutes. Tennessee Department of Health. Retrieved Feb 23, 2026, from https://www.tn.gov/health/health-program-areas/health-professional-boards/pt-board/pt-board/meeting-minutes.html

Tennessee Board of Physical Therapy. Policies. Tennessee Department of Health. Retrieved Feb 23, 2026, from https://www.tn.gov/health/health-program-areas/health-professional-boards/pt-board/pt-board/policies.html

Tennessee Board of Physical Therapy. Statutes and rules. Tennessee Department of Health. Retrieved Feb 23, 2026, from https://www.tn.gov/health/health-program-areas/health-professional-boards/pt-board/pt-board/statutes-and-rules.html

Tennessee Code Annotated § 63‑1 (Division of Health Related Boards) (2026). Retrieved Feb 23, 2026, from https://advance.lexis.com/container?config=014CJAA5ZGVhZjA3NS02MmMzLTRlZWQtOGJjNC00YzQ1MmZlNzc2YWYKAFBvZENhdGFsb2e9zYpNUjTRaIWVfyrur9ud&crid=b3346cf4-57dc-45a2-8a93-1d3e75755a94

Tennessee Code Annotated § 63‑13 (Occupational and Physical Therapy Practice Act) (2026). Retrieved Feb 23, 2026, from https://advance.lexis.com/container?config=014CJAA5ZGVhZjA3NS02MmMzLTRlZWQtOGJjNC00YzQ1MmZlNzc2YWYKAFBvZENhdGFsb2e9zYpNUjTRaIWVfyrur9ud&crid=b3346cf4-57dc-45a2-8a93-1d3e75755a94

Rev 2/2026