How Tennessee regulates memory care units

Does Tennessee license memory care separately?

No. Tennessee has no stand-alone memory care license; a licensed ACLF that locks a distinct part of its building reports those beds to the Health Facilities Commission as secured beds, and nursing homes report secured and Alzheimer's beds the same way.

The rule defines a secured unit as a distinct part of an ACLF where residents are intentionally denied egress except as necessary to comply with life safety requirements (0720-26-.02(37)). “Distinct part” means physically identifiable and run separately from the rest of the building: a wing, a floor, a separate building, or even several rooms at one end of a hall (0720-26-.02(13)).

The Health Facilities Commission's October 2026 bed report shows 24 of the 35 licensed ACLFs in Shelby, Fayette and Tipton counties running secured units, with 774 secured beds between them, plus 7 nursing homes reporting 464 secured or Alzheimer's beds. That count is the most reliable way to tell a real secured unit from a marketing phrase, because “memory care” on a brochure carries no legal meaning by itself.

What must a Memphis memory care unit document for state surveyors?

At each annual survey an ACLF with a secured unit must show twelve months of unit-specific records: pre-admission evaluations, quarterly placement reviews, deaths and hospitalizations, incidents, a daily staffing log, an activity calendar with attendance, pressure ulcers and infections, and proof of staff training (0720-26-.08(9)).

• An interdisciplinary team of at least a physician, a registered nurse and a family member or patient care advocate evaluates each resident before admission to the secured unit
• The team reviews the appropriateness of the placement every quarter
• The facility keeps current lists of deaths and hospitalizations with diagnoses, unusual incidents, and pressure ulcers or infections on the unit
• A daily staffing pattern and staff ratios for the unit are recorded
• A calendar of daily group activities with three months of attendance records
• 100% of unit staff receive annual in-service training on Alzheimer's disease and related disorders, dysfunctional behavior and catastrophic reactions, safety risks, help with daily activities, and communicating with families

For families, those documentation duties translate into practical questions. Who sat on the team that evaluated your parent before admission? When is the next quarterly review, and can you attend as the family member? May you see the daily staffing pattern for the unit?

How many staff must be on a secured unit at night?

Tennessee requires at least one attendant who is awake, on duty and physically located on the secured unit 24 hours a day, seven days a week (0720-26-.08(9)(e)); beyond that minimum the rule sets no numeric staff-to-resident ratio.

One awake person is a floor, not a staffing plan. A 30-bed unit and an 8-bed unit can both meet the letter of the rule with one overnight attendant. Ask each Memphis community how many people are on the unit at 2 a.m., whether they are permanent staff or agency workers, and who covers the unit when that attendant is helping a resident in the bathroom. The daily staffing record the rule requires is the document that answers the question.

What training do Tennessee memory care workers need?

All staff who work on a Tennessee secured unit must receive annual in-service training covering the causes, progression and management of Alzheimer's disease and related disorders, handling dysfunctional behavior and catastrophic reactions, identifying safety risks, helping with daily activities, and communicating with families (0720-26-.08(9)(h)).

The rule requires 100% of unit staff to be trained every year but does not set an hour count. Ask how many hours the community actually provides, who teaches it, and whether night and weekend staff attend. Ask too how the community manages exit-seeking, falls and sundowning, because those behaviors, not the diagnosis, decide whether a resident can stay.

When does a memory care resident have to move to a nursing home in Tennessee?

An ACLF may not keep a resident who needs continuous nursing care, treatment for stage III or IV pressure ulcers, restraints, or who shows aggressive behavior posing an imminent threat, or whose needs cannot be met safely (0720-26-.08(1)); in those cases the resident must be transferred to an appropriate setting.

Dementia itself is not a discharge reason. A resident who meets nursing facility level of care can stay in an ACLF if the treating physician certifies in writing that needs can be met there and the facility can assure a timely evacuation (0720-26-.08(3)). Several Memphis-area nursing homes also report secured or Alzheimer's beds, which is where residents usually go when nursing needs grow. See the memory care directory.