A provision in Tennessee's HB2110 imposes new state licensing requirements on diagnostic imaging providers—and most owners don't realize it applies to them yet.
Most Tennessee health services owners haven't heard about a quiet but significant change buried in HB2110. Starting July 1, 2026, any business providing MRI or PET services for diagnostic purposes will need to obtain a state license from Tennessee's health facilities commission. For many small and mid-sized providers, this is a new requirement that will affect operations, compliance timelines, and regulatory standing.
HB2110, formally titled "AN ACT to amend Tennessee Code Annotated, Title 33; Title 63 and Title 68, relative to health facility regulation," introduces a licensing mandate for diagnostic MRI and PET services through amendments to Tennessee Code Annotated Section 68-11-204(a)(1). The provision appears on Page 3, Section 8 of the bill.
The core requirement is straightforward: if your organization operates MRI or PET equipment and uses it to provide diagnostic imaging services to patients, you must now be licensed by the state. This applies regardless of whether you're a hospital system, urgent care center, standalone imaging clinic, or other health service provider.
Failure to obtain this license exposes your business to regulatory sanctions. The state health facilities commission will have authority to enforce compliance, meaning non-licensed providers could face penalties, operational restrictions, or other enforcement actions.
The licensing requirement applies specifically to diagnostic use of these imaging technologies. This distinction matters. Section 7 of HB2110 creates a carve-out under new subdivision (a)(4): non-diagnostic use of MRI and PET services is excluded from the licensing mandate.
In practical terms, if your organization uses MRI or PET equipment for research, training, or other non-diagnostic purposes, you may not fall under this requirement. However, if the same equipment is used for diagnostic imaging—the standard clinical use—licensing is mandatory.
The effective date for rule promulgation is upon the bill's signing. This means Tennessee's health facilities commission will begin developing the specific rules, application procedures, and standards that will govern licensing. Providers should monitor the commission's rulemaking process for details on application requirements, fees, and compliance deadlines.
All other provisions of the bill, including the licensing requirement itself, become effective July 1, 2026. This gives providers roughly 18 months from the bill's signing to understand the requirements, prepare applications, and obtain licensure before the mandate takes effect.
If your Tennessee health services business operates diagnostic MRI or PET equipment, begin tracking the health facilities commission's rulemaking process. Understand whether your specific services fall under the diagnostic or non-diagnostic category. Document your current operations and equipment use. When draft rules are published, review them carefully to understand application timelines, documentation needs, and any compliance costs.
This isn't an immediate crisis—you have time before July 2026—but it is a real regulatory change that requires attention and planning.
For detailed guidance specific to your health services business, consult your legal or compliance team, or contact the Tennessee health facilities commission directly.