Sometimes the biggest compliance questions start with a simple observation: “Why would a state stop approving new nursing programs?”
That was the question our research team began asking after identifying new Tennessee legislation that temporarily paused approval of new out-of-state nursing education programs. While headlines have focused on the moratorium itself, the more important story may be what Tennessee is trying to accomplish and what it could signal about the future of nursing program oversight.
Our nursing licensure expert, Allen Clarkson, JD, first identified the legislative change during routine monitoring. As we dug deeper into the law, it became clear that the change raises important questions for institutions serving Tennessee students, particularly those considering future expansion into the state.
Understanding exactly what changed and what didn’t is essential for compliance teams, nursing programs, and institutional leaders as they evaluate their next steps.
This spring, our team found that Tennessee has enacted a significant change to the approval process for nursing education programs, creating new challenges for institutions serving Tennessee students and raising important questions about the future of professional licensure oversight.
Under the Tennessee Nursing Education Integrity and Oversight Act, the Tennessee Board of Nursing is prohibited from approving new nursing education programs offered by institutions based outside of Tennessee for a two-year period beginning April 27, 2026. While the legislation has generated considerable discussion, understanding exactly what changed- and what did not change – is critical for institutions evaluating their compliance obligations and enrollment strategies.
What Changed?
The new law places a two-year moratorium on the approval of new out-of-state nursing education programs in Tennessee. From April 27, 2026, through at least April 27, 2028, institutions that do not already have Tennessee nursing program approval will have no regulatory pathway to obtain that approval.
For institutions hoping to establish new clinical placements or expand nursing education activities into Tennessee during this period, the practical effect is straightforward: new approvals are temporarily unavailable.
What Didn’t Change?
Importantly, the law does not alter Tennessee’s state authorization requirements, nor does it affect participation in the State Authorization Reciprocity Agreement (SARA).
Out-of-state institutions enrolling Tennessee students must still comply with all applicable state authorization requirements. Likewise, institutions participating in SARA must continue to meet SARA obligations.
The new legislation focuses specifically on nursing program approval, not on institutional authorization.
This distinction is important because many institutions may assume the moratorium affects their broader ability to operate or recruit students in Tennessee. It does not. The law targets nursing program approvals administered by the Tennessee Board of Nursing.
What About Institutions Already Approved?
Existing approved programs remain authorized to operate and continue serving Tennessee students.
The Tennessee Board of Nursing retains full authority to oversee those programs and enforce compliance with existing rules and requirements. Institutions that already hold approval should expect continued regulatory oversight throughout the moratorium period.
The restriction applies only to new approvals.
Why Is Tennessee Taking This Approach?
According to the legislation, the state intends to use the moratorium period to evaluate nursing program quality, clinical placement capacity, and the overall regulatory framework governing nursing education.
State leaders have indicated that the goal is to improve nursing education outcomes and strengthen oversight of nursing programs serving Tennessee residents.
As part of that effort, Tennessee plans to convene a special commission to work alongside the Board of Nursing and develop recommendations for future program approvals.
The result may be a more clearly defined and transparent approval process when the moratorium ends.
What Could This Mean for Students and Workforce Development?
Tennessee state officials framed the legislation as an opportunity to align nursing education more closely with workforce needs and clinical training capacity within Tennessee.
The review process may lead to:
- Clearer approval requirements
- Greater transparency in regulatory expectations
- Updated standards for clinical placements
- Stronger alignment between nursing education and workforce development goals
- Enhanced oversight of program performance
Whether these changes ultimately improve outcomes remains to be seen, but institutions should expect the approval process after the moratorium to look different from what it does today.
Is This the Start of a National Trend?
At this point, there is no indication that other states are pursuing similar legislation.
Tennessee’s action appears to be unique. At the time of this blog publication, no other state licensing boards have publicly proposed comparable moratoriums on the approval of out-of-state nursing programs.
That said, regulators across the country continue to pay close attention to program quality, workforce needs, clinical placement capacity, and licensure outcomes. If Tennessee’s approach is viewed as successful, other states may see it as a model.
For now, however, institutions should view this as a Tennessee-specific development rather than evidence of a broader national movement.
Read more about nursing boards’ requirements for out-of-state nursing programs.
What Should Institutions Watch Over the Next 12–24 Months?
The moratorium creates a period of uncertainty, but it also offers some clues about where Tennessee may be headed.
Institutions should monitor developments related to:
- Changes to nursing program approval standards
- Clinical placement capacity assessments
- New reporting requirements
- Performance benchmarks for approved programs
- Expectations for out-of-state institutions serving Tennessee students
- Recommendations from the special commission and the Board of Nursing
Many observers expect Tennessee to emerge from the moratorium with a more rigorous approval process and increased scrutiny of program quality and outcomes.
Institutions considering future expansion into Tennessee should begin monitoring these developments now rather than waiting for the moratorium to expire.
How HELP Can Help
Regulatory requirements affecting professional licensure programs continue to evolve, often with little warning.
Through The Bookmark and our add-on nursing information, webinars, newsletters, regulatory monitoring, and expert analysis, HELP helps institutions stay informed about legislative and regulatory developments that can affect licensure compliance, student pathways, and institutional risk.
Want to see how The Bookmark helps institutions stay ahead of licensure changes? Attend an information session.
As Tennessee’s review process unfolds, HELP experts will continue to monitor developments and share updates to help institutions make informed decisions.
If your institution has questions about Tennessee’s nursing program approval requirements or other professional licensure compliance issues, contact our team to learn how HELP can support your work.