
Tennessee Department of Health Certifies Updated COPA Terms in Agreement Serving Northeast Tennessee
NASHVILLE – Today, the Tennessee Department of Health (TDH) announced it has completed updates to the Terms of Certification (TOC) covering the Certificate of Public Advantage (COPA), which guides the access and delivery of health care services in Northeast Tennessee. The updated TOC can be found here (tn.gov/health/health-program-areas/health-planning/certificate-of-public-advantage/redir-copa/copa-announcements.html).
“For more than a year we have worked with the Tennessee Attorney General’s Office and Ballad Health to ensure the COPA continues to provide a public benefit in meeting Northeast Tennessee’s health needs,” Commissioner Ralph Alvarado, MD, FACP said. “Our effort and progress serve as a model for health care in Tennessee, the Appalachia Region, and the entire nation. It is vitally important we get it right.”
The revisions to the TOC address Ballad’s performance under the COPA in five key health care areas, prioritizing quality of care, overall system scoring, rural hospitals, charity care, and listening sessions.
Specific items in the revised COPA TOC applicable to Ballad include:
• Utilizing all U.S. Centers for Medicare and Medicaid hospital star measurements instead of combining state and national priority measurements;
• Increasing the weight of quality improvements from 20 percent to 40 percent in overall scoring;
• Implementing a pass or fail for the overall score for better public transparency, with a score of 60 or above required to pass;
• Memorializing Ballad’s commitment to maintain the more generous financial assistance policy that Ballad implemented after the COPA was granted; and
• Maintaining rural hospital investments to the COPA’s 10th anniversary in 2028, or to the COPA’s 8th year if CMS does not approve the federal Medicaid Hospital Investment Program by Dec. 31, 2025.
TDH will prepare a narrative review for the assessment of Ballad’s performance through the end of the company’s 2025 Fiscal Year, on June 30, 2025.
This is to allow Ballad time to implement the new, numerical COPA performance scoring process for the 2026 Fiscal Year, beginning on July 1, 2025.
“We will continue to be active in our supervision of the COPA, to make changes to the TOC where and when they are needed, and to listen to those in the region the COPA directly impacts,” Dr. Alvarado said. “These goals guide us, and we do not take our role lightly as we remain committed to transparency in our COPA oversight.”
The State of Tennessee issued the COPA in 2018 when Northeast Tennessee’s two largest health systems, Mountain States Health Alliance and Wellmont Health System, merged under the name Ballad Health.
TDH is responsible for COPA oversight to ensure the merger provides a public advantage to the citizens of Northeast Tennessee.
This is the fifth time the State has amended and revised the COPA TOC since 2018.
Click for more COPA information on the TDH website, including the Fiscal Year 2024 COPA Monitor’s Report and the COPA Annual Report for Fiscal Year 2024.
The mission of the Tennessee Department of Health is to protect, promote and improve the health and well-being of all people in Tennessee. Learn more about TDH services and programs at www.tn.gov/health.
Connect with TDH on Facebook, X, and LinkedIn @TNDeptofHealth!

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