Tennessee Daycare Substitute Caregiver Requirements

When You Need a Substitute and What Tennessee Requires

Running a licensed home daycare alone means every doctor's appointment, family emergency, or sick day creates a coverage problem. When the primary educator is absent, Tennessee requires a qualified educator to be on-site during operating hours. The research checklist expects an approved back-up caregiver aged 18 or older to remain on-site, and parents must be notified in advance of who is in charge.

The 36-Hour Background Check Threshold

Here's the critical number: any substitute who works more than 36 hours in a calendar year and is counted in the adult:child ratio must complete the full five-source background screening through IdentoGO. That includes the FBI national fingerprint check, TBI in-state criminal history, National Crime Information Center (sex offender registry), Tennessee Sexual Offender Registry, and the DCS child abuse and neglect registry check via Form CS-0741.

Below 36 hours, a substitute still cannot have unsupervised access to children without clearance — they must work under the direct supervision of a screened adult. As a practical matter, most providers get their substitutes fully screened upfront because 36 hours goes fast. Two weeks of half-day coverage burns through it.

TDHS covers the cost of one background check per person per agency per year. If a fingerprint sample gets rejected and needs resubmission, or if you submit a second check for the same person within 30 days, you pay the resubmission fee.

Training Requirements for Substitutes

Substitutes don't need to complete the primary applicant's 8-hour TDHS orientation or 2-day Small Business Academy pre-licensure path. Tennessee does require pre-service training for all staff before they assume duties, and substitutes providing more than 36 hours in a calendar year must have a physical exam before beginning duties.

• Keep the substitute's required staff records and training documentation on file

The research identifies 18 clock hours of approved annual training for primary educators. It does not identify a separate annual-hour threshold for substitutes.

Who Qualifies as a Substitute

A substitute must be at least 18 years old and capable of meeting the supervision requirements for the children in care. If your license authorizes care for infants, the substitute must understand and follow the infant-specific ratio rules — no more than four children under age two with a single caregiver.

Household members aged 15 and older already require full background screening under Tennessee licensing rules, regardless of whether they serve as substitutes. The separate backup-caregiver requirement identifies an approved caregiver aged 18 or older when the primary educator is absent.

Documentation to Keep on File

For each approved substitute, maintain:

• A copy of their background check clearance letter
• Their required pre-service training and physical-exam documentation, when applicable
• A log of hours worked (to track the 36-hour threshold and annual training requirements)

Licensing consultants review staff records during monitoring visits. When a substitute's hours and role trigger the background-check requirement, retain proof of the clearance and keep the hours log current.

Planning Ahead

Don't wait for the emergency to find a substitute. Identify two to three people during your pre-licensure phase, confirm that they meet the age, approval, screening, and training requirements, and walk them through your home's specific setup. The Tennessee home daycare licensing guide covers how to build a substitute roster and what documentation each person needs.

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