Tennessee Code Annotated

Tenn. Code Ann. § 63-6-204 (2026)

"Practice of medicine" defined - Construction

✓ current as of May 2026
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Amended by 2024 Tenn. Acts, ch. 1042,s 13, eff. upon promulgation of rules governing the collaborative agreements of physician assistants with physicians; see T.C.A. § 63-19-106(h)(1).

Amended by 2024 Tenn. Acts, ch. 893,s 2, eff. 5/1/2024.

Amended by 2023 Tenn. Acts, ch. 196, s 1, eff. 7/1/2023.

Amended by 2020 Tenn. Acts, ch. 574, s 1, eff. 3/19/2020.

Amended by 2019 Tenn. Acts, ch. 259, s 1, eff. 4/30/2019.

Amended by 2017 Tenn. Acts, ch. 259, s 1, eff. 7/1/2017.

Amended by 2016 Tenn. Acts, ch. 766, s 2, eff. 4/19/2016.

Amended by 2014 Tenn. Acts, ch. 832, s 5, eff. 7/1/2014.

Amended by 2014 Tenn. Acts, ch. 695, Secs.s 1, s 2 eff. 4/15/2014.

Acts 1901, ch. 78, § 19; Shan., § 3609a33; mod. Code 1932, § 6937; Acts 1945, ch. 181, § 10; impl. am. Acts 1947, ch. 2, §§ 1, 2; C. Supp. 1950, § 6937; modified; Acts 1973, ch. 166, § 7; T.C.A. (orig. ed.), § 63-608; Acts 1983, ch. 168, § 1; 1994, ch. 901, § 3; 1995, ch. 200, § 1; 1995, ch. 466, § 1; 1996, ch. 986, §§ 2, 3; 1996, ch. 1043, § 2; 1997 , ch. 349, § 1; 1998, ch. 1081, § 1; 2002, ch. 801, §§ 1, 2; 2003 , ch. 115, §§ 1, 2; 2005, ch. 20, § 1; 2008 , ch. 891, § 2; 2009 , ch. 70, § 1; 2011 , ch. 271, §§ 1, 2; 2012 , ch. 649, § 2.


Notes of Decisions
Cited in 18 cases (1 in the last 5 years), 1991–2026 · leading case: Murfreesboro Med. Clinic, P.A. v. Udom, 166 S.W.3d 674 (Tenn. 2005).
Murfreesboro Med. Clinic, P.A. v. Udom, 166 S.W.3d 674 (Tenn. 2005). · cites it 59× “This statute specifically allows such non-compete covenants in two limited circumstances and with closely prescribed restrictions.”
Lee Med., Inc. v. Paula Beecher, 312 S.W.3d 515 (Tenn. 2010). · cites it 4× “45 Tenn. Code Ann. § 63-6-201 (2004). 46 Tenn.”
Cox v. MA Primary & Urgent Care Clinic, 313 S.W.3d 240 (Tenn. 2010). · cites it 4× “A physician assistant is defined under the Act as “an individual who renders services, whether diagnostic or therapeutic, that are acts constituting the practice of medicine or osteopathic medicine and, but for the provisions of § 63-6-204 8 and § 63-9-113, 9 could only be…”
Massachusetts Mut. Life Ins. Co. v. Jefferson, 104 S.W.3d 13 (Tenn. Ct. App. 2002). · cites it 2× “Tenn.Code Ann. § 63-6-204(d)(7)(F) (Supp.”
UT Med. Grp., Inc. v. Vogt, 235 S.W.3d 110 (Tenn. 2007). · cites it 2× “2005), that, except for those specifically prescribed by statute, physician covenants not to compete are unenforceable and void as against public policy, the non-competition agreement at issue in this case is specifically authorized under Tenn.Code Ann. § 63-6-204(e) (2004).…”
Med. Educ. Assistance Corp. v. State Ex Rel. East Tennessee State Univ. Quillen Coll. of Med., 19 S.W.3d 803 (Tenn. Ct. App. 1999). · cites it 7× “Despite the later-enacted amendment of T.C.A § 63-6-204 to allow for faculty practice plans, Dr.”
Bryant v. HCA Health Servs. of No. Tennessee, Inc., 15 S.W.3d 804 (Tenn. 2000). · cites it 2× “” Tenn.Code Ann. § 63-6-204(d)(l)(A). Accordingly, the language of the statute suggests that the legal duty to obtain consent is imposed only on the physician who orders or directs the surgical procedure.”
Kelley v. Apria Healthcare, LLC, 232 F. Supp. 3d 983 (E.D. Tenn. 2017). · cites it 2× “Section 63-6-204(a)(l) defines practicing medicine only for purposes of title 63, chapter 6.”
Bolton v. CNA Ins. Co., 821 S.W.2d 932 (Tenn. 1991). · cites it 2× “The practice of medicine from which physical therapists are excluded is defined as: “Any person shall be regarded as practicing medicine within the meaning of this chapter who shall treat, profess to treat, operate on, or prescribe for any physical ailment or any physical injury…”
Murfreesboro Med. Clinic, P.A. v. David Udom - Concurring & Dissenting (Tenn. 2005). · cites it 20× “See Tenn. Code Ann. § 63-6-204 (d) (Supp. 1994).”
Hoover (M.D. Tenn. 2026). · cites it 10× “The statute at issue was Tenn. Code Ann. § 63-6-204 , which, at the time, specifically authorized physician covenants not to compete in “two limited circumstances”: “(1) when the employer is a hospital or an affiliate of a hospital, and (2) when the employer is a ‘faculty…”
MEAC v. State, 19 S.W.3d 803 (Tenn. Ct. App. 1999). · cites it 8× “Mehta argues that, when he entered into this contract, T.C.A §§ 63-6-204 and XX-XX-XXX provided that a corporation and any state, local, county governmental unit or division thereof were prohibited from the practice of medicine and physicians were not permitted to divide or…”
Tenn. Code Ann. § 63-6-204(a)(l): 2 cases
Cox v. MA Primary & Urgent Care Clinic, 313 S.W.3d 240 (Tenn. 2010). “A physician assistant is defined under the Act as “an individual who renders services, whether diagnostic or therapeutic, that are acts constituting the practice of medicine or osteopathic medicine and, but for the provisions of § 63-6-204 8 and § 63-9-113, 9 could only be…”
Kelley v. Apria Healthcare, LLC, 232 F. Supp. 3d 983 (E.D. Tenn. 2017). “Section 63-6-204(a)(l) defines practicing medicine only for purposes of title 63, chapter 6.”
Tenn. Code Ann. § 63-6-204(b): 2 cases
Cox v. MA Primary & Urgent Care Clinic, 313 S.W.3d 240 (Tenn. 2010). “A physician assistant is defined under the Act as “an individual who renders services, whether diagnostic or therapeutic, that are acts constituting the practice of medicine or osteopathic medicine and, but for the provisions of § 63-6-204 8 and § 63-9-113, 9 could only be…”
Melissa Michelle Cox v. M. A. Primary (Tenn. Ct. App. 2009).
Tenn. Code Ann. § 63-6-204(d): 2 cases
Murfreesboro Med. Clinic, P.A. v. Udom, 166 S.W.3d 674 (Tenn. 2005). “This statute specifically allows such non-compete covenants in two limited circumstances and with closely prescribed restrictions.”
Murfreesboro Med. Clinic, P.A. v. David Udom - Concurring & Dissenting (Tenn. 2005). “See Tenn. Code Ann. § 63-6-204 (d) (Supp. 1994).”
Tenn. Code Ann. § 63-6-204(d)(7)(F): 1 case
Massachusetts Mut. Life Ins. Co. v. Jefferson, 104 S.W.3d 13 (Tenn. Ct. App. 2002). “Tenn.Code Ann. § 63-6-204(d)(7)(F) (Supp.”
Tenn. Code Ann. § 63-6-204(d)(l)(A): 1 case
Bryant v. HCA Health Servs. of No. Tennessee, Inc., 15 S.W.3d 804 (Tenn. 2000). “” Tenn.Code Ann. § 63-6-204(d)(l)(A). Accordingly, the language of the statute suggests that the legal duty to obtain consent is imposed only on the physician who orders or directs the surgical procedure.”
Tenn. Code Ann. § 63-6-204(e): 5 cases
Murfreesboro Med. Clinic, P.A. v. Udom, 166 S.W.3d 674 (Tenn. 2005). “This statute specifically allows such non-compete covenants in two limited circumstances and with closely prescribed restrictions.”
UT Med. Grp., Inc. v. Vogt, 235 S.W.3d 110 (Tenn. 2007). “2005), that, except for those specifically prescribed by statute, physician covenants not to compete are unenforceable and void as against public policy, the non-competition agreement at issue in this case is specifically authorized under Tenn.Code Ann. § 63-6-204(e) (2004).…”
Med. Educ. Assistance Corp. v. State Ex Rel. East Tennessee State Univ. Quillen Coll. of Med., 19 S.W.3d 803 (Tenn. Ct. App. 1999). “Despite the later-enacted amendment of T.C.A § 63-6-204 to allow for faculty practice plans, Dr.”
MEAC v. State, 19 S.W.3d 803 (Tenn. Ct. App. 1999). “Mehta argues that, when he entered into this contract, T.C.A §§ 63-6-204 and XX-XX-XXX provided that a corporation and any state, local, county governmental unit or division thereof were prohibited from the practice of medicine and physicians were not permitted to divide or…”
Murfreesboro Med. Clinic, P.A. v. David Udom - Concurring & Dissenting (Tenn. 2005). “See Tenn. Code Ann. § 63-6-204 (d) (Supp. 1994).”
Tenn. Code Ann. § 63-6-204(f)(2)(B): 1 case
Hoover (M.D. Tenn. 2026). “The statute at issue was Tenn. Code Ann. § 63-6-204 , which, at the time, specifically authorized physician covenants not to compete in “two limited circumstances”: “(1) when the employer is a hospital or an affiliate of a hospital, and (2) when the employer is a ‘faculty…”
Tenn. Code Ann. § 63-6-204(h)(2): 1 case
Hoover (M.D. Tenn. 2026). “The statute at issue was Tenn. Code Ann. § 63-6-204 , which, at the time, specifically authorized physician covenants not to compete in “two limited circumstances”: “(1) when the employer is a hospital or an affiliate of a hospital, and (2) when the employer is a ‘faculty…”
Tenn. Code Ann. § 63-6-204(h)(6): 1 case
Hoover (M.D. Tenn. 2026). “The statute at issue was Tenn. Code Ann. § 63-6-204 , which, at the time, specifically authorized physician covenants not to compete in “two limited circumstances”: “(1) when the employer is a hospital or an affiliate of a hospital, and (2) when the employer is a ‘faculty…”
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