Illinois home health agency license: IDPH rules, staffing and the Medicare step
In Illinois, an agency that sends its own nurses into patients' homes under a practitioner's plan of treatment, plus at least one other home health service such as therapy or aide care, needs a home health agency license from the Illinois Department of Public Health (IDPH). As published on 2026-10-12, the license costs $1,500 for two years. New agencies start on a 240-day provisional license that ends with an on-site survey. Medicare certification is a separate federal step, and CMS has stopped enrolling new home health agencies nationwide since May 13, 2026.
Contents12 sections
Key takeaways
- Illinois defines a home health agency by what it does: skilled nursing plus at least one other home health service. Your own staff must provide the basic skilled nursing. You may contract it out only to cover vacations or specialized skills.37
- The fee is $1,500 for a two-year license, set in statute, nonrefundable, and payable by check or money order with a paper application (as published on 2026-10-12).367
- You must name a qualified administrator and a separate full-time RN agency supervisor. One person cannot hold both jobs.7
- New agencies get a 240-day provisional license. IDPH surveys within the last 30 days, and a passing agency gets a license running two years from the end of the month the provisional license was issued.7
- Illinois has no certificate of need for home health. Medicare is the bottleneck: CMS has blocked new home health enrollments nationwide since May 13, 2026, and Illinois Medicaid enrolls home health agencies only if they are Medicare-certified.81012
Quick facts
| Agency | IDPH, Office of Health Care Regulation, Health Care Facilities and Programs, Springfield |
|---|---|
| Law | 210 ILCS 55; 77 Ill. Adm. Code 245 |
| Fee | $1,500 per two-year license, initial or renewal (as published on 2026-10-12) |
| Insurance | Liability coverage of at least $1 million per occurrence and $3 million aggregate |
| First license | 240-day provisional license, then an on-site survey |
| Certificate of need | Not required |
| Medicare | New enrollments frozen nationwide since May 13, 2026 |
The fee comes from 210 ILCS 55/4(c) and IDPH Form 445103 (updated 11/2024), both checked October 12, 2026. Certified local health departments pay no fee.
Which Illinois license fits your agency
Illinois puts three in-home care licenses under one statute, the Home Health, Home Services, and Home Nursing Agency Licensing Act (210 ILCS 55), and one rule, 77 Ill. Adm. Code 245 67. IDPH licenses all three. The definitions decide which one you need, and picking the wrong one changes your whole application.
- Home health agency. A public agency or private organization that provides skilled nursing services and at least one other home health service 7. Home health services follow a plan of treatment prescribed by a physician, a licensed physician assistant or a licensed advanced practice registered nurse. They include part-time and intermittent nursing, physical therapy, occupational therapy, speech therapy, medical social services and home health aide services 7. “Part-time or intermittent” means at least once every 60 days, up to a few hours a day several times a week 7.
- Home nursing agency. The statute now ties this license to in-home shift nursing for people receiving or eligible for Medicaid EPSDT services, or for the 1915(c) waiver for medically fragile, technology-dependent people. The Act says a home nursing agency does not need a home health agency license 6.
- Home services agency. Non-medical help with daily activities, housekeeping, laundry and companionship. IDPH’s comparison chart says this license excludes skilled services 5. That license has its own guide: Illinois home services agency license.
You can hold these licenses in any combination. Each one needs its own application and its own fee 27. Agencies run by a church whose members rely on prayer or spiritual means for healing are exempt 7.
An agency based in another state still needs the Illinois license to serve Illinois patients. It must also be registered or otherwise authorized to do business in Illinois and have an office in Illinois. Its professional staff must hold the Illinois licenses their work requires 7.
The skilled nursing test and what you can contract out
Part 245 requires your agency to provide skilled nursing and at least one other home health service on a part-time or intermittent basis. Agency staff must directly provide basic skilled nursing. Therapy, social work and aide services may be provided directly or bought by contract. You may also contract for extra skilled specialty nursing, or for more nurses when the caseload changes 7. You must state in writing which services you provide directly and which by contract 7.
The application form is stricter. It says skilled nursing may not be contracted except to cover regular staff on vacation or for specialized skills you don’t routinely offer. If you contract any skilled nursing, you must explain why 3. The form also requires at least one RN on the staff list, part-time allowed, who is a separate person from the agency supervisor 3. Plan for at least two RNs before you file.
Every contract for services must be a written agreement that covers 7:
- a detailed description of the services;
- adherence to agency policies, including initial health evaluations and employee health policies;
- agency control over the contracted services;
- how clinical and progress notes get submitted;
- charges, liability and insurance, and the term of the agreement;
- signatures and termination terms.
On the staff page of the application, list at least one contracted person for each therapy or social work specialty you plan to offer 3.
Administrator and RN supervisor: two separate people
Home health agency administrator. The administrator must be an employee of the agency and one of the following, each with experience in health service administration and at least one year of supervisory or administrative experience in home health or a related health provider program 7:
- a physician;
- a registered nurse;
- someone with an undergraduate degree; or
- someone who meets the Public Health Administrator qualifications in the Certified Local Health Department Code.
Attachment A of the application asks for five years of work history and says resumes are not accepted in place of it. The administrator’s current employer must be the applicant agency. If the administrator also works part time somewhere else, attach a letter confirming both employers know about it and that there is no conflict of interest 3.
Agency supervisor. This person must be a full-time RN who is available at all times during operating hours 7. They must qualify one of two ways:
- an RN with a baccalaureate nursing degree and at least one year of nursing experience; or
- an RN without a baccalaureate degree who has three years of nursing experience. At least two of those years must be in a home health agency, a community health program that cared for the sick, or a family-centered community health nursing program, and at least two must fall within the five years before hire 7.
The supervisor directs the entire clinical program. That includes supervising every RN, LPN, aide, therapist and social worker, whether employed or contracted 7. One person may not be both administrator and agency supervisor 7. The application also asks whether either person is responsible for another Illinois agency 3.
Your governing body must adopt bylaws, review them every year, hire a qualified administrator, meet, and keep minutes 7. Corporations must name at least a president and a secretary on the application 3.
Staffing rules you will be surveyed on
| Requirement | Interval |
|---|---|
| RN or therapist supervisory visit for home health aide care | At least every two weeks |
| On-site observation of each aide giving care | At least once a year |
| RN progress notes to the patient’s health care professional | At least every 60 days, or when the condition changes |
| On-site supervision of PT assistants, OT assistants and social work assistants | Every four to six visits |
| Written plan of treatment after acceptance | Within 14 days; signed within 30 days of start of care |
| Plan of treatment review by the team | Every 60 days |
| Clinical notes | Written on the day of service, filed in the record at least weekly |
Home health aides. An aide must be on IDPH’s Health Care Worker Registry, have completed a training program approved under 77 Ill. Adm. Code 395, or meet an equivalency. Equivalencies include registration in another state, certain nursing coursework, military training, or foreign nursing education plus the written competency test 7. An RN must evaluate each aide’s competency in 16 listed areas, including dementia care, infection control, vital signs and safe transfers. You must check the Registry for findings of abuse, neglect or misappropriation before you hire an aide 7.
Licensed staff. Before hiring anyone whose job requires a state license, check with the Illinois Department of Financial and Professional Regulation that the license is active, and file a copy of that check in the personnel record 7.
Background checks. Part 245 applies the Health Care Worker Background Check Act and 77 Ill. Adm. Code 955 to every agency 7. Under the Act, you may employ an applicant conditionally for up to 3 months while the fingerprint-based check is pending 9. Your application must show that the agency is registered with the IDPH Web Portal and has access to the Health Care Worker Registry 37.
Dementia care. If you provide any services for Alzheimer’s disease or related dementias, you must also comply with the Alzheimer’s Disease and Related Dementias Services Act 7.
Policies and documents to have ready before you file
IDPH approves the provisional license on paper, before any survey of your office 7. Section 245.90 and Form 445103 require 37:
- a certificate of insurance showing liability coverage of at least $1 million per occurrence and $3 million in the aggregate;
- owners with 5% or more, corporate officers and shareholders over 5%. The form asks whether the applicant, any officer or the administrator has been convicted of a felony, or of two or more misdemeanors involving moral turpitude, in the last five years;
- an Illinois registered agent with an Illinois address, matching the Secretary of State record;
- a description of services, a fee schedule, sources of revenue, signed affiliation agreements and a job description for every position;
- a staff list with copies of professional licenses, plus Attachments A (administrator) and B (supervisor), and Attachment D for each medical social worker or social work assistant;
- policies on complaint resolution, employee health and safety, infection control, background checks and mandated reporting, supervisory visits, clinical records, staff training, and criteria for accepting patients;
- your plan of treatment format.
Service area. List counties, not a mileage radius. The counties must be contiguous, and IDPH recommends that new agencies start with 3 to 5 3. You need IDPH approval before serving any new county later 2.
Office. The administrator must keep an office with a working telephone that is staffed during business hours. It must protect the confidentiality of records and comply with local fire-safety ordinances 7. You also need a written policy that tells patients how to get care outside your operating hours 7.
Clinical program policies. The rule also requires these policies, and surveyors check them 7:
- QAPI. A data-driven quality assessment and performance improvement program that tracks adverse patient events.
- Infection control. An infection control program that is part of the QAPI program.
- Medications. Drug administration policies, including an emergency plan whenever potentially hazardous compounds are given.
- Records. Retention of clinical records for at least five years after the last date of service.
- Vaccines. Each year, give or arrange flu vaccination for every patient, finishing patients 65 and over by November 30. Offer pneumococcal vaccination to patients 65 and over. Document every offer, refusal and contraindication 7.
From application to full license
File the paper application
Mail Form 445103 with the attachments and a $1,500 check or money order payable to the Illinois Department of Public Health, Health Care Facilities and Programs, 4th Floor, 525 W. Jefferson St., Springfield, IL 62761-0001 3. The affidavit needs an original signature 3.
Answer IDPH’s first review
IDPH reviews the application within 30 days and asks for revisions by email. The application must be complete and approved within 90 days of submission, or IDPH may deny it 2.
Receive the provisional license
A new agency, meaning one never licensed or not operating when it applies, gets a provisional license within 90 days of a compliant application. It is valid for 240 days 7. IDPH says that within the first six months it will tell you the operational requirements for the licensure survey 2.
Operate and pass the survey
IDPH inspects within 30 days before the provisional license ends. If you substantially meet the requirements, IDPH issues a license that expires two years from the end of the month in which the provisional license was first issued. Your initial $1,500 fee covers the provisional period 7. If you have made significant progress but are not there yet, IDPH may renew the provisional license once for up to 90 days 7.
Section 8 of the Act lets IDPH deny an application for several reasons 6:
- failure to meet the minimum standards;
- the applicant’s or supervisor’s moral character (convictions may be considered but are not an automatic bar);
- lack of qualified personnel;
- insufficient financial or other resources;
- final findings of certain unemployment insurance or workers’ compensation violations.
Section 245.80(e) still says every license runs one year. The statute (210 ILCS 55/4(c)) and the home health provisions of Sections 245.95 and 245.100 set a two-year license for home health agencies 67.
Fees, renewal and changes after licensure
| Item | Amount or deadline |
|---|---|
| License fee, initial or renewal | $1,500 per two-year license, nonrefundable |
| Certified local health departments | No fee |
| Renewal filing window | 60 to 90 days before expiration |
| Late renewal | Fine possible under Section 245.140 |
| Fines for violations | Up to $100 per day |
| Notice before a sale or change of ownership | At least 30 days |
| Report changes in name, administrator, supervising nurse, address, hours, phone, fax or email | Within 10 days |
Renewal applications must report patient load for the preceding year, including patients over 65, plus utilization by type of service and visits 7. An agency must be operating and able to show patient activity before its second renewal 7. Every year you must also file an attested financial statement on IDPH’s form. State law bars public funds from paying an agency that hasn’t filed it 7.
Adding services. To add a service, send IDPH a letter, board minutes approving it, the job description, policies, the hire’s license and any contract. Adding medical social work requires Attachment D. Adding aide services requires proof of aide competency. Medicare-certified agencies also file form CMS-1572 2.
Branches. A branch must be within 100 miles of the parent office. It must offer the same services within part of the parent’s area, and the parent’s administrator, supervising nurse or manager must visit it at least monthly. Use the Branch Questionnaire to apply 27. A drop-site may not have staff, take referrals, do billing or store files 7.
Selling the agency. Licenses can’t be transferred. The buyer files the renewal/change-of-ownership application at least 30 days before the sale and needs its own license. Each franchise unit needs its own license 7.
Medicare and Medicaid: where the money question sits
The Illinois license lets you operate. Billing Medicare requires separate federal certification, and Illinois Medicaid home health enrollment depends on it 10.
Medicare certification. IDPH’s instruction sheet sets out the route 4:
- File CMS-855A with your Medicare contractor.
- An accrediting organization (ACHC, CHAP or The Joint Commission) can do the initial certification survey. If it hasn’t surveyed within 150 days of the approved 855A, IDPH must do the survey.
- Send IDPH the original CMS-1572, two originals of CMS-1561, the OCR civil rights clearance and your accreditation letter.
- These forms are valid for only six months, so IDPH suggests holding them until your accreditation survey is done.
The 2026 moratorium. CMS imposed a six-month nationwide moratorium on Medicare enrollment of new home health agencies, effective May 13, 2026. It runs six months from that date and can be extended in six-month increments. It blocks new agencies, branches and practice locations unless the Medicare contractor received the enrollment application before the effective date 12. While it lasts, accreditation does not give a new agency deemed status for Medicare 13. Illinois has been here before: CMS froze new home health enrollments in Cook County and nearby counties in 2013, expanded the freeze statewide in Illinois in 2016, and let it expire on January 30, 2019 12. As of October 12, 2026, no Federal Register notice extending or lifting the 2026 moratorium was found.
Illinois Medicaid. The Department of Healthcare and Family Services handbook (May 2016) lets three kinds of providers enroll as home health providers 10:
- a Medicare-certified home health agency licensed by IDPH;
- a home nursing agency licensed by IDPH;
- a health department certified by IDPH.
The handbook’s list has no route for a home health agency without Medicare certification; the other two provider types are home nursing agencies and certified health departments. The federal notice leaves Medicaid moratoria up to each state 12. HFS’s checklist for new home health providers (rev. 6/12/2024) requires 11:
- enrollment in the IMPACT system;
- Livescan fingerprints for each owner of 5% or more and each managing employee;
- your IDPH license and your accreditation report, or an explanation of why you have none;
- Secretary of State good standing;
- a lease or proof of ownership for the business location;
- building and workers’ compensation insurance;
- professional liability coverage of $1 million per occurrence and $3 million aggregate.
No certificate of need, and what else is not required
The Illinois Health Facilities Planning Act lists the “health care facilities” that need a permit from the state review board. The list includes hospitals, nursing homes, surgery centers and dialysis centers, but not home health agencies 8. You don’t need certificate-of-need approval to open a home health agency in Illinois.
For questions about OASIS clinical issues, IDPH’s home health page lists the Chicago office at 312-793-2222. Questions about Medicare forms go to 217-558-2854 14. Licensing correspondence goes to the Division of Health Care Facilities and Programs at 525 W. Jefferson St., Springfield, or [email protected] 2.
Recent rule changes
Part 245 has been amended repeatedly since 2023 7:
- January 30, 2026. The definitions in Section 245.20 and the staffing section, 245.40, were amended.
- September 2, 2025. The fee section, 245.95, was amended. It keeps the $1,500 two-year home health fee.
- August 5, 2024. The application and provisional-license sections (245.90 and 245.100) were amended. They now contain the 90-day issuance rule and the two-year post-survey term.
- November 8, 2023. Sections 245.30 (administration) and 245.80 (licensure required) were amended. They now contain the branch and drop-site rules and the 10-day change notices.
The statute’s license section was last amended by P.A. 103-734, effective January 1, 2025 6. If you are also weighing a residential model, IDPH licenses small senior homes under the Assisted Living and Shared Housing Act; see the Illinois shared housing establishment license.
Sources
- 1 Illinois Department of Public Health, Home Health Agencies Checked 12 Oct 2026 · Back to text ↑
- 2
- 3
- 4 Illinois Department of Public Health, Home Health Medicare Information Checked 12 Oct 2026 · Back to text ↑
- 5
- 6
- 7
- 8
- 9
- 10
- 11
- 12
- 13
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Related guides
Illinois and neighboring states
Compare all 51| State | License | Who needs it | State fee |
|---|---|---|---|
| Illinois (this guide) | Home Health Agency license (Home Nursing Agency license for shift nursing) | Skilled nursing plus one other home health service in clients' homes | $1,500 per two-year license, initial or renewal |
| Wisconsin | Home Health Agency license | Skilled nursing or therapy delivered in clients' homes | $300 nonrefundable + $15 per background check |
| Missouri | Home Health Agency license | Offers 2+ home health services incl. nursing, from a non-home office | $600 initial, $600 each year at renewal, $600 on change of ownership |
| Kentucky | Home Health Agency License | Own nurses, therapists or aides into homes; license plus certificate of need | $500 initial and annual |
| Indiana | Home Health Agency (HHA) license | Sending your own nurses, therapists or aides into homes | $250 initial and $250 each annual renewal, nonrefundable |
Shortened from each state's guide and our 51-state table, as of each guide's last review. Fees are the state's own; local permits and background checks cost extra.