Illinois shared housing establishment license: the 16-resident senior home under IDPH

The legal definition, piece by piece

Under 210 ILCS 9/10, a shared housing establishment is “a publicly or privately operated free-standing residence for 16 or fewer persons, at least 80% of whom are 55 years of age or older and who are unrelated to the owners and one manager of the residence.”⁠¹ Every part of that sentence affects your plans:

• Free-standing residence. The model is a single house or building, not a wing or a floor of a larger building.
• 16 or fewer persons. The Act sets this ceiling, and IDPH’s Life Safety Code inspection request form labels the category “Shared Housing (max of 16 residents).”⁠¹⁠²² Above 16 you are planning an assisted living establishment.
• 80% age 55 or older. Up to one in five residents can be younger adults. Only adults may be admitted.⁠¹⁠⁷
• Unrelated to the owners and one manager. A home for your own relatives is not a shared housing establishment.

The home must also deliver a defined package. The Act requires services “consistent with a social model” based on the idea that the resident’s unit is their own home, plus residential care for people who need help with activities of daily living (eating, dressing, bathing, toileting, transferring, personal hygiene), available 24 hours a day if needed.⁠¹ Six mandatory services must be provided, either directly or through another entity you arrange: three meals a day; housekeeping of the resident’s unit; personal laundry and linen service; 24-hour security (such as locked entrances); an emergency communication response system that works 24 hours a day; and help with daily living as each resident requires.⁠¹

Operating, maintaining or offering such a home without a license is prohibited, and an unlicensed operator is subject to the penalties of the Nursing Home Care Act. A licensed shared housing establishment may advertise “assisted living services,” but only a licensed assisted living establishment (or a Nursing Home Care Act shelter care facility that also meets the assisted living definition) may use “assisted living” in its name.⁠²

Shared housing, assisted living or a CILA

Illinois law treats these as separate licenses, and none of them can also be one of the others: the shared housing definition excludes assisted living establishments, supportive living facilities, and community-integrated living arrangements (CILAs) licensed by the Department of Human Services.⁠¹

Scroll the table sideways to see every column.

Sources: ⁠¹⁠⁹⁠¹³⁠¹⁶⁠²⁴

If your residents are mostly people with developmental disabilities rather than older adults, the CILA path is the relevant one: under 210 ILCS 135/3, a CILA is a living arrangement for 8 or fewer people with a developmental disability, certified by a community developmental services agency.⁠²⁴ If you want more than 16 residents, or private apartments with bathrooms, see the assisted living establishment license under the same Act. Assisted living units must have private bathing, washing and toilet facilities (or private washing and toilet facilities with a common bathing room), and are single occupancy unless two residents choose to share.⁠¹

There is no certificate of need. The Health Facilities Planning Act excludes facilities licensed under the Assisted Living and Shared Housing Act.⁠²³

Ownership suitability and the manager

The applicant. IDPH must find that the individual or entity applying is “responsible and suitable” to operate, based on financial capacity, relevant business or professional experience, a record of complying with IDPH orders, and no license revoked in the previous 5 years under this Act, the Nursing Home Care Act, the Specialized Mental Health Rehabilitation Act of 2013, the ID/DD Community Care Act or the MC/DD Act.⁠⁴

The director (manager). The Act requires supervision by a full-time director who is at least 21 and has a high school diploma or equivalent plus one of these:⁠⁴

1. Care experience

   2 years of management experience, or 2 years in positions of progressive responsibility, in health care, housing with services, adult day care or similar services to older adults.

2. Hospitality experience

   2 years of management or progressive responsibility in hospitality, plus training in health care and housing with services management.

3. Education

   A college degree in health administration, or completion of an approved program within 6 months after hiring.

Section 295.3010, as amended effective July 29, 2024, lists only the first two routes.⁠¹⁴ The statute still lists the health administration degree or approved-program route in 210 ILCS 9/35(a)(2)(C) (text as published 2026-10-12), but the rule leaves it out and does not say whether IDPH accepts it for a shared housing manager. If you rely on a degree rather than 2 years of experience, ask the Division of Assisted Living in writing before you hire.⁠⁴⁠¹⁴ The director must complete at least 20 hours of training every 2 years as a condition of licensure.⁠⁴⁠¹⁰

The three-home rule. This is the biggest operating difference from assisted living. Every assisted living establishment needs its own full-time manager, but a shared housing manager “may oversee no more than three establishments” if the homes are within 30 minutes’ driving time of each other during non-rush hour and the manager can be reached immediately by an electronic communication device.⁠¹⁴ The manager must name someone capable of acting in an emergency when the manager is away, must meet the Health Care Worker Background Check Act if they give direct care, and any change of manager must be reported to IDPH within 10 working days.⁠¹⁴

Staffing a shared housing home

The staffing standard is need-based, not a fixed ratio. You must have staff “sufficient in number” and with the skills to meet residents’ 24-hour scheduled and unscheduled needs, including all mandatory services, each service plan, general supervision, crisis response, food and environmental services, and evacuation in an emergency.⁠¹³ The fixed rules are:

• On site at all times. At least one staff member on site at all times. Brief absences are allowed, such as taking a resident to the emergency room or a trip to the grocery store, if arrangements are made to monitor residents’ safety under the service delivery plan.⁠¹³ Assisted living, by contrast, needs one staff member awake, on duty and on site 24 hours a day.⁠¹³
• Awake staff if residents cannot self-evacuate. If you accept residents who cannot move to a safe area on their own, enough staff must be present and awake 24 hours a day to move them.⁠¹³
• CPR. At least one direct care staff person with current adult CPR certification, including a skills demonstration, on duty at all times.⁠¹³
• Age. Direct care staff must be at least 16 on their first day.⁠¹³
• Screening. Check every applicant against the Nurse Aide Registry before hiring; you may not hire anyone with a finding of abuse, neglect or misappropriation of property. Employees covered by the Health Care Worker Background Check Act must meet it, and professional licenses must be verified before hire.⁠⁴⁠¹³
• Files. Personnel files must document freedom from tuberculosis, orientation and ongoing training; direct care files also need CPR, an initial health evaluation, the background check and the registry check. Keep them, and the staff schedules showing actual hours worked, for at least 12 months after the person leaves or after the last scheduled date.⁠¹³

Training. New employees complete a first orientation within 10 days of starting (resident rights, confidentiality, infection control, abuse and neglect reporting, disaster procedures) and a second within 30 days (residents’ needs, service plans, policies, job limits, CPR and emergency procedures if applicable, and help with daily living). The manager and every direct care worker then need at least 8 hours of training every 12 months, covering, among other topics, assisting residents who take their own medications. Each session must be documented with date, start and end times, instructor qualifications, content and the staff member’s signature.⁠¹⁵

The building

Illinois applies institutional fire-safety standards to these homes, even to small ones. The Act requires compliance with the residential board and care chapter of the NFPA Life Safety Code, local and State building codes for the building type, and ADA accessibility standards.⁠²⁹ Section 295.9000 specifies Life Safety Code (NFPA 101) Chapter 32 for new establishments and Chapter 33 for existing ones, plus local ordinances, fire codes and zoning. Where a local rule and Part 295 conflict, the stricter one applies; you can petition IDPH to decide which applies, and it must respond within 30 days.⁠¹⁶ IDPH grants no waivers of the Life Safety Code, though it recognizes equivalencies.⁠¹⁶

Requirements specific to small homes and to shared housing:

Sources: ⁠¹⁶⁠¹⁷⁠¹⁸

The 10-resident kitchen line deserves attention when you set capacity. IDPH’s inspection request form states that “cooking facilities for 10 or more residents require commercial cooking installation,” and it asks for hood fire-suppression inspection records under NFPA 96.⁠²² If the establishment is subject to the Illinois Accessibility Code, it is treated as residential.⁠¹⁶

If you serve food, Section 295.8000 applies the Food Service Sanitation Code (77 Ill. Adm. Code 750) and local requirements. Menus must be available 48 hours in advance, snacks and beverages must be available, and a dietitian must be employed or contracted if you offer therapeutic diets.⁠²⁸

The Life Safety Code inspection

IDPH’s Design and Construction Section performs the Life Safety Code and physical plant survey before licensure.⁠²¹ You request it on IDPH’s “Request for Life Safety Code/Physical Environment Inspection” form, sent to the Division of Assisted Living, 525 W. Jefferson St., 5th Floor, Springfield, IL 62761. The form says the survey will not be scheduled until the packet is complete:⁠²²

• Code Certification of Compliance forms for the area being inspected
• Building floor plans on sheets at least 11 by 17 inches
• A Fire Alarm System Record of Completion (NFPA 72, 2010 edition or newer)
• For new sprinkler work, the Sprinkler Contractor’s Material and Test Certificate (NFPA 13 or 13R); for existing sprinklers, the latest quarterly and annual inspection reports at the visit
• A narrative and floor plan locations for any special locks (magnetic or delayed-egress)
• Building construction type under NFPA 220 and, for commercial kitchens, NFPA 96 hood records
• The final approved plumbing inspection report from the State-licensed plumber, carrying the inspector’s name, signature and Illinois license number and the inspections completed (underground, roughed-in, final)

The plumbing report is a hard gate: “Life safety code approval will not be issued” until IDPH has it, and any plumbing work needs approval from IDPH’s Plumbing and Water Quality Program.⁠²² On inspection day all life safety systems must be working and will be tested, so someone who can reset them must be on site.⁠²²

Who you can admit, and who must leave

Section 75 of the Act sets admission limits that apply to every resident. You may not accept or keep anyone whose needs you cannot meet or secure. You also may not accept anyone who:⁠⁷

• poses a serious threat to themselves or others
• cannot communicate their needs and has no resident representative living in the establishment with a prior relationship to them
• needs total assistance with 2 or more activities of daily living, or more than one paid caregiver at a time for any one of them
• needs more than minimal help moving to a safe area in an emergency
• has a severe mental illness as the section defines it (Alzheimer’s disease and other dementias are expressly not included)
• needs intravenous therapy, gastrostomy feedings, sterile catheter care or sterile wound care, unless self-administered or given by a licensed health care professional (catheter care may also be done by a nurse trained to CDC standards, with oversight from an infection preventionist or infection control committee)
• needs routine insulin injections not self-administered or given by a licensed professional
• needs treatment of stage 3 or 4 pressure ulcers or exfoliative dermatitis
• needs 5 or more skilled nursing visits a week for 3 or more consecutive weeks, unless a physician certifies the need is temporary and for rehabilitation

A resident who develops one of these conditions must have residency terminated. The exceptions are hospice residents, when all parties agree, and residents with quadriplegia, paraplegia or neuromuscular disease who can communicate their needs, for some of the listed items.⁠⁷ For IV, feeding tube, catheter and wound care, the licensed professional may not be employed by your company, its parent or an affiliate.⁠⁷

Before admission, a physician, physician assistant or advanced practice registered nurse must complete a comprehensive physical, cognitive and psychosocial assessment, repeated at least annually and on a significant change such as a dementia diagnosis. A written service plan, agreed with the resident, follows from it and is reviewed at least annually.⁠²⁵

Medications: what your staff may do

Medication help is an optional service. If you offer it, the limits are strict. Unlicensed staff may give medication reminders and supervise self-administration (reading labels, opening containers, checking the dose, documenting), but only “under the direction of a licensed health care professional.” Actual medication administration (routine insulin and B-12 injections, oral medications, topicals, eye and ear drops, nitroglycerin patches) is limited to a licensed health care professional employed by the establishment: “Non-licensed staff may not administer any medication.”⁠¹⁹ The Act’s certified medication aide role is defined for assisted living establishments, not for shared housing.⁠¹

If you supervise or administer medications, your policies must be approved by a physician, pharmacist or registered nurse. You also need a drug reference guide no more than 2 years old, locked storage that is never in a bathroom or laundry room, and no pre-poured doses except medication organizers, which may be filled up to one month ahead by the resident, a relative or a nurse.⁠¹⁹ Homes that offer medication administration must also administer or arrange annual flu vaccination for each resident and pneumococcal vaccination for residents 65 and older, unless refused or contraindicated, and any home that provides catheter care must designate an Infection Prevention and Control Professional.⁠²⁶

What goes into the IDPH application

Section 30 of the Act and Section 295.500 list what the application must contain:⁠³⁠⁹

• business name, address and phone; owners, and for entities, the officers and governing body members
• the managing agent (if different from the owner) and the full-time director
• the natural person authorized to accept legal service for the owners
• the number and types of units, the maximum census, and the mandatory and optional services
• the Code Certification of Compliance form, as proof of compliance with State and local residential standards
• the standard resident contract and verification that every resident will sign one
• documentation of adequate liability insurance
• proof of an ongoing quality improvement program that uses data analysis and documents corrective actions⁠³⁰
• the Alzheimer’s Disease and Related Dementias Special Care Disclosure form, and a schematic drawing of the establishment
• a request for standard or floating licensure

Financial feasibility. Shared housing applicants prove it with one of these: a surety bond equal to at least three months of operating expenses; an independent CPA’s opinion on the establishment’s financial status; an audited financial report; a bond rating of “A” or better less than two years old; evidence of at least two years operating a facility licensed under the Nursing Home Care Act, the MC/DD or ID/DD Acts, or this Act; or other information IDPH accepts.⁠⁹ If you charge entrance or application fees above three months of a resident’s minimum fees, you must hold a bond or restricted account guaranteeing refunds.⁠⁹

The resident contract. It must be titled “shared housing establishment contract,” printed in at least 12-point type, and include the elements in Section 90. These include base rate and extra-service fees, admission and termination criteria, the complaint process with the Department on Aging’s Senior Helpline, an Ombudsman-prepared rights statement, and a statement that Illinois Medicaid (Articles V and VI of the Public Aid Code) does not pay for services in the establishment, except in contracts with residents of licensed establishments in the Department on Aging’s Comprehensive Care in Residential Settings Demonstration Project.⁠⁸

IDPH’s assisted living page (checked 2026-10-12) lists a complaint form, termination and appeal forms and the Life Safety Code inspection request, but no initial application packet. The rule says applications are filed “on forms provided by the Department,” so ask the Division of Assisted Living in Springfield for the current forms.⁠⁹⁠²¹

From application to regular license

1. Settle zoning and local codes

   Part 295 makes local ordinances, fire codes and zoning binding, and the application needs the Code Certification of Compliance.⁠⁹⁠¹⁶

2. Finish the building and plumbing sign-off

   Get the final plumbing inspection report and the fire alarm and sprinkler documents the inspection form requires.⁠²²

3. File the licensure application with the $1,000 fee

   Report any changes to IDPH in writing while it is pending.⁠⁹

4. Pass the Life Safety Code survey

   IDPH Design and Construction inspects before licensure.⁠²¹

5. Receive a probationary license

   IDPH may issue it within 90 days after a completed application. It lasts 120 days and is the standard first license for an applicant never licensed under the Act or an establishment not yet operating.⁠¹²⁠⁵

6. Pass the full review

   Within the last 30 days of the probationary period, IDPH fully reviews the establishment. If you meet the requirements, it issues a regular license; if you have made substantial progress, it may renew the probationary license once for up to 120 more days.⁠⁵⁠¹²

7. Post the license

   The regular license is valid one year, names the premises, persons and number of units, cannot be transferred, and must be posted in public view.⁠⁴⁠¹⁰

Section 295.600 says IDPH will issue a regular license within 120 days after receiving an application that meets the requirements.⁠¹⁰ After licensure, changes to ownership details, the managing agent, the agent for service, units or services must be reported within 30 days.⁠¹⁰

Floating licenses. If you run senior housing and want to license only some units, a floating license covers any number of units up to, but not including, total capacity. You request it on the initial or renewal application. The location must be operated as housing for the elderly with at least 80% of residents 55 or older, and you must keep a current list of designated units.⁠²⁰

Fees as published on 2026-10-12

Sources: ⁠⁹⁠¹¹

Section 295.700 says a renewal application must come with “the fee prescribed in Section 295.500,” but 295.500 states only the application fees above and no separate renewal amount, and neither says whether a 2-year renewal costs more than a 1-year one. IDPH’s page says renewal applications carry “the applicable licensure fee.” Ask the Division of Assisted Living for the renewal amount before you budget.⁠⁹⁠¹¹⁠²¹

Inspections, renewal and the two-year license

IDPH must make an annual unannounced on-site visit to every shared housing establishment and may make more visits without notice.⁠²⁷ The annual review also examines your quality improvement process, which the Act says must be benchmarked, customer centered, data driven and focused on resident satisfaction.⁠³

File for renewal at least 120 but no more than 150 days before expiration.⁠⁶⁠¹¹ Renewal can bring a 2-year license if, in the preceding 24 months, you have had no Type 1 or Type 2 violation, no inspection finding 10 or more Type 3 violations, and no admission or retention of a resident in violation of Section 75. If you later commit a Type 1 or Type 2 violation or an inspection finds 10 or more Type 3 violations, IDPH revokes the 2-year license and replaces it with a 1-year license until you again meet those conditions.⁠⁶

How residents pay

This is a private-pay license. The statute requires every contract to tell residents that Illinois medical assistance is not available to pay for services in the establishment, with an exception only for the Department on Aging’s Comprehensive Care in Residential Settings Demonstration Project.⁠⁸ Supportive living facilities, the program established under Section 5-5.01a of the Public Aid Code, are a separate setting: the Act excludes them from the shared housing definition.⁠¹⁠²³ If your plan depends on Medicaid, a home care model may fit better; see the Illinois home services agency license and the Illinois home health agency license.

Recent changes to watch

• July 24, 2026. P.A. 104-589 and P.A. 104-641 amended Section 15: service plans must now account for residents’ interests, preferences, dislikes and known triggers for behavior that endangers the resident or others.⁠²⁵ P.A. 104-589 also amended Section 35, the licensing-standards section; its published text (2026-10-12) still lists the applicant, director, staffing and fee findings described above, and the Act does not mark what changed, so ask IDPH whether the amendment alters what it checks at licensure.⁠⁴
• January 1, 2026. P.A. 104-191 amended Sections 10, 15, 75 and 90.⁠¹⁠⁷⁠²⁵⁠⁸
• July 1, 2025. P.A. 103-844 allowed catheter care by trained nurses under infection preventionist oversight and required homes that provide catheter care to designate an Infection Prevention and Control Professional.⁠⁷⁠²⁶
• August 2, 2024. P.A. 103-775 last amended Section 45, which sets the 2-year renewal license conditions.⁠⁶
• July 29, 2024. IDPH amended Sections 295.600 and 295.3010 (manager qualifications).⁠¹⁰⁠¹⁴
• August 30, 2023. IDPH amended Section 295.500 (application contents and fees) and Section 295.9000 (physical plant).⁠⁹⁠¹⁶

Sources

1. 1
   Illinois General Assembly, 210 ILCS 9/10, Assisted Living and Shared Housing Act: Definitions Checked 12 Oct 2026 · Back to text ↑
2. 2
   Illinois General Assembly, 210 ILCS 9/25: License requirement Checked 12 Oct 2026 · Back to text ↑
3. 3
   Illinois General Assembly, 210 ILCS 9/30: Licensing Checked 12 Oct 2026 · Back to text ↑
4. 4
   Illinois General Assembly, 210 ILCS 9/35: Issuance of license Checked 12 Oct 2026 · Back to text ↑
5. 5
   Illinois General Assembly, 210 ILCS 9/40: Probationary licenses Checked 12 Oct 2026 · Back to text ↑
6. 6
   Illinois General Assembly, 210 ILCS 9/45: Renewal of licenses Checked 12 Oct 2026 · Back to text ↑
7. 7
   Illinois General Assembly, 210 ILCS 9/75: Residency requirements Checked 12 Oct 2026 · Back to text ↑
8. 8
   Illinois General Assembly, 210 ILCS 9/90: Contents of service delivery contract Checked 12 Oct 2026 · Back to text ↑
9. 9
   Illinois Joint Committee on Administrative Rules, 77 Ill. Adm. Code 295.500: Application for License Checked 12 Oct 2026 · Back to text ↑
10. 10
    Illinois Joint Committee on Administrative Rules, 77 Ill. Adm. Code 295.600: Issuance of an Initial Regular License Checked 12 Oct 2026 · Back to text ↑
11. 11
    Illinois Joint Committee on Administrative Rules, 77 Ill. Adm. Code 295.700: Issuance of a Renewal License Checked 12 Oct 2026 · Back to text ↑
12. 12
    Illinois Joint Committee on Administrative Rules, 77 Ill. Adm. Code 295.800: Probationary License Checked 12 Oct 2026 · Back to text ↑
13. 13
    Illinois Joint Committee on Administrative Rules, 77 Ill. Adm. Code 295.3000: Personnel Requirements, Qualifications and Training Checked 12 Oct 2026 · Back to text ↑
14. 14
    Illinois Joint Committee on Administrative Rules, 77 Ill. Adm. Code 295.3010: Manager's Qualifications Checked 12 Oct 2026 · Back to text ↑
15. 15
    Illinois Joint Committee on Administrative Rules, 77 Ill. Adm. Code 295.3020: Employee Orientation and Ongoing Training Checked 12 Oct 2026 · Back to text ↑
16. 16
    Illinois Joint Committee on Administrative Rules, 77 Ill. Adm. Code 295.9000: Physical Plant Checked 12 Oct 2026 · Back to text ↑
17. 17
    Illinois Joint Committee on Administrative Rules, 77 Ill. Adm. Code 295.9005: Units Checked 12 Oct 2026 · Back to text ↑
18. 18
    Illinois Joint Committee on Administrative Rules, 77 Ill. Adm. Code 295.9020: Supplemental Physical Plant Requirements for Shared Housing Establishments Checked 12 Oct 2026 · Back to text ↑
19. 19
    Illinois Joint Committee on Administrative Rules, 77 Ill. Adm. Code 295.5000: Medication Reminders, Supervision of Self-Medication, Medication Administration and Storage Checked 12 Oct 2026 · Back to text ↑
20. 20
    Illinois Joint Committee on Administrative Rules, 77 Ill. Adm. Code 295.1110: Floating Licenses Checked 12 Oct 2026 · Back to text ↑
21. 21
    Illinois Department of Public Health, Assisted Living Checked 12 Oct 2026 · Back to text ↑
22. 22
    Illinois Department of Public Health, Assisted Living and Shared Housing Facilities: Request for Life Safety Code/Physical Environment Inspection Checked 12 Oct 2026 · Back to text ↑
23. 23
    Illinois General Assembly, 20 ILCS 3960/3, Illinois Health Facilities Planning Act: Definitions Checked 12 Oct 2026 · Back to text ↑
24. 24
    Illinois General Assembly, 210 ILCS 135/3, Community-Integrated Living Arrangements Licensure and Certification Act: Definitions Checked 12 Oct 2026 · Back to text ↑
25. 25
    Illinois General Assembly, 210 ILCS 9/15: Assessment and service plan requirements Checked 12 Oct 2026 · Back to text ↑
26. 26
    Illinois General Assembly, 210 ILCS 9/76: Vaccinations Checked 12 Oct 2026 · Back to text ↑
27. 27
    Illinois General Assembly, 210 ILCS 9/110: Powers and duties of the Department Checked 12 Oct 2026 · Back to text ↑
28. 28
    Illinois Joint Committee on Administrative Rules, 77 Ill. Adm. Code 295.8000: Food Service Checked 12 Oct 2026 · Back to text ↑
29. 29
    Illinois General Assembly, 210 ILCS 9/20: Construction and operating standards Checked 12 Oct 2026 · Back to text ↑
30. 30
    Illinois Joint Committee on Administrative Rules, 77 Ill. Adm. Code 295.2060: Quality Improvement Program Checked 12 Oct 2026 · Back to text ↑

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