Illinois - Adult Companion Services — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-09-09
Illinois does not cover a distinct service named "Adult Companion Services" under its Medicaid Home and Community-Based Services (HCBS) waivers; instead, non-medical supervision and socialization are funded primarily as "Personal Support" through the Department of Human Services (DHS) Division of Developmental Disabilities (DDD) waivers, or as "In-Home Service" through the Department on Aging (DoA) Community Care Program (CCP). To bill for Personal Support, an agency must first be established as a Developmental Disability provider with DHS, which requires transmitting provider data through the Reporting of Community Services (ROCS) system or a Fiscal Employer Agent (F/EA) before any Medicaid enrollment application is accepted.
Approval to deliver these services requires enrolling in the Illinois Medicaid Program Advanced Cloud Technology (IMPACT) system and securing a formal Service Agreement with DHS Region staff. Providers must comply with DHS training requirements for direct support workers and undergo targeted desk reviews and on-site visits by the State to maintain their active Medicaid provider status.
1. Service Definition and Scope
Because Illinois does not use the term "Adult Companion Services," providers deliver non-medical care, supervision, and socialization under the "Personal Support" service definition in the Adults with Developmental Disabilities Waiver. This service ensures the health and safety of the adult while promoting community inclusion and socialization.
For older adults, similar non-medical supervision is provided under the Department on Aging's "In-Home Service" (formerly Homemaker), which assists individuals aged 60 and older with non-medical tasks to prevent premature institutionalization.
- Service Name (DHS): Personal Support
- Service Name (DoA): In-Home Service
- Target Population (DHS): Adults with intellectual or developmental disabilities
- Target Population (DoA): Individuals over 60 years of age determined eligible for the Community Care Program
- Scope of Service: Non-medical supervision, socialization, and assistance with activities of daily living
- Exclusions: Cannot duplicate services provided under the Medicaid State Plan
2. Regulatory and Oversight Agencies
The Illinois Department of Healthcare and Family Services (HFS) is the single State Medicaid Agency responsible for overall waiver administration and provider enrollment. HFS delegates day-to-day operation of the developmental disabilities waivers to the Department of Human Services (DHS).
Within DHS, the Division of Developmental Disabilities (DDD) manages provider qualifications, service agreements, and monitoring for Personal Support services. The Department on Aging (DoA) oversees the Community Care Program for older adults.
- Medicaid Agency: Illinois Department of Healthcare and Family Services (HFS) (https://hfs.illinois.gov)
- Operating Agency (DD): DHS Division of Developmental Disabilities (DDD) (https://www.dhs.state.il.us/page.aspx?item=32253)
- Operating Agency (Aging): Illinois Department on Aging (DoA) (https://ilaging.illinois.gov)
- Licensing Body: DHS Bureau of Accreditation, Licensure and Certification (BALC) (https://www.dhs.state.il.us/page.aspx?item=114910)
- Enrollment Portal: Illinois Medicaid Program Advanced Cloud Technology (IMPACT) (https://impact.illinois.gov)
3. Gatekeeping Prerequisites: Who Can Even Apply
Before an agency can enroll in IMPACT to provide Personal Support, it must be established as a Developmental Disability provider with DHS. This structural precondition requires the transmission of provider data in the Reporting of Community Services (ROCS) system or through the Fiscal Employer Agent (F/EA).
Agencies providing services must also work with DHS Division Region staff to determine whether they require a formal Service Agreement or contract with the Department. Without this regional establishment and data transmission, HFS will not process the IMPACT enrollment.
- DHS Establishment: Must be established as a Developmental Disability provider with DHS prior to Medicaid enrollment
- Data Transmission: Requires transmission of provider data in ROCS or through the F/EA
- Regional Approval: Must work with Division Region staff to secure a formal Service Agreement or contract
- DoA Procurement: For In-Home Service under DoA, providers must respond to specific procurement solicitations to obtain a CCP contract
- Exclusion Checks: Must be screened against the federal Health and Human Services excluded provider database
4. Licensure and Certification Requirements
Personal Support is generally delivered by non-licensed providers and agency staff. Illinois does not require a specific facility license for agencies providing only in-home Personal Support, but the agency must meet DHS provider qualifications and maintain its Service Agreement.
If the agency also intends to provide residential services, such as Community-Integrated Living Arrangements (CILA), it must obtain a license from the DHS Bureau of Accreditation, Licensure and Certification (BALC) pursuant to 59 Ill. Adm. Code 115.
- Licensure Status: Personal Support is a non-licensed provider type monitored via desk reviews and on-site visits
- CILA Licensure: Required only if providing residential services (59 Ill. Adm. Code 115)
- BALC Application: Prospective CILA providers must fulfill new provider requirements within one year of requesting an application from [email protected]
- Operational Timeline: CILA agencies must be operational within 18 months or the licensure process is considered abandoned
- Professional Licensure: Any licensed professionals employed must maintain active registration with the Department of Financial and Professional Regulation (DFPR)
5. Medicaid Provider Enrollment
All waiver agencies and individual providers must enroll with the Department of Healthcare and Family Services (HFS) as Medicaid Waiver providers through the IMPACT system. HFS enrolls all willing and qualified providers who have met the DHS establishment prerequisites.
During enrollment, providers must complete the Provider Agreement for Participation in the Illinois Medical Assistance Program (HFS 1413AS). The database match between DFPR and the Medicaid Management Information System (MMIS) is transmitted monthly to verify ongoing provider status.
- Enrollment System: IMPACT (Illinois Medicaid Program Advanced Cloud Technology)
- Required Form: Provider Agreement for Participation in the Illinois Medical Assistance Program (HFS 1413AS)
- Individual Enrollment: All personal support workers and behavior analysts must be enrolled individually
- System Match: Monthly database match between HFS and DFPR to verify licensure status
- Disenrollment Trigger: If the match finds licensure or registration has expired, the provider is disenrolled
6. Staffing, Training and Background Checks
The Division of Developmental Disabilities has specific training requirements for direct support workers who work for community agencies. Direct support workers must be trained using a curriculum developed by the State or a comparable curriculum approved by the State.
Agencies must also meet ongoing continuing education requirements for Qualified Intellectual Disability Professionals (QIDPs). All staff must pass required background checks before providing unsupervised care.
- Direct Support Training: Must use a State-developed or State-approved curriculum
- Continuing Education: Ongoing CE requirements apply for QIDPs and agency staff
- DoA Training (if applicable): Minimum of 12 hours continuing education per year mandatory for CCP employees
- Background Checks: Required screening against the federal Health and Human Services excluded provider database
- Professional Verification: Division staff check all professional licensure or registration status upon waiver enrollment
7. Documentation, Policies and Records
Providers must maintain adequate documentation of actual service delivery to support all bills submitted. Failure to maintain these records is grounds for termination from program participation.
When terminating waiver services to an individual, providers must submit the Service Termination Approval Request (STAR) form (IL462-2028) to the PAS/ISSA agency. The Independent Service Coordinator (ISC) reviews and signs its approval before submitting it to the Division.
- Service Documentation: Must maintain adequate documentation of actual service delivery to support submitted bills
- Termination Form: Service Termination Approval Request (STAR) (IL462-2028)
- ISC Review: Independent Service Coordinator must review and approve service terminations
- Record Retention: Records must be maintained for at least 5 years or until all State and federal audits are completed
- Overpayment Policy: Providers must notify DHS promptly of overpayments and reimburse the State
8. Billing, Rates and Claims
Reimbursement for Personal Support is processed through the Medicaid Management Information System (MMIS) after data is transmitted via the ROCS system or a Fiscal Employer Agent (F/EA). Providers must accept reimbursement at or below the federally-approved Medicaid rates.
Submitting false, duplicate, or fraudulent bills will result in immediate termination or suspension by HFS pursuant to 89 Ill. Adm. Code 104 and 140.
- Billing System: Reporting of Community Services (ROCS) or Fiscal Employer Agent (F/EA)
- Claims Processor: Medicaid Management Information System (MMIS)
- Rate Standard: Must accept reimbursement at or below the federally-approved Medicaid rates for the 1915(c) waiver
- Fraud Penalty: Termination or suspension pursuant to 89 Ill. Adm. Code 104 and 140 for false billing
- Cost Limits: Services are included in the participant's monthly cost limit for home-based supports
9. Approval Sequence and Timeline
The approval sequence begins with contacting DHS Region staff to establish the agency as a Developmental Disability provider and secure a Service Agreement. Once established and data is transmitted via ROCS, the agency applies through the IMPACT system.
If the agency is pursuing a CILA license for residential services alongside Personal Support, they must fulfill new provider requirements within one year of requesting the application and become operational within 18 months.
- Step 1: Contact DHS Division Region staff for provider establishment
- Step 2: Transmit provider data in ROCS or through the F/EA
- Step 3: Submit Medicaid enrollment application through the IMPACT system
- Step 4: Complete State-approved direct support worker training curriculum
- CILA Timeline: Must be operational within 18 months of licensure application if providing residential services
10. Common Denials and Survey Findings
The State monitors non-licensed and approved providers through targeted desk reviews and on-site visits. A common cause for termination is when a provider no longer meets the Medicaid waiver provider standards, such as falling out of compliance with contractual requirements.
Providers are frequently disenrolled if the monthly database match between HFS and DFPR finds that a required professional licensure or registration has expired, or if the provider fails to maintain adequate documentation of actual service delivery.
- Expired Licensure: Disenrollment due to expired DFPR registration caught during monthly MMIS match
- Documentation Failure: Termination for failing to maintain adequate documentation of actual service delivery
- Overpayment Retention: Failure to notify DHS promptly of overpayments or reimburse the State
- Contract Non-Compliance: Falling out of compliance with DHS Service Agreement requirements
- Fraudulent Billing: Submitting false, duplicate, or fraudulent bills
11. Key Contacts and Resources
Prospective providers should begin by reviewing the 'Becoming a New Developmental Disabilities Provider' guidelines on the DHS website. For Medicaid enrollment technical assistance, providers utilize the IMPACT portal resources.
Agencies seeking to provide residential services in addition to Personal Support must coordinate with the DHS Bureau of Accreditation, Licensure and Certification (BALC).
- DHS Provider Enrollment Guide: Becoming a New Developmental Disabilities Provider (https://www.dhs.state.il.us/page.aspx?item=47336)
- Medicaid Enrollment Portal: IMPACT (https://impact.illinois.gov)
- Licensing Contact: DHS Bureau of Accreditation, Licensure and Certification (BALC) ([email protected])
- Medicaid Agency: Illinois Department of Healthcare and Family Services (HFS) (https://hfs.illinois.gov)
- Aging Services: Illinois Department on Aging (DoA) (https://ilaging.illinois.gov)
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