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Illinois - Home Health Service — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-09

The Illinois Department of Public Health (IDPH) licenses Home Health Agencies under the Home Health, Home Services, and Home Nursing Agency Licensing Act (210 ILCS 55), requiring applicants to submit Form 445103 and a $1,500 biennial fee. To qualify for this specific license class, an agency must directly provide skilled nursing services plus at least one other recognized service, such as physical therapy or home health aide services, rather than contracting out the core nursing component.

Medicaid reimbursement for these intermittent skilled services is administered by the Illinois Department of Healthcare and Family Services (HFS) through the IMPACT enrollment system. Agencies must secure IDPH licensure and typically obtain Medicare certification before HFS will approve them to bill Medicaid for traditional home health services under the state plan.

1. Service Definition and Scope

In Illinois, a Home Health Agency provides intermittent skilled nursing and at least one other therapeutic service (physical therapy, occupational therapy, speech therapy, medical social services, or home health aide services) to patients in their residences. These services must be delivered under a physician-ordered plan of care.

The state distinguishes Home Health Agencies from Home Nursing Agencies (which provide skilled nursing but do not require the second therapeutic service) and Home Services Agencies (which provide non-medical personal care). Only the Home Health Agency license permits the full scope of Medicare-certified, multi-disciplinary intermittent skilled care.

2. Regulatory and Oversight Agencies

The Illinois Department of Public Health (IDPH) is the primary regulatory body responsible for licensing and surveying Home Health Agencies. IDPH's Health Care Facilities and Programs division processes initial applications, renewals, and changes of ownership.

The Illinois Department of Healthcare and Family Services (HFS) serves as the state Medicaid agency, managing provider enrollment and claims processing through the IMPACT system. HFS establishes the fee schedules and coverage policies for Medicaid home health services.

3. Gatekeeping Prerequisites: Who Can Even Apply

Illinois requires Home Health Agencies to meet strict structural preconditions before an application is approved. An agency cannot be licensed as a Home Health Agency if it intends to contract out its core skilled nursing services; skilled nursing must be provided directly by agency employees, except for temporary vacation coverage or highly specialized skills.

Furthermore, to enroll as a Medicaid Home Health provider through HFS, agencies generally must first achieve Medicare certification. Illinois does not currently require a Certificate of Need (CON) for home health agencies, but the direct-provision mandate and Medicare certification requirement serve as the primary structural gates.

4. Licensure and Certification Requirements

Prospective providers must submit the Home Health Agency Initial Licensure Application (Form 445103) to IDPH. The application requires detailed disclosures of ownership, governing body officers, geographic service areas, and copies of affiliation agreements for any contracted secondary services.

Licenses are valid for two years and require a $1,500 fee. Applicants must also submit job descriptions for each service offered and demonstrate registration with the IDPH Web Portal for access to the Health Care Worker Registry.

5. Medicaid Provider Enrollment

Once licensed by IDPH and Medicare-certified, the agency must enroll in the Illinois Medical Assistance Program via the IMPACT portal. Providers must select the appropriate Provider Type and Specialty corresponding to Home Health Agencies.

Enrollment requires the agency to input its IDPH license number, Medicare number, and National Provider Identifier (NPI). The agency must also clear federal and state exclusion list checks during the IMPACT enrollment process.

6. Staffing, Training and Background Checks

Illinois mandates specific qualifications for agency leadership and direct care staff. The Agency Supervisor must be an Illinois registered professional nurse with home health experience. All unlicensed direct care staff, such as home health aides, must meet training requirements under 77 Ill. Adm. Code 395 or establish equivalency.

All employees must undergo fingerprint-based criminal history checks in accordance with the Health Care Worker Background Check Act (225 ILCS 46). Agencies must maintain documentation of these checks and verify status on the Health Care Worker Registry.

7. Documentation, Policies and Records

Agencies must establish and maintain comprehensive policies governing patient care, personnel, and equipment management. 77 Ill. Adm. Code 245 requires written criteria for the acceptance of patients and clients, as well as detailed employee training policies.

Clinical records must be maintained for every patient, documenting the physician's plan of care, clinical notes, and supervisory visits. Agencies must also maintain evidence of liability insurance as part of their licensure file.

8. Billing, Rates and Claims

Medicaid home health claims are submitted electronically to HFS or the applicable Medicaid Managed Care Organization (MCO) using standard institutional claim formats. HFS publishes fee schedules for home health services, which dictate the maximum allowable rates for skilled nursing visits, therapy visits, and home health aide services.

Providers must ensure that all billed services are supported by a physician-signed plan of care and documented clinical notes. Services provided to beneficiaries enrolled in Medicaid managed care must be billed directly to the contracted MCO according to their specific authorization and billing guidelines.

9. Approval Sequence and Timeline

The approval process begins with the submission of Form 445103 and the $1,500 fee to IDPH. IDPH reviews the application, ownership disclosures, and policies, which can take several months depending on application completeness and department volume.

Following IDPH licensure, the agency typically seeks Medicare certification via an initial survey. Once Medicare-certified, the agency submits its enrollment application through the HFS IMPACT system, which involves additional screening and verification steps before a Medicaid provider number is issued.

10. Common Denials and Survey Findings

Initial licensure applications are frequently delayed or denied due to incomplete ownership disclosures, missing professional staff licenses, or failure to demonstrate that skilled nursing will be provided directly by the agency. IDPH will halt processing if the required $1,500 fee or contiguous county service area map is incorrect.

During surveys, common deficiencies include failure to maintain updated physician plans of care, inadequate documentation of home health aide supervision by an RN, and missing fingerprint-based background checks in personnel files.

11. Key Contacts and Resources

Providers should regularly consult the IDPH and HFS websites for updated forms, fee schedules, and administrative code changes. The IDPH Health Care Facilities and Programs division handles all licensure inquiries.

For Medicaid billing and enrollment questions, providers must utilize the IMPACT portal and HFS provider notices. Maintaining contact with these agencies ensures compliance with both state licensure and federal Medicaid requirements.

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