Illinois - Skilled Nursing Services — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-09

The Illinois Department of Public Health (IDPH) licenses in-home RN and LPN care under two distinct categories: Home Nursing Agency (HNA) for nursing-only models, and Home Health Agency (HHA) for providers offering skilled nursing plus at least one other qualifying service. Both pathways authorize the delivery of skilled treatments, medication administration, and assessments under physician orders.

Approval requires submitting Form 445103 to the IDPH Office of Health Care Regulation, followed by Medicaid enrollment through the Illinois Medicaid Program Advanced Cloud Technology (IMPACT) system. The most rigid structural requirement is the mandate to employ an Illinois-licensed Registered Nurse as the Agency Supervisor, as independent LPNs cannot enroll or operate without RN oversight and IDPH licensure.

1. Service Definition and Scope

In Illinois, skilled nursing services delivered in the home are defined under the Home Health, Home Services, and Home Nursing Agency Licensing Act. These services include patient observation, medication administration, complex dressing changes, tube feedings, and catheter care.

The state distinguishes between a Home Nursing Agency, which provides skilled nursing and home health aide services directly, and a Home Health Agency, which must provide skilled nursing plus at least one other recognized therapeutic service.

• Statutory Authority: 210 ILCS 55 (Home Health, Home Services, and Home Nursing Agency Licensing Act).
• Regulatory Code: 77 Ill. Adm. Code Part 245.
• Home Nursing Agency (HNA): Delivers skilled nursing and home health aide services without requiring a second therapeutic discipline.
• Home Health Agency (HHA): Requires skilled nursing plus at least one other recognized service (e.g., physical therapy) to qualify for licensure.
• Covered Tasks: Patient assessment, complex dressing changes, infusion, venipuncture, and psychiatric evaluation.
• Excluded Tasks: Companionship and housekeeping are outside the scope of skilled nursing and fall under Home Services.

2. Regulatory and Oversight Agencies

The Illinois Department of Public Health (IDPH) is the primary regulatory body responsible for licensing home nursing and home health agencies. They conduct initial reviews, issue licenses, and perform compliance surveys.

The Illinois Department of Healthcare and Family Services (HFS) serves as the state Medicaid agency, managing provider enrollment and reimbursement through its IMPACT system.

• Licensing Agency: Illinois Department of Public Health (IDPH) (https://dph.illinois.gov).
• Medicaid Authority: Illinois Department of Healthcare and Family Services (HFS) (https://hfs.illinois.gov).
• Medicaid Enrollment Portal: IMPACT (Illinois Medicaid Program Advanced Cloud Technology) (https://impact.illinois.gov).
• Waiver Oversight: Illinois Department of Human Services (IDHS) Division of Developmental Disabilities (https://www.dhs.state.il.us).

3. Gatekeeping Prerequisites: Who Can Even Apply

Illinois does not require a Certificate of Need (CON) or Facility Need Review for Home Nursing Agencies or Home Health Agencies. The market is open to willing providers who meet the structural and staffing requirements.

There are no closed procurement windows or RFP requirements to apply for basic IDPH licensure, though subsequent contracting with managed care organizations (MCOs) is subject to network adequacy needs.

• Certificate of Need: None exists for this specific licensure category in Illinois; applications are accepted on a rolling basis.
• Procurement Windows: None; IDPH accepts Form 445103 at any time.
• Corporate Registration: Must be registered with the Illinois Secretary of State and have an Illinois-based Registered Agent.
• Agency Supervisor: Must have an Illinois-licensed RN designated as the Agency Supervisor prior to application submission.

4. Licensure and Certification Requirements

Prospective providers must submit the Home Health, Home Services, Home Nursing Agency Initial Licensure Application (Form 445103) to IDPH. The application requires detailed disclosures of ownership, governing body officers, and service lines.

Agencies applying for multiple license types (e.g., Home Nursing and Home Services) must pay the higher of the applicable licensure fees.

• Application Form: Form Number 445103 (Home Health, Home Services, Home Nursing Agency Initial Licensure Application).
• Licensure Fee: $500 initial fee for a Home Nursing Agency license.
• Multiple Licenses: Applicants applying for multiple licenses pay the higher of the applicable fees.
• Financial Statement: Annual financial statement required under Section 245.60.
• Medicare Certification: Optional for HNA, but required if an HHA intends to bill Medicare (requires CMS 855A and accreditation).

5. Medicaid Provider Enrollment

Once licensed by IDPH, agencies must enroll as Medicaid providers through the IMPACT system. Enrollment requires an active license and a Type 2 National Provider Identifier (NPI).

Medicaid enrollment alone does not guarantee patient volume, as most Illinois Medicaid beneficiaries receive services through HealthChoice Illinois managed care plans, requiring separate credentialing.

• System: IMPACT (Illinois Medicaid Program Advanced Cloud Technology).
• Prerequisite: Must possess an active IDPH license before IMPACT enrollment is approved.
• NPI Requirement: Must obtain a Type 2 National Provider Identifier (NPI) for the agency.
• Application Fee: Subject to the ACA institutional provider application fee unless waived by Medicare enrollment.
• MCO Contracting: Providers must separately contract with HealthChoice Illinois MCOs after IMPACT approval.

6. Staffing, Training and Background Checks

Agencies must employ qualified clinical leadership, specifically an Illinois-licensed Registered Nurse to serve as the Agency Supervisor. All staff must undergo background checks before client contact.

Illinois mandates that agencies register with the IDPH Web Portal to access the Health Care Worker Registry (HCWR) for verifying employee backgrounds.

• Agency Supervisor: Must be an RN licensed under the Illinois Nursing Act (225 ILCS 65).
• Administrator: Required to oversee daily operations; can be the same person as the Agency Supervisor if qualified.
• Background Checks: Mandatory registration and verification through the IDPH Health Care Worker Registry (HCWR).
• Training: Employee training must comply with 77 Ill. Adm. Code 245.70.
• LPN Supervision: Licensed Practical Nurses must practice under the direction of a Registered Nurse or physician.

7. Documentation, Policies and Records

Title 77 Ill. Adm. Code Part 245 outlines strict documentation requirements for licensure. Agencies must submit specific policies with their initial application, including job descriptions and acceptance criteria.

Ongoing compliance requires maintaining a formal Quality Improvement Program and strict adherence to infection control protocols.

• Acceptance Criteria: Written policies for acceptance of patients as required per Section 245.200(d).
• Job Descriptions: Must submit a copy of the job description for each service offered (Section 245.30(c)(1)(D)).
• Infection Control: Documented infection control policies per Section 245.75.
• Abuse Prevention: Policies for Abuse, Neglect and Financial Exploitation Prevention and Reporting (Section 245.250).
• Quality Improvement: Must maintain a Quality Improvement Program per Section 245.240.

8. Billing, Rates and Claims

Reimbursement for skilled nursing services is processed either through the state's fee-for-service MMIS or through contracted MCOs. Services must be ordered by a physician and often require prior authorization.

Rates are established by HFS and vary depending on whether the service is billed under the state plan or a specific HCBS waiver.

• Billing System: Fee-for-service claims are submitted through the HFS MEDI system or clearinghouses to IMPACT.
• Managed Care: Claims for HealthChoice Illinois enrollees must be sent directly to the specific MCO.
• Procedure Codes: Typically billed using standard HCPCS codes (e.g., G0299 for RN, G0300 for LPN).
• Prior Authorization: Skilled nursing visits generally require prior authorization and a physician's order.

9. Approval Sequence and Timeline

The approval process is sequential, beginning with corporate formation and ending with MCO contracting. IDPH licensure must be fully secured before Medicaid enrollment can begin.

The entire process from application to billable status typically spans 6 to 12 months, depending on IDPH processing times and MCO credentialing cycles.

• Step 1: Entity formation and Secretary of State registration (1-2 weeks).
• Step 2: Submission of IDPH Form 445103 and $500 fee.
• Step 3: IDPH application review and initial licensure (typically 3-6 months).
• Step 4: IMPACT Medicaid enrollment (1-3 months post-licensure).
• Step 5: MCO credentialing and contracting (3-6 months, often concurrent with or after IMPACT).

10. Common Denials and Survey Findings

Initial applications are frequently delayed or denied due to missing attachments or incomplete forms. IDPH requires exact adherence to the instructions on Form 445103.

During surveys, agencies are commonly cited for failing to maintain updated background checks or lacking proper RN oversight documentation.

• Missing HCWR Access: Failure to demonstrate registration with the IDPH Web Portal for Health Care Worker Registry access.
• Incomplete Sole Proprietor Declaration: Missing the required declaration on Page 8 of Form 445103 for sole proprietorships.
• Unqualified Supervisor: Nominating an Agency Supervisor who lacks an active Illinois RN license.
• Contracting Violations: Attempting to contract out skilled nursing services for routine care (only allowed for vacations or specialized skills).
• Missing Job Descriptions: Failing to attach job descriptions for each intended service line.

11. Key Contacts and Resources

Providers should rely on the official IDPH and HFS websites for the most current forms, fee schedules, and regulatory updates.

The Illinois General Assembly website hosts the official text of the administrative code governing these agencies.

• IDPH Office of Health Care Regulation: https://dph.illinois.gov
• Illinois Administrative Code Part 245: https://ilga.gov/agencies/JCAR/EntirePart?titlepart=07700245
• IMPACT Provider Portal: https://impact.illinois.gov
• Health Care Worker Registry: https://dph.illinois.gov/topics-services/health-care-regulation/health-care-worker-registry.html
• Illinois Department of Healthcare and Family Services (HFS): https://hfs.illinois.gov

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