Illinois ranks as the sixth most populous state in the nation, with approximately 2.3 million residents aged 65 and older. The state's aging population, combined with high rates of chronic conditions and a strong preference for aging in place, creates substantial demand for home health services across both metropolitan Chicago and rural downstate communities.

Illinois maintains a comprehensive regulatory framework for home health agencies through the Illinois Department of Public Health (IDPH) and the Department of Healthcare and Family Services (HFS) for Medicaid programs. The state requires more training hours than federal minimums for home health aides and has implemented extensive HCBS waiver programs. This guide covers everything agencies and caregivers need to know about providing home health services in Illinois, from licensing requirements to Medicaid reimbursement and strategies for building a sustainable workforce.

Illinois Home Health Agency Licensing Requirements

The Illinois Department of Public Health (IDPH) oversees home health agency licensing under the Home Health, Home Services, and Home Nursing Agency Licensing Act (210 ILCS 55) and IDPH Administrative Code 245. These regulations establish comprehensive requirements for agencies providing skilled home health services.

Definition and scope. Home Health Agencies in Illinois are defined as public agencies or private organizations that provide skilled nursing services and at least one other home health service. Services must be provided to a person at their residence in accordance with a plan of treatment for illness or infirmity prescribed by a physician or podiatrist.

Licensing authority. All home health agencies must secure a license from IDPH before offering services. The licensing process evaluates staffing qualifications, patient care protocols, and administrative practices to ensure compliance with state regulations.

Application process. The licensing process begins with submitting a detailed application to IDPH providing comprehensive information about agency ownership, organizational structure, and the range of services offered. IDPH conducts an initial review within 30 days of submission and contacts applicants for necessary revisions. The application must be completed and approved within 90 days, or it may be denied per section 245.130(b).

Provisional license. If an agency's application is approved, IDPH issues a provisional license valid for 240 days. IDPH must conduct an on-site survey to determine compliance within 30 days before the provisional license expires.

Staffing requirements. Agencies must employ qualified personnel, including registered nurses and licensed therapists, who meet state certification standards. Skilled nursing may not be contracted out except to cover staff vacations or for specialized skills not routinely offered. Skilled nursing must be directly provided by the agency plus at least one other recognized service to qualify for licensure.

Financial requirements. Agencies must submit a financial statement demonstrating ability to sustain operations and provide evidence of adequate liability insurance to protect against potential legal claims.

Inspections and compliance. IDPH conducts inspections, often unannounced, to ensure agencies comply with the licensing act. Inspections evaluate patient care plans, staff qualifications, and care environment safety.

Key regulations. Agencies must comply with the Home Health, Home Services, and Home Nursing Agency Licensing Act (210 ILCS 55), IDPH Administrative Code 245, Health Care Worker Background Check Act (225 ILCS 46), and Alzheimer's Disease and Related Dementias Services Code 973.

Contact information. For licensing submissions: IDPH, Division of Health Care Facilities and Programs, Home Health Program, 525 W. Jefferson St., 4th Floor, Springfield, IL 62761. Email: [email protected]

Home Health Aide Certification Requirements

Illinois requires significantly more training for home health aides than the federal minimum, reflecting the state's commitment to quality care. Understanding these requirements is essential for both agencies and prospective caregivers.

Training hours. HHA training programs in Illinois must consist of at least 120 hours of training, including at least 40 hours of clinical training. This exceeds the federal minimum of 75 hours and is more than required in most other states.

Basic requirements. Prospective home health aides must meet several criteria: be at least 16 years of age, be of temperate habits and good moral character, be honest, reliable, and trustworthy, speak and understand English or a language understood by a substantial percentage of the facility's residents, provide evidence of employment or occupation and residence for 2 years prior to present employment, and have completed at least 8 years of grade school or provide proof of equivalent knowledge.

Background check. All applicants must undergo a criminal history records check as prescribed by the Health Care Worker Background Check Act with no disqualifying convictions. There must also be no administrative finding of abuse, neglect, or misappropriated property in Illinois or any other state.

Competency evaluation. After completing training, candidates must pass a competency evaluation conducted by a registered nurse, covering both written knowledge and practical skills. The evaluation must be documented in the aide's personnel file.

Initial clinical contact. Prior to any direct contact with a resident, employees must complete a specified 16 hours of classroom training in a state-approved CNA or HHA training program.

Continuing education. Home Health Aides need 12 hours of annual in-service training, including 2 hours on dementia-related topics. This ongoing training ensures aides maintain skills and stay current with care techniques.

Program duration. Most approved programs finish in 3-8 weeks, depending on schedule and pacing. Many schools offer evening or weekend options to accommodate working students.

Approved programs. The Illinois Department of Public Health maintains a list of approved training programs, including colleges, technical institutes, and authorized healthcare agencies.

CNA Certification Requirements

Certified Nursing Assistants form a significant portion of Illinois's home health workforce. Many agencies prefer or require CNA certification due to the comprehensive training and registry verification.

Training requirements. Certification requires successful completion of a state-approved nursing assistant training program consisting of at least 120 hours of instruction. Prior to any direct contact with a resident, employees must complete 16 hours of classroom training.

Competency testing. The CNA certification process is overseen by IDPH and administered through Southern Illinois University Carbondale (SIUC). Candidates must pass both a written and skills test, demonstrating 21 mandated manual skills.

Alternative pathways. Individuals may also qualify through RN or LPN coursework, U.S. military health care training, foreign nursing education with verified transcripts, or out-of-state CNA certification that meets federal standards. If a registered nurse or licensed practical nurse has a current, valid Illinois license in good standing, they can work as a CNA without being on the registry.

Registry placement. The Illinois Nurse Aide Registry, maintained by IDPH through the Health Care Worker Registry (HCWR), is the official record of CNAs authorized to work in Illinois. It tracks training, employment, background checks, and administrative findings. Illinois does not issue license numbers or paper certificates; the registry listing is the only official proof of certification.

Maintaining certification. To maintain active certification, a CNA must work at least one 8-hour shift within a 24-month period, performing nursing or nursing-related services for pay under the supervision of a licensed nurse. If 24 consecutive months pass without paid nursing work, certification is lost.

Employer verification. Employers must use the registry to verify work eligibility before hiring. The online registry is accessible at hcwrpub.dph.illinois.gov.

Contact information. Illinois Department of Public Health Nurse Aide Registry, 525 W. Jefferson St., Springfield, IL 62761. Phone: 217-785-5133.

Medicaid Reimbursement in Illinois

Illinois Medicaid, administered by the Department of Healthcare and Family Services (HFS), provides home health coverage for eligible residents. The state maintains fee schedules and multiple waiver programs to support home-based care.

Fee schedule administration. HFS maintains a Home Health Fee Schedule that governs reimbursement rates for Medicaid-covered services. The fee schedule is updated periodically and providers should verify current rates through the HFS website.

Provider enrollment. Home health agencies must enroll as Medicaid providers through HFS to receive reimbursement for services provided to Medicaid beneficiaries. The enrollment process includes verification of licensing, background checks, and financial documentation.

Claims submission. Illinois Medicaid requires electronic claims submission for most providers. Claims must include appropriate procedure codes, modifiers, and documentation to support medical necessity.

Coverage limitations. Fee schedules do not address various coverage limitations routinely applied before final payment, including client and provider eligibility verification, benefit limits, billing instructions, frequency of services, prior authorization requirements, and applicable co-payments or coinsurance.

Rate resources. Current fee schedules are available through the HFS Medicaid Reimbursement page. The Home Health Fee Schedule can be accessed at hfs.illinois.gov/medicalproviders/medicaidreimbursement/hhfeeschedule.html.

HCBS Waiver Programs

Illinois operates nine 1915(c) Home and Community-Based Services (HCBS) waiver programs, providing alternatives to institutional care for individuals with various needs. These programs allow eligible individuals to receive care in their homes or community settings.

Program overview. The Medicaid HCBS waiver program permits Illinois to furnish an array of home and community-based services that assist Medicaid beneficiaries to live in the community and avoid institutionalization. Each waiver has its own individual eligibility requirements.

General eligibility. To qualify for Illinois HCBS waivers, individuals must meet Medicaid financial eligibility criteria, require an institutional level of care, have service needs at a cost equal to or less than institutional care, and meet any age or diagnosis requirements specific to each waiver program.

Home Services Program (HSP). HFS and the Department of Human Services Division of Rehabilitation Services (DHS-DRS) are working to merge several HCBS waivers into one combined waiver under the Home Services Program.

Persons with Disabilities Waiver. This waiver provides services to persons with physical disabilities ages 0-59 who meet nursing facility level of care. Services include adult day service, homemaker, individual provider, respite, home health aide, occupational therapy, physical therapy, speech therapy, environmental accessibility adaptations, home delivered meals, in-home shift nursing, intermittent nursing, personal emergency response systems, and specialized medical equipment.

Persons Who Are Elderly Waiver. This waiver provides HCBS for seniors aged 65 and older at risk of nursing home placement. It is a component of the Community Care Program (CCP) administered through the Illinois Department on Aging (DoA). Services help elderly residents maintain independence at home.

Brain Injury Waiver. This waiver serves individuals with brain injury who meet nursing facility level of care. Services include day habilitation, prevocational services, supported employment, cognitive behavioral therapies, and other home-based supports.

HIV/AIDS Waiver. This waiver provides home-based services to individuals with HIV/AIDS who meet nursing facility level of care.

Enrollment limitations. The Elderly Waiver and other HCBS waivers are not entitlement programs. There are maximum enrollment slots, and when reached, qualified individuals are placed on waiting lists.

Contact information. For medical benefits: Health Benefits Hotline 1-866-468-7543. For DHS-DRS services: 1-877-581-3690 or 1-800-447-6404 (TTY). Seniors can call the Senior Helpline at 800-252-8966.

Electronic Visit Verification (EVV) Requirements

Per the 21st Century Cures Act of 2016, Illinois implements Electronic Visit Verification for all Medicaid-funded personal care services and home health care. The state uses a hybrid model with HHAeXchange as the designated vendor and aggregator.

Implementation timeline. December 31, 2023 was the implementation date for EVV requirements for home health services. Effective January 1, 2024, EVV is required for Occupational Therapists, Physical Therapists, Speech Therapists, Licensed Practical Nurses, and Registered Nurses providing home health care services.

Illinois hybrid model. Illinois operates as a hybrid state where agencies can use any qualified EVV vendor, but EVV information must be submitted to HHAeXchange, selected as the state's EVV vendor and aggregator in March 2022. To use an alternative EVV system, agencies must ensure compatibility with the Electronic Data Interchange (EDI) process.

Covered services. All home health care services providers billing Illinois Medicaid, HealthChoice Illinois (HCI) Managed Care Organizations, and Medicare-Medicaid Alignment Initiative (MMAI) MCOs must use HHAeXchange for EVV or transmit EVV data to HHAeXchange through a third-party system. Physical Therapy Assistants and Occupational Therapy Assistants must also use EVV when providing Medicaid billable services.

Required data elements. The EVV system must verify the type of service performed, the date, time, and location of service, the individual receiving the service, and the individual providing the service.

System requirements. The system must maintain accurate time reporting, allow review and approval by the participant or designee, be accessible 24/7 for persons with hearing, physical, or visual impairments, and notify supervisory staff of untimely, missed shifts, or schedule deviations.

Privacy restrictions. Illinois does not allow biometric data, pictures, videos, or voice recordings to identify customers or substantiate visit data. Only location information at the beginning and/or end of a visit is accepted; continual GPS tracking during visits is prohibited.

Compliance requirements. An overall EVV compliance rate of 50% was required by May 1, 2025. Effective April 1, 2025, providers must use HHAeXchange's new Customer Support portal for technical support requests.

Contact information. For EVV questions: [email protected] or visit hfs.illinois.gov/medicalproviders/electronicvisitverification.html.

Medicare Home Health Coverage

With Illinois's large elderly population, Medicare remains a critical payer for home health services. Medicare certification allows agencies to serve beneficiaries and typically provides better reimbursement than Medicaid programs.

Eligibility requirements. To qualify for Medicare home health coverage, beneficiaries must be homebound (leaving home requires considerable effort due to illness or injury), need skilled nursing care on an intermittent basis or require physical therapy, speech-language pathology services, or continued occupational therapy, have a physician certify the need for home health care and establish a plan of care, and receive services from a Medicare-certified home health agency.

2026 payment rates. CMS's Calendar Year 2026 Home Health Prospective Payment System Final Rule establishes updated payment rates, including permanent and temporary behavior adjustments and recalibrated case-mix weights.

PDGM considerations. The Patient-Driven Groupings Model (PDGM) determines Medicare payment based on patient characteristics including admission source, clinical grouping, functional level, and comorbidity adjustments.

Plan of care requirements. Medicare requires a plan of care signed by a physician specifying services needed, frequency, and duration, reviewed at least every 60 days.

Medicare certification. Agencies seeking Medicare certification must meet federal Conditions of Participation and undergo a state survey. Given Medicaid rate constraints, Medicare certification is essential for financial sustainability.

Labor Laws and Wage Requirements

Illinois maintains robust labor protections that exceed federal minimums. Understanding these requirements is essential for compliance and competitive compensation.

Minimum wage. The Illinois minimum wage is $15.00 per hour for workers age 18 and older as of 2026. The tipped minimum wage is $9.00 per hour. Workers under 18 may be paid $13.00 per hour for less than 650 hours worked for an employer in a calendar year; once exceeding 650 hours, they must be paid the full $15.00.

Chicago wage requirements. Chicago's minimum wage is $16.20 per hour, higher than the state minimum. Cook County (excluding Chicago) follows the state minimum of $15.00 per hour.

Overtime requirements. Overtime must be paid after 40 hours of work per week at time and one-half the regular rate. Illinois does not specify daily overtime limits. Most hourly employees are entitled to overtime for hours worked beyond 40 in a single workweek.

Exemptions. Workers exempt from overtime include those covered by federal FLSA classifications, salesmen and mechanics at auto or farm implement dealerships, executives, administrators, and professionals earning at least $455 per week, external salespeople, certain computer-related workers, and independent contractors.

Penalties for violations. Employers who fail to pay minimum wage are subject to fines, back pay awards, and additional damages equal to 5% of the underpayment per month. For overtime violations, workers can often recover unpaid overtime plus an equal amount as damages.

Illinois Workforce Challenges

Illinois faces significant home health workforce challenges driven by demographic trends, competition from other industries, and regional disparities between Chicago and downstate communities.

Current wages. According to available data, the average hourly pay for a Home Health Aide in Illinois ranges from $15.65 to $19.14, with annual salaries averaging $29,400 to $36,540 depending on the source. The majority of wages fall between $13.51 (25th percentile) and $17.45 (75th percentile).

National comparison. The Bureau of Labor Statistics reports the national average annual personal care and home health aide salary at $34,990, with an hourly rate of $16.82. Illinois wages are generally competitive with national averages but vary significantly by region within the state.

Aging population. With approximately 2.3 million residents aged 65 and older, Illinois faces sustained demand for home health services. This demographic trend will continue driving workforce needs for decades.

Training barrier. Illinois's 120-hour HHA training requirement, while ensuring quality, creates a barrier to entry compared to states with lower requirements. The time and cost investment can deter potential workers.

Regional disparities. Chicago and suburban Cook County offer higher wages and more job opportunities, while downstate communities face worker shortages and lower pay scales. Rural areas struggle particularly with recruitment and retention.

Industry competition. With Illinois's $15.00 minimum wage, home health positions must compete with retail, hospitality, and warehouse jobs that may offer comparable pay with less demanding work and more predictable schedules.

Job market conditions. Some data suggests the home health aide job market in Illinois is not highly active, with relatively few companies currently hiring, potentially reflecting budget constraints or difficulty filling positions.

Strategies for Illinois Agencies

Given Illinois's specific market dynamics, agencies must adopt targeted strategies to build sustainable operations and competitive workforces.

Maximize Medicare revenue. With Medicaid constraints, maximizing Medicare patient volume is essential for financial sustainability. Proper documentation and coding ensure appropriate PDGM payments and provide margin for competitive wages.

Offer competitive wages. With the state minimum wage at $15.00 and average HHA wages around $15-17 per hour, agencies must offer above-market compensation to attract quality candidates. In Chicago, matching or exceeding the $16.20 local minimum is essential.

Provide training support. Given the 120-hour training requirement, offering free or subsidized HHA training removes barriers to entry and builds a pipeline of qualified workers committed to your agency.

Leverage HCBS waiver programs. Build relationships with the various HCBS waiver programs to serve participants in the Persons with Disabilities, Elderly, Brain Injury, and HIV/AIDS waivers. This provides stable Medicaid-funded patient volume.

Ensure EVV compliance. Select an EVV system compatible with HHAeXchange requirements. Train staff thoroughly on clock-in/clock-out procedures and maintain the required compliance rate to avoid claim denials.

Address regional needs. Develop strategies specific to your service area. Chicago agencies compete on wages and benefits; downstate agencies may emphasize community connection, schedule flexibility, and career advancement opportunities.

Invest in retention. Given training requirements and workforce shortages, retaining workers is critical. Provide thorough onboarding, consistent scheduling, supervisor support, and recognition programs. Consider retention bonuses tied to tenure milestones.

Build community partnerships. Partner with community colleges, workforce development boards, and community organizations to identify and train potential caregivers. IDPH maintains a list of approved training programs that can serve as pipeline sources.

Emphasize career pathways. Create clear advancement opportunities from HHA to CNA to licensed nursing programs. Partner with nursing schools to offer tuition assistance tied to employment commitments.

Key Resources and Contacts

Agencies operating in Illinois should maintain relationships with these key regulatory and support organizations:

Illinois Department of Public Health (IDPH)
Home health agency licensing and inspection
525 W. Jefferson St., 4th Floor, Springfield, IL 62761
Email: [email protected]
Website: dph.illinois.gov/topics-services/health-care-regulation/health-care-facilities/home-health.html

Illinois Department of Healthcare and Family Services (HFS)
Medicaid administration and reimbursement
Website: hfs.illinois.gov
Fee Schedules: hfs.illinois.gov/medicalproviders/medicaidreimbursement.html

Illinois Nurse Aide Registry
CNA certification verification
Phone: 217-785-5133
Online Registry: hcwrpub.dph.illinois.gov

Electronic Visit Verification (EVV)
Email: [email protected]
Website: hfs.illinois.gov/medicalproviders/electronicvisitverification.html

Illinois Department on Aging
Community Care Program and Elderly Waiver
Senior Helpline: 800-252-8966

DHS Division of Rehabilitation Services
Persons with Disabilities Waiver
Phone: 1-877-581-3690 or 1-800-447-6404 (TTY)

Illinois Department of Labor
Wage and hour enforcement
Website: labor.illinois.gov

The Bottom Line

Illinois presents both significant opportunities and challenges for home health agencies. The state's large aging population of 2.3 million residents aged 65 and older ensures sustained demand for home health services. Comprehensive HCBS waiver programs provide multiple pathways to serve Medicaid beneficiaries, while Medicare certification offers better reimbursement for financial sustainability.

Operating successfully in Illinois requires understanding the state's comprehensive regulatory framework. The 120-hour HHA training requirement exceeds federal minimums and most other states, ensuring quality but creating workforce barriers. The hybrid EVV model with HHAeXchange integration requires careful system selection and staff training. Multiple HCBS waiver programs offer opportunities to serve diverse populations from the elderly to persons with disabilities and brain injuries.

Illinois's $15.00 minimum wage and average HHA wages around $15-17 per hour create a competitive labor market. Chicago's higher $16.20 minimum wage adds regional complexity. Agencies must offer competitive compensation, training support, and career advancement opportunities to build and retain quality workforces.

The state's mix of metropolitan Chicago and rural downstate communities requires flexible strategies. Chicago agencies compete on wages and benefits; downstate agencies may emphasize community connection and schedule flexibility. Either way, investing in workforce development through free training programs and clear career pathways will be essential for success.

Agencies that understand Illinois's regulatory environment, maintain strong relationships with IDPH and HFS, invest in workforce development, and ensure strict compliance with EVV and documentation requirements will be best positioned to serve the Prairie State's growing home health care needs and build sustainable operations.