The Illinois home services agency manager: who can run your agency

"The agency shall have a governing body or a clearly defined body with legal authority and responsibility for the conduct of the agency." 245.30(a) By our reading, in a small agency it can be the owner or owners. The officers of the governing body go on IDPH’s application form, with a president for every agency and a president and secretary for entities listed as corporations with the Secretary of State. Form 445104, page 4

The rule’s list has one more item, "Employ a qualified administrator for home health agencies", which applies to home health agencies only. A home services agency designates an agency manager instead. 245.30(a)(2); 245.30(f)(1) The governing body also needs written administrative policies to ensure clients get safe and adequate care. 245.30(b)(1) IDPH’s surveyor checklist lists bylaws and governing body meeting minutes among the materials for review. IDPH surveyor checklist (archived August 30, 2025)

Our suggestion for a one-person governing body: still write, sign and date short minutes of each review, so the surveyor can see the governing body met.

That is all. Part 245 sets no degree, license or minimum years of experience for the agency manager of a home services agency. IDPH’s own form points back to the same place: "See Section 245.30f for the requirements for the agency manager". Attachment E, page 1

That does not mean anyone will do. IDPH may consider adverse licensure action for "Lack of personnel qualified by training and experience to properly perform the function of an agency", judged against Part 245’s personnel requirements, 245.130(b)(3) or on satisfactory evidence that the moral character of the applicant or the agency’s supervisor is not reputable. 245.130(b)(2) Attachment E is where IDPH sees the manager’s experience.

The manager also signs for the agency. The affidavit on page 8 of form 445104 is signed by the agency manager with an original signature, Form 445104, page 8 the form asks for a manager contact number that is different from the agency phone number, Form 445104, page 2 and it asks whether the manager is responsible for more than one Illinois agency and, if so, which. Form 445104, page 4

Attachment E is for every agency type except home health, with boxes for home nursing and home services. Attachment E, page 1 It goes in with an initial application, and IDPH’s form asks for it again when there has been a change in the agency manager. Form 445104, page 9 If you apply for more than one type of license, complete a separate Attachment E for each manager. Attachment E, page 1

Attachment E asks about convictions with no time limit, while the application form asks about the last five years and the rule about the previous year. The three look-back periods compared → A conviction is not an automatic bar: the rule says IDPH may take convictions into account, "but such convictions shall not operate as a bar to licensing." 245.130(b)(2)

Our suggestion: describe the work experience in terms of the duties below and the tasks home services workers do, with dates and weekly hours for each job, since that is what the form asks for and what IDPH has to judge the manager on.

Elsewhere, the rules give the manager a named part in a few routines:

• Surveys. IDPH’s surveyor checklist says "the agency manager or a designee must be available for the survey when an IDPH nurse surveyor arrives", and the manager or designee must be able to show access to the Health Care Worker Registry through the IDPH web portal. IDPH surveyor checklist
• Background checks. The registry account that runs every caregiver check is opened by an employee registering for the portal, who can then give others access. 955.115(a) Background checks, step by step →
• Branch offices. If you have one, "The administrator/agency manager of the parent agency shall provide supervision during all operating hours of the agency's branch office", and any branch supervisor or manager stays under the parent manager’s supervision. 245.80(k)(1)(A)-(C) The parent office manager, administrator or supervising nurse also makes a documented on-site visit to the branch at least monthly. 245.80(k)(1)(I)

Duty 11 is short: "Designate in writing the qualified staff member to act in the absence of the administrator;" 245.40(a)(11) The application has to show it: "Ownership, organization and governing structure of the agency including the alternate administrative staff required per Section 245.40(a)(11)". 245.90(a)(3)(B) The staff list in Form 445104 has its own lines for the Administrator/Agency Manager and the Alternate Agency Manager. Form 445104, page 7

Part 245 does not define “qualified” for the alternate. Our suggestion: choose someone who knows your policies and could carry out the manager’s duties for a few weeks, give them a short handover before each planned absence, and keep the signed designation with the governing body’s records.

Part 245 has one rule against combining posts: "No one person may hold the positions of both home health agency administrator and agency supervisor." 245.30(d)(5) It is written for home health agencies. We found no similar bar for home services agencies, so by our reading one person can be the manager and the supervisor of caregivers, as long as they meet the supervisor and trainer qualifications below and can do both jobs.

We also found nothing in Part 245 that stops an owner from being the agency manager. The rule leaves the choice to the governing body or the entity legally responsible for the agency. 245.20

If the manager or supervisor will also step in and give care, two more sets of rules come in. By our reading, the worker training and competency rules apply to anyone giving home services: no assignment before passing a competency evaluation on the first five hours of training. 245.71(c) And your written list of direct care positions decides who goes through the health care worker background check. 955.140 CareRulebook’s manual writes covering visits into the manager, alternate and supervisor job descriptions and treats those roles as direct care positions. The rules do not settle whether a manager who covers only occasionally counts; that question is on our list for IDPH.

This is where Part 245 does set qualifications. "The agency shall have home services supervisors or trainers that provide initial training and supervision on an ongoing basis to home service workers" on the tasks in 245.40(c)(4)(A) to (P). Each supervisor or trainer meets one of two routes: 245.71(g)

What supervisors do, under the rules:

• Available at all times. "An individual who is in a supervisory capacity shall be designated and available to the worker for responses to questions at all times." 245.40(c)(6)(A)
• Visits. "On-site supervision shall take place at a minimum of every 90 days or more often if the plan of service requires it." Each worker is observed giving care on site at least once a year, and sooner, by the next supervisory visit, when there is a concern. 245.40(c)(6)(B)
• Continuing education. Supervisors and trainers must be available to workers for updated and continuing education on their client care responsibilities. 245.71(h)
• Not billable. "Supervision does not constitute time or an activity that can be billed as a service to the client or consumer." 245.40(c)(6)(C)

Our suggestion: because a supervisor must be available at all times, name a second person for the on-call phone when the supervisor is off, and put both on your organization chart. Service plans and supervision in the start-up guide →

This role applies only if you provide Alzheimer’s disease and related dementias services, which Part 973 defines as "services offered to individuals diagnosed with Alzheimer's disease or a dementia-related disease for the purpose of managing the individual's disease". 973.100 If you do: "The entity shall designate an Alzheimer's services supervisor to oversee the entity's Alzheimer's disease and related dementias services." 973.130(b)

For an agency licensed under Part 245, the supervisor completes at least eight hours of training a year on caring for people with Alzheimer’s disease and related dementias, and meets one of two routes: 973.140(b)

Part 973 sets a different Alzheimer's services supervisor standard (12 hours of continuing education a year plus a degree or RN route, or five years' experience) for entities licensed under Parts 295 and 300, which 973.130(c) ties to assisted living and nursing homes. Agencies licensed under Part 245 follow the eight-hour standard in 973.140(b). 973.140(a); 973.130(c) The supervisor oversees your dementia services, which include a care plan for each client with a diagnosis, disclosure materials at enrollment, and 6 hours of initial and 3 hours of annual dementia training for staff with direct access to clients with dementia. 973.130(c)-(d); 973.140(c), (f) Advertising or offering dementia services that do not comply with Part 973 is prohibited. 973.130(e) CareRulebook’s manual covers the role in Policy 5.4 (Alzheimer’s disease and related dementias services) when you tell the builder you offer dementia services.

No. Part 245 does not require a home services agency to have a registered nurse, as manager, supervisor or in any other role. The RN requirement belongs to other licenses: "If the home nursing agency has appointed an agency manager who is not an RN or an APRN, the home nursing agency shall identify an RN or APRN to supervise the provision of skilled nursing services" 245.30(f)(2) Home health agencies need a full-time RN agency supervisor. 245.30(d)

A nurse can still be your manager or supervisor, but the license does not change what the agency may do: "As a non-medical service license, this license does not allow for any skilled services to be provided regardless of whether an individual is licensed or certified in their respective discipline." Form 445104, page 7 Which Illinois license fits your services →