Illinois · Home health vs home care · 210 ILCS 55

Illinois home health vs home care license

Illinois has five licenses for agencies that work in people’s homes, all issued by IDPH under one Act: home services, home nursing, home health, and two kinds of placement agency. Here is what each one allows, what IDPH charges, where Medicare and the 2026 moratorium fit in, and which license matches what you plan to do.

Side by side Which license matches your plan?

Rule-verified October 1, 2026
Quoted from 210 ILCS 55 and 77 Ill. Adm. Code 245
CMS moratorium memo QSO-26-11

Four manila folders on a wooden table labelled Home services, Home nursing, Home health and Placement, with a sticky note reading One application and fee per license, beside a CareRulebook binder

Quick answer

Illinois licenses in-home agencies under one law, the Home Health, Home Services, and Home Nursing Agency Licensing Act, with a separate license for each kind. What most people call home care is a home services agency: help with daily living, housekeeping, laundry and companionship, with nothing that would need a licensed nurse. A home nursing agency provides services that need a licensed nurse. A home health agency provides skilled nursing and at least one other home health service, such as therapy or home health aide services, under a plan of treatment. Two placement licenses cover agencies that place workers or nurses whom clients hire themselves.

IDPH issues all five, and one entity can hold them "singly or in any combination", with a completed application and fee for each. 245.90(f) IDPH FAQ

Medicare is a separate step. A licensed home health agency may be eligible for Medicare, but CMS halted Medicare enrollment of new home health agencies nationwide from May 13, 2026. That pause is about federal enrollment, not the state licenses (our reading of QSO-26-11).

Rule-verified, checked against official sources on October 1, 2026

Side by side

Part 245 puts it plainly: "Health care and support services are provided in the consumer's home by three basic types of agencies: home health care, home nursing care, and home support services." Each has its own rules, set out below. 245.10(c)

	Home services (home care)	Home nursing	Home health
What it covers	Help with activities of daily living, housekeeping, personal laundry and companionship. Nothing that would need a licensed nurse. 210 ILCS 55/2.09	Services that need someone licensed under the Nurse Practice Act, on a shift, one-time, full-time, part-time or intermittent basis. 77 Ill. Adm. Code 245.20	Skilled nursing plus at least one other home health service: therapy, medical social services or home health aide services. 210 ILCS 55/2.05
Who gives the care	Home services workers the agency trains and checks for competency before their first assignment. 77 Ill. Adm. Code 245.71(c)	Nurses, with any home health aides working under an RN. If the manager is the nursing supervisor, another nurse gives the direct care. 77 Ill. Adm. Code 245.205(a)	Agency staff give basic skilled nursing directly; other services may be contracted. 77 Ill. Adm. Code 245.200(a)
Plan	A service plan made with the client. No physician signature is needed. 77 Ill. Adm. Code 245.210(f)	A plan of treatment from the client’s health care professional, written within 30 days and signed within 45 days after acceptance. 77 Ill. Adm. Code 245.205(d)(1), (f)(1)	A plan of treatment written within 14 days after acceptance and signed within 30 days after the start of care, reviewed every 60 days. 77 Ill. Adm. Code 245.200(d)(1), (f)(1)
Who leads	An agency manager designated to supervise services. The rule sets no degree or license for the role. 77 Ill. Adm. Code 245.30(f)(1)	If the agency manager is not an RN or APRN, an RN or APRN supervises skilled nursing. 77 Ill. Adm. Code 245.30(f)(2)	A qualified administrator and a separate full-time RN agency supervisor. 77 Ill. Adm. Code 245.30(d)(2), (3), (5)
Supervisory visits	On site at least every 90 days, and each worker observed giving care at least once a year. 77 Ill. Adm. Code 245.40(c)(6)(B)	For home health aides: an RN visit at least every 60 days. 77 Ill. Adm. Code 245.40(b)(4)	For home health aides: an RN or therapist visit at least every two weeks. 77 Ill. Adm. Code 245.40(b)(3)
Records kept	At least two years after the last date of service. 77 Ill. Adm. Code 245.210(i)	At least five years after the last date of service. 77 Ill. Adm. Code 245.200(h)(2); 245.205(g)(2)	At least five years after the last date of service. 77 Ill. Adm. Code 245.200(h)(2); 245.205(g)(2)
IDPH license fee	$1,500 a year. Form 445104, page 1	Up to $1,500 a year. 77 Ill. Adm. Code 245.95(b)	$1,500 for a two-year license. 210 ILCS 55/4(c)
Medicare	IDPH says this license covers private pay and private insurance clients. FAQ, client payor sources	Part 245 mentions Medicare eligibility for home health agencies only. 77 Ill. Adm. Code 245.10(b)	A licensed agency may be eligible for Medicare, but new enrollment is paused nationwide from May 13, 2026. 77 Ill. Adm. Code 245.10(b) QSO-26-11, Memorandum Summary

Fees are IDPH’s, paid to the state, and separate from any CareRulebook price. Home health also uses its own IDPH application and qualification forms for the administrator, supervisor and social worker. IDPH Home Health Agencies page (archived May 21, 2026)

The rule that draws the line for a home services agency: "A home services agency shall not provide medical services that would be performed by an agency licensed as a home health agency or home nursing agency." 245.210(d)(1) Skilled nursing covers, among other things, "the administration of medications and treatments; and the coordination or management of a nursing or medical plan of care". 245.20 The Illinois start-up guide lists what home services workers may and may not do, task by task.

Placement agencies: matching, not employing

A placement agency finds work for workers or workers for clients. In Illinois the client becomes the employer, and the agency steps back after the placement.

IDPH fee $500 a year

Home services placement agency

A home services placement agency is not the worker's employer. After placement it cannot control the worker's assignments or duties, help the client pay the worker, or manage the client's needs on an ongoing basis. A placement contract lasts no longer than 12 months, and the placement agency may charge only a one-time placement fee (payable in installments during the contract).

IDPH adds: "A Home Service Placement agency must be dually licensed by the Illinois Department of Labor as a Private Employment Agency (PEA)."

245.214(a)IDPH placement page (archived June 15, 2026)Placement application, page 1

IDPH fee up to $500 a year

Home nursing placement agency

A home nursing placement agency is not the employer of the nurses it places. The nurse performs services ordered by the client's physician, without direction, control or supervision by the placement agency. The same 12-month contract limit and one-time placement fee apply.

245.212(a)245.95(c)

Holding a placement license alongside the matching agency license (home services with home services placement, or home nursing with home nursing placement) is allowed, but the rule says you "shall operate each licensed agency as a separate entity to meet the requirements of the Act and this Part as an employer of workers and as a placement agency that places individuals". 245.95(e)

Which license matches your plan

A decision aid we built from the definitions, not legal advice. IDPH’s own first step for applicants is to read Parts 245, 955 and 973 "to determine which license(s) reflects the services the agency plans to provide". IDPH FAQ (archived March 21, 2026)

If you plan to offer	The license that matches	IDPH fee	Source
Companionship, housekeeping, laundry, meals, errands and hands-on help with daily activities such as bathing and dressing, by caregivers you employ	Home services agency	$1,500 a year	210 ILCS 55/2.09
Matching caregivers with families who hire and direct them	Home services placement agency, plus a private employment agency license from the Illinois Department of Labor	$500 a year	IDPH placement page Placement application
Nursing in the home, such as giving medications and treatments, by RNs or LPNs on shifts or visits	Home nursing agency	Up to $1,500 a year	245.20 245.95(b)
Skilled nursing plus therapy, medical social services or home health aide services under a plan of treatment, with the aim of billing Medicare	Home health agency, then Medicare certification (paused for new agencies, see below)	$1,500 for 2 years	210 ILCS 55/2.04 245.10(b)
Placing nurses with clients who employ them, to work to the client’s physician’s orders	Home nursing placement agency	Up to $500 a year	245.212(a)245.95(c)
Both non-medical care and nursing	Two licenses, with an application and fee for each. With home services and home nursing, two separate client contracts.	Each license’s fee	IDPH FAQ 245.220
Serving only clients of the Community Care Program, the DHS Office of Rehabilitation Services or the VA	Not a home services agency under the Act	Not applicable	210 ILCS 55/2.08

If your plan is non-medical care, the license check on the Illinois guide asks what your business will do and points you to the right license. If you are unsure where a service falls, IDPH answers application questions on 217-782-7412. Form 445104, page 1

National · In force from May 13, 2026

Medicare certification and the 2026 moratorium

Part 245 says "Home health agencies licensed under the Act and this Part may be eligible for participation in the federal Medicare program" under CMS’s rules. 245.10(b) IDPH’s home health page links to guidance on "How to Become Medicare Certified". IDPH Home Health Agencies page (archived May 21, 2026)

For new agencies, Medicare enrollment is paused nationwide: "Effective May 13, 2026, CMS will halt the enrollment of new Hospice and HHA providers or HHA branch or practice locations." CMS, QSO-26-11

The moratorium lasts six months and can be extended for further six-month periods. Any extension or lifting is announced in the Federal Register. The first six months run to about November 13, 2026, by our count. QSO-26-11
"CMS regulations do not permit exceptions to a moratorium for individual providers or suppliers." QSO-26-11
Applications that Medicare contractors received before May 13, 2026 continue to be processed. Initial applications submitted during the moratorium are denied and must be resubmitted once it is lifted. QSO-26-11
During the moratorium, accreditation of a prospective home health agency by a CMS-approved accrediting organization does not lead to Medicare participation through deemed status. QSO-26-11
The moratorium affects new enrollments, not the ongoing compliance obligations of existing Medicare-certified agencies. QSO-26-11

What it does not do, by our reading: QSO-26-11 is about enrollment. It says nothing about state licensing, so it does not stop IDPH licensing a home health agency, and it does not touch a home services agency, which provides non-medical services and is not a Medicare home health agency.

Its instructions speak of Medicare enrollment applications. Its background adds that CMS announced the moratoria under its authority to fight fraud, waste and abuse in Medicare, Medicaid and CHIP, without saying how that applies to Medicaid enrollment in Illinois. If you plan to bill Medicaid for home health, check with the state Medicaid program. QSO-26-11, page 1

No certificate of need stands in the way either, by our reading: Illinois’ Health Facilities Planning Act applies to the health care facilities it lists, such as hospitals, ambulatory surgical treatment centers, long-term care facilities and kidney disease treatment centers, and home health agencies are not on the list. 20 ILCS 3960/3

Medicaid and the Community Care Program

Asked which client payor sources a home services license can accept, IDPH answers: "Private pay (out of pocket) or private insurance (HMO, PPO). Medicaid clients are through the Illinois Department on Aging (Community Care Program) or the Illinois Department of Human Services Division of Rehabilitation Services." It tells agencies to contact those departments directly for approval to serve those clients. IDPH FAQ (archived March 21, 2026)

What the Community Care Program buys. "In-home service is defined as general non-medical support by supervised homecare aides who have received specialized training in the provision of in-home services." 89 Ill. Adm. Code 240.210
How the two connect. The Department on Aging may accept an IDPH home services license as documentation for some of its own provider requirements. 89 Ill. Adm. Code 240.1505(c)
Program-only providers. A program serving clients only through the Community Care Program, the DHS Office of Rehabilitation Services or the VA is not a home services agency under the Act. 210 ILCS 55/2.08

This page does not cover how the Department on Aging or DHS approve providers. Ask them directly, as IDPH suggests.

CareRulebook

Starting with home services? Your policies come first.

CareRulebook writes the Illinois policies IDPH reviews with a home services application, with your agency’s details filled in and the rule quoted under every policy. It covers home services agencies, not home nursing or home health.

37 policies, 113 rule requirements mapped
Worker tasks, medication reminding and supervision rules built in
Editable Word and PDF, delivered instantly

Preview your manual

$199CareRulebook founding price for the first 50 Illinois agencies, then $249. Not an IDPH fee.

Myths

Is Illinois closed to new home health agencies in 2026?

It depends. Not to the state license: IDPH licenses home health agencies under the Act ($1,500 for two years), and Illinois' certificate of need law does not list home health agencies (our reading). What is paused is Medicare: from May 13, 2026, CMS halted Medicare enrollment of new home health agencies nationwide for six months, which it can extend, with no exceptions for individual providers.

"Effective May 13, 2026, CMS will halt the enrollment of new Hospice and HHA providers or HHA branch or practice locations."
QSO-26-11-HHA & Hospice: Six-Month National Moratoria on Hospice and Home Health Agency Enrollment (May 20, 2026), QSO-26-11, Memorandum Summary

If a nurse owns an Illinois home services agency, can its staff give medications or nursing care?

No. IDPH's application says the home services license allows no skilled services, even when the worker is licensed or certified. Workers may remind clients to take medications from pre-filled minders, but must not set up medications. Nursing needs a home nursing or home health agency license.

"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."
Home Services Application, Form 445104 (Initial, Renewal and Change of Ownership; archived copy of March 21, 2026), Form 445104, page 7

Can an Illinois placement agency (registry) supervise and schedule the caregivers it places?

No. A home services placement agency is not the worker's employer. After placement it cannot control the worker's assignments or duties, help the client pay the worker, or manage the client's care on an ongoing basis. If you want to schedule and supervise caregivers, you need a home services agency license.

"Following the placement of the worker with the client, the placement agency shall not have any control of the worker's assignments or duties, or assist the client in the payment of the worker."
77 Ill. Adm. Code 245, Home Health, Home Services, and Home Nursing Agency Code (current through 50 Ill. Reg. 2147, effective January 30, 2026), 77 Ill. Adm. Code 245.214(a)

Is an Illinois home services license good for two years?

No. A home services agency license lasts one year and costs $1,500. The two-year, $1,500 license is for home health agencies. File each renewal 60 to 90 days before the license expires.

"Each license shall be for a term of one year and shall expire one year from the date of issuance."
77 Ill. Adm. Code 245, Home Health, Home Services, and Home Nursing Agency Code (current through 50 Ill. Reg. 2147, effective January 30, 2026), 77 Ill. Adm. Code 245.80(e)

Frequently asked questions

What is the difference between home health and home care in Illinois?

Illinois calls non-medical home care "home services": help with activities of daily living, housekeeping, personal laundry and companionship, with nothing that would need a licensed nurse. A home health agency provides skilled nursing and at least one other home health service, such as physical, occupational or speech therapy, medical social services or home health aide services, under a plan of treatment prescribed by a physician, physician assistant or APRN. Between them sits the home nursing agency, which provides services that need a licensed nurse. IDPH licenses all three separately under the same Act.

Does an Illinois home services agency need a nurse?

No. A home services agency designates a person to supervise services, and the rule sets no degree or license for that role. An RN or APRN supervisor is required for a home nursing agency whose manager is not one, and a home health agency needs a full-time RN agency supervisor. Those are different licenses.

Can my home services caregivers do nursing tasks if they are CNAs or nurses?

No. IDPH’s application says the home services license does not allow any skilled services, regardless of whether the worker is licensed or certified. Workers may remind clients to take medications from pre-filled minders, but must not set up medications. Nursing work needs a home nursing or home health agency license.

Do I need a certificate of need for home health in Illinois?

Illinois’ certificate of need law, the Health Facilities Planning Act (20 ILCS 3960), applies to the health care facilities it lists, such as hospitals, ambulatory surgical treatment centers, long-term care facilities and kidney disease treatment centers. Home health, home nursing and home services agencies are not on that list, by our reading of the definition. If your plan depends on it, confirm with the Health Facilities and Services Review Board, which the Act sets up.

Can I start a Medicare home health agency in Illinois in 2026?

You can apply to IDPH for a home health agency license; the moratorium does not change Illinois licensing, by our reading. Medicare is the obstacle: CMS halted Medicare enrollment of new home health agencies nationwide from May 13, 2026, for six months, which it can extend, with no exceptions for individual providers. Initial enrollment applications submitted during the moratorium are denied and must be resubmitted after it is lifted, and accreditation does not get around it.

Can one company hold more than one Illinois license?

Yes. An entity that meets the requirements can hold the licenses singly or in any combination, with a completed application and fee for each. An agency with both home services and home nursing licenses keeps two separate client contracts, one for skilled medical care and one for non-medical services. An entity with both a home services agency license and a home services placement license (or a home nursing agency license and a home nursing placement license) runs each as a separate entity: one as the employer, one as the placement agency.

Know when this changes

We watch Part 245, the Illinois licensing Act and the CMS home health moratorium. Leave your email and we will tell you when an Illinois rule or fee changes, or when CMS extends or lifts the moratorium.

No spam. Only emails about Illinois rule changes and the CMS moratorium. How we use your email.

Keep reading

Illinois

How to start a home care agency in Illinois

The home services license, the policies IDPH reviews, training and supervision.

Illinois

Illinois license cost and timeline

The $1,500 IDPH fee, the 240-day provisional license and renewal.

Illinois

Illinois office and premises rules

The staffed office, records, branch offices, drop sites and your service area.

Texas

Texas home health vs home care

One HCSSA license with separate service categories.

Georgia

Georgia home health vs home care

Two licenses there, and a Certificate of Need for home health.

North Carolina

North Carolina home health vs home care

Three licenses there, and a Certificate of Need for Medicare-certified home health.

Virginia

Virginia home health vs home care

One HCO license covers both, with no Certificate of Public Need.

Sources

77 Ill. Adm. Code 245, Home Health, Home Services, and Home Nursing Agency Code (current through 50 Ill. Reg. 2147, effective January 30, 2026) · Illinois Department of Public Health (Illinois Administrative Code, Joint Committee on Administrative Rules, ilga.gov) · retrieved October 1, 2026
Home Health, Home Services, and Home Nursing Agency Licensing Act (210 ILCS 55) · Illinois General Assembly (Illinois Compiled Statutes, ilga.gov) · retrieved October 1, 2026
89 Ill. Adm. Code 240, Community Care Program · Illinois Department on Aging (Illinois Administrative Code, ilga.gov) · retrieved October 1, 2026
Home Services Agencies Frequently Asked Questions (archived copy of March 21, 2026) · Illinois Department of Public Health · retrieved October 1, 2026
Home Services/Home Nursing Placement (archived copy of June 15, 2026) · Illinois Department of Public Health · retrieved October 1, 2026
Home Health Agencies (archived copy of May 21, 2026) · Illinois Department of Public Health · retrieved October 1, 2026
Home Services Application, Form 445104 (Initial, Renewal and Change of Ownership; archived copy of March 21, 2026) · Illinois Department of Public Health · retrieved October 1, 2026
Home Services Placement Initial, Renewal and Change of Ownership Application (archived copy of March 21, 2026) · Illinois Department of Public Health · retrieved October 1, 2026
QSO-26-11-HHA & Hospice: Six-Month National Moratoria on Hospice and Home Health Agency Enrollment (May 20, 2026) · Centers for Medicare & Medicaid Services · retrieved October 1, 2026
Illinois Health Facilities Planning Act (20 ILCS 3960) · Illinois General Assembly (Illinois Compiled Statutes, ilga.gov) · retrieved October 1, 2026

Build your Illinois manualfrom $199