Illinois Department of Public Health Adopts Modifications Proposed by HCAOA IL Chapter

On June 23, 2023, the Illinois Department of Public Health (IDPH) proposed a First Notice of new, proposed regulatory rules to update the Home Health, Home Services, and Home Nursing Agency Code to include administrative requirements for home health and home services agencies with more than one location. Additionally, the rulemaking also sought changes to the requirements for client service plans, including required elements of the plan.

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The HCAOA Illinois Chapter leadership team, in consultation with HCAOA lobbyists David Ormsby and Andrew Kretschmar of the Nolan Group, drafted several written objections as “official comments.” Additionally, HCAOA held a virtual meeting on July 25, 2023, to review HCAOA's draft IDPH comments with HCAOA IL members and to solicit feedback. Afterwards, HCAOA IL Chapter’s comments were filed with IDPH’s rules coordinator within the required 45-day First Notice period.
 
HCAOA lobbyists met with the chair and a member of the Joint Committee on Administrative Rules (JCAR), which has the authority to accept, reject, or modify proposed state agency rules, Senator Bill Cunningham and Senator Christina Castro, to review and discuss HCAOA IL Chapter’s objections and seek their support.
 
HCAOA is pleased to announce the IDPH responded favorably to the HCAOA IL Chapter’s most important objections and substantially modified the proposed language.
 
Specifically, IDPH responded to the comments made by HCAOA as follows:
 

• DPH is keeping the term “drop site” since Medicare uses it and many home health and home nursing agencies use drop sites. An agency that does not use drop sites does not have to use this term, but it is defined and mentioned in this rule for the sake of those agencies that do use them.
• DPH clarified that the term “office” includes both parent and branch offices.
• DPH significantly revised Sec. 245.210(e) to clarify the (non-medical) services that can be included in a home services plan.

HCAOA is pleased with this positive outcome and is appreciative of Senators Cunningham and Castro for their support in this endeavor.

The rule changes can be reviewed here.