Illinois Public Health Department Issues Proposed Updates for Branch Offices, Drop Sites, and More Affecting In-Home Care

​Last week, IDPH released proposed rulemaking updates for the Home Health, Home Services, and Home Nursing Agency Code to include requirements for home health and home services agencies with more than one location. The proposed rules impact branch offices, drop-sites, parent agencies, service plans, and service contracts.

According to IDPH, the proposed amendments are consistent with current industry standards in other states and CMS home health regulations regarding branch office locations. The rulemaking provides clarifications and adds new terms in Section 245.20 (Definitions) related to branch offices – drop-site, parent agency, service plan, and service contract. Click here to view the rules, which begin on p. 8817.
 
The rulemaking also clarifies a few operational requirements including that agencies maintain an office with a working telephone that is staffed during business hours. Additionally, the rulemaking adds a requirement that agencies adopt and enforce written policies to identify the agency's operating hours including a provision that ensures clients are provided information regarding procedures for accessing care from the agency or another health care provider outside of operating hours.
 
Further, the rulemaking updates licensure requirements regarding notification to the Department prior to closure of the agency, including the closure of any branch office and adds a requirement that the licensee shall notify the Department within 10 days after any change to certain information about the agency. The rule also adds requirements related to branch offices and drop sites to ensure consistency in compliance and enforcement.
 
IDPH is seeking public comments, due 45 days from the rule’s release date of June 23. The HCAOA Illinois Chapter is reviewing the impact of these rules, and will submit comments on behalf of members. Please share any thoughts with Eric Reinarman, HCAOA VP Government Relations at eric@hcaoa.org.