May 15, 2025
On May 8 the Illinois State Board of Health met to review the draft Nurse Delegation rules which had been approved by the Illinois Department of Public Health’s Home Health, Home Service and Home Nursing Advisory Committee. The Advisory Committee amended the rules to only allow delegation to Certified Nursing Assistants (CNAs) who are also CNA2s and Medication Aides.
The Illinois Homecare and Hospice Council (IHHC) does not support this requirement. Here is the public testimony presented to voice that disagreement. We will keep you posted on next steps.
Good afternoon, Chair Karen Phelan and members of the State Board of Health.
My name is Sheila McMackin, MSW, LCSW, and I am the founder of Wellspring Personal Care, as well as a member of the Illinois Homecare and Hospice Council (IHHC). On behalf of IHHC, thank you for the opportunity to provide public comment on the proposed nurse delegation rules.
IHHC represents home care and hospice providers across the state who are committed to ensuring safe, high-quality care for Illinois residents. We appreciate the State Board of Health’s attention to nurse delegation as a way to strengthen the home-based care workforce. However, we want to express serious concerns about key aspects of the proposed delegation language.
Specifically, the requirement that tasks can only be delegated to individuals holding both a CNA2 and a medication aide certification is deeply problematic. These are new designations in Illinois and, as noted during the recent Home Health, Home Services, and Home Nursing Advisory Council meeting, they are exceedingly rare in practice.
There are three primary barriers:
- Lack of Financial Incentives: There is currently no funding mechanism to support increased compensation for individuals who obtain these advanced certifications. Without a pathway to higher wages, there is little motivation for workers to pursue these additional credentials.
- Limited Access to Training Programs: Few, if any, institutions in Illinois currently offer CNA2 or medication aide training. This makes it nearly impossible for employers to hire staff with these qualifications or to upskill their existing workforce.
- Workforce Reality: There is virtually no existing pipeline. One advisory council member noted that there are only four CNA2s in the entire state. Requiring both credentials significantly limits the potential for nurse delegation in practice and may ultimately make this rule unworkable from the outset.
IHHC strongly recommends that the State Board of Health revise the proposed rule by removing the dual-credential requirement and instead allow for delegation to certified nursing assistants. CNAs receive foundational training in areas such as patient safety, infection control, personal care, and communication, and with appropriate supervision and training by a registered nurse, they are well-positioned to safely and effectively carry out delegated tasks.
Illinois has an opportunity to improve care access for thousands of residents who depend on home-based services. We urge you not to adopt rules that, while well-intentioned, will be unimplementable due to workforce constraints. Let’s instead work together to create a practical framework that supports delegation, protects patients, and strengthens our care delivery system.
Thank you for your time and consideration.
Additional information
How Nurse Delegation Can Help Home Care Clients and Agencies