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Heightened Scrutiny

Illinois Heightened Scrutiny Locations

The HCBS Settings Regulation describes three categories or "prongs" of residential or non-residential settings that are presumed to have the qualities of an institution, but for which states can submit evidence for the application of heightened scrutiny:

Prong 1: Settings that are located in a building that is also a publicly or privately operated facility that provides inpatient institutional treatment;

Prong 2: Settings that are in a building located on the ground of, or immediately adjacent to, a public institution; and

Prong 3: Any other settings that have the effect of isolating individuals receiving Medicaid home and community-based services (HCBS) from the broader community of individuals receiving Medicaid HCBS. 

Between 2016 and 2018, Illinois identified Heightened Scrutiny locations through provider response to self-surveys and on-site assessments conducted by State Waiver Operating Agency staff.  The State has since refined their list of Heightened Scrutiny locations to be reflective of guidance issued by Federal CMS on March 17, 2019: SMD # 19-001 Re: Home and Community-Based Settings Regulation – Heightened Scrutiny (see https://www.medicaid.gov/sites/default/files/Federal-Policy-Guidance/Downloads/smd19001.pdf). 

The following sites have been removed due to closure:

  • Advocate Health & Hospital d/b/a Advocate BroMenn Adult Day Center
  • Champaign County Nursing Adult Day Care
  • McDonough Adult Health Services
  • Midwest Medical Center d/b/a Galena-Stauss Adult Day Center
  • Gottlieb Adult Day Center
  • St. Mary's Adult Day Center


The following sites have been removed due to their withdrawal from the Supportive Living Program (SLP) waiver:

  • Lavender Ridge Dementia Care Supportive Living
  •  Saint Clare's Villa Supportive Living


The Supportive Living Program (SLP) waiver has been amended to require Elopement Risk Assessments for each individual participant and if there is no identified safety risk, the individual participant will be provided with guidance on how to circumvent the delayed egress.  As a result, the following Supportive Living sites no longer meet Prong 3 criteria and have been removed from the list:

  • Asbury Court Dementia Care
  • Asbury Gardens Dementia Care
  • Asbury of Kankakee Dementia Care
  • Cedarhurst of Quincy Dementia Care
  • Cottages at Carlinville Dementia Care
  • Cottages at Salem Dementia Care
  • Eagle's View Memory Care (formerly Katy's Cottage
  • Legacy Memory Support
  • The Pointe at Kilpatrick Dementia Care
  • Rockford Supportive Living Center Dementia Care
  • White Oaks at Heritage of South Elgin Dementia Care


The following sites have been removed from the list as the State determined these sites did not meet the three categories (or prongs) of residential or non-residential settings that are presumed to have the qualities of an institution:

  • Circle of Friends Adult Day Center
  • Friends & Family Adult Day Center


The Supportive Living Program (SLP) previously identified sites as meeting criteria for Prong 2 (on the ground of, or immediately adjacent to a public institution), but determined that these sites were actually adjacent to private institutions.  The following sites have been removed from the list:

  • Carlyle Senior Living (formerly Villa Catherine) Supportive Living
  • Castle Manor Supportive Living
  • Courtyard Estates of Canton Supportive Living
  • Courtyard Estates of Sullivan Supportive Living
  • Covenant Home of Chicago Supportive Living
  • Evergreen Place (Litchfield) Supportive Living
  • Foxes Grove Supportive Living, Oak Wood Estates Supportive Living
  • The Pointe at Kilpatrick Supportive Living
  • Prairie Crossing Supportive Living
  • Supportive Living of Wabash
  • Supportive Living of Washington
  • Vistas Fox Valley (formerly Aurora Supportive Living)

 
In March of 2021, Illinois Department of Human Services' Division of Developmental Disabilities (DDD) disseminated a Provider Self-Assessment survey to identify Prong 1 and 2 Heightened Scrutiny locations.  DDD further examined their sites through direct outreach to Provider Agencies, discussions with their Quality Assurance staff, and a mandatory Pre-Validation Survey that was made available to Provider Agencies from December of 2021 through mid-February 2022.  Through 2022 Site Validation efforts that include on-site assessments for Heightened Scrutiny locations, DDD is consolidating evidence for public and Federal CMS review.  The State will release a Public Notice once evidence for DDD Heightened Scrutiny locations has been added to this website.

Illinois Department on Aging (IDoA) is also collecting additional evidence for Cherished Place Adult Day Services (Arlington Heights).  The State will release a Public Notice once evidence for Cherished Place Adult Day Services has been added to this website.

Supportive Living Program (SLP) Heightened Scrutiny Locations

Residential Supportive Living Facilities

Prong 1:

  1. Asbury Court Supportive Living
  2. Asbury Gardens Supportive Living
  3. Evergreen Place Beardstown Supportive Living
  4. Evergreen Place Streator Supportive Living
  5. Hawthorne Inn of Clinton Supportive Living
  6. Hawthorne Inn of Freeport Supportive Living
  7. Hawthorne Inn of Princeton Supportive Living
  8. Magnolia Terrace Supportive Living
  9. Maple Point Supportive Living
  10. Park Point Supportive Living
  11. Symphony Residences of Lincoln Supportive Living

 
Prong 2: 

  1. Heritage Woods of DeKalb Supportive Living  

Illinois Department on Aging (IDoA) and Illinois Department of Human Services' Division of Rehabilitation Services (DRS) Heightened Scrutiny Locations

Non-Residential Adult Day Services Provider Sites

Prong 2: 

  1. Cherished Place Adult Day Services (Arlington Heights) 
  2. OSF Senior World Peoria Adult Day Center  



Statewide Transition Plan

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Illinois Department of Healthcare and Family Services

JB Pritzker, Governor • Theresa Eagleson, Director