DDD Staffing Crisis Flexibilities Q & A

Illinois Department of Human Services Division of Developmental Disabilities (IDHS DDD)

October 2021

The Division understands there is a continued nationwide staffing crisis impacting providers which is leading not only to provider fatigue and stress but also reduced capacity, closures and consolidations. The Division has created the following Q & A to help providers understand current flexibilities under existing regulatory requirements. 

  1. Residential DSP
  2. QIDP
  3. RN Trainer
  4. Staffing

**Denotes items that are NEW regulatory flexibilities that will be ongoing.

Residential DSP

1. I would like to be able to hire staff that do not have a high school diploma or GED? 

DDD Response: This is currently allowed in our residential settings under our waiver. Residential DSPs have to meet the following educational requirements:

  • Must be age 16 or older.
  • Must have completed eight years of grade school or provide proof of ability to read at an 8th grade level.
  • Transcripts or the TABE can be used to determine an 8th grade reading level. This equates to 26 of the 47 questions correct on paper TABE 11.

The high school diploma/GED requirement is needed for the residential DSP to pass medication under Rule 116. A provider can hire individuals older than 16 without a diploma or GED to work with, and support, individuals but they could not pass medication.

2. Would I be able to hire a staff who has a high school diploma but hasn't had it translated?

DDD Response: While they could not pass medication per Rule 116, they could work as a residential DSP if they met the other requirements as outlined above. They could work as a DSP, and not pass medication, until their transcripts are translated by a qualified vendor.

3. I have a DSP candidate that is enrolled in an accredited college. Do I need to get a copy of the high school diploma or GED?**

DDD Response: Transcripts illustrating enrollment in a degree program, either an Associate's Degree or a Bachelor's Decree, at a U.S. Department of Education accredited 2 or 4-year college or university is deemed by the Division of Developmental Disabilities to have met the requirement for a high school diploma. The provider should keep a copy of the transcripts in the employee file for potential review.

4. Can I ask volunteers to do work as residential DSPs?

DDD Response: Volunteers can work as DSPs as long as all DSP educational, training and background check requirements are still met.

5. Do CNAs have to complete the full DSP training?

DDD Response: No, the Division takes into account their CNA training. CNAs only need to take the 3-hour Abuse & Neglect course and the associated OJT.

6. I have a DSP candidate that worked as a DSP in another state. Do they have to complete the full DSP training?**

DDD Response: The DDD Bureau of Quality Enhancement (QE) will review provider requests on a case by case basis, with the exception of Abuse & Neglect that must be completed from the Illinois DSP training. Providers should ask the DSP for a copy of the training they completed in the other State and proof of completion. The provider should then map how the current training tracks with the Illinois DSP training. The provider should then send this mapping to BQM QE who will approve specific trainings at DHS.BQM@illinois.gov. Any trainings that do not transfer will be required to be completed. In addition, this does not relieve the provider of providing appropriate OJT.

7. Can I hire temp staff to work at my organization?

DDD Response: Yes, you can hire temporary staff to work at your organization. All staff would still be required to meet educational, training and background check requirements. Temp agencies may be more likely to be able to provide CNAs and RN Trainers, although some provide DSPs. Providers would need to contact individual temp staffing agencies.

8. Can DSP training be done virtually to allow more flexibility in completing training requirements? 

DDD Response: The following online training programs have been approved as meeting all DSP classroom training requirements and can be completed online:


1. Can more degrees be considered for QIDP qualification? Currently, only degrees in sociology, special education, rehabilitation counseling, and psychology are permitted. 

DDD Response: While those degrees are explicitly listed, they are not the only degrees accepted. DDD will review transcripts to determine if potential QIDPs have 30 semester hours in human services. If so, they may meet the educational requirement to become a QIDP.

2. Can I contract with another agency to provide QIDP training for my agency?

DDD Response: Yes, providers often collaborate to share training departments and, in particular, for QIDP training.

RN Trainer

1. How many years of experience does an RN Trainer have to have in order to be hired?

DDD Response: Rule 116 requires an RN to have one year of experience. It was previously 2 years. This is something we will review as part of our Rule 116 review process.

2. Can I share an RN Trainer with another organization?

DDD Response: The requirement is that providers have access to an RN Trainer 24/7 for any medication administration management needs. It is also a requirement that the RN Trainer has reviewed and signed the nursing assessments for the individuals within the agency for which they are providing the support. There is no reason an agency could not share an RN Trainer with another organization.


1. Can I ask my staff to work 12-hour shifts, long weekend shifts or overtime? Can I ask DSPs to rotate and shift across homes during shifts?

DDD Response: There is nothing in Rule, Statute or Waiver that prohibits an agency directing the work schedules of their DSPs. These are business decisions that providers must make in accordance with local labor and employment laws and any controlling bargaining unit agreements. In cases where providers are extremely short staffed it might make sense to have DSPs rotate between homes to help during high need periods or to extend shifts, again complying with labor and employment laws.

2. Can I ask families to take home individuals on a short-term basis during a staffing crisis?

DDD Response: Providers cannot require families to remove individuals from the CILAs as they are their homes. Families are able to take individuals to the families' homes on a short-term basis if the individual and the family agree, which may be an appropriate option during a true staffing crisis.

3. In a severe staffing crisis, are there other temporary, family-based options that should be considered?

DDD Response: In a severe staffing crisis a provider could work with the individual, family, and Independent Service Coordination (ISC) agency to see if Family CILA or Home-Based Support Services might be an option for a determined period of time. The family could provide day to day care and supervision, with reduced support from the provider organization. The individual could return to 24-hour CILA at a point in the future.

4. Can I consolidate my homes to make them larger to reduce staffing needs?

DDD Response: Homes may be consolidated due to staffing shortages. Consolidation may not exceed the maximum number of the licensed capacity for the home. Providers should work with the ISC agency and the individuals and their families to discuss this prior to moving individuals. Individuals also have a right to change service providers or homes if they do not want to live in a larger home. The Division should be notified, and a Turnaround form should be created and submitted.

5. What other options should I consider to reduce staffing demands?

DDD Response: Providers, with support from the ISC agency, could explore two models that may create more independence for individuals, while decreasing staffing demands.

  • Intermittent CILA
    • Providers and ISC agencies, in conjunction with the individual, should continually assess individuals for their ability to live in a less restrictive environment. It's possible that individuals who are currently receiving 24-hour supports would be safely served with intermittent staffing support.
  • Remote Supports
    • Providers and ISC agencies, in conjunction with the individual, should assess an individual's ability to use remote supports as an alternative to staff. This creates more independence for the individual and less reliance on direct staff support. This is a billable service for all CILA environments in our Adults with DD waiver.

The information contained herein should not be considered a substitute for the appropriate official statutes, rules, regulations, or the advice of legal counsel.