Dear CON Team,

What a first quarter this year has brought. Winter lasted a bit longer than expected, even as summer is already trying to pop up. But as spring is officially here according to the calendar, we hope the weather catches up. While spring is traditionally about new beginnings, I find myself going back to my beginnings with the State.

Despite expected changes as we review our governing laws and rules, this is a renewed commitment to continue the progress we have made and to keep building on this program. This commitment comes even with the changes to our Board membership, from losing members Antonette Waller and David Katz last year, to Dr. Audrey Tanksley resignation this year. All three made an incredible impact during their tenure. Their legacy will have lasting effects on the remaining Board and staff, and we will have to work hard to continue to meet the bar set by these three industry leaders. All of the Board members I have worked with since joining the State have not only been knowledgeable about their spheres of the health care delivery system but have been open to learning and pushing the industry—and us, as staff—to do better. On behalf of the Board and Board staff, thank you for your service. Your insight and perspectives will be missed.

We continue to work through this year’s legislative session, with the ultimate goal of making the statutes and rules better and more reflective of today's healthcare landscape.

We have also worked diligently on our pending rulemaking on the Cardiac Catheterization category of service is promulgated. We are always looking for ways to improve our regulatory and legislative mandates, but we cannot do this without our partners in the health care industry. Please do not hesitate to reach out to me or Don Jones—we welcome your thoughts and look forward to continued discussion on moving health care for all Illinoisians forward.

Let’s plan together.

Sincerely yours,

John P. Kniery

PS: Let’s go Cubbies!!

 

Monica Hendrickson has served on the Health Facilities & Services Review Board since 2022. She currently serves as the Administrator at Peoria County Health Department.

Monica approaches her work on the Board with a public health background and perspective. She has spent most of her career serving in local health departments throughout central Illinois, in health protection, emergency preparedness, epidemiology, and administrative roles. 

Monica brings awareness of the complexity of healthcare access, as well as, an understanding that an individual's health is not defined by quality.

Highlighted Application Content

Project Fees - Keys Reminders

For projects received before July 1, 2025: The old fee scale applies for the following post-permit transactions:

Extension of Financial Commitment: $500.00. An additional $500 late fee applies for an extension request received 45 days prior to the project completion date (untimely).

Permit Renewal: $500.00. An additional $500 late fee applies for an extension request received 45 days prior to the project completion date (untimely).



Permit Alteration: $1,000. An additional $500 late fee applies for an extension request received 45 days prior to the project completion date (untimely). Permit Alterations that increase total project cost will have its fee reassessed using the new project cost amount, and Applicants pays the difference in fees not to exceed $50,000.



Relinquishment of Permit or Exemption: All requests for Relinquishment are assessed at a fee of $1,000.  Any relinquishment undertaken without prior Board approval shall be considered a violation of the Act and shall be subject to sanctions/penalties

For project received after July 1, 2025, the fees for Certificate of Need Transactions increased to the following amounts: (per IL Adm 77 1130.230)

1130.230 (1): Exemption Fees

·      Exemption Other than Change of Ownership: $5,000 (1130.230(1)(a))

·      Change of Ownership Exemption between related persons: $5,000 (1130.230(1)(b)

·      All other Exemption applications for Change of Ownership: The greater of $5,000, or .22% of the Fair Market Value of the transaction. (1130.230(1)(c))

1130.230(2): Certificate of Need (CON) Application Fees

·      Projects with costs less than $2,250,000: $5,000. (1130.230(2)(b)(i))

·      Projects with costs that exceed $2,250,000: .22% of the total project costs (minus the initial application fee of $5,000, if submitted (1130.230(2)(b)(ii)

1130.230(3): Modification of an Application

·      If modification increases the initial project fee, then the fee shall be the difference between the old fee and the newly modified fee (1130.230(3)(a)

·      If the modification requires an additional public notification/opportunity for a public hearing (Type B modification): $4,000. (1130.230(3)(b)

1130.230(4): Extension of Financial Commitment

·      Financial Commitment Extension Requests submitted 45 days before Financial Commitment date: $1,000.  (1130.230(4)(a)

·      Financial Commitment Extension Requests submitted within 45 days of Financial Commitment date: $1,000 + $500 late fee.  (1130.230(4)(b)

1130.230(5): Permit Renewal

·      Permit Renewal Requests submitted 45 days before Project Completion date: $1,000.  (1130.230(5)(a)

·      Permit Renewal Requests submitted within 45 days of Project Completion date: $1,000 + $500 late fee.  (1130.230(5)(b)

1130.230(6): Permit Alterations

·      Permit Alteration Requests submitted 45 days before Project Completion date: $1,000.  (1130.230(6)(a). (Alteration does not result in increased project costs).

·      Permit Alterations that increase total project cost will have its fee reassessed using the new project cost amount, and Applicants pays the difference in fees not to exceed $50,000. (1130.230(5)(a)

·      Permit Alteration Requests submitted 45 days before Project Completion date: An additional $500.00 late fee.  (1130.230(5)(a)

1130.230(7) Relinquishment of Permit or Exemption

·      All requests for Relinquishment are assessed at a fee of $1,000. (1130.230(7)(b).

·      Any relinquishment undertaken without prior Board approval shall be considered a violation of the Act and shall be subject to sanctions/penalties (1130.230(7)(a)

Rulemaking Updates

During the Spring 2026 legislative session, the Illinois General Assembly is considering several bills that would affect HFSRB, including:

House Bill 1325. Amends the Planning Act and mandates HFSRB to establish a trauma center between the communities of Calumet City and Dolton. Once established, HFSRB would select a provider to operate the trauma center and determine the sources of revenue needed to maintain the center.

House Bill 3674. Amends the Planning Act and requires HFSRB to include a definition of “Professional Services Expenditures” and that hospitals must report spending goals for professional service expenditures in conjunction with reporting capital expenditure information to HFSRB.

House Bill 5022. Amends the Birth Center Licensing Act to state that a Birth Center cannot provide surgery except as allowed by the Illinois Department of Public Health. Would allow Birth Centers to provide “reproductive health care” including pregnancy prevention, pregnancy termination, improving maternal health, contraception, sterilization, preconception care, and counseling regarding reproductive health care.

Senate Bill 3239. Amends the Planning Act to allow HFSRB to review applicable criteria in consideration of any application for an exemption (COE). The bill proposes changes regarding administrative hearings, the powers and duties of HFSRB and review and investigation of applications for permits. The bill would also remove the requirement that legal notices for applications be published in newspapers. House Bill 4757 is the companion bill.

The Strategic Benefits of Proactively Requesting a Public Hearing 

The administrative rules governing the Certificate of Need (“CON”) and Certificate of Exemption (“COE”) application process can also serve as a practical procedural tool to strengthen the administrative record and support informed review by the Board. One such tool is the proactive request for a public hearing.

Historically, public hearings have been associated only with contested or high-profile projects and have been conducted at the request of a party opposing a proposed project. However, an applicant’s foresight in requesting a public hearing can offer significant strategic benefits. When used proactively, a public hearing can provide a comprehensive administrative record, ensure transparency, and inform the affected community early in the process to avoid misunderstandings later.

Public hearings provide an opportunity for applicants to supplement written documentation with live testimony and supporting statements that further explain the project’s purpose, need, and anticipated impact in the community.

Another benefit of proactively requesting a public hearing is that it may also help identify and address questions and/or concerns ahead of the Board’s consideration. For example, testimony from health care facility executive leadership, clinicians, planners, financial officers, and/or CON consultants may clarify issues about the proposed project’s utilization projections, need for the project, patient demand, impact on the surrounding facilities, or the scope of the project. Addressing such issues early reduces the possibility of concerns or uncertainty during the deliberation phase.

Perhaps most notably, public hearings provide an appropriate forum for all stakeholders to express their support and the anticipated public benefit of the proposed project. Applicants should promote attendance at a public hearing as a place for local officials, community organizations, health care providers, and residents of the impacted community to provide testimony concerning:

• accessibility to services,
• existing service gaps,
• meeting the need for services and population changes,
• equity in patient care, and
• the project’s anticipated impact on addressing concerns regarding patient care in the area.

Voluntarily requesting a public hearing, encouraging attendance by all stakeholders, and providing as much information as possible about a proposed project early in the process not only ensures transparency but also builds trust between the applicant and the affected community. Public hearings offer an opportunity for community engagement and meaningful dialogue in what will be a long-term relationship between the applicant and its prospective patients.

A public hearing under 77 Ill. Adm. Code 1130 should not be viewed as an adversarial tool or a mere procedural mechanism. Rather, a proactive request for a public hearing and commitment to openness may enhance the quality of a CON or COE application and furnish the Board with a more comprehensive record for review and consideration.



Applicants should weigh the benefits of requesting a public hearing during application preparation, especially in situations where a project is expected to generate community interest, involves substantial changes to an existing facility or to access to services, or would benefit from testimony that clarifies complex operational or financial decisions for stakeholders. 

For information on the deadlines associated with pending projects, please make sure to check out the "Project Search" tab on the HFSRB website by clicking here



Access information about the Certificate of Need process and Application materials by clicking here