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Transforming Child Care Licensing in Illinois: Background Check Reform

Policy Manager Mercedes Mondragón continues our blog series on Illinois’ current child care licensing system and our recommendations for improvements.

Mercedes Mondragón January 26, 2026
  • Policy and Systems
  • Blog
  • Resource

During the first phase of IDEC’s child care licensing transformation plan, the Department spent months obtaining input from providers and families to better understand the major concerns within our licensing system. IDEC grouped the results from stakeholder engagement into 4 focus areas: background checks, exemptions, external communication and training and support for day care licensing representatives. Now that stakeholder engagement has wrapped up, IDEC is shifting its attention to concerns raised regarding the background check process and exemptions during phase 2 of the transformation work. Below we will explore these proposed changes.

Background Checks

  • Linking background checks to individuals: Currently, background check results are tied to employers rather than the individual. This structure requires individuals to have a conditional offer of employment at a program site before they may begin the background check process. Furthermore, our current process also does not allow prospective staff to apply for employment at multiple sites before deciding which program would be the best fit for them. IDEC is proposing linking background check results to the individual applicant, which should provide prospective staff additional employment flexibility and allow them to begin the background check process earlier in their job search.
  • IDEC to issue background check employment decisions: In our current system, a series of criminal offenses bar prospective employees from working with young children. However, aside from those offenses, directors have leeway to interpret any other offenses that appear on an applicant’s background check results and decide whether to offer employment to the applicant. Under the proposed system, IDEC will make a final determination on all offenses and ultimately issue clearances to work at a site to ensure consistency across the state.

Start Early applauds IDEC for taking these long-awaited steps to improve the functionality of our background check process. Yet, it remains unclear what steps the department will take to reduce the weeks-long delay in the processing of background checks. We ask the department to take a deeper look at ways to expedite and streamline background check processing and tracking, like creating an online portal, so prospective employees and directors are not left to wait several weeks for updates or results.

Exemptions

Providers have raised concerns that our current exemption process is vague and the administrative rule is convoluted. IDEC is proposing a different framework to think of licensing requirements on a spectrum, based on the level of agency oversight required by the program and whether Child Care Assistance Program (CCAP) payments are accepted.

 

Level of Oversight

No Oversight (Exempt)

Child Care that operates without any licensing or regulatory oversight; no reporting or compliance obligations are required

Oversight by Other Agency (Non-IDEC Oversight)

Programs that are exempt from IDEC licensure but must comply with requirements or reporting from another regulatory agency

Partial Oversight by IDEC (Alternative licensure)

Programs that do not require full licensure but must meet some IDEC requirements

Full Oversight by IDEC (Full licensure)

Programs that require complete licensing and ongoing compliance with all IDEC rules and regulations

Proposed program type for future state: Small-scale care, Drop-in Services, Extracurricular Activities

Proposed program type for future state: Federal premises, Schools

Proposed program type for future state: Short-term care, part-day care, before- and after-care

Proposed program type for future state: Day care homes, day care centers, group day care homes

Types of requirements: None; CCAP certification and requirements optional

Types of requirements: Determined by other agency; CCAP certification and requirements optionsl

Types of requirements: Personnel and business requirements, including CCAP certification requirements

Types of requirements: Full degree of licensure requirements related to facilities, personnel, business, and program

No Oversight (Exempt)

Child Care that operates without any licensing or regulatory oversight; no reporting or compliance obligations are required

Proposed program type for future state: Small-scale care, Drop-in Services, Extracurricular Activities

Types of requirements: None; CCAP certification and requirements optional

Oversight by Other Agency (Non-IDEC Oversight)

Programs that are exempt from IDEC licensure but must comply with requirements or reporting from another regulatory agency

Partial Oversight by IDEC (Alternative licensure)

Programs that do not require full licensure but must meet some IDEC requirements

Full Oversight by IDEC (Full licensure)

Programs that require complete licensing and ongoing compliance with all IDEC rules and regulations

Proposed program type for future state: Federal premises, Schools

Proposed program type for future state: Short-term care, part-day care, before- and after-care

Proposed program type for future state: Day care homes, day care centers, group day care homes

Types of requirements: Determined by other agency; CCAP certification and requirements optionsl

Types of requirements: Personnel and business requirements, including CCAP certification requirements

Types of requirements: Full degree of licensure requirements related to facilities, personnel, business, and program

Table data provided by IDEC. 

This initial proposal by the department would be a welcome change, considering that our current exemption structure is opaque and difficult to navigate. Creating various levels of exemptions seems like a positive change in bringing additional clarity to our licensing structure. Nonetheless, we do encourage IDEC to release additional details on this exemption structure and publish resource guides for each category, so programs can have a clear understanding of the requirements they must meet. This will be especially helpful for family, friend and neighbor providers who are likely not familiar with our child care licensing system.

As IDEC prepares to implement these proposed changes later this year, Start Early believes that these initiatives will improve licensing functions. However, we cannot lose sight of what we envision in the long-term to improve our child care licensing system. We encourage IDEC to consider what additional support and resources they can offer to reduce administrative burden, enhance program quality, and increase the number of slots across the state, especially infant-toddler slots. We look forward to the department unveiling further details on licensing redesign over the next 5 months.

In the meantime, if you would like to learn more about IDEC’s proposals as the new agency readies to launch or offer the department any feedback, click here for information on listening sessions, meetings, and workgroups.

About the Author

Mercedes Mondragón

Policy Manager, Illinois Policy

Mercedes Mondragón is a Policy Manager on the Illinois Policy team at Start Early, where she focuses on advocating for improvements to the child care system and alleviating issues faced by the early childhood workforce.

More About Mercedes

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