What Is the CNA Scope of Practice in Illinois?

The CNA scope of practice in Illinois covers hands-on personal care and basic clinical observations performed under the supervision of a licensed nurse: bathing, dressing, feeding, transferring and positioning patients, basic hygiene, vital signs, intake and output, and reporting changes in a patient’s condition. It does not include administering medications in a nursing home or hospital, performing invasive procedures, or making independent decisions about what care a patient needs. Those lines are drawn by the Illinois Nurse Practice Act, the Department of Public Health’s training rules, and federal nursing home regulations, and crossing them carries real consequences.

What a CNA Is Allowed to Do

The Illinois Department of Public Health approves the curriculum for CNA training programs, and the list of approved performance skills effectively sets the outer boundary of independent CNA practice. Those skills include bathing, dressing, and feeding residents; oral hygiene and nail care; transferring patients with a transfer belt or mechanical lift; helping patients walk; measuring temperature, pulse, respiration, blood pressure, height, and weight; calculating intake and output; and positioning patients in bed.¹ A CNA must demonstrate competency in these skills before certification, and they form the day-to-day work of the role.

Observing and reporting is just as much a part of the job. A CNA often spends more continuous time with a patient than any other member of the care team, which is why noticing a change in skin color, appetite, or mental state and relaying it to the supervising nurse is part of the scope rather than a courtesy. The reporting itself is in bounds; interpreting what the change means clinically, or acting on that interpretation, is not.

What a CNA Cannot Do

The Illinois Nurse Practice Act draws hard lines around what a registered nurse can hand off to unlicensed personnel, which is the legal category CNAs fall into. A nurse cannot delegate nursing judgment, the comprehensive patient assessment, development of a care plan, or evaluation of care to any licensed or unlicensed person.² In practical terms, a CNA can never independently decide what care a patient needs or change the care plan, no matter how obvious the right answer looks.

Medication administration is the restriction most often misunderstood. In any institutional or long-term care facility, the Nurse Practice Act specifically prohibits delegation of medication administration to unlicensed personnel.² A standard CNA in a nursing home or hospital cannot hand a patient a pill. The rules loosen in community-based or home care settings, where a registered nurse may delegate oral, subcutaneous, or topical medication administration to unlicensed personnel if specific delegation conditions are met. The institutional prohibition has one formal exception, the Certified Medication Aide program, described below.

Invasive procedures are also out of scope. Inserting catheters, drawing blood, and administering injections all require the clinical training and judgment of a licensed nurse or other qualified medical professional. A CNA who performs these tasks risks disciplinary action and, if a patient is harmed, criminal liability.

How Delegation Actually Works

Scope of practice in a given shift is not just what the training curriculum covers; it is also what the supervising nurse has specifically delegated. Only a registered professional nurse can delegate nursing interventions, and the decision requires assessing the patient’s stability, the potential for harm, the complexity of the task, the predictability of the outcome, and the competency of the CNA receiving the delegation.² This is an individual judgment, not a standing authorization, and the nurse can refuse to delegate or revoke a previous delegation at any time if patient safety requires it.

A CNA who receives a delegated task cannot pass it along to someone else. The Act explicitly prohibits re-delegation by unlicensed personnel.² If one CNA is asked by another to take over a task the first was given, the answer has to come from the supervising nurse, not from the CNAs themselves.

The supervising nurse keeps professional accountability for whatever they delegate, which is why nurses are selective about what and to whom. No employer or facility can force a nurse to delegate a task the nurse judges unsafe. The Act protects nurses from disciplinary or adverse action for refusing to delegate based on patient safety concerns.² If a facility is pressuring nurses to offload tasks beyond what is appropriate, the legal exposure runs to the facility, not to the nurse who pushes back.

The Certified Medication Aide Exception

Illinois recognizes that the blanket prohibition on CNAs administering medications in institutional settings creates staffing pressure in skilled nursing facilities, and the state established the Certified Medication Aide program to carve out a narrow exception. To qualify, you must already be a certified CNA in good standing with at least 2,000 hours of CNA practice within the three years before applying.³

The additional training runs a minimum of 60 hours of classroom education, 10 hours of simulation laboratory study, and 30 hours of supervised clinical practicum with progressively increasing responsibility. Even with the credential, a certified medication aide cannot administer Schedule II controlled substances or any injectable medication, including subcutaneous, intramuscular, intradermal, or intravenous drugs.³ The program is limited to skilled nursing facilities and requires direct supervision by a registered nurse. A standard CNA without this additional credential does not inherit any of its authority.

Consequences of Working Outside Scope

A CNA who steps outside the scope of practice faces consequences on several fronts at once. IDPH can place administrative findings on the Health Care Worker Registry, and those findings are permanent under federal rules unless the finding was made in error, the person was found not guilty in court, or the state is notified of the person’s death.⁴ Any health care employer running a registry check before hiring sees that finding, and most will not hire someone who has one. The practical effect is often the end of a healthcare career.

IDPH also has authority to investigate CNAs during facility surveys and can require any certified nursing assistant to demonstrate competency through written examination, practical testing, or both when problems with care are observed.⁵ An out-of-scope incident does not have to produce a formal finding to trigger retesting.

Employers carry their own exposure. A healthcare employer that allows CNAs to perform tasks outside their scope, or that fails to verify registry status before hiring, faces fines and sanctions from IDPH, and registry verification is a condition of operating as a licensed facility.⁶

Then there is the patient. A CNA whose out-of-scope action injures a patient can face civil liability for negligence and, in egregious cases, criminal prosecution. The nurse who delegated the task may share responsibility if the delegation was inappropriate under the circumstances. That shared accountability is one reason the Nurse Practice Act insists on individualized delegation decisions rather than blanket task assignments, and it is also the clearest reason to decline a task that falls outside what you are trained and authorized to do, even when a coworker or supervisor is asking.

1
Illinois General Assembly. Illinois Administrative Code Title 77, Part 395 – Long-Term Care Assistants and Aides Training Programs Code
2
Illinois General Assembly. Illinois Compiled Statutes 225 ILCS 65/50-75
3
Illinois General Assembly. Illinois Compiled Statutes 210 ILCS 45/3-220
4
eCFR. 42 CFR 483.156 – Registry Requirements
5
Legal Information Institute. Illinois Administrative Code Title 77, Section 300.660 – Nursing Assistants
6
Illinois Department of Public Health. Health Care Worker Registry