On August 27, 2021, Governor Pritzker signed the Consumer Coverage Disclosure Act (the Act), which came into effect immediately. The law requires Illinois employers (both private and government) to disclose annually to all new hires eligible for group health insurance coverage and to all plan members. Group Health Insurance an easy-to-understand comparison between the benefits provided by the plan and the “health benefits benefits” required by the Illinois Department of Insurance (DOI) for individual and small group health insurance coverage. The law does not mandate essential health benefit coverage, it simply requires a disclosure that compares an employer’s current benefit coverage with the list of essential health benefits provided by the DOI. This comparison can be provided by email or posted on a website that an employee can access on a regular basis.
The DOI recently published Faq regarding the law and included a sample comparison table that lists the Illinois Essential Health Benefits list for 2020-2022. Employers who sponsor group health insurance plans should work with their third-party administrators and insurance companies to prepare for disclosure. Because the timing requirements under the Act are similar to those that apply to Summary of Benefits and Coverage (SBC), many employers may wish to schedule to send the new disclosure with the SBC. The Illinois Department of Labor has the power to enforce the law. Employers who fail to provide the disclosure will have 30 days to comply or face penalties.