Illinois Health Coverage Disclosure Requirements

Compliance, Employee Benefits

In late August 2021, the Illinois legislature passed the Consumer Coverage Disclosure Act and it was signed into law by Governor Pritzker. These new disclosure requirements apply to employers who offer group health plan coverage to employees in the State of Illinois.

The Consumer Coverage Disclosure Act requires an employer that offers group health plan coverage in Illinois to provide employees with a list of essential health insurance benefits regulated by the State of Illinois and a comparison to what is covered by the employer provided health plan. This requirement applies to both fully insured plans and self-funded plans offered in Illinois by in-state employers and out-of-state employers with employees who work in Illinois.  Employers should consult with their carriers or third party administrators for assistance with the disclosure.

Here are some specifics for employers regarding this new coverage disclosure requirement: 

  • Who:  This new requirement pertains to Illinois-based employees who are eligible for group health plan coverage. 
  • Sample form:  Employers may, but are not required to, use the form created by the State of Illinois – Essential Health Benefits Form – PDF
  • Timing: Employers should provide this information to employees upon hire, on an annual basis and upon request. 
  • Delivery: Employers may notify employees by email or by posting on-line to a site accessible by employees.
  • Effective: January 1, 2022
  • More information: Illinois Department of Labor FAQs

These new disclosure requirements are effective January 1, 2022 for Illinois employers who offer group health coverage to their employees. 


If your organization operates in Illinois and makes an offer of group health coverage, you would be well-served by reviewing the provisions of this Act.  Organizations will want to be ready to comply with the group health plan benefit disclosure requirements of this Act effective on January 1, 2022.

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