State Provides Sample Form and FAQs for Essential Health Benefits Disclosure Requirement

On November 16, 2021, the Illinois Department of Labor (DOL) released guidance on the new Illinois Consumer Coverage Disclosure Act (CCDA) disclosure requirement and also provided a sample disclosure form.

The CCDA (signed by Gov. Pritzker in August 2021) requires employers to provide eligible employees with a disclosure that compares their coverage to essential health benefits required for coverage received through the Illinois marketplace. The disclosure must be provided upon hire, annually thereafter and at the request of an employee, and can be provided via email or posted on a website that an employee is able to regularly access.

The CCDA is applicable to all employers with employees in Illinois who provide group health insurance coverage. Importantly, this requirement applies to both fully insured and self-insured plans. The DOL explains this further in its FAQs, noting that the CCDA creates a notification requirement for all employers, regardless of the type of insurance they provide.

Employers who offer group health plans in Illinois should be aware of this requirement, review the FAQs provided and sample disclosure, and discuss with carriers and TPAs, as applicable, to ensure compliance.

Consumer Coverage Disclosure Act »

Consumer Coverage Disclosure FAQ »

Sample Disclosure »