The Illinois Consumer Coverage Disclosure Act: An Updated Review

The Illinois Consumer Coverage Disclosure Act (the “Act”) became law on August 27, 2021, and it was an addition to Illinois employment law under the jurisdiction of the Illinois Department of Labor (IDOL). The Act requires an employer to compare its medical coverage against Illinois’ list of essential health insurance benefits applicable to the individual and small group insurance markets and disclose this information to its Illinois workforce. The disclosure’s purpose is to help employees make informed decisions about whether coverage through their employer or the individual market will best meet their needs. In collaboration with the Illinois Department of Insurance, the IDOL provides a model disclosure form.

This Alert addresses the Act’s requirements and other related information, including guidance we received directly from the IDOL. This Alert is relevant for all employers offering medical coverage to employees working in the State of Illinois.