Since Aug. 27, 2021, the Illinois Consumer Coverage Disclosure Act (ICCDA) requires that employers offering “group health insurance coverage” must provide a new notice to eligible employees. Under this law, a covered employer must prepare and provide its Illinois employees with a new notice that compares the benefits offered under the employer’s “group health insurance coverage” with the “essential health benefits” (EHBs) required through the Illinois insurance marketplace (Get Covered Illinois). The law puts the onus on employers, not insurers, to provide the benefit comparison notice.
Which employers are covered?
The new law applies to all employers (including state and local governments), regardless of size and where they are located, if (i) they have employees in Illinois and (ii) provide “group health insurance coverage” to Illinois employees. The Illinois Department of Labor (IDOL) recently issued guidance, including FAQs, stating that the law applies to Illinois employers that provide group health insurance coverage to Illinois employees in the form of fully insured plans and self-insured coverage
Is the Illinois Law Preempted by ERISA?
Not clear. Not clear. An argument can be made that the new law, at least as to self-insured plans, is preempted by the Employment Retirement Income Security Act (ERISA) under recent U.S. Supreme Court precedents. However, employers in Illinois may choose to comply with the new law in order to avoid the penalties discussed below,...
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