Illinois guidance says new requirements for mental health and substance use disorder coverage apply to policies amended, issued or renewed from January 2027.
Illinois Department of Insurance explains new coverage requirements
The Illinois Department of Insurance said Company Bulletin 2026-12 clarifies provisions of Section 370c.4 of the Illinois Insurance Code. The bulletin, dated September 11, 2026, was issued to companies writing accident and health insurance, certain self-funded public entities, administrators, and contracted third parties.
According to the Illinois Department of Insurance, Section 370c.4 was added by HB 1085, which was enacted as Public Act 104-0446. The Department said the legislation became law effective June 1, 2026, but the coverage-administration requirements have a later policy-effective date.
Requirements begin with certain 2027 policies
The Illinois Department of Insurance said Section 370c.4 imposes requirements on insurers and contracted third parties for group or individual policies that are amended, delivered, issued, or renewed on or after January 1, 2027.
The Department’s bulletin addresses how affected organizations administer coverage for mental health and substance use disorder treatment. The guidance applies to the administration of coverage rather than describing a new treatment program or a specific provider network.
Areas covered by the bulletin
According to the Illinois Department of Insurance, the requirements concern reimbursement rate floors for participating providers. The bulletin also covers same-day services provided on an outpatient and inpatient basis by the same provider or facility.
The Department said the law addresses services furnished by behavioral health trainees who are working under the supervision of a fully licensed provider. It also addresses 60-minute psychotherapy sessions billed with CPT Code 90837.
The bulletin further covers contracting and credentialing processes for providers applying to become participating providers. According to the Department, it also addresses claims for mental health and substance use disorder services submitted after a provider contract takes effect.
Scope of treatment
The Illinois Department of Insurance said it recognizes prevention, screening, management, and diagnosis as falling within the meaning of “treatment” under Section 370c.4.
What this means for Illinois patients
The Illinois Department of Insurance guidance outlines coverage-administration requirements that apply to certain policies beginning in 2027. For people seeking treatment locally, this directory lists 218 published clinics in Illinois.
This is general information, not medical advice.
More Illinois reporting on access & coverage.
This report is educational and is not medical advice. Coverage, availability and eligibility can change; verify details with the named source or your care team.