Illinois Company Bulletin 2025-05

Springfield Office 320 W. Washington Street Springfield, Illinois 62767 (217) 782-4515 Chicago Office 115 S. LaSalle Street, 13th Floor Chicago, Illinois 60603 (312) 814-2420 JB PRITZKER ANN GILLESPIE Governor Acting Director TO: All Companies Writing Accident and Health Insurance, Health Maintenance Organization Health Care Plans, and Stand-Alone Dental Plans in Illinois FROM: Ann Gillespie, Acting Director DATE: February 28, 2025 RE: Company Bulletin 2025-05 Provider Directory Self-Audit Filings – Update The Illinois Department of Insurance (“Department”) is providing additional updated guidance related to provider directory self-audits for all network plans subject to the Network Adequacy and Transparency Act ("NATA") due to the recent enactment of the Healthcare Protection Act, signed into law July 10, 2024. See Public Act 103-0650. The accuracy of the provider directory remains a top priority of the Department to ensure consumers have current, accurate, and transparent information to access network providers included under their health plan. As of January 1, 2025, Section 25(a)(3) of the NATA requires an issuer to conduct self-audits of the entire provider directory for each of its network plans at least every 90 days, which must include all the current network provider directories. Issuers must submit to the Department an unredacted, internal self-audit report as well as a summary. Although the deadlines in 50 Ill. Adm. Code 4540.60(a) and (b) have been superseded by statute, the report must include all information described in those provisions, and the summary must include all information described in 50 Ill. Adm. Code 4540.60(c). Filings should be submitted by the first day of the second month following expiration of each 90-day audit period. For example: Reporting period of: - January 1, YYYY – March 31, YYYY – Due no later than May 1, YYYY - April 1, YYYY – June 30, YYYY – Due no later than August 1, YYYY - July 1, YYYY – September 30, YYYY – Due no later than November 1, YYYY - October 1, YYYY – December 31, YYYY – Due no later than February 1, YYYY Illinois Department of Insurance Springfield Office 320 W. Washington Street Springfield, Illinois 62767 (217) 782-4515 Chicago Office 115 S. LaSalle Street, 13th Floor Chicago, Illinois 60603 (312) 814-2420 The Department has updated the Audit Summary Template to assist in compiling the data required, which replaces the previous template version “CB 2024-06 Audit Summary Template”. All network directories must be posted online and clearly identify which directory applies to which network plan. Printed copies must be available upon request and must be updated quarterly unless the printed copy draws from the same provider information as the online directory on each printed copy’s date of printing. Online directories must be accessible to the public without requiring creation of an account or input of a policy or member number to view. Each plan’s online provider directory must be updated monthly, but also within 2 business days of the issuer being notified of a change by a participating provider. Failure to update a network plan’s directory within the prescribed timelines shall subject the issuer to a civil penalty of $5,000 per month. 215 ILCS 124/25(a)(2). If an issuer knew or reasonably should have known that a provider was incorrectly included in a provider directory, the Director may assess a fine of up to $25,000 per violation against the issuer. 215 ILCS 124/25(i). This bulletin supersedes Company Bulletin 2024-06. However, the manner for submission of the audits remains unchanged. As a reminder, the Department established the following TOI/Sub-TOI within SERFF: • TOI: – “NA00 Network Adequacy.” • Sub-TOI “NA00.002 Network Adequacy Directory Audit.” For questions regarding this Company Bulletin, please direct inquiries to DOI.InfoDesk@Illinois.gov.