Illinois Company Bulletin 2025-18

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 Illinois Department of Insurance JB PRITZKER Governor ANN GILLESPIE Director TO: All Health Insurance Issuers Writing Accident and Health Insurance, Health Maintenance Organization Health Care Plans, Limited Health Care Plans, and Voluntary Health Services Plans; All Plan Sponsors and Administrators of Self-Funded State, County, Municipality, and School District Group Health Plans FROM: Ann Gillespie, Director DATE: November 7, 2025 RE: Company Bulletin 2025-18 Emergency Rule and Guidance on Vaccine Coverage In accordance with Executive Order 2025-04,1 the Illinois Department of Insurance (“Department”) issues this Bulletin to announce an emergency rulemaking, which is currently effective, to implement recent immunization recommendations from the Illinois Department of Public Health (“IDPH”) for health insurance coverage and group health plans that are subject to the jurisdiction of this State. A copy of the emergency rulemaking documents is attached to this bulletin. State Guidelines for Preventive Immunization IDPH has a statutory mandate to supervise the interest of the health and lives of people in Illinois. 20 ILCS 2305/2(a). On September 23, 2025, in response to recent federal actions that no longer follow rigorous scientific review for vaccine recommendations, the IDPH Director issued “Respiratory Virus Season Guidance for Clinicians”, as well as a statewide standing order authorizing health care professionals to administer COVID-19 vaccines without needing an order from an attending physician if the individual meets criteria specified in the standing order.2,3 IDPH’s recommended guidelines are widely distributed, known to health care professionals, and made publicly available to provide guidance to protect the health and wellness of Illinois residents. Although the title of the IDPH guidance refers to respiratory viruses, the guidance also includes a recommendation that, for all other vaccines that appear on the CDC immunization schedules, clinicians follow the version of the immunization schedules as revised on August 7, 2025. Coverage for Preventive Immunizations To ensure that persons covered by Illinois-regulated plans actually have access to affordable vaccinations, the Department has issued the enclosed emergency amendments. Plans and issuers must cover without cost-sharing preventive immunizations and their administration whenever an individual meets the criteria in either the ACIP recommendations or the IDPH guidance to the extent specified by the emergency amendments. Health insurance coverage that covers immunizations through a prescription drug formulary may limit coverage to those vaccines specified on their formularies, 1 https://www.illinois.gov/government/executive-orders/executive-order.executive-order-2025-04.2025.html. 2 https://dph.illinois.gov/content/dam/soi/en/web/idph/publications/idph/topics-and-services/diseases-andconditions/respiratory-disease/guidance/respiratory-virus-season-guidance.pdf. 3 https://dph.illinois.gov/content/dam/soi/en/web/idph/resources/topics-services/prevention-wellness/immunization/2025-26- covid19-vaccination-standing-order.pdf. 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 provided that there is at least one product on the plan formulary that will address each item on the IDPH guidelines. Plans and issuers must implement these requirements in a manner consistent with Section 356z.62(c)-(j) of the Illinois Insurance Code (the “Code”) (215 ILCS 5/356z.62(c)-(j)). Of particular note, pursuant to Section 356z.62 of the Code, the Department is requiring health insurance issuers offering group or individual health insurance coverage and self-funded State, county, municipality, and school district group health plans to adhere to all emergency rule provisions related to coverage of COVID-19 immunizations. These plans and issuers also must comply with the emergency rule’s clarification of how long the State and ACA preventive service coverage mandates require any immunization to remain covered even after it has been removed from CDC immunization schedules. Other provisions in this emergency rulemaking apply only to health insurance issuers offering fullyinsured group or individual health insurance coverage. Some provisions only apply to fully-insured health insurance coverage offered under certain licensures to certain policyholders. None of the provisions affect excepted benefits or grandfathered health plans. However, no exemption has been provided for “transitional plans” described in Company Bulletin 2022-05,4 which have never been exempt from the preventive service coverage mandates in the ACA or Section 356z.62 of the Code. Policy Forms and Other Filings Health insurance issuers offering group or individual health insurance coverage must ensure that their policy forms comply with the emergency amendments. For policy forms that have already been approved but have not yet been issued, issuers should submit a new replacement filing referencing the tracking number of the previously approved SERFF form filing(s) if they need to submit a revised policy form. Only changes related to compliance with the emergency amendments are permitted. If an issuer in the individual, small, or large group markets needs to correct a policy form that has already been issued, the issuer may submit a new filing with a policy amendment or endorsement in SERFF with reference to the SERFF tracking number of the previously approved filing. Please note, due to these extraordinary circumstances, the Department is making this one-time exception to allow issuers with plans in the individual and small group the ability to submit amendments or endorsements for previously approved form filings. Issuers are expected to provide clear explanations in their policy forms and other communications with prospective and current enrollees about coverage for vaccines. For non-grandfathered individual and small group health insurance coverage, the Department is not requiring updates to any of the QHP certification templates for Plan Year 2026. Because the rulemaking essentially preserves the status quo on coverage of immunizations that existed during the summer, the Department does not believe the rulemaking is a basis for health insurance issuers to revise their rate filings. Self-funded non-federal governmental plans are not required to file plan documents with the Department. However, plan sponsors and administrators should ensure that plan documents and other communications with prospective and current enrollees provide clear explanations of coverage for vaccines consistent with the applicable requirements of the emergency amendments. Issuers Acting as Administrators 4 https://idoi.illinois.gov/content/dam/soi/en/web/insurance/companies/companybulletins/cb2022-05.pdf. 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 When issuers act as administrators for self-funded group health plans of private employers or of other self-funded plans outside the scope of the emergency rule, the Department urges issuers to encourage plan sponsors to take steps that are consistent with this bulletin and the emergency amendments. It is important that plan sponsors be made aware of the IDPH guidelines and their effect on how health care professionals will administer immunizations in this State. Please direct questions regarding this Bulletin to DOI.InfoDesk@illinois.gov.