IL Company Bulletin 2022-03
All Companies Writing Accident and Health Insurance and Managed Care Plans in Illinois : Company Bulletin 2022-03 Initial Implementation of the Federal No Surprises Act in Illinois
ovider is a participating
provider in the health care plan, will remain in force on and after January 1, 2022. This provision does not
apply to voluntary health services plans.
III. Air Ambulances
Currently, no Illinois law applies to balance billing by air ambulance providers. Therefore, CMS will
directly enforce the NSA and all implementing regulations for both PPO and HMO coverage.
IV. Self-funded Plans of Individual Employers, Employee Organizations, and State or Local
Governments
Self-funded plans of individual employers, employee organizations, and state or local governments are
subject to the NSA default requirements and are not subject to Section 356z.3a. To the extent that any
private or non-Federal governmental employer or employee organization offers fully-insured, networkbased coverage to its employees, that coverage will be subject to Illinois insurance laws applicable to the
health insurance issuer.
The Department may issue further guidance as issuers, providers, facilities, and consumers adjust to the
new regulatory framework.
Questions regarding this Company Bulletin should be directed to DOI.InfoDesk@illinois.gov.