IL: MH/SUD Coverage Implementation Guidance (HB 1085)

This bulletin provides the Illinois DOI’s official implementation guidance for HB 1085 (Public Act 104-0446), which adds Section 370c.4 to the Illinois Insurance Code imposing new MH/SUD coverage administration requirements on insurers and contracted third parties. The requirements include reimbursement rate floors, same-day service coverage, coverage of supervised trainee services, 60-minute psychotherapy session coverage, and revised contracting/credentialing processes. These obligations take effect for policies issued or renewed on or after January 1, 2027, giving insurers a limited window to update contracts, provider networks, claims systems, and rate structures.