IL| The Illinois Department of Insurance issued an addendum (Company Bulletin 2025-09) to clarify guidance for accident and health insurance and managed care plan filings for Plan Year 2026, acknowledging that some regulatory items, including MOOP (Maximum Out-of-Pocket) amounts, remain unfinalized and may require later adjustments.
Insurers are instructed to:
- Prepare plan templates according to current validation rules, with the Department committing to assist issuers in resolving any issues once final rules are established.
- Clearly describe the impact of any state mandates on pricing in the Actuarial Memorandum and assume a 2.75% exchange user fee, based on Illinois’ anticipated approval as a State-based Marketplace.
- Report the actual cost-sharing reductions (CSRs) paid in Plan Year 2024 and explain the relationship between CSR-related revenue and expected CSR outlays for 2026, with estimates permitted if exact figures are unavailable.
