IL| The Illinois Department of Insurance Bulletin 2025-20 explains how Illinois PBMs must revise 2025 covered individual reports and fees under the Prescription Drug Affordability Act (PDAA) in light of HB 767, clarifies which plans and covered individuals are in scope, and announces enforcement flexibility on revised-report and payment deadlines once HB 767 is signed into law.
- Confirms 2025 PBM reporting and $15-per-covered-individual fee apply based on Illinois residents, with potential underpayment “true-up” or overpayment credits/refunds once reports are corrected.
- Announces limited enforcement discretion, allowing revised reports up to 30 business days after HB 767 is signed and corresponding fee payments within one month of that deferred date.
- Clarifies applicability across plan types, including ERISA, church, self-funded governmental, Medicaid/All Kids, and custody-related pharmacy services, and lists categories that are excluded (e.g., ERISA self-funded multiemployer, Medicare, Tricare, FEHBP, certain out-of-state situs plans).
- Adopts and refines federal-style definitions and provides methods to determine when plans and individuals inside or outside Illinois are subject to Article XXXIIB and the PDAA.
- Provides detailed instructions for completing a revised Excel reporting template (columns A–D), calculating any fee difference at $15 per covered individual, and submitting reports, payments, and any credit/refund requests to the Department of Insurance.