January 13, 2026
In 2024, Illinois enacted Public Act 103-0751, which amended the Illinois Insurance Code to address infertility coverage requirements levied on group health plans. This legislation created a tiered approach for coverage requirements, beginning with policies that cover more than 25 employees. Until December 31, 2025, medical policies amended, delivered, issued, or renewed in Illinois that provided pregnancy-related benefits must cover infertility benefits if the policy covers more than 25 employees. Effective January 1, 2026, the employer size requirement was lifted. Medical policies amended, delivered, issued, or renewed in Illinois must cover infertility benefits regardless of employer size.
This is an important reminder that this change is now effective. Employers who sponsor fully insured health plans in Illinois should work closely with their insurance carrier to understand this change. Importantly, this only applies to policies written in Illinois, so employers with policies issued outside of Illinois do not have to comply, even if the policy covers Illinois residents. Self-insured plans are also exempt from the requirement.
PPI Benefit Solutions does not provide legal or tax advice. Compliance, regulatory and related content is for general informational purposes and is not guaranteed to be accurate or complete. You should consult an attorney or tax professional regarding the application or potential implications of laws, regulations or policies to your specific circumstances.
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