April 02, 2020

State Insurance Spotlight: Illinois Department of Insurance Guidance Concerning COVID-19

State insurance departments across the country are continuing to provide guidance in response to the COVID-19 outbreak. In this update, Faegre Drinker spotlights the current Illinois Department of Insurance (Department) guidance with respect to COVID-19 issues.


Governor Pritzker was among the earlier executives issuing general stay-at-home orders. The office locations of the Department are temporarily closed and staff continues to work on a limited scale while other staff works remotely. The Department has issued a more targeted set of bulletins and other guidance than other states concerning COVID-19, but that is consistent with the Department’s general approach. Nevertheless, the Department plays a national leadership role, especially on financial regulation, so as the National Association of Insurance Commissioners (NAIC) further addresses COVID-19 issues, we anticipate that Illinois regulators’ approach may have outsized influence.

Department Bulletins

CB 2020-06: Electronic Filing and Delays in Processing (March 31, 2020)
  • This Bulletin discusses the current status of operations at the Department:
    • The Department is working to process and respond to filings, applications and consumer inquiries as quickly as possible, but the response time may be extended, particularly for anything sent via U.S. mail. The Department requests submission of information electronically, whenever possible.
    • Where electronic corporate and financial filings are not an option, in addition to normal mailing procedures, please reach out to your assigned Department contact to determine a secure means of transmitting electronically. In addition, applications for producer and administrative licenses may encounter delays.
    • Consumers can still submit insurance complaints electronically through the IDOI Message Center or by calling 866-445-5364.
    • If a company or consumer has mailed a paper filing or inquiry to the Department in the past two weeks, the Department is asking to be contacted to ensure such documents are processed in a timely manner.
    • The Department requests that all insurers adjust their internal procedures to allow Illinois consumers to transact business remotely wherever possible.
CB 2020-04: Requirements for Telehealth Services under Executive Order 2020-09 (March 25, 2020)
  • Details the requirements for telehealth services under Governor Pritzker’s Executive Order 2020-09 that orders all health insurers to expand the availability and affordability of telehealth coverage.
  • These requirements apply so long as Illinois remains subject to the Governor’s proclamation of disaster.
CB 2020-02: Insurance Coverage for Coronavirus COVID-19 (March 2, 2020)
  • Covers all issuers of health insurance coverage and travel insurance, does not apply to “excepted benefit policies or short-term, limited-duration health insurance coverage.”
  • Reminds insurers of Illinois law that requires health insurers to charge the same cost-sharing on out-of-network care when receiving care at a participating provider, even if the specialist at that provider is out-of-network.
  • Encourages health insurance issuers to consider ways to reduce cost-sharing for testing and treatment of COVID-19 during the outbreak.
  • Encourages issuers to cover enrollees for early prescription drug refills (does not apply to opioids and other drugs with high abuse issues).
  • Reminds insurers that under Illinois law, they cannot cancel or fail to renew coverage based on an enrollee’s attempting to receive or receiving treatment or testing for COVID-19, and that an issuer may not deny enrollment in new coverage based on testing or treatment for COVID-19.
  • States that travel policies must cover sickness, accident, or death unless there is an exception applicable to COVID-19.
  • Encourages insurers to explain to enrollees health care options available for COVID-19.

Other Department Information

Frequently Asked Questions about Insurance Coverage and the Coronavirus COVID-19 (March 3, 2020)
  • List of 10 Consumer Insurance Coverage FAQs.

Additional Information

For additional Illinois COVID-19 information, please visit:

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