
Illinois continuation is not just federal COBRA for smaller groups
Under 215 ILCS 5/367e, qualifying employees losing covered group insurance through termination or reduced hours can continue hospital, surgical and major medical coverage for themselves and eligible dependents. The ordinary prior-coverage requirement is three continuous months, including qualifying replacement coverage. The ordinary maximum is 12 months, subject to statutory termination conditions, and the premium cannot exceed the applicable group rate.
The employer must provide written notice within 10 days of the event, with a copy to the insurer. The employee requests continuation within 30 days after the later of the event or the notice, subject to the statute’s 60-day outside limit after the event. The law also prevents an insurer from denying continuation solely because the employer failed to notify the employee. Missing an employer deadline is not a sound basis for HR to declare that the person has no rights.
Medicare, other group coverage and specified employment-related felony or theft circumstances can affect eligibility. Separate spousal-continuation provisions may apply after divorce, death or qualifying retirement. Have the insurer evaluate those events separately; the 12-month employment-termination rule is not a complete description of every Illinois dependent’s rights.
For a business approaching 20 employees, ask the administrator to coordinate federal COBRA and state continuation. Do not simply add the periods together or assume one notice satisfies both laws. For a self-funded proposal, establish whether state insurance continuation applies at all. The plan’s legal structure and governing policy matter more than the administrator’s brand name.
Read the 2026 infertility provision using the policy date
Illinois changed the employee-count language in its infertility coverage law. Section 356m(a-5) applies to group accident and health policies providing pregnancy-related benefits that are issued, amended, delivered or renewed in Illinois on or after January 1, 2026. It does not retain the old more-than-25-employees threshold. The earlier version and the new provision appear together in the Illinois Insurance Code.
I would ask the carrier to identify the governing policy, renewal date and applicable benefit provision. Employees need the covered services, authorization process, network facilities and cost sharing, not an assurance that every fertility expense is paid. Do not carry forward a retrieval limit from an old benefits presentation without checking the current contract and law. State insurance mandates also should not be presented as automatically governing every employer plan nationwide.
Compare Chicago and downstate needs without using statewide price shortcuts
A Chicago company hiring downstate or across the Indiana or Wisconsin border should verify the employee’s actual home area. Ask whether a network is available for routine appointments and which hospitals participate. For an employee using an academic medical center, confirm the facility, physician group and proposed service rather than relying on the center’s name alone.
Get Covered Illinois is the state’s official ACA Marketplace. Employees considering individual coverage should use the current state enrollment route and compare plans for their own address. The Illinois Department of Insurance’s Uninsured Ombudsman Program can help people who lack coverage or are about to lose it explore options. Give departing staff that resource alongside continuation information, without promising that they qualify for financial assistance.
Count employees before comparing quotes
I separate three questions: whether the business can buy a small group policy, who is eligible to enroll, and whether federal employer responsibility applies. Those questions can use different counting rules. Send the broker a workforce census and the prior year’s payroll totals, including part-time staff and related businesses. Ask for a written explanation of the market classification. The number of people who accept insurance is not a substitute for the employer count.
Under the IRS rules, an applicable large employer generally averaged at least 50 full-time employees, including full-time equivalents, in the preceding calendar year. Related employers may need to aggregate their workforces, and a seasonal-worker exception can apply. This determines whether the employer shared responsibility provisions apply; it does not mean every business with 50 names on one payroll must immediately buy a particular policy. Use the ALE calculator as a starting point and have payroll review the underlying hours.
For SHOP, HealthCare.gov requires at least one qualifying employee other than owners and specified family members. A company consisting only of founders should resolve eligibility before asking for prices. Do not label a contractor an employee merely to create a group. Give the carrier the actual ownership and employment facts, and ask which documents it needs. Participation and contribution requirements also need written confirmation for the specific product and enrollment date.
Choose the arrangement around the work you need done
| Option | When I would consider it | What to resolve first |
|---|---|---|
| Fully insured group coverage | A common employer benefit with a defined insurer contract. | Exact network, covered services, contribution policy and renewal terms. |
| Individual coverage HRA (ICHRA) | A defined employer allowance toward qualifying individual coverage. | Plans at every home address, subsidy effects, employee classes and administration. |
| PEO benefits offer | The business also wants the employment services in the PEO contract. | All service fees, benefits eligibility, cancellation terms and the replacement plan if you leave. |
| Other group proposals | The written terms address an identified problem with the current offer. | Who owes payments, maximum employer obligations, exclusions and obligations after termination. |
I would not choose an arrangement from its headline monthly price. Request the full agreement and a benefits summary. For a PEO, separate the insurance charge from the services contract and establish what happens to coverage when the relationship ends. For any proposal with employer claims obligations, ask for a maximum-cost illustration, renewal provisions and treatment of claims submitted after the contract ends. These are due-diligence questions, not a prediction that one approach will save money.
An ICHRA requires qualifying individual coverage or Medicare and has rules for employee classes and notices. An employee offered an affordable ICHRA generally cannot receive a Marketplace premium tax credit. If the offer is unaffordable, opting out may allow a credit if the employee otherwise qualifies. Do not add a projected subsidy to the allowance as though both were automatically available. Compare the employee’s remaining premium and care costs using the actual individual policy and household circumstances.
Ask the tax adviser to screen the small business health care tax credit before budgeting it. It generally requires fewer than 25 full-time equivalents, wages below the applicable tax-year limit and a qualifying employer contribution. The maximum is generally 50% of eligible premiums for taxable employers or 35% for eligible tax-exempt employers, over a two-consecutive-tax-year credit period. SHOP is generally required, but the IRS instructions contain limited exceptions where SHOP coverage is unavailable. A credit is not automatic just because a plan is called small business coverage.
An illustrative Chicago benefits budget
Now test an assumed 10% premium increase with the same people and benefits. Total premiums become $14,520 monthly. Maintaining the 80% contribution raises the employer cost to $11,616 and the combined employee cost to $2,904. Freezing the employer contribution at $10,560 instead leaves employees paying $3,960, a 50% increase in their combined contribution. Neither scenario is a prediction. It shows why a renewal percentage alone does not explain the impact on paychecks.
Build a second worksheet for each household’s care exposure. Record annual payroll contributions, the deductible, visit copays, prescription costs and the in-network out-of-pocket maximum. Premiums are separate from that maximum, and out-of-network or excluded services may add costs outside it. Have the insurer explain which expenses count. Compare the same services under each offer; a lower deductible alone does not establish that the entire plan is less expensive.
Check care access where your Illinois team lives
A Chicago office address does not tell you where the team receives care. Map home ZIP codes, regular work locations and out-of-state dependents before choosing a network. Give employees a private way to identify important doctors and prescriptions. The employer needs enough information to compare access without collecting diagnoses in a shared enrollment spreadsheet. A carrier logo alone is not a network confirmation.
- Verify the exact product and network name with both the insurer and the provider. Include the physician’s location, medical group and facility, because a directory entry for one location may not answer the question for another.
- Ask how routine care works away from home. Emergency coverage does not establish access to an ordinary follow-up appointment for a remote employee or a child at college.
- Check the precise drug, dose and formulation on the formulary. Record the tier, required pharmacy, prior authorization and any step-therapy requirements before comparing prescription copays.
- For ongoing treatment, ask whether transition-of-care arrangements are available, how to request them and whether existing authorizations transfer. Do not promise that every current provider will remain covered.
- Save dated answers and reference numbers. Give employees an escalation contact for conflicting directory information and a process for reporting an enrollment problem.
I would test a routine appointment, a specialist visit and a prescription refill against each finalist. Ask what happens if no participating provider can offer an appointment within a reasonable distance or time. Get the plan’s process for arranging access rather than assuming the employee can use any doctor at in-network rates. Those checks make a comparison useful for employees whose needs differ from the person selecting the plan.
Launch the plan with a calendar and an accepted roster
- Prepare the quote request Use one census and effective date for all proposals. Include coverage tiers, locations and waivers. Have the broker identify missing eligibility evidence before employees start making elections.
- Set the contribution policy Show employer and employee costs for every tier. Ask the administrator to review eligibility and contribution rules, including any proposed differences between employee groups. Identify payroll deductions and any separate service charges.
- Distribute the enrollment packet Give employees the Summary of Benefits and Coverage, network details, payroll costs, enrollment deadline and a private contact for questions. Explain how they can decline coverage and document their election.
- Confirm the start date Get written acceptance, the effective date, payment instructions and the accepted enrollment roster. Reconcile missing spouses, children and new hires before ending existing coverage. Do not equate an application submission with confirmed insurance.
- Audit the first invoice Match insurer billing to accepted elections and payroll deductions. Track corrections until the insurer confirms them. Keep a record of who owns enrollment, notices, billing and employee support after launch.
Start several weeks before the proposed effective date as a planning choice, then work backward from the carrier’s actual deadlines. Federal waiting-period rules generally prohibit a wait exceeding 90 days after someone is otherwise eligible. A rule that starts coverage on the first of the month after 90 days can exceed that limit. Ask the administrator to test real hire dates, including month-end hires, rather than relying on a short handbook phrase.
At renewal, keep the census constant for the first comparison so you can distinguish a rate change from hiring, dependent additions or a new contribution policy. Ask whether accumulated deductibles receive credit when switching midyear and obtain the answer in writing. Send employees a clear explanation of the effective date and any new identification cards, pharmacies or referral procedures. Reconcile the old policy’s final invoice as carefully as the new policy’s first one.
Handle departures, Medicare and family changes separately
Federal COBRA generally covers private-sector group health plans of employers with at least 20 employees on more than half of the prior year’s typical business days. Part-time workers count fractionally. Termination other than gross misconduct or a reduction in hours generally supports up to 18 months; other events and extensions can change the period. The usual premium ceiling is 102% of total plan cost, not 102% of the employee’s former payroll deduction. Government and church arrangements require separate scope review.
Give a departing employee the actual coverage end date, the continuation administrator’s contact and the complete premium. Loss of qualifying job-based coverage generally creates a Marketplace special enrollment opportunity during the 60 days before or after the loss. The employee should compare effective dates, networks and accumulated deductibles promptly. Voluntarily dropping continuation later generally does not create another special enrollment period by itself. Do not tell someone to wait for the continuation packet before investigating replacement coverage.
Medicare coordination depends on why the person qualifies for Medicare, current employment, employer size and sometimes multiemployer-plan rules. For age-based Medicare with current-employment coverage, Medicare generally pays first below 20 employees and the group plan generally pays first at 20 or more. Disability and end-stage renal disease use different rules. Have the employee confirm enrollment timing and payment order with Medicare and the plan; a blanket instruction to delay Part B can create a costly gap.
Marriage, birth, adoption, reduced hours and a dependent moving away can require different enrollment actions. Tell employees where to report a change and ask the administrator for the applicable deadlines. A payroll update alone does not update an insurer’s membership file. For leave, determine whether federal or state protections require continued benefits before processing the worker as a termination. State continuation also depends on the policy’s jurisdiction and funding, so the headquarters address cannot answer every case.
Illinois: a local procedure price and estimate checklist
Public self-pay examples help identify questions for a provider. They are not negotiated insurance rates, state market averages, comparable prices across states or estimates of insured out-of-pocket spending. Confirm a current written total before booking; a published amount is not a guarantee.
| Provider / primary source | Procedure | Published cash price / availability | Includes, excludes and unknowns | Effective date / status |
|---|---|---|---|---|
| Bright Light Medical Imaging, Chicago-area centers | MRI without contrast | $345 self-pay | Professional fee is not separately defined; specialized MRI studies have separate rows. | Effective January 1, 2026, for appointments on or after that date. |
Confirm the exact center and study before booking. The group sheet does not identify a scanner location for this row or establish that every specialized noncontrast study costs the same.
What to ask for an all-in written estimate:
- Which exact facility, procedure or CPT, body part and contrast protocol does the estimate cover?
- Does the total include the scan, facility charge and radiologist interpretation? Itemize contrast, sedation, labs and any other separate bills.
- Am I eligible for this self-pay offer, when is payment due, and how long is the written price valid? What changes could increase the total?
- If using insurance instead, ask the plan about network status, authorization and a separate benefit-based estimate. Ask whether a self-pay purchase receives any deductible credit; do not assume it does.
Where Prescience fits for an Illinois employer
At Prescience, we design and run your company’s health plan, from setup and enrollment to claims, compliance and COBRA. The plan offers an effective $0 deductible, simple copays shown before a visit, a low out-of-pocket maximum, a broad national PPO network plus providers we contract with directly, and 24/7 physician-led care navigation. The care team helps find providers, book appointments and explain costs up front.
I would compare the written Prescience offer with the same census, contribution policy and provider checklist used for other options. Your company can keep its payroll provider, and the plan can start midyear. A local group policy may be the better fit if it meets the team’s provider needs and budget. An individual coverage allowance may fit employees who prefer individual policies and understand the enrollment work. Make the decision from the actual benefits and terms available to your company.
See what your team would pay with Prescience
Answer a few questions about your team and get a quote in about 60 seconds, or talk it through with one of our benefits experts.


