Key Takeaways

  • Illinois group health insurance is regulated under both state and federal law (ERISA, ACA)
  • COBRA continuation coverage applies to employers with 20 or more employees
  • Illinois mini-COBRA applies to employers with fewer than 20 employees
  • Small group defined as 2-50 employees in Illinois
  • Mental health parity requirements apply to group health plans
Last updated: January 2026

Illinois Group Health Insurance

Illinois group health insurance is heavily regulated at both state and federal levels to protect employees and their dependents.

Regulatory Framework

RegulationApplies To
ERISAMost private employer plans
ACAAll health plans
Illinois Insurance CodeInsured group plans
Illinois HMO ActHMO group plans

Group Size Definitions

Illinois uses federal group size definitions:

Market SegmentEmployee Count
Small Group2-50 full-time equivalent
Large Group51 or more full-time equivalent

Small Group Requirements

Illinois small group health insurance must provide:

  • Guaranteed issue (cannot deny coverage)
  • Community rating (no health-based rates)
  • Essential health benefits
  • Mental health parity
  • No pre-existing condition exclusions

COBRA Continuation Coverage

The federal COBRA law requires continuation coverage:

COBRA Basics

AspectRequirement
Applies ToEmployers with 20+ employees
Duration18-36 months depending on event
PremiumUp to 102% of group rate
CoverageSame as active employees

Qualifying Events

EventDuration
Employment termination18 months
Reduced hours18 months
Divorce/legal separation36 months
Death of employee36 months
Medicare entitlement36 months
Dependent child aging out36 months

Exam Tip: COBRA applies to employers with 20 or more employees. For smaller employers, look to Illinois mini-COBRA.

Illinois Mini-COBRA

For employers with fewer than 20 employees, Illinois provides mini-COBRA continuation:

Mini-COBRA Coverage

AspectIllinois Requirement
Applies ToEmployers with 2-19 employees
DurationUp to 12 months
PremiumUp to 102% of group rate
CoverageSame benefits as active employees

When Mini-COBRA Applies

  • Employee loses coverage due to termination or reduced hours
  • Dependent loses coverage due to death, divorce, or age-out
  • Employee becomes Medicare-eligible

Mental Health Parity

Illinois requires mental health parity in group health plans:

Parity Requirements

AspectMust Be Equal
CopaysSame as medical/surgical
DeductiblesSame as medical/surgical
Annual LimitsSame as medical/surgical
Lifetime LimitsSame as medical/surgical
Treatment LimitsSame as medical/surgical

Covered Conditions

Illinois mental health parity applies to:

  • All mental health conditions
  • Substance use disorders
  • Autism spectrum disorders
  • Behavioral health conditions

HIPAA Portability

Group health plans must comply with HIPAA portability:

Key HIPAA Provisions

  • Cannot deny enrollment based on health status
  • Must provide certificate of creditable coverage
  • Limits pre-existing condition exclusions
  • Protects against discrimination
Test Your Knowledge

What is the minimum employer size for federal COBRA to apply?

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Test Your Knowledge

How long is Illinois mini-COBRA continuation coverage?

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Test Your Knowledge

What does mental health parity require in Illinois group health plans?

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Test Your Knowledge

What is the definition of a small group in Illinois?

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