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IL House Bill 3019/Public Act 104-0028: Behavioral Health Prior Authorization Changes

Nov. 19 2025

Applies to Individual & Family Markets; Student health plans; Fully Insured Small Group, Mid-Market, Large Group plans, including PPO, HMO, POS; Non-ERISA ASO County/Municipality/School and the State Employees plan; Blue Balance FundedSM; Medicaid*

Illinois Public Act 104-0028 establishes new requirements regarding utilization management and notification of behavioral health treatment.

What you need to know:
The law prohibits prior authorization of the following behavioral health levels of care:

  • The first 72 hours for inpatient mental health, inpatient detox, inpatient substance use or residential substance use
  • The first 48 hours for partial hospitalization
  • The first two business days for other outpatient behavioral health treatment: Transcranial Magnetic Stimulation, Electroconvulsive Therapy and psychological testing

What’s the impact to Blue Cross and Blue Shield of Illinois Individual & Family Markets, Student health, Fully Insured and non-ERISA ASO Group plans?

  • No review/prior authorization for the first 72 hours for inpatient behavioral health services as listed above.
  • No review/prior authorization for the first 48 hours for mental health partial hospitalization.
  • No review/prior authorization for the first two business days for other outpatient behavioral health treatment: Transcranial Magnetic Stimulation and psychological testing.

What’s the impact to Blue Cross and Blue Shield of Illinois Medicaid plans?

  • No review/prior authorization for the first 72 hours for inpatient mental health care if providers notify BCBSIL within 48 hours of admission.
  • No review/prior authorization for the first 24 hours for substance use residential treatment if providers notify BCBSIL within 24 hours.
  • No review/prior authorization for the first 24 hours for outpatient behavioral health care, including partial hospitalization and intensive outpatient treatment, if providers notify BCBSIL within 24 hours.

When do the prior authorization changes noted above go into effect?

  • Jan. 1, 2026, regardless of renewal.

*This article, or a similar version, is being shared with employer groups in the BlueVISIONSM newsletter or news alert.