Bifurcated

Illinois No Surprises Act & IDR Rules

Last verified: July 2026 · For informational purposes only, not legal advice

Quick answer: Illinois is a bifurcated state. Some disputes are governed by Illinois's own specified state law, while others default to the federal No Surprises Act IDR process depending on the plan type and service involved.

How it works

Illinois's specified state law applies broadly to emergency items and services, non-emergency items and services at in-network facilities, and (since July 2022) items and services furnished by HMO plans. The federal IDR process applies mainly to air ambulance services.

Key dates

Federal No Surprises Act protections took effect January 1, 2022. State-specific protections vary — check the official source below for exact effective dates in this state.

Official source: Centers for Medicare & Medicaid Services — Illinois enforcement letter and specified state law documentation (cms.gov/nosurprises)

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