Transparency in Downcoding Act (Public Act 104-0568)
Illinois | SB 3114
Categories
Key Requirements
A payor may not implement a policy or use an algorithm or automated process that bypasses evaluation of all information submitted by the billing health care professional in order to downcode a claim. Automated processes may only flag claims for possible downcoding; every downcoding determination must be made or reviewed by a natural person and must follow AMA CPT coding guidelines in effect at the time. The Act also requires detailed notice of downcoding decisions and an appeals process.
Regulated Parties
Health care payors, health insurance issuers and managed care organizations (ERISA self-insured plans, workers' compensation and occupational disease coverage excluded)
Enforcement
Illinois Department of Insurance; managed care organizations must comply via the Illinois Public Aid Code
Sources
Notes
One of only two AI-downcoding laws enacted nationally as of Q2 2026 (with Indiana HB 1271). Separately, Illinois enacted the Artificial Intelligence Safety Measures Act (SB 315, PA 104-0538, signed 7/6/2026), a frontier-model law that is not healthcare-specific. Illinois HB 2411 (104th GA) is the Tiny Homes Act, not a health AI bill, and no enacted health AI law numbered HB 4330 could be confirmed.
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