The Impact of HB 1085 on Illinois Providers

For therapists who accept insurance, reimbursement rates can make a big difference to whether private practice feels financially sustainable.

A new Illinois law could start changing that equation in 2027.

Illinois House Bill 1085, now Public Act 104-0446, introduces a minimum reimbursement floor for many in-network mental health and substance use disorder services. It also tackles some other familiar pain points for private practices, including lengthy credentialing, reimbursement while clinicians are waiting to join networks, and additional scrutiny around 60-minute therapy sessions.

For some therapists, the financial impact could be significant. For others, the change may be smaller — or may not apply at all.

Here’s what Illinois therapists need to know.

1. What is HB 1085?

HB 1085 was passed by the Illinois General Assembly in October 2025 and signed into law by Governor JB Pritzker on December 12, 2025, becoming Public Act 104-0446. The Act officially took effect June 1, 2026, with its major insurance provisions applying to qualifying plans that are issued, amended, delivered or renewed on or after January 1, 2027.

In simple terms, Illinois is putting new guardrails around how certain insurance plans pay for mental health care.

One of the biggest changes is a minimum reimbursement floor.

The goal is to bring behavioral health reimbursement more closely in line with other areas of health care and make it more sustainable for mental health professionals to participate in insurance networks.

But reimbursement is only one part of the law.

HB 1085 also creates new protections around:

60-minute psychotherapy sessions
insurance credentialing timelines
payment during certain credentialing periods
services delivered by behavioral health trainees
newly hired clinicians joining group practices
multiple medically necessary behavioral health services provided on the same day

So, while the reimbursement floor is getting most of the attention, the law could have a wider impact on how Illinois private practices work with insurance.

2. What does the law actually change?

A new minimum for in-network reimbursement

HB 1085 requires qualifying insurance plans to meet minimum reimbursement levels for in-network mental health and substance use disorder services provided by Illinois providers and facilities.

Rather than creating one universal “therapy rate,” the minimum is calculated for individual services.

That includes services classified through CPT and HCPCS codes, as well as other payment classifications used for hospitals and higher levels of care.

For private-practice therapists, that means commonly used codes such as 90791, 90834 and 90837 can have their own applicable reimbursement benchmark rather than there being one flat mental health reimbursement rate.

What is the reimbursement minimum and where does the number come from?

The law is based on Illinois reimbursement data included in a national behavioral health parity study by RTI International.

That research found a sizeable difference between reimbursement for behavioral health providers and reimbursement for medical/surgical providers.

NASW-Illinois summarizes the resulting HB 1085 formula as producing a reimbursement floor equivalent to approximately 141.7% of the applicable Medicare-based benchmark.

That number is useful for understanding the scale of the policy change, but it is not the same thing as saying every therapist will receive a 141.7% Medicare rate or a 30% raise.

Your actual change will depend on things like:

the CPT code
your geographic area
the applicable benchmark
your current contracted reimbursement
your license/provider classification
and whether the client’s insurance plan is actually subject to HB 1085

What could this mean financially?

This is where the law becomes particularly interesting for therapists running their own businesses. A change of $20 or $30 per session can look relatively small on an individual EOB.

Across an entire year, it can be much more meaningful.

Here’s an example using eligible sessions only and assuming 48 working weeks per year:

Increase per eligible session	Total Potential Increment (Assuming 15 eligible sessions/week)	Total Potential Increment (Assuming 20 eligible sessions/week)
+$10	+$7,200/year	+$9,600/year
+$20	+$14,400/year	+$19,200/year
+$30	+$21,600/year	+$28,800/year
+$40	+$28,800/year	+$38,400/year
+$50	+$36,000/year	+$48,000/year

* These are examples, not predictions. The law does not automatically add $20, $30 or $50 to every claim. Think of the table as a way of understanding why the reimbursement floor matters. Even a relatively modest change across part of an insurance-based caseload can add up over time.

There is also an important distinction: If your current contracted rate is already above the new floor, you may see little or no increase.

HB 1085 creates a minimum — not an automatic raise for every therapist.

More protection for 60-minute therapy

There is particularly good news for therapists who regularly provide medically necessary 60-minute psychotherapy.

For qualifying plans, HB 1085 specifically requires coverage of medically necessary CPT 90837 and says insurers cannot place more burdensome documentation requirements on 90837 than other psychotherapy codes.

They also cannot audit 90837 more frequently than other psychotherapy codes. This means insurers should have less ability to single out longer psychotherapy sessions for disproportionate scrutiny.

Faster credentialing

Another major change: qualifying insurers will generally need to complete the contracting process, including credential verification, within 60 days of receiving a completed application.

That doesn’t mean an insurer has to accept every provider. But it does put a time limit around a process that can currently feel open-ended.

More importantly, if the provider ultimately becomes contracted, the law allows qualifying medically necessary services delivered between the date of the completed application and the contract’s effective date to be reimbursed at the contracted rate, provided the required conditions are met and the claims are submitted after the contract becomes effective.

For a clinician building a practice, that could reduce some of the lost revenue associated with waiting months for credentialing.

3. How might HB 1085 affect different types of practices?

Individual private-practice owners

For individual providers, the biggest potential impact is fairly straightforward: better protection around in-network reimbursement.

If you accept insurance, it will be worth comparing your current reimbursement for your most frequently billed CPT codes against the applicable 2027 floors once those figures are available.

The new credentialing timeline may also make it easier for therapists who are:

joining insurance panels for the first time
adding another payer
transitioning into private practice
or expanding the number of insurance plans they accept

That could make insurance participation more predictable financially.

Group-practice owners

HB 1085 includes a provision addressing fully licensed clinicians who join a group practice but are still waiting for their own insurance contracting process to finish.

Under qualifying circumstances, their medically necessary services can be covered while they work under the supervision of an already participating, fully licensed provider within the same group. Those services are billed under the supervising provider’s rendering NPI until the incoming clinician’s contract becomes effective.

That could reduce one of the frustrating gaps group practices face when hiring: The clinician is ready to work, clients need appointments, but insurance credentialing isn’t finished yet.

HB 1085 also includes coverage provisions for qualifying behavioral health trainees working toward licensure while appropriately supervised. Their services must be billed under the supervising clinician’s rendering NPI.

For practices that train emerging clinicians, that could make those positions more financially workable.

4. Is my client’s insurance plan actually covered?

This is one of the most important questions.

Seeing Aetna, Blue Cross Blue Shield, Cigna or UnitedHealthcare on an insurance card does not automatically tell you whether HB 1085 applies.

Those companies can offer or administer very different types of health plans.

In general, the law is most relevant to qualifying Illinois-regulated commercial insurance plans, including many individual and fully insured group plans.

For example, an Illinois-regulated fully insured employer plan offered through a major carrier could potentially fall under HB 1085.

But that same insurance company might also administer a large employer’s self-funded plan, which can be governed primarily by federal law instead.

So the logo on the card isn’t enough.

When you’re unsure, ask the payer: “Is this plan fully insured or self-funded?”

5. What doesn’t HB 1085 cover?

This is where the headline “Illinois is raising therapist reimbursement” becomes misleading.

There are several important limitations.

Medicaid and CHIP

The reimbursement-floor provisions specifically exclude health plans serving Illinois Medicaid and CHIP populations.

So HB 1085 should not be interpreted as an increase to the Illinois Medicaid fee schedule.

Medicare

HB 1085 also does not change Original Medicare reimbursement.

Medicare is a federal program. The law uses federal payment benchmarks as part of its reimbursement methodology, but Illinois is not rewriting Medicare’s own reimbursement rules.

Many private-employer self-funded plans

Many larger employers pay their employees’ health claims themselves and use an insurance company simply to administer the plan.

These are often called self-funded or self-insured plans.

Because many private-employer self-funded plans are governed by federal ERISA rules, Illinois insurance mandates generally cannot be assumed to apply to them in the same way.

Out-of-network therapy

The reimbursement floor is aimed at in-network behavioral health services.

It does not create a minimum private-pay fee or a guaranteed reimbursement amount for out-of-network claims and superbills.

Providers already being paid above the floor

If you’re already being reimbursed above the new minimum, the law does not automatically require another increase.

Again: it’s a floor, not a percentage raise.

Not every plan will change on January 1

The requirements apply to qualifying policies issued, amended, delivered or renewed on or after January 1, 2027.

Many plans renew January 1. Others don’t. So we may see the impact roll out gradually during 2027 rather than every eligible reimbursement rate changing overnight.

6. How does this impact the future landscape of health insurance?

The timing of HB 1085 is particularly interesting given what therapists have recently seen with Aetna and Alma.

Earlier in 2026, Aetna proposed changes to reimbursement for providers participating through Alma.

The initial proposal included paying 90834 and 90837 at the same rate, flattening some reimbursement differences based on provider degree/training, and combining some psychiatric E/M reimbursement levels.

After provider and professional-association pushback, Alma announced that several of those changes had been partially reversed.

90834 and 90837 remained separately reimbursed, reimbursement continued to reflect degree and training, and 99214 and 99215 remained separate.

However, overall Aetna reimbursement still decreased for affected Alma providers, with the revised rates taking effect August 15, 2026.

While HB 1085 does not automatically reverse those reductions, it could in future put a bottom limit on how far reimbursement for eligible Illinois-regulated claims can fall, creating much stronger reimbursement protections around eligible Illinois-regulated claims — and gives providers another reason to ask platforms and payers how their 2027 rates will comply with the law.

7. Could this create bigger changes for mental health care in Illinois?

Hopefully — but probably not overnight. There is a bigger idea behind HB 1085:

If insurance networks don’t pay therapists enough to make participating financially sustainable, clinicians leave networks or choose not to join them.

That can leave clients with an insurance card but very few therapists they can actually see.

The new law attempts to interrupt that cycle by improving reimbursement while also making credentialing and network participation easier.

An optimistic outcome could look something like:

more sustainable reimbursement → more providers willing to accept insurance → stronger networks → better access to care.

For private practices, that could also mean less pressure to choose between financial sustainability and accepting insurance.

And the impact could extend beyond the statutory floor itself.

Recent situations such as the Aetna/Alma reimbursement changes show that provider advocacy can influence payer decisions. A legally established reimbursement floor adds another source of pressure — and another reference point — when clinicians, professional organizations and group practices push back against unsustainable rates.

8. What should you do as a therapist before 2027?

The law itself says reimbursement subject to the section must comply with the rate floor and gives the Illinois Department of Insurance authority to monitor and enforce those requirements. It does not appear to say therapists lose that protection simply because their existing contract doesn’t contain specific HB 1085 wording.

That doesn’t mean you should do nothing.

2026 is actually a great time to get your practice organized.

Know your current rates

Pull your current fee schedules or recent EOBs/ERAs. Make a simple list of what each payer currently reimburses for your most-used codes.

For example:

90791
90834
90837
90847

Without that baseline, it will be difficult to tell what actually changed in 2027.

Understand your insurance mix

Start paying attention to how many of your clients have:

Illinois-regulated fully insured plans
self-funded employer plans
Medicaid
Medicare
out-of-network benefits
private pay

The percentage of your caseload that is potentially subject to the new law will heavily influence its financial impact on your practice.

Ask payers and platforms questions

As 2027 approaches, providers can start asking:

When will your 2027 Illinois behavioral health fee schedule be available?

How are you implementing PA 104-0446?

Which of your plans are subject to the new reimbursement floor?

Will existing contracted rates update automatically when necessary?

And, if you participate through a platform such as Alma: How will PA 104-0446 affect reimbursement for Illinois clinicians participating through your contracts?

Keep records when credentialing

If you’re applying to a new insurance network, keep documentation showing exactly when your completed application was submitted. That date could become important under the new 60-day credentialing and reimbursement provisions.

Check your reimbursements in 2027

Don’t assume your payer got everything right automatically.

Once an eligible patient’s plan comes under the new requirements, compare the reimbursement you receive against your previous rate and the applicable published floor.

The bottom line

HB 1085 has the potential to be a meaningful change for Illinois mental health professionals — particularly therapists who rely heavily on commercial insurance.

For some practices, even a $20 or $30 change across eligible weekly sessions could translate into thousands — or tens of thousands — of dollars in additional annual practice revenue.

For other providers, the impact could be smaller because:

their current rates are already above the floor
much of their caseload is Medicare or Medicaid
they are primarily private pay
or many of their clients have self-funded employer plans

So rather than asking:

“How much of a raise am I getting in 2027?”

A better question is:

“Which parts of my caseload are likely to be affected, what am I being paid for those claims now, and how do those rates change as HB 1085 is implemented?”

For private-practice owners, that’s worth paying attention to.

Want to read more?

For therapists who want to dig into the details:

Illinois General Assembly — Public Act 104-0446
The actual enacted law and the most authoritative source for what HB 1085 requires.
Read Public Act 104-0446

NASW-Illinois — Summary of HB 1085
An approachable overview written specifically with Illinois behavioral health providers in mind.
Read the NASW-Illinois summary

Illinois Department of Insurance
The agency responsible for implementing and enforcing the insurance provisions of the new law.
Visit the Illinois Department of Insurance

This article is intended as general educational information for Illinois mental health professionals and should not be considered legal, billing or insurance-contract advice. Individual reimbursement and coverage will depend on the provider, service, payer, insurance product and applicable regulations.