SB 3114 · Illinois · introduced Feb 2, 2026Introduced

SB 3114

TRANSPARENCY IN DOWNCODING ACT

High RiskCreates new compliance requirements or restricts common AI uses. Action needed.

TL;DR

Illinois SB 3114, introduced by Sen. Dave Koehler with broad bipartisan support, would require health insurers to disclose when they use AI or algorithms to 'downcode' medical claims (paying providers less than what was billed by reassigning codes). Insurers would have to explain the downcoding decision, identify whether AI was involved, and give providers a way to appeal.

How This Might Impact Your Business

Health insurers operating in Illinois would need to disclose every time they downcode a claim, including whether an AI or algorithm made or assisted the decision.

Insurers using automated claim review tools (Optum, Cotiviti, EXL, internal ML models) would need to document the specific reasoning behind each downcoded claim, not just the outcome.

Healthcare providers (hospitals, physician groups, billing companies) gain a formal appeal pathway, which means insurers should expect higher appeal volumes and need staffing to handle them.

Revenue cycle management vendors and AI claims-adjudication startups selling into Illinois payers would need product changes to surface AI involvement and rationale in a provider-facing format.

Non-compliance would likely fall under Illinois Department of Insurance enforcement, exposing insurers to regulatory penalties and potential bad-faith claims from providers.

Bill is still in introduced status with no effective date set, but the large bipartisan co-sponsor list (60+ legislators) signals strong momentum toward passage.

Self-insured ERISA plans would likely remain exempt under federal preemption, narrowing direct impact to fully-insured commercial, Medicaid managed care, and state-regulated plans.

What Should You Do

1

Health insurance executives should inventory every automated or AI-assisted tool currently used in claims adjudication and coding review, and confirm each can generate a human-readable rationale.

2

Compliance and legal teams should draft template downcoding disclosure and appeal notices now so they can be deployed quickly if the bill passes.

3

Provider organizations and billing companies should prepare to capture and track downcoding notices to build appeal workflows and identify payer patterns.

4

Vendors selling AI claims tools to Illinois payers should add transparency and audit-log features to their roadmap and brief payer clients on readiness.

5

Monitor the bill through Illinois Senate Insurance Committee; given the 60+ co-sponsor list, assume passage is plausible and plan a 6 to 12 month implementation runway.

Who It Affects

Health InsuranceHealthcare ProvidersHealthcare AIRevenue Cycle ManagementMedical BillingInsurTech

Sponsors

Dave Koehler (Democratic)Julie Morrison (Democratic)Cristina Castro (Democratic)Robert Peters (Democratic)Laura Fine (Democratic)Andrew Chesney (Republican)Christopher Belt (Democratic)Graciela Guzmán (Democratic)Paul Faraci (Democratic)Suzy Glowiak Hilton (Democratic)Linda Holmes (Democratic)Ram Villivalam (Democratic)Mike Porfirio (Democratic)Meg Loughran Cappel (Democratic)Doris Turner (Democratic)Sally Turner (Republican)Sue Rezin (Republican)Napoleon Harris (Democratic)Rachel Ventura (Democratic)Elgie Sims (Democratic)Lakesia Collins (Democratic)Mike Halpin (Democratic)Mike Simmons-Gessesse (Democratic)Chris Balkema (Republican)Emil Jones (Democratic)Sharon Chung (Democratic)Bill Hauter (Republican)Jeff Keicher (Republican)Katie Stuart (Democratic)Omar Williams (Democratic)Nicolle Grasse (Democratic)Dee Avelar (Democratic)Ryan Spain (Republican)Dave Vella (Democratic)Rick Ryan (Democratic)Anthony DeLuca (Democratic)Joyce Mason (Democratic)Mary Gill (Democratic)Michael Kelly (Democratic)Natalie Manley (Democratic)Matt Hanson (Democratic)Marti Deuter (Democratic)Tracy Katz Muhl (Democratic)Harry Benton (Democratic)Gregg Johnson (Democratic)Will Davis (Democratic)Jen Gong-Gershowitz (Democratic)Kelly Cassidy (Democratic)Michelle Mussman (Democratic)Maurice West (Democratic)Mary Beth Canty (Democratic)Bob Morgan (Democratic)Stephanie Kifowit (Democratic)Murri Briel (Democratic)Sue Scherer (Democratic)Lisa Davis (Democratic)Rita Mayfield (Democratic)Mike Crawford (Democratic)Larry Walsh (Democratic)

Status Timeline

  1. introduced

    Added Alternate Co-Sponsor Rep. Lawrence "Larry" Walsh, Jr.

    May 27, 2026

AI-generated analysis for informational purposes only. Not legal advice. Always consult a qualified attorney for legal guidance.Last action May 27, 2026

Need help preparing your team for AI compliance?

Talk to LaunchReady about AI Training

Get the Weekly AI Law Roundup

Plain-English summaries of the AI laws that matter for your business. Every Monday. Free.

No spam. Unsubscribe anytime.