Illinois House Bill 1697 introduces a new annual fee tied to prescription drug benefits, and many employers will begin seeing this charge in 2026. Most Blue Cross Blue Shield of Illinois (BCBS of IL) health plans use BCBS of IL’s subsidiary, Prime Therapeutics, as its pharmacy benefit manager (PBM), and this update applies directly to those plans. Under the Prescription Drug Affordability Act, PBMs are required to pay the State of Illinois fifteen dollars per covered individual who is enrolled in pharmacy benefits and lives in Illinois. This includes both employees and dependents. BCBS of IL & Prime Therapeutics will pay the fee to the state fund, and BCBS of IL will pass the cost through to employer groups that fall under the law.
The fee applies broadly to fully insured, Cost Plus ERISA ASO, and certain non-ERISA ASO groups such as state employee plans, school districts, and churches. It does not apply to cities, counties, municipalities, Taft-Hartley plans, or multi-employer groups. Employers using a PBM other than Prime should look to their PBM for separate guidance.
Beginning with the January 2026 billing statement, which arrives in February, affected self-insured & ASO plans will see a new line item showing this fee. It will be billed at $1.25 per member per month, totaling $15 per member annually. The 2025 fee will be based on enrollment as of August 1, 2025, while the 2026 fee will be based on enrollment as of December 2025.
IMPORTANT: Fully insured and Cost Plus plans will not see the fee itemized; instead, it will be incorporated into annual premiums.
This fee supports a state-run program known as the Prescription Drug Affordability Fund, which directs money toward cost-related initiatives, including grants for Illinois community pharmacies. Because the law was signed on July 1, 2025, insurers were unable to incorporate the fee into their 2025 pricing. To avoid sudden financial disruption, BCBSIL/Prime Therapeutics paid the initial 2025 fee up front and will spread the employer share across monthly invoices for greater transparency and easier budgeting.
Looking ahead, employers should understand how this new requirement will influence future renewals. For fully insured plans, the fee will become part of premium calculations moving forward. While it may not be the sole driver of increases, it will contribute to upward pressure in annual rates. Enrollment growth will amplify this effect. ASO plans using Prime Therapeutics will continue to see the fee passed along as a recurring monthly charge, functioning like a fixed annual cost tied directly to member counts.
Since the fee is calculated per covered individual, employers can expect year-to-year changes based on enrollment shifts alone. Adding members increases the total fee, while reductions in membership lower it. Because this fee is now a permanent requirement under Illinois law, employers should treat it as a standard component of future budgeting. Renewal conversations will need to include this cost as part of the overall pharmacy and administrative expenses, with clear communication that this is a statutory charge rather than a carrier-driven adjustment.
Unless future legislation changes the requirement, this fee will remain an ongoing part of group health plan costs in Illinois. Employers may want to review enrollment trends, budget for annual variations, and ensure leadership teams understand the purpose and permanence of this charge.