Sarah Borders September 2, 2026 3 min read

Updated Model Employer CHIP Notice: Illinois Added, Plus New Jersey Change

The Department of Labor (DOL) has updated the Model Employer Children’s Health Insurance Plan (CHIP) Notice as of July 31, 2026. This version adds Illinois to the list of states providing premium assistance, which means that employers must now also distribute the notice to employees and dependents residing in Illinois. This new version also reflects a revised Medicaid website address for New Jersey. All other state entries remain unchanged from the January 31, 2026, version.

Applies To:

All size employers sponsoring any type of medical plan in which employees pay part of the premium, with employees living in a state with a Medicaid and/or CHIP premium assistance subsidy (which now includes Illinois).

Go Deeper:

An employer must provide the Employer CHIP Notice to employees eligible for the employer’s medical plan who reside in a state with a premium assistance subsidy, regardless of the employer’s location.The notice is typically updated at the end of January and end of July each year reflecting whether states made changes to phone, email, and website information. For the July 2026 update, Illinois has been added to the list of premium subsidy states, while New Jersey made changes to its website address.Employers sponsoring a group health plan should provide the CHIP notice with other health plan eligibility materials, such as new hire and annual open enrollment materials.

Penalties for Non-Compliance:
Employers who fail to provide the Employer CHIP Notice to employees in premium assistance states may face a penalty of up to $145 per person per day. The Model Employer CHIP Notice is considered a safe harbor way to meet the notice language requirements. While the employer is permitted to remove from the notice any states in which employees do not reside, keep in mind that if they eventually hire anyone in such a state, they need to add that state back to the notice.

Practical Impact to Employers:
The intent of the notice is to ensure employees understand how to contact a state to inquire about and apply for premium assistance. Even though it is not necessary to redistribute the notice just because a newer version has become available, it is strongly recommended employers always provide the latest version of the model notice to incorporate into plan materials for new hires and for open enrollment (in this instance, particularly if there are employees or other plan participants residing in Illinois or New Jersey).

Sarah Borders

Principal, Benefits Compliance Solutions. Sarah has spent the last 15 years in the employee benefits industry, has numerous designations and serves on NAHU’s Employer Working Group Subcommittee and is an active board member of Austin AHU. She recently stepped down as Vice President of Benefits Compliance at one of the nation's largest brokerage firms to start her own compliance consulting practice. Her designations include an active license with the Texas Department of Insurance, CEBS (Certified Employee Benefits Specialist), Certified Health Care Reform Professional, HIPAA certification and Health Care Service Associate. She holds an MBA from Texas A&M Corpus Christi and a BA from University of Incarnate Word. Her consulting firm, Benefits Compliance Solutions, partners with employers to identify unknown risks and avoid hundreds of thousands of dollars in fines and lawsuits from failure to comply with their healthplan obligations.