IHA Daily Briefing: December 10

Governor Signs into Law Immigration Bill Affecting Hospitals
Yesterday, Gov. JB Pritzker signed HB 1312 /PA 104-0440, which enshrines protections of Illinois residents' constitutional rights from aggressive law enforcement activities and ensures safe access to critical public services, including healthcare services.

HB 1312 ensures immigrants and others can safely attend court hearings, protect their health information, join university communities, and access childcare for their families without fear of aggressive civil immigration enforcement actions. Additionally, the new law outlines steps to provide legal recourse for individuals harmed by law enforcement agents who knowingly violated Constitutional rights during civil immigration enforcement operations.

Significant measures in HB 1312 include:

• Holding Federal Immigration Enforcement Accountable: The Illinois Bivens Act allows for civil legal action against any law enforcement officer who knowingly violated the Illinois or United States Constitution.
• Protecting Immigrants at Illinois Courthouses: Creates the Court Access, Safety, and Participation Act, prohibiting the civil arrest of anyone in and around courthouses who is attending certain state court proceedings. Allows for civil damages for false imprisonment, including statutory damages of $10,000 if the person knew or should have known the person arrested was attending a state court proceeding.
• Ensuring Privacy at Hospitals: Creates the Health Care Sanctity & Privacy Law, preventing the unlawful release of protected health information. Requires all general acute care hospitals to implement a policy regarding interactions with law enforcement agents by Jan. 1, 2026, and all other hospitals by March 1, 2026.
• Defending Immigrants at Universities: Amends the Public Higher Education Act, barring schools from taking certain actions regarding the actual or perceived immigration status of students, employees, or those associated with them, unless required by law. Requires Illinois schools to submit procedures by Jan. 1, 2026 to approve requests from law enforcement agents attempting to enter campus.
• Safeguarding Children and Families at Day Care Centers: Amends the Child Care Act by prohibiting day care centers from sharing the actual or perceived immigration status of a child or associated person, unless required by law. Requires the Illinois Dept. of Children and Family Services (DCFS) and the Illinois Dept. of Early Childhood (IDEC) to provide know-your-rights materials, preparedness plans, and other resources to families online. Compels licensed day care centers to adopt a plan of action by Jan. 1, 2026 for interacting with enforcement agents and notifying parents if an agent requests a child's personally identifiable information.

IHA published a detailed member memo summarizing the provisions affecting hospitals in November. See a full copy of the IHA memo here.

Now that this legislation has been signed and is effective immediately, hospitals should take the following steps:

• Finalize their policies as required by the new law and be prepared to submit them to the Illinois Dept. of Public Health (IDPH) by the deadline-by Jan. 1 for general acute care hospitals, and by March 1 for all other hospitals.
• Stay alert for emergency rules issued by IDPH, which will provide a template for the notice that must be posted, as well as instructions for how to submit policies to IDPH by the deadline.

IHA will be monitoring the development of IDPH's emergency rules and will notify the membership once these become available.

Staff contact: Karen Harris

CY 2026 Medicare OPPS Top 10 List
On Nov. 25, the Centers for Medicare & Medicaid Services (CMS) published its calendar year (CY) 2026 Medicare Outpatient Prospective Payment System (OPPS) final rule. Taking into account all policy changes, we estimate CMS finalized a rate increase of 1.63% relative to CY 2025. CMS also finalized several policies that will impact hospital reimbursement and operations. IHA's Top 10 List outlines 10 policies we want IHA members to be aware of.

IHA will release a more detailed OPPS fact sheet and CY 2026 OPPS facility-specific estimated financial impact reports in the coming days.

Staff contact: Cassie Yarbrough

RFP: Training, Implementation of Brief Therapy in Integrated Care Settings
The Illinois Behavioral Health Workforce Center has announced a Request for Proposals (RFP) for organizations providing integrated primary and behavioral healthcare services to apply for funding for staff training and implementation of an evidence-based brief psychotherapy. Successful applicants will receive funding to cover the costs of expert-led trainings and staff time to train behavioral health providers in the skills and techniques of Solution-Focused Brief Therapy (SFBT). Applications are due Feb. 5 by 11:59 p.m. CT. Please view the RFP for detailed application, eligibility and programmatic information. An optional information session will be held at 2 p.m. CT on Jan. 8; click here to join the session. Questions can be directed to [email protected] and [email protected].

Coming in January 2026: AARP Community Challenge
The AARP Community Challenge is the organization's annual "quick-action" grant program that funds local projects intended to make communities more livable for people of all ages. Coming in January 2026, community-based nonprofit organizations will be eligible to apply. The applications will be due in March, and selected grantees will be announced in June. Click here for more information about the AARP Community Challenge, including links to past grantees and the types of projects AARP has funded.