Bill
HB 3645
Requires large-city EMS providers to report overdose data within 24 hours to a secure OD mapping system, protecting privacy and restricting law enforcement use.
Status and effective date
- Enacted as Public Act 104‑0321. Governor approved 8/15/2025. Effective date: January 1, 2026.
- Amends Section 3.233 of the Emergency Medical Services (EMS) Systems Act (210 ILCS 50/3.233).
Purpose
- To standardize and require rapid reporting of suspected or actual opioid overdoses by certain licensed EMS vehicle providers into an overdose‑detection mapping system, while protecting patient privacy and restricting law‑enforcement use of the surveillance data. The law aims to improve overdose surveillance and support targeted public‑health and harm‑reduction responses.
Key provisions
- Definitions: “Covered vehicle service provider” is a licensed vehicle service provider that is a municipality with a population of 1,000,000 or greater (i.e., large city providers). “Covered vehicle service provider personnel” includes EMS licensees (EMT, EMT‑I, A‑EMT, EMT‑P) and, in the enrolled version, also lists Paramedics and various public‑health RN/APRN/PA designations.
- Documentation requirement: Covered personnel who treat and either release or transport an individual for a suspected/actual opioid overdose must document specified data in the patient care report within 24 hours.
- Required data elements (patient care report): (1) date and time of overdose; (2) location as latitude/longitude (no more than 4 decimal places); (3) whether an opioid‑overdose reversal drug (e.g., naloxone) was administered; (4) whether the overdose was fatal or nonfatal at initial encounter and during transport.
- Reporting to surveillance platforms: Covered providers must transmit the listed data to the Washington/Baltimore HIDTA Overdose Detection Mapping Application (ODMAP) or a similar secure federal/state/local platform approved by the Department.
- Privacy and use limits: Data submitted must not include information that allows or creates a risk of identifying the individual. Data reported under this section may not be used in opioid‑use criminal investigations or prosecutions, welfare checks, or warrant checks of the treated individual.
- Misuse and rules: Any misuse of the information must be reported (including reporting misuse to ODMAP or similar platforms). The Department may adopt rules setting standards for reporting misuse.
- Liability and HIPAA: Good‑faith reporters are immune from civil or criminal liability for making reports. Reporting may proceed under HIPAA exceptions for public‑health surveillance; data is limited for public‑safety and public‑health use.
- Department coordination: Directs the Department to enhance information sharing, work with Regional Care Coordination Advisory Councils or a risk‑reduction advisory group, partner with harm‑reduction providers, local health departments, and law enforcement to identify performance measures and use the surveillance data to develop evidence‑based prevention strategies.
Who is affected
- Primary: covered municipal EMS vehicle service providers in jurisdictions with population ≥1,000,000 and their licensed EMS personnel.
- Secondary: the Department (Department of Public Health), public‑health and harm‑reduction organizations, law enforcement (as data users but with restricted uses), and vendors/operators of the overdose mapping platforms.
Potential impacts and considerations
- Public‑health: Improves timeliness and geographic specificity of overdose surveillance to target harm‑reduction and prevention resources.
- Privacy and trust: Explicit prohibitions on criminal use and requirements to avoid identifiable data aim to encourage EMS reporting and protect patients, but latitude/longitude reporting (even at 4 decimal places) and platform security will be scrutinized.
- Operational: Imposes a 24‑hour reporting timeframe and technical reporting obligations on large municipal EMS providers; state rulemaking will shape implementation details and misuse reporting procedures.
- Scope: The statutory reporting requirement is limited to covered providers in very large municipalities; smaller jurisdictions and private EMS providers are not required under this provision.
Compiled from official sources — confirm details with the bill’s official record.
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