News from the Blues

June 25, 2025

Illinois House Bill 5258 Dependent Parent and Stepparent Coverage; FAQs Included

• Individual & Family Markets plans, including Grandfathered and Transitional
• UPDATE: Student plans
• Fully Insured Group plans, including Cost Plus, Minimum Premium, PPO, HMO, POS, Grandfathered and Transitional

• The parent/stepparent must meet the definition of qualifying relative under 26 U.S.C. §152(d)  of the Internal Revenue Code (IRC); and
• The parent/stepparent must live within the service area of the subscriber’s health plan.

• The parent(s)/stepparent(s) of the subscriber can be added if they meet the criteria for qualifying relative and live in the service area of the plan.
• Parent(s)/stepparent(s) of the subscriber’s spouse are not eligible for coverage.

• If a group has a Jan. 1, 2026, renewal, their subscribers can add a dependent parent/stepparent during their plan’s open enrollment for Jan. 1, 2026, coverage.
• If a group has a Sept.1, 2025, renewal, their subscribers can add a dependent parent/stepparent during their plan’s open enrollment for Sept. 1. 2026, coverage.

Q: Does this mandate apply to Cost Plus plans?
A: This mandate applies to all fully insured group plans, including Cost Plus.

Q: Does the dependent parent/stepparent have to live with the subscriber to be added to their plan?
A: A dependent parent/stepparent must meet the definition of qualifying relative  under IRS code 26 U.S.C. §152(d). A dependent parent/stepparent does not have to live with the subscriber to be added to their plan. They do have to live in the service area of the subscriber’s plan, per HB 5258.

Q: What is the service area of a plan?
A: The service area generally describes where a member is covered/can access services, but the definition varies by plan, and may or may not include geographic restrictions. You can refer to the benefit booklet for the service area definition for a specific plan.

Q: Who can be added as a dependent parent/stepparent?
A: The parent(s)/stepparent(s) of the subscriber can be added if they meet the criteria for qualifying relative and live in the service area of the plan.

• The parent/stepparent loses coverage due to the death of a spouse or divorce (and meets the criteria for qualifying relative and lives in the service area of the plan).
• The parent/stepparent loses coverage due to job loss (and meets the criteria for qualifying relative and lives in the service area of the plan).
• The parent/stepparent moved, changing their health plan options (and meets the criteria for qualifying relative and lives in the service area of the plan).

Q: Will there be a one-time Special Enrollment period for adding dependent parent(s)/stepparent(s)?
A: This new law goes into effect upon renewal on or after Jan. 1, 2026, so there will not be a Special Enrollment for adding dependent parent(s)/stepparent(s). They can be added outside of Open Enrollment if they have a qualifying event according to the terms of the plan.

Q: Can an ASO account add dependent parent/stepparent coverage?
A: ASO groups can elect to add dependent parent/stepparent coverage. If an ASO account wants to add this dependent type, it should be documented in the renewal paperwork. We encourage any ASO accounts electing this coverage to add for a future effective date.

Q: Is there an age limit for dependent parent/stepparent coverage?
A: No. As long as the dependent parent/stepparent meets the definition of a qualifying relative and lives in the service area, they are eligible to be added under this mandate.

Q: Can a subscriber add a dependent parent/stepparent who is currently enrolled in Medicare?
A: The parent/stepparent of the subscriber can be added to the plan if they meet the criteria for qualifying relative and live in the service area.

Q: Can a subscriber add a dependent parent/stepparent who qualifies for Medicare, but is still working?
A: The parent/stepparent of the subscriber can be added to the plan if they meet the criteria for qualifying relative and live in the service area.

Q: Can a subscriber add a dependent parent/stepparent who has not yet qualified for Medicare but then becomes eligible later in the year?
A: The parent/stepparent of the subscriber can be added to the plan if they meet the criteria for qualifying relative and live in the service area.

• For IFM plans: Medicare will be the primary payor over the IFM plan.
• For Group plans:
• If the dependent parent/stepparent is under 65 and enrolled in Medicare due to disability, a large group (100+) health plan will be the primary payor over Medicare. For group health plans of employers with less than 100 employees, Medicare will be the primary payer.
• If the dependent parent/stepparent is 65+ and enrolled in Medicare due to age, Medicare will be the primary payor.

Q: Can a subscriber/spouse add a parent/stepparent who is enrolled in Medicaid?
A: The parent/stepparent of the subscriber can be added to the plan if they meet the criteria for qualifying relative and live in the service area.

Q: How will Medicaid coordinate with the BCBSIL plan if a dependent parent/stepparent is enrolled?
A: BCBSIL will be the primary payor if a member is also enrolled in a Medicaid plan.

Q: Can a subscriber add a parent/stepparent who is no longer eligible for Medicaid?
A: Loss of other coverage would fall under the criteria for a qualifying event, and the parent/stepparent may be eligible to be added outside of Open Enrollment, according to the terms of the plan. The subscriber should follow the protocol for application based on qualifying event either through the Marketplace for IFM plans, or through their employer for group plans.

Q: How will dependent parent/stepparent coverage be captured at enrollment?
A: We will be updating paperwork and enrollment applications for all impacted plans to add “Sponsored Dependent Parent” to the list of dependent types.