IL House Bill 2464: Neonatal Cost Share

Nov. 19 2025

Applies to Individual & Family Markets, including PPO, HMO, POS, Grandfathered and Transitional; Student Health plans; Fully Insured including Small Group, Mid-Market, Large Group, PPO, HMO, POS, Grandfathered and Transitional; Blue Balance Funded^SM *

Illinois House Bill 2464 requires neonatal intensive care emergency services to be covered as in-network, regardless of the provider’s network status.

What you need to know:
A previous Illinois law, House Bill 4703, established surprise billing protections intended to reinforce the federal No Surprises Act and set a state-specific dispute resolution process. But HB 4703 did not specifically address neonatal intensive care. HB 2464 clarifies that neonatal intensive care emergency services must be protected from surprise billing, just like other emergency services.

What’s the impact to Blue Cross and Blue Shield of Illinois plans?
BCBSIL plans already process neonatal intensive care claims as emergent, so there is no anticipated impact to member benefits as a result of this bill. Inpatient services during a NICU stay should continue to be covered at the in-network level when delivered at a Level II, III or IV NICU.

Does IL HB 2464 protect members for any services not included in existing federal surprise billing law?
No. Existing federal surprise billing law protects members from surprise billing when they receive emergency care, which would include neonatal intensive care emergency services. Now state law specifically calls out those services as being protected by surprise billing as well.

Are all neonatal intensive care services considered “emergency” treatment?
NICU stays are considered emergent for both PPO and HMO plans, except for routine services performed at a Level I NICU. These services are not in the scope of this mandate.

*This article, or a similar version, is being shared with employer groups in the BlueVISION^SM newsletter or news alert.