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Updated FAQs: Illinois House Bill 5258 Dependent Parent and Stepparent Coverage

Nov. 19 2025

Applies to Individual & Family Markets, including Grandfathered and Transitional; Fully insured group, including Cost Plus, Minimum Premium, PPO, HMO, POS, Grandfathered and Transitional*

We have updated our previous FAQs for House Bill 5258 – new or updated questions are noted below in red.

House Bill 5258 requires health plans that cover dependents to offer coverage to a parent or stepparent who meets the following criteria:

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

Q: What’s the impact to our plans?
A:We are updating our coverage to allow subscribers to add dependent parent(s)/stepparent(s) to their plan under the dependent type, “Sponsored Dependent Parent.”

  • 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.

Q: When does it go into effect?
A: Upon renewal on or after Jan. 1, 2026, for example:

  • 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: 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.

NEW Q: When will the Blue Cross and Blue Shield of Illinois group enrollment form be updated to include dependent parent/stepparent?
References to Dependent Parent will not be on the BPA. The Dependent Parent language is included in the GAD because the definition of “Covered Person” was broadened to include Dependent Parent.

NEW Q: What is the code value for the dependent parent/stepparent that should be sent over to BCBSIL on the file?
The code for dependent parent/stepparent is “Sponsored Dependent Parent.” The relationship code for Sponsored Dependent Parent that should be passed on the 834/5010 file is relationship value 03.

  • Reminder: This is not the same code as Disabled Adult Dependent (“DIS”) and it does not require any forms to certify status, as the disabled code does.

NEW Q: Will BCBSIL require documentation to certify the status of a dependent parent/stepparent?
No. There are no forms required to certify dependent parent status. BCBSIL will not be monitoring dependent parent/stepparent eligibility.

NEW Q: Can this update be suppressed for clients whose benefit administration vendors are not able to accommodate this new value by Jan. 1. 2026?
We’re not able to change our systems logic at this time. If the client/vendor isn’t able to report that information in their AEP enrollment file, that won’t be an issue. Once they’re able to do so, the value will be in place.

NEW Q: What tiering structure will Dependent Parent/Stepparent coverage follow?
A: We are following the same tiering structure as Child Amount for Dependent Parent.

  • Subscriber only + dependent parent/stepparent = Employee + Child
  • Subscriber + spouse + dependent parent/stepparent = Employee + Family
  • Subscriber + spouse + at least one child + dependent parent/stepparent = Employee + Family
  • Subscriber + at least one child + dependent parent/stepparent = Employee + Children
  • Subscriber + dependent parent/stepparent+ second dependent parent/stepparent = Employee + Children

NEW Q: For plans using age rating, how will dependent parent/stepparent be calculated?
The age of the dependent parent/stepparent will be used to calculate the monthly premium, as an additional amount on the existing policy premiums being paid. Each person on the policy is rated/charged based on their own age, regardless of relationship codes.

NEW Q: Why can’t the dependent parent/stepparent of the subscriber’s spouse also be eligible for coverage?
We are aligning with the Illinois Health Insurance Marketplace (Get Covered IllinoisSM), Leaving site icon which only extends the coverage to the dependent parent/stepparent of the subscriber.

NEW Q: Are dental or vision plans also eligible for dependent parent/stepparent coverage?
No, standalone dental or vision plans are not in scope for this mandate.

NEW Q: Would the dependent parent/stepparent also be eligible for COBRA if the subscriber’s coverage terminates?
If the subscriber loses coverage due to job loss, the subscriber can choose to elect COBRA for themselves and any dependents, including dependent parent/stepparents. The dependent parent/stepparent cannot elect COBRA coverage on their own.

Q: Does this mandate apply to Cost Plus plans?
A: Yes, 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 Leaving site icon 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.

Q: Can a subscriber add a parent/stepparent outside of Open Enrollment?
A: Dependent parent(s)/stepparent(s) can be added outside of Open Enrollment if they have a qualifying event according to the terms of their plan. Some examples may include:

  • 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.

UPDATED Q: What happens if a subscriber adds a dependent parent/stepparent who is currently enrolled in Medicare?

  • If Individual & Family Markets (IFM) Members are not eligible to enroll in both a Medicare and a Qualified Health plan at the same time.
  • If Group: 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.

UPDATED Q: Can a subscriber add a dependent parent/stepparent who has not yet qualified for Medicare but then becomes eligible later in the year?

  • If IFM: Members are not eligible to enroll in both a Medicare and a Qualified Health plan at the same time.
  • If Group: the parent/stepparent of the subscriber can remain on the plan if they meet the criteria for qualifying relative and live in the service area.

UPDATED Q: How will Medicare coordinate with the BCBSIL plan if a dependent parent/stepparent is enrolled?

  • For IFM plans: Medicare does not coordinate with IFM plans. See the CMS Medicare and Marketplace resource Leaving site icon for more information.
  • For Group plans: Medicare Secondary Payor guidelines will be followed accordingly based on the information provided by each employer group at least annually.
    • If the Group is 100+, and the dependent parent/stepparent is under 65 and disability entitled, the Group plan will be primary
    • If the Group is less than 100 lives, and the dependent parent/stepparent is 65+ and age entitled, Medicare will be primary

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.

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