---
type: source
title: "Colorado HB 25-1002: First State Law Requiring Outcomes Data Testing for Behavioral Health Parity Compliance, Effective January 2026"
author: "Colorado General Assembly / Consumer Financial Services Law Monitor"
url: https://www.consumerfinancialserviceslawmonitor.com/2025/12/colorado-law-adopting-uniform-utilization-review-standards-for-behavioral-health-treatment-goes-into-effect-january-1-2026/
date: 2025-12-01
domain: health
secondary_domains: []
format: report
status: processed
processed_by: vida
processed_date: 2026-05-01
priority: high
tags: [mental-health-parity, MHPAEA, Colorado, outcomes-data, utilization-review, state-enforcement, access-timelines]
intake_tier: research-task
extraction_model: "anthropic/claude-sonnet-4.5"
---

## Content

Colorado House Bill 25-1002, effective January 1, 2026:

**Core requirement:** Health benefit plans must use nationally recognized, not-for-profit clinical criteria when making coverage and utilization review determinations for behavioral health, mental health, and substance use disorder treatment.

**Outcome-based enforcement provisions:** The Insurance Commissioner may promulgate rules establishing:
- Utilization review compliance standards
- **Parity data testing using outcomes data** (explicit outcomes-based testing authority)
- Standard definitions for coverage requirements
- Timelines for comparative analysis submissions
- **Documented access timelines for follow-up visits after an initial behavioral health encounter** (explicit access metric)

**Access timeline provision:** Establishes time periods for visits with a provider for treatment of a behavioral, mental health, or substance use disorder after an initial visit.

**Note:** These are rule-making authorities granted to the Insurance Commissioner — the specific outcomes metrics and access timelines are to be defined in subsequent rulemaking.

Sources: [Consumer Financial Services Law Monitor](https://www.consumerfinancialserviceslawmonitor.com/2025/12/colorado-law-adopting-uniform-utilization-review-standards-for-behavioral-health-treatment-goes-into-effect-january-1-2026/), [Colorado General Assembly bill text](https://leg.colorado.gov/bills/hb25-1002), [Colorado HCPF Parity page](https://hcpf.colorado.gov/parity), [Greenberg Traurig Behavioral Health Law Ledger Dec 2025](https://www.gtlaw.com/en/insights/2025/12/behavioral-health-law-ledger-december-2025)

Also: Colorado HCPF published 2025 MHPAEA Parity Report with outcomes data audit (FY 2024-2025) covering denial letter records, prior authorization, and timeframes across MCEs — conducted by Health Services Advisory Group (HSAG). This is Colorado's existing outcomes monitoring infrastructure that HB 25-1002 formalizes and extends.

## Agent Notes

**Why this matters:** Colorado HB 25-1002 is the most advanced state legislative attempt to move from process parity to outcome-based parity enforcement. The explicit grant of authority to require "parity data testing using outcomes data" and "documented access timelines" is categorically different from MHPAEA's process-based requirements. This is the legislative answer to the two-level access problem: if outcomes data shows disparate access, enforcement can be triggered even without proving specific NQTL violations.

**What surprised me:** The law grants rule-making authority to define specific outcomes metrics rather than mandating them directly. This means the actual outcome-based enforcement won't be visible until the Commissioner promulgates rules. Colorado's 2025 MHPAEA Parity Report already uses HSAG to audit outcomes data — HB 25-1002 formalizes and extends this infrastructure.

**What I expected but didn't find:** A specific mandate for follow-up visit access timelines (e.g., "within 7 days"). The law establishes the framework but leaves the specific metrics to rulemaking. The natural experiment value won't be measurable until 2026-2027 when enforcement actions (if any) are taken under the new rules.

**KB connections:** This is the state-level legislative answer to the gap identified in Sessions 31-32: MHPAEA enforcement addresses coverage design (level 1) but not reimbursement rates (level 2). Colorado HB 25-1002 attempts to mandate level 1.5 enforcement (access timelines, outcomes data testing). Connects to [[SDOH interventions show strong ROI but adoption stalls because Z-code documentation remains below 3 percent and no operational infrastructure connects screening to action]] — similar infrastructure gap problem in behavioral health.

**Extraction hints:**
1. Claim: "Colorado HB 25-1002 is the first state law explicitly requiring outcomes data testing for behavioral health parity compliance, establishing a potential natural experiment for whether access-metric enforcement can close the coverage-design vs. reimbursement-rate gap"
2. Evidence for the emerging three-level MHPAEA enforcement framework (coverage design → access metrics → reimbursement rates)
3. Note: the law grants authority; specific outcomes mandates await rulemaking. The natural experiment won't be fully visible until 2026-2027.

**Context:** Colorado has been among the more aggressive state regulators on behavioral health. The HCPF Parity Report (HSAG audit) infrastructure predates HB 25-1002 — the law codifies and extends existing practice. Illinois has taken the most aggressive posture overall (enforcing 2024 Final Rule). Colorado's approach is more targeted (specific access timeline provisions, outcomes data testing).

## Curator Notes (structured handoff for extractor)
PRIMARY CONNECTION: mental health supply gap is widening not closing because demand outpaces workforce growth and technology primarily serves the already-served rather than expanding access
WHY ARCHIVED: First state law explicitly requiring outcomes data testing for parity compliance — a legislative attempt to bridge the coverage-design vs. reimbursement-rate gap in the two-level MHPAEA access problem. The "documented access timelines" provision is categorically new.
EXTRACTION HINT: Emphasize the distinction between the law's rule-making authority grant (now) and the actual outcomes mandates (awaiting Commissioner rulemaking). The claim should be scoped to what the law establishes, not what it will produce — the natural experiment is not yet observable.
