---
type: source
title: "Illinois DOI Company Bulletin 2025-10: State Defies Federal MHPAEA Enforcement Pause, Enforces 2024 Final Rule in Full"
author: "Illinois Department of Insurance"
url: https://idoi.illinois.gov/content/dam/soi/en/web/insurance/companies/documents/cb-2025-10-enforcement-of-2024-mhpaea-rulemaking.pdf
date: 2025-07-01
domain: health
secondary_domains: []
format: report
status: processed
processed_by: vida
processed_date: 2026-05-01
priority: high
tags: [mental-health-parity, MHPAEA, Illinois, state-enforcement, federal-pause, 2024-final-rule, natural-experiment]
intake_tier: research-task
extraction_model: "anthropic/claude-sonnet-4.5"
---

## Content

Illinois Department of Insurance issued Company Bulletin 2025-10 in response to the federal May 2025 MHPAEA enforcement pause:

**Federal context:** On May 15, 2025, HHS announced it would not enforce amendments to MHPAEA regulations from the 2024 Final Rule. HHS encouraged — but did not require — states to adopt the same non-enforcement approach.

**Illinois response:** DOI announced it would NOT waive or defer enforcement on ANY provision of the 2024 Final Rule for health insurers and HMOs under state law.

**Legal basis:** The 2024 Final Rule has not been formally repealed, overturned by a court, or superseded by federal legislation or replacement rules. Illinois law and public policy require continued enforcement.

**Specific provisions Illinois continues enforcing** (the paused federal provisions):
- Outcome data evaluation requirements (the tool designed to detect reimbursement rate discrimination)
- New NQTL standards
- These are precisely the provisions that would bridge the coverage-design vs. reimbursement-rate gap in the two-level access problem

**Illinois infrastructure:** Illinois DOI has contracted with Health Services Advisory Group (HSAG) to conduct a Mental Health Parity Analysis of all HealthChoice Illinois and Youth Care health plans — assessing processes for MHPAEA compliance including the 2024 rule's outcome data evaluation requirements.

**Natural experiment:** Illinois (full 2024 rule enforcement) vs. states following the federal pause creates a policy natural experiment. If Illinois shows measurable improvement in mental health access metrics over 2-3 years, it would provide the strongest evidence yet that outcome-based enforcement can address the two-level access problem.

Sources: [Illinois DOI Company Bulletin 2025-10](https://idoi.illinois.gov/content/dam/soi/en/web/insurance/companies/documents/cb-2025-10-enforcement-of-2024-mhpaea-rulemaking.pdf), [ReSource Pro Compliance summary](https://www.ilsainc.com/bulletin/illinois-confirms-continued-enforcement-of-2024-mental-health-parity-rule-despite-federal-shift/), [Illinois DOI 2026 Compliance Report](https://idoi.illinois.gov/content/dam/soi/en/web/insurance/reports/reports/compliance-actions-under-state-and-federal-mhsud-coverage-and-parity-laws-2026.pdf)

## Agent Notes

**Why this matters:** Illinois is the most aggressive state MHPAEA enforcement jurisdiction in the country — enforcing the exact provisions the federal government paused. The 2024 Final Rule's outcome data evaluation requirements are the specific tool that would have bridged the coverage-design vs. reimbursement-rate gap identified in Sessions 31-32. Illinois's enforcement creates a rare policy natural experiment: we will be able to observe whether outcome data evaluation actually changes insurer reimbursement practices in one state vs. others.

**What surprised me:** HHS explicitly said it "encouraged but did not require" states to follow the pause — this means the 2024 rule remains legally in force at the state level for states that choose to enforce it. Illinois's defiance is legally sound, not merely political posturing. Other states could do the same — Illinois may not be alone.

**What I expected but didn't find:** I expected more states to join Illinois in enforcing the 2024 rule. The search showed Illinois as the most explicit defier, but didn't confirm how many other states have taken similar positions. The Georgia, Washington state enforcement fines (Session 32) were under pre-2024 rules — different from Illinois's explicit enforcement of the 2024 rule's outcome data requirements.

**KB connections:** This is the most important finding for resolving the Belief 3 question about whether the structural misalignment problem can be addressed through enforcement alone. If Illinois's outcome data evaluation enforcement changes insurer reimbursement practices, Belief 3 needs nuancing — enforcement can work when it targets the right level. Connects to the MHPAEA two-level access problem framework and the Mental Health Parity Index (same session).

**Extraction hints:**
1. Claim: "Illinois's enforcement of the paused 2024 MHPAEA Final Rule creates a natural experiment for whether outcome data evaluation can change insurer reimbursement practices for mental health providers"
2. Cross-reference with Mental Health Parity Index (April 2026): Illinois was the first state to pilot the Index — consistent with its role as most aggressive enforcement jurisdiction
3. Flag for Leo: this is a governance mechanism question (state enforcement vs. federal withdrawal) that connects to the futarchy/mechanism design domain

**Context:** Date approximate — the bulletin was issued in response to the May 2025 federal enforcement pause; exact date is sometime in 2025. The enforcement continues through 2026 based on the 2026 Compliance Report.

## Curator Notes (structured handoff for extractor)
PRIMARY CONNECTION: [[value-based care transitions stall at the payment boundary because 60 percent of payments touch value metrics but only 14 percent bear full risk]] — analogous structural problem where process compliance ≠ outcome alignment
WHY ARCHIVED: Illinois's explicit enforcement of the paused 2024 MHPAEA provisions creates a natural experiment for whether outcome-based enforcement can change reimbursement practices. This is the closest we have to empirical evidence on the two-level access problem resolution.
EXTRACTION HINT: Scope clearly: the natural experiment hasn't produced results yet (2025-2026 enforcement, outcomes won't be visible for 2-3 years). The claim should be about what the experiment is testing, not its results. Flag as a future evidence source.
flagged_for_leo: ["state vs federal enforcement withdrawal creates mechanism design question about which governance level is appropriate for structural market failures"]
