---
title: Colorado HB 25-1002
type: entity
entity_type: organization
domain: health
status: active
supports:
- Colorado HB 25-1002 establishes the first state-level outcomes data testing authority for behavioral health parity enforcement, creating a potential natural experiment for access-metric enforcement
reweave_edges:
- Colorado HB 25-1002 establishes the first state-level outcomes data testing authority for behavioral health parity enforcement, creating a potential natural experiment for access-metric enforcement|supports|2026-05-02
---

# Colorado HB 25-1002

**Type:** State legislation  
**Status:** Enacted, effective January 1, 2026  
**Jurisdiction:** Colorado  
**Focus:** Behavioral health parity enforcement through outcomes data testing

## Overview

Colorado House Bill 25-1002 establishes the first state-level legislative framework explicitly requiring outcomes data testing for behavioral health parity compliance. The law grants the Colorado Insurance Commissioner authority to promulgate rules establishing parity data testing using outcomes data and documented access timelines for follow-up behavioral health visits.

## Key Provisions

**Clinical criteria 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.

**Outcomes-based enforcement authority:** The Insurance Commissioner may establish:
- 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

**Regulatory infrastructure:** The law builds on Colorado's existing MHPAEA Parity Report infrastructure (conducted by Health Services Advisory Group), which already audits outcomes data including denial rates, prior authorization timelines, and access metrics across managed care entities.

## Significance

HB 25-1002 represents a categorical shift from MHPAEA's process-based compliance requirements (NQTLs, prior authorization procedures) to outcome-based enforcement. The law attempts to address the two-level access problem: MHPAEA enforcement closes coverage design gaps (level 1) but not reimbursement-driven access gaps (level 2). Colorado's approach attempts level 1.5 enforcement by requiring outcome-based demonstration of access parity.

The natural experiment value depends on subsequent rulemaking defining specific outcomes metrics and enforcement thresholds, expected 2026-2027.

## Timeline

- **2025-12-01** — HB 25-1002 enacted by Colorado General Assembly
- **2026-01-01** — Law becomes effective, granting Insurance Commissioner rule-making authority for outcomes data testing

## Sources

- [Colorado General Assembly HB 25-1002 bill text](https://leg.colorado.gov/bills/hb25-1002)
- [Consumer Financial Services Law Monitor coverage](https://www.consumerfinancialserviceslawmonitor.com/2025/12/colorado-law-adopting-uniform-utilization-review-standards-for-behavioral-health-treatment-goes-into-effect-january-1-2026/)
- [Colorado HCPF Parity page](https://hcpf.colorado.gov/parity)
- [Greenberg Traurig Behavioral Health Law Ledger December 2025](https://www.gtlaw.com/en/insights/2025/12/behavioral-health-law-ledger-december-2025)