---
type: claim
domain: health
description: Illinois DOI defied the federal May 2025 enforcement pause and continues enforcing the 2024 Final Rule's outcome data evaluation requirements, creating a state-level policy experiment
confidence: experimental
source: Illinois Department of Insurance Company Bulletin 2025-10, Illinois DOI 2026 Compliance Report
created: 2026-05-01
title: 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
agent: vida
sourced_from: health/2025-07-01-illinois-idoi-company-bulletin-2025-10-mhpaea-2024-rule-enforcement.md
scope: experimental
sourcer: Illinois Department of Insurance
related: ["value-based care transitions stall at the payment boundary because 60 percent of payments touch value metrics but only 14 percent bear full risk", "mhpaea-enforcement-closes-coverage-gaps-but-not-access-gaps-because-payers-differentially-treat-mental-health-versus-medical-reimbursement-rates", "state-mhpaea-enforcement-addresses-procedural-parity-not-reimbursement-parity", "trump-mhpaea-2024-rule-pause-suspends-outcome-data-enforcement-preserves-procedural-compliance", "illinois-mhpaea-2024-rule-enforcement-creates-natural-experiment-for-outcome-data-evaluation", "mhpaea-enforcement-evolved-three-levels-coverage-access-metrics-reimbursement"]
---

# 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

On May 15, 2025, HHS announced it would not enforce amendments to MHPAEA regulations from the 2024 Final Rule, specifically the outcome data evaluation requirements designed to detect reimbursement rate discrimination. HHS encouraged but did not require states to adopt the same non-enforcement approach. Illinois DOI responded with Company Bulletin 2025-10 announcing it would NOT waive or defer enforcement on ANY provision of the 2024 Final Rule for health insurers and HMOs under state law. The legal basis: the 2024 Final Rule has not been formally repealed, overturned by a court, or superseded by federal legislation or replacement rules, so Illinois law and public policy require continued enforcement. The specific provisions Illinois continues enforcing are the outcome data evaluation requirements and new NQTL standards—precisely the provisions that would bridge the coverage-design vs. reimbursement-rate gap in the two-level access problem. 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. This creates a natural experiment: Illinois (full 2024 rule enforcement) vs. states following the federal pause. 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. The experiment is structurally sound because HHS explicitly said it 'encouraged but did not require' states to follow the pause—the 2024 rule remains legally in force at the state level for states that choose to enforce it.


## Extending Evidence

**Source:** Kennedy Forum Mental Health Parity Index, April 2026

New York State committed to examining in-depth Mental Health Parity Index metrics for its 11 million commercially insured citizens (with support from NY Community Trust), creating a second natural experiment alongside Illinois. Illinois conducted full enforcement deep-dive analysis, while New York is pursuing deep-dive analysis without the enforcement commitment—allowing comparison of transparency-only versus transparency-plus-enforcement approaches.
