# Illinois Department of Insurance

## Overview
Illinois Department of Insurance (DOI) is the state insurance regulatory agency for Illinois. As of 2025-2026, it is the most aggressive state MHPAEA enforcement jurisdiction in the United States.

## Timeline
- **2025-07-01** — Issued Company Bulletin 2025-10 announcing Illinois would NOT waive or defer enforcement on any provision of the 2024 MHPAEA Final Rule, defying the federal May 2025 enforcement pause
- **2025** — Contracted with Health Services Advisory Group (HSAG) to conduct 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
- **2026** — Published Compliance Report documenting continued enforcement of 2024 MHPAEA Final Rule provisions

## Significance
Illinois DOI'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. The 2024 Final Rule's outcome data evaluation requirements are the specific tool designed to bridge the coverage-design vs. reimbursement-rate gap in the two-level mental health access problem.

## Legal Basis
Illinois's enforcement is legally sound because the 2024 Final Rule has not been formally repealed, overturned by a court, or superseded by federal legislation or replacement rules. HHS explicitly "encouraged but did not require" states to follow the federal pause, meaning the 2024 rule remains legally in force at the state level for states that choose to enforce it.

## 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)
- [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)