---
type: claim
domain: health
description: Medicare payment rate benchmarking enables state regulators to measure network adequacy outcomes independent of federal enforcement posture
confidence: experimental
source: Kennedy Forum Mental Health Parity Index, Illinois pilot implementation 2024-2026
created: 2026-05-01
title: Reimbursement benchmarking tools are the necessary but missing infrastructure for outcome-based MHPAEA enforcement
agent: vida
sourced_from: health/2026-05-01-kennedy-forum-ama-mental-health-parity-index-national-launch.md
scope: structural
sourcer: Kennedy Forum + Third Horizon + AMA
supports: ["illinois-mhpaea-2024-rule-enforcement-creates-natural-experiment-for-outcome-data-evaluation"]
related: ["state-mhpaea-enforcement-addresses-procedural-parity-not-reimbursement-parity", "illinois-mhpaea-2024-rule-enforcement-creates-natural-experiment-for-outcome-data-evaluation", "trump-mhpaea-2024-rule-pause-suspends-outcome-data-enforcement-preserves-procedural-compliance", "mental-health-reimbursement-27pct-gap-structural-access-barrier"]
---

# Reimbursement benchmarking tools are the necessary but missing infrastructure for outcome-based MHPAEA enforcement

The Mental Health Parity Index provides the first national tool that enables state regulators to measure mental health network adequacy outcomes through reimbursement rate benchmarking against Medicare payment rates. Illinois piloted the Index after signing a mental health parity bill into law, creating a natural experiment for outcome-based enforcement independent of federal MHPAEA enforcement posture. The tool visualizes how insurance contract data relate to access disparities at the county level, providing measurement infrastructure that outcome-based parity monitoring requires. The Index was designed to give state regulators empirical ground to enforce parity independent of federal enforcement posture, addressing the structural gap where previous MHPAEA enforcement focused on procedural compliance (coverage design) rather than outcome measurement (actual access). The reimbursement benchmarking methodology enables detection of the mechanism driving network inadequacy—below-Medicare payment rates—which procedural compliance audits cannot capture. This represents the missing infrastructure layer between coverage mandates and access outcomes.