At a Glance is a Department of Health Care Policy & Financing (HCPF) publication that provides information on major initiatives, policy changes and program updates. Feel free to share At a Glance with your colleagues. Find previous editions of At a Glance on our website. Thank you for your interest! | | A Message from the Executive Director | | H.R. 1 Update: Rural Health Transformation Program and Other Federal Policy Updates | | |
Rural Health Transformation Program. The Department of Health Care Policy and Financing (HCPF) is collaborating with a broad array of stakeholders to apply for the Rural Health Transformation Program (RHTP), authorized by H.R. 1. The RHTP is designed to transform the existing rural health care infrastructure and build sustainable health care systems that expand access, enhance quality of care, and improve outcomes for members. This federally funded opportunity will provide grants totaling $50 billion from Federal Fiscal Year (FFY) 2026 through FFY 2030, with $10 billion available each year. Half of the funding will be evenly distributed to all states with approved applications, totaling an estimated $100 million per state per year. The other half will be awarded to approved states based on individual state-scored metrics and applications that reflect the greatest potential for, and scale of impact, on the health of rural communities.
Applications are due November 5, 2025, and the Centers for Medicare and Medicaid Services (CMS) is expected to announce awardees by December 31, 2025. In addition to engaging with stakeholders, HCPF is researching existing state programs and priorities to identify opportunities for alignment and efficiency; developing information on financial status and economic impact analysis; and establishing an Advisory Board to make recommendations for implementation. For more information and to sign up for the RHTP newsletter, please visit our website.
H.R. 1 Specifics and Impacts. In addition to the Rural Health Transformation Program, H.R. 1 will have a significant effect on the 375,000 low-income adults without disabilities covered through the Affordable Care Act (ACA) Medicaid Expansion. Starting in January 2027, states must implement renewal redeterminations every 6 months instead of every 12 for this population. We also need to implement Work Requirements for most “able-bodied” Expansion adults, who will need at least 80 hours per month of work, job training, school, or volunteering to maintain their Medicaid coverage. People with disabilities are not subject to the Work Requirements mandate, nor are individuals who are defined by the state as Medically Frail. More information about exemptions is on our website.
These H.R. 1 federal mandates will create administrative burden for members, county partners and Medical Assistance sites, while requiring new technology investments to build the necessary administrative systems as well as increasing eligibility processing staff to handle the workload. The loss of coverage due to H.R. 1 will also impact members, care providers, and our economy. We will be working with members, providers and stakeholders to mitigate those negative impacts in the coming months. We thank you in advance for your partnership on this important, collaborative work.
All HCPF’s emerging advances and project work necessary to comply with H.R. 1 will pursue the following shared goals. Thank you for your support in achieving these critical goals:
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North Star: Protecting Coloradans’ Access to Medicaid. Our North Star focuses on reducing inappropriate loss of Medicaid coverage impacting 375,000 Expansion members due to H.R. 1 federal mandates such as renewal determinations every 6 months versus 12, the new Work Requirements mandate, other H.R. 1 provisions and the downstreaming impact of H.R. 1 on members, providers, county and other eligibility site partners. Loss of coverage reduces the health and well-being of impacted Coloradans, fuels medical debt and personal bankruptcies, increases provider uncompensated care while also threatening available services and the health care workforce. 92% of our August 12 Webinar attendees agreed with this important North Star goal.
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Mitigation of Significant Federal Funding Clawback Risks. Medicaid and CHP+ benefits are subject to CMS’s Payment Error Rate Measurement (PERM) audits. Historically, CMS has accepted corrective action plans when audit findings exceed tolerance thresholds. Under H.R. 1, CMS federal funding clawback risk starts above a 3% error rate, with each 0.1% audit finding above 3% representing about $9.3 million General Fund in potential federal funding clawbacks. In other words, if we incur a 5% error rate, the hit to our General Fund could be around $186 million. Further, there is no longer an option to avoid state fiscal clawbacks with a corrective action plan. These PERM audits will cover 2026 eligibility determinations, so our ability to quickly implement risk mitigation initiatives is key. HCPF audit teams are evaluating the drivers of historic audit findings and the actions and resources necessary to insulate Colorado from this increasing H.R. 1 federal PERM clawback risk.
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Driving Operational Efficiencies and Compliance. Strained budgets combined with increasing administrative burden will necessitate new thinking and improved efficiencies to help us better navigate these realities. This may include county infrastructure efficiencies like the Joint Agency Interoperability work, advances in CBMS automation, increasing use of AI, other technology advances, HCPF/CDHS - County efficiency collaborative pathways, and more.
H.R. 1 Work Requirements. HCPF is actively working with CMS to pursue flexibilities to help us achieve these important shared goals. Final federal guidance will not be available until June 2026, so we are designing and building eligibility system advances leveraging interim CMS communications.
- First, CMS communications indicate states may release a “Minimum Viable Product” or MVP to be in compliance with H.R. 1 Medicaid Expansion Work Requirements effective January 2027 versus completing all the IT work and connectivity required in H.R. 1. This new MVP alternative provided by CMS makes sense given the extreme challenge in completing H.R. 1’s heavy IT lift by January 1, 2027, in combination with the lack of Waivers allowing states more time to build out H.R. 1’s massive IT infrastructure. The MVP approach will enable Colorado to pursue reasonable advances in automation to reduce member and county processor burden given the realities of Colorado’s system build capacity and budget constraints. This MVP allows us to educate stakeholders earlier so we can build the stakeholder partnerships and member outreaches necessary to help members get through the new processes.
- A second Work Requirements flexibility communicated by CMS is the ability to potentially leverage member “self-attestation” of their exemptions and compliance with Work Requirements, including some of the required 80 hours of volunteering and potentially school. That approach could mean members may complete a new questionnaire or form as part of the renewal or new application process to attest as to which exemptions or Work Requirements criteria that apply to them. Additional federal guidance on this potential flexibility is expected before the end of the year.
- A third CMS flexibility allows states to define Medically Frail, which is one of the exempting factors from Work Requirements. That might include such attributes as homelessness, active chemotherapy treatment, inpatient substance use disorder treatment and more.
We are pursuing each of these flexibilities in the initial design of our Work Requirements Minimum Viable Product. As with implementation of any new federal law, we will balance evolving federal guidance in our operational design and planning.
How You Can Engage. We will be engaging with stakeholders beginning this month to gather feedback on all this important work. Please complete this survey to help us understand your concerns about H.R. 1 implementation and how we can best share information with you.
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In the coming weeks, we’ll be adding a calendar of events for stakeholders to engage with us on this important work as well as additional videos and FAQs to keep you updated on all things H.R. 1. The next upcoming stakeholder engagement opportunity is on Member Communications on October 16 at 12 p.m., you can register here.
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Additionally, we launched Colorado’s Medicaid Sustainability Framework webpage that outlines our plans to manage Medicaid trends and avoid draconian cuts in the face of state budget challenges and decreased federal funding due to H.R. 1.
To submit a question or comment related to H.R. 1, please use our online form. You can also email us at hcpf_HR1@state.co.us. Together, we can navigate this new chapter to achieve our shared goals. As always, we thank you for your partnership and support.
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H.R. 1 Updates:
On July 4, 2025, the House Reconciliation bill (H.R. 1), previously known as the “H.R. 1 One Big Beautiful Bill Act,” was signed into law. The bill makes several changes to Medicaid that take effect over the next few years. All states, including Colorado, are required to follow these changes. We value your partnership in navigating this challenging time together. Please complete this survey to help us understand:
- Your concerns about H.R.1
- Where you go for trusted information
- How we can best share information with you
To submit a question or comment related to H.R. 1, please use our online form. You can also email us at hcpf_HR1@state.co.us.
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2025 Annual 1115 Waiver Substance Use Disorder Stakeholder Forum:
On Oct. 28, 2025, HCPF will host the annual 1115 Expanding the Substance Use Disorder Continuum of Care (1115 SUD Waiver) stakeholder forum. During the forum, HCPF will review the most recent Annual Report outlining the SUD component of Demonstration Year 4 of the 1115 waiver and update the community about ongoing efforts and anticipated changes.
This year’s forum will be held virtually Tuesday, Oct. 28 from 9 to 10:30 a.m. Participants can register now to attend!
For more information on the 1115 SUD waiver, visit Expanding the Substance Use Disorder (SUD) Continuum of Care Waiver webpage. Please send any questions and comments to hcpf_1115waiver@state.co.us.
Auxiliary aids and services for individuals with disabilities and language services for individuals whose first language is not English may be provided upon request. Please notify hcpf_1115waiver@state.co.us or the Civil Rights Officer at hcpf504ada@state.co.us at least one week prior to the webinar to make arrangements.
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Notice of Award for Reentry State Planning Grant:
HCPF is pleased to announce that Colorado has been awarded a four-year, $4.6 million Reentry State Planning Grant by the Centers for Medicare & Medicaid Services (CMS). This funding will be used to support operationalizing the Medicaid Reentry and Community Health (M-REACH) program. Efforts will focus on helping correctional facilities establish billing infrastructure, expanding Health Information Exchange and providing technical assistance for jails.
M-REACH is a new program under Colorado’s 1115 Expanding the Substance Use Disorder (SUD) Continuum of Care Waiver (1115 Waiver). HCPF continues to work with CMS to begin reimbursing for reentry services provided 90 days prior to release from incarceration. Through expanding coverage prior to release, we expect to see improved continuity of care, coordination and communication between correctional systems and the community for justice-involved members. This should result in individuals more successfully transitioning back into their communities, and reducing recidivism, death rates, emergency department visits and inpatient hospitalization for these members.
To stay up-to-date, sign up for criminal justice updates or join a future meeting with the HCPF Criminal and Juvenile Justice Collaborative. For more information, please visit our webpage.
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Prescriber Tool Update:
The Prescriber Tool is a powerful resource available directly within many Electronic Health Record (EHR) system workflows, giving providers seamless access to vital member pharmacy benefit information. This tool has integrated features such as
e-prescribing, Real-Time Benefits Inquiry (RTBI) and electronic prior authorizations to deliver transparency and efficiency at the point of care. Providers can make faster, more informed decisions with instant access to medication coverage details and lower-cost therapeutic alternatives—improving care while managing rising pharmaceutical costs.
Key Benefits Include:
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EHR Integration: The Prescriber Tool is accessible in most EHRs within the provider workflow, making it easily accessible during patient visits.
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Real-Time Pharmacy Benefit Information: Gain immediate access to member-specific benefits, including cost-effective therapeutic alternatives and coverage details.
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Faster Prior Authorizations: Submit and manage prior authorizations electronically and efficiently.
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System Upgrade Coming: Beginning in February 2026, the new Pharmacy Benefit Management System will expand access to the tool by integrating with more EHR systems.
Visit the Prescriber Tool Project webpage for more information.
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Certified Community Behavioral Health Clinics Planning Grant Stakeholder Engagement Opportunities:
HCPF and the Behavioral Health Administration (BHA) continue to learn from our stakeholders as we work together on the Certified Community Behavioral Health Clinics (CCBHCs) Planning Grant Project. We are seeking feedback from all stakeholders, including providers, advocates, those who receive behavioral health services, and their loved ones. Please join us for any and all of the following stakeholder engagement opportunities:
Monthly CCBHC Stakeholder Meeting
Held on the last Wednesday each month from 1 to 2 p.m.
HCPF and BHA host a monthly public meeting for all stakeholders to review progress and share input on CCBHC Planning Grant efforts. The forum is open to members, providers, individuals with lived experience and their families, advocates, state agencies, managed care entities, and anyone interested in learning more about the CCBHC model in Colorado.
Please register in advance to attend.
CCBHC Steering Committee
Held on the last Monday each month from 3 to 4 p.m.
A CCBHC Steering Committee (CCBHC-SC) meets monthly to provide input throughout the CCBHC planning process. CCBHC-SC Meetings are open for public observation with time reserved for comments and questions.
Please register in advance to attend.
The CCBHC-SC is guided through contractor consultation, state leadership, stakeholder feedback, and the work of the following subcommittees:
- Prospective Payment System and Finance Subcommittee
- Held on the third Wednesday of each month at 2 p.m.
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Please register in advance to attend.
- Certification and Provider Readiness Subcommittee
- Held on the first Tuesday of each month at 2 p.m.
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Please register in advance to attend.
- Quality Measure Data Management Subcommittee
- Held on the third Tuesday of each month at 2 p.m.
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Please register in advance to attend.
Subcommittees will include subject matter experts from clinics and organizations who render care to the CCBHC Planning Grant’s populations of focus, Colorado’s priority populations, as well as urban, rural, and frontier communities to ensure CCBHC-SC and subcommittees are reflective of Colorado's geographic and cultural diversity.
All CCBHC meetings are open to the public. We value the feedback and participation of all stakeholders from all levels and perspectives.
Thank you for helping us continue to improve the Behavioral Health system in Colorado.
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Provide Feedback on Member Correspondence Improvements:
HCPF is holding a series of quarterly virtual stakeholder meetings to present information about ongoing improvements to member correspondence.
At the meetings, HCPF staff will share:
- updates on improvements being made,
- timelines for making changes, and
- plans for future letter improvements.
In addition to providing updates, attendees will have the opportunity to provide feedback on member letters in smaller workgroups. Registered attendees will receive materials to review at least one week in advance of the meeting. Please come prepared to provide feedback. Attendees will also be able to submit feedback via Google form for two weeks following the meeting.
The meeting will be in English and Spanish. ASL interpretation will be provided.
- Thursday Oct. 16, 2025, 12 to 1 p.m.
- Thursday, Jan. 15, 2026, 12 to 1 p.m.
Please register for the meetings in advance. After registering, you will receive a unique link to join the meeting.
Meeting Accommodation and Language Access Notice: Auxiliary aids and services for individuals with disabilities and language services for individuals whose first language is not English may be provided upon request. Please notify Ryan Lazo at HCPF_stakeholders@state.co.us at least one week prior to the meeting to make arrangements.
Current Projects Open for Feedback
Materials are posted on the Member Correspondence Improvements webpage.
Feedback may be submitted using the online form, available in English and Spanish.
Motion to Dismiss Cover Letter: HCPF is testing a cover letter for court motions, briefs, and other pleadings. The goal of this project is to improve readability by members while still keeping language that is legally sufficient for the courts.
Files for review: English | Spanish
Health First Dental Benefit Summary: HCPF is updating the member facing benefit summaries. This update includes summaries for adults, children, and individuals with developmental disabilities.
Files for review:
If you have general questions, please contact the Stakeholder Engagement Section at HCPF_stakeholders@state.co.us for more information.
El Departamento de Política Sanitaria y Financiación de Colorado (HCPF) está realizando una serie de reuniones virtuales trimestrales con las partes interesadas para compartir las actualizaciones sobre las mejoras que se están llevando a cabo en la correspondencia con los miembros.
En las reuniones, el personal de HCPF compartirá:
- actualizaciones de las mejoras que se están realizando,
- los plazos para realizar cambios, y
- los planes para mejoras futuras en las cartas.
Las reuniones se llevarán a cabo en inglés y en español. También se proporcionará interpretación en lengua de señas americana (ASL)
Fechas y horarios de las reuniones:
- Jueves, 16 de octubre de 2025, desde las 12 hasta la 1 p.m.
- Jueves, 15 de enero de 2026, desde las 12 hasta la 1 p.m.
Por favor, regístrese para las reuniones con anticipación. Después de registrarse, recibirá un enlace único para unirse a la reunión.
Aviso sobre el alojamiento para reuniones y el acceso a los idiomas: Si lo solicita, se pueden proporcionar ayudas y servicios auxiliares para personas con discapacidades y servicios del idioma para personas cuya lengua materna no sea el inglés. Por favor, notifíquelo a Ryan Lazo en HCPF_stakeholders@state.co.us con al menos una semana de anticipación a la reunión para hacer los arreglos necesarios.
Proyectos actuales abiertos a opiniones
Los materiales se publican en el sitio web Mejoras en la correspondencia con los miembros. Las opiniones se pueden enviar mediante el formulario en línea, disponible en inglés y español.
- Carta de presentación de la moción de desestimación: el HCPF está probando una carta de presentación para mociones judiciales, informes y otros alegatos. El objetivo de este Proyecto es mejorar la legibilidad para los miembros, manteniendo al mismo tiempo un lenguaje que sea suficiente de manera legal para los tribunales.
2. Resumen de beneficios dentales de Health First: HCPF está actualizando los resúmenes de beneficios para los miembros. Esta actualización incluye resúmenes para adultos, niños y personas con discapacidades del desarrollo.
- Archivos para revisión:
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Resumen de beneficios para personas con discapacidades del desarrollo: inglés | español
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Resumen de beneficios para adultos: inglés | español
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Resumen de beneficios para niños: inglés | español
Si tiene preguntas generales, contáctese con la Sección de participación de las partes interesadas en HCPF_stakeholders@state.co.us para obtener más información.
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Colorado Receives Federal Approval to Better Support Health First Colorado Members:
Starting October 1, 20254, HCPF is expanding coverage for inpatient mental health services. In the past, Medicaid could only pay for inpatient care in a psychiatric hospital under 15 days. Following a budget change, HCPF was able to secure federal approval through an 1115 waiver to cover up to 60 days for individuals with a serious mental illness (SMI) or serious emotional disturbance (SED). This policy change will help ensure that Medicaid members are not discharged before they are fully stabilized, improving their outcomes and reducing the likelihood of readmission for psychiatric care.
More information will be provided on the Behavioral Health webpage and State Behavioral Health Services Billing Manual webpage when it becomes available. Join the upcoming public SMI stakeholder engagement forum to learn more about the change and available training opportunities.
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