Health First Colorado Behavioral Health Updates

Welcome to the Health First Colorado Behavioral Health Updates from the Department of Health Care Policy and Financing (HCPF).

Health First Colorado Behavioral Health Updates provides content relevant to the full spectrum of behavioral health services in Colorado. Feel free to share this information with other interested stakeholders!

Feedback, ideas, and questions are welcome and can be shared at hcpf_bhbenefits@state.co.us.

What’s New

Updates to HCPF Led Forums and Office Hours

Please join us for the *NEW* Serious Mental Illness (SMI) and Serious Emotional Disturbance (SED) Stakeholder Engagement Forum. This forum begins May 15 and creates a stakeholder engagement opportunity to inform implementation planning for the SMI/SED demonstration under Colorado's 1115 Waiver. Interested stakeholders are encouraged to sign up in advance. It will be held monthly on the third Thursday from 12 p.m. to 1 p.m.

The Behavioral Health Hospital and Residential Facility Forum has replaced the Behavioral Health Hospital Engagement Forum. The purpose of this forum is to be a space for stakeholders to discuss behavioral health in acute settings, such as hospitals and residential facilities. It will be held quarterly on the third Thursday from 12 p.m. to 1 p.m.

HCPF combined the Safety Net Provider Office Hours and the Crisis Office Hours into the Safety Net and Crisis Office Hours which will be held monthly on the 2nd Tuesday from 12 p.m. to 1 p.m.

To attend these or any of the other forums, office hours, or technical assistance sessions available, please register using the links below. 

Email hcfp_bhbenefits@state.co.us with any questions or concerns.

Benefits Spotlight

Supporting SUD Withdrawal Management Providers in Preparing for the Transition to the ASAM Criteria, 4th Edition Standards

Colorado is preparing to transition into alignment with the American Society of Addiction Medicine (ASAM) Criteria 4th Edition Standards, effective July 1, 2026. HCPF and BHA have been holding monthly listening sessions with substance use disorder (SUD) providers to gather feedback, questions, and concerns regarding the transition to ASAM 4. More information can be found on the Behavioral Health Administration (BHA) website, including previously recorded listening sessions and slide decks and registration links for upcoming community engagement and stakeholdering events.

One way that HCPF and BHA are supporting SUD providers through this transition is by offering a Provider Ambassador Program for SUD providers who currently deliver ASAM 3.2 withdrawal management (WM) services. HCPF and BHA have contracted with Health Management Associates (HMA) to provide resources and direct technical assistance to 3.2-WM providers in preparing for the ASAM 4 transition. If you are a 3.2-WM provider and would like to participate in this program, you can complete this Feedback and Technical Assistance Form.



Email hcpf_sudbenefits@state.co.us with any questions.

New Benefit: What is High Fidelity Wraparound?

High Fidelity Wraparound (HFW) is a youth and family-centered care model that coordinates services for children and adolescents with complex behavioral health needs. By focusing on individualized care, HFW brings together family members, caregivers, service providers, and community members to develop a comprehensive treatment plan that is individualized and provides the needed services for the youth and family. This approach has proven to improve outcomes by offering customized support, reducing out-of-home placements, and enhancing overall wellbeing. The Medicaid System of Care, in partnership with the BHA, will be adopting the National Wraparound Implementation Center (NWIC) model for HFW training and fidelity guidelines. This strategic investment in NWIC and the Workforce Capacity Center (WCC) is about building a sustainable system that can support Colorado’s most vulnerable children and youth while ensuring statewide consistency.

BHA will be utilizing its System of Care grant to begin training the HFW workforce in April 2025 with a limited number of 45 individuals available. If the need arises, a second training session can be added in May. Once the WCC is established, HFW trainings will be accessible through the WCC. These trainings are reserved for providers who plan on offering HFW services within the Medicaid System of Care, including Colorado's Trauma Informed System of Care (COACT) HFW providers.

If you are interested in the HFW Workforce Trainings please complete the HFW Workforce Trainings form.

Email any questions to Kelli Reidford at kelli.reidford@state.co.us or Crystal Soto at crystal.soto@state.co.us.

FAQs/Clarifications of Coverage and Billing Questions

Discontinuation of Behavioral Health Outpatient State Directed Payments

Effective July 1, 2025, the Department of Health Care Policy and Financing (HCPF) will no longer set directed payments for outpatient behavioral health services, except those for Mobile Crisis Response services and Opioid Treatment Programs (OTPs). Directed payments for services in a bedded facility will remain in place until June 30, 2026.

When launching the safety net in 2024, directed payments were utilized as a time-limited method to infuse funds into the system to support providers through the transition to the new system, support network access, and create growth for specific services. Directed payments are reviewed on a regular basis to monitor their effectiveness and are not a sustainable funding mechanism within a managed care model.

The factors that inform when a Directed Payment is considered include:

• When a service is new or is being underutilized across the state.
• When there are identified access issues related to a specific service.

As a Directed Payment is phased out, Regional Accountable Entities (RAEs) may negotiate provider rates based on quality and network needs.

This policy update will be reflected in Appendix D of the July 2025 edition of the State Behavioral Health Services Billing Manual.

Email hcpf_bhbenefits@state.co.us with any questions.

Behavioral Health Providers ACC Phase III Contracting Reminders

All behavioral health providers who want to receive reimbursement for providing services covered by the capitated behavioral health benefit must be enrolled as a Health First Colorado provider AND be contracted and credentialed directly with the RAEs. Behavioral Health providers are encouraged to contract with multiple RAEs to promote a statewide behavioral health network.

Providers who are currently contracted with a RAE, as well as providers that are interested in joining the provider network, will need to establish a new contract with one or more RAEs for ACC Phase III, starting July 1, 2025. Information for each RAE is available on the ACC Phase III webpage.

While the RAEs are required to contract with certain federally defined essential community providers, such as Federally Qualified Health Centers, the RAEs have the authority to determine which providers they contract into their network.

Visit the ACC Phase III webpage for more information. 

Peer Support Services Policy Updates

In response to budget adjustments authorized by the state legislature, HCPF is limiting the providers that can bill for services performed by a Peer Support Professional, in addition to updating the services that can be billed for when performed by a Peer Support Professional. Effective July 1, 2025:

• The following services are reimbursable when performed by Peer Support Professionals, and billed by Comprehensive Safety Net Providers - Provider Type (PT) 78/ Specialty Type (ST) 877; Substance Use Disorder Clinics - PT 64/ ST 371; or Recovery Support Services Organizations - PT 89/ST 889:
• H0038 Self-Help/Peer Services
• H0023 Behavioral Health Outreach Service
• Peer Support Professionals are encouraged to continue to participate in team-based treatment.

These services must tie to measurable goals specified on an individualized service plan, in compliance with Centers for Medicare and Medicaid Services (CMS) guidance.

These policy updates will be reflected in the July 2025 edition of the State Behavioral Health Services Billing Manual.

Email hcpf_peerservices@state.co.us with any questions.

Supportive Housing Services Policy Update

In preparation for implementation of the Health-Related Social Needs (HRSN) 1115 Waiver Amendment later this year, reimbursement for the two Supportive Housing Services codes (H0043 and H0044) will be limited to providers enrolled as a Supportive Housing Provider (PT 89/ ST 208), effective July 1, 2025. If your organization manages an allocation of Permanent Supportive Housing (PSH) vouchers, please consider enrolling with Medicaid as a Supportive Housing Provider (PT 89/ ST 208). 

Email hcpf_housing_supports@state.co.us with any questions.

Behavioral Health Secure Transportation Capitated Benefit 

Behavioral Health Secure Transport (BHST) is currently a fee-for-service benefit billed directly to HCPF. Beginning July 1, 2025, BHST will be included in the capitation and paid by the Regional Accountable Entities (RAEs). This change will require providers to contract with the RAEs in order to bill for payment. 

Email hcpf_bhbenefits@state.co.us with any questions or visit the Behavioral Health Secure Transportation for more information. 

Behavioral Health Group Practices Provider Type Guidance 

HCPF created Provider Type 77 - Behavioral Health Group, effective January 1, 2024 to create more network specificity for group practices who deliver behavioral health services. Many group providers are currently enrolled with Medicaid as a Non-Physician Practitioner Group (PT 25) or a Clinic Practitioner (PT 16). The PT 25 and PT 16 enrollments do not allow HCPF to differentiate between providers who primarily deliver behavioral health services, compared to those who primarily deliver medical services or integrated care.

Therefore, HCPF issues the following guidance for behavioral health group practices:

• All newly enrolling Medicaid providers that only deliver behavioral health services must enroll as PT 77 - Behavioral Health Group.
• Current Medicaid providers enrolled as PT 25 or PT 16 that only provide behavioral health services must re-enroll as a PT 77 upon revalidation or when making an update to their enrollment.

Email hcpf_bhbenefits@state.co.us with any questions regarding this guidance.

Terming SUD Provider Specialty Type 64/477 

On July 1, 2024, new Specialty Types (ST) were added under PT 64 (Substance Use Continuum) to align with BHA Endorsements. Providers should no longer be enrolled with ST 477. All SUD providers who currently have an ST 477 enrollment must submit a maintenance request through Gainwell to modify your Specialty Type to align with your BHA Endorsement for level of care. The deadline for SUD Providers to submit their maintenance request is June 15, 2025. Claims with dates of service after June 30, 2025, will be denied when billed by Provider Specialty Type 64/477.

Email hcpf_sudbenefits@state.co.us with any questions.

Workaround for “Unique Taxonomy” Issue for SUD Providers When Adding “Additional Specialties” to a Provider Profile 

SUD providers may use the following steps when they are unable to add an “unique taxonomy” when adding “additional specialties” to a provider profile during a Maintenance Request:

Step 1: Enter a Maintenance Request that includes the following attachments:

• Upload a list of the specialties you would like to add. Add the document (Word, Google Doc, or PDF) as an “Other Attachment.” (Note: If the primary specialty should be changed, indicate which specialty should be listed as primary) 
• All supporting documentation available to verify the new specialty. (Note: Provider does not need to add a new specialty to the Maintenance request) 

Step 2: Submit the Application Tracking Number (ATN). Email the ATN number to the provider’s department contact at hcpf_bhcoding@state.co.us.

Other Things Happening in Behavioral Health

CCBHC Feedback Survey and Update

BHA and HCPF continue work on the collaborative CCBHC Planning Grant Project. Learning from our stakeholders is an important part of the planning grant process. We are seeking feedback from all stakeholders, including providers, advocates, members, and their families. In order to help facilitate this, BHA and HCPF have launched a CCBHC Feedback Survey.

Please complete this two-minute survey to provide your feedback! Do you think we are on the right track or need to make some changes? Although feedback may be provided anonymously, we encourage you to provide your contact information so we may reach out if we have follow-up questions.

The survey is available on the CCBHC Planning Grant webpage or can be accessed directly.

PLEASE NOTE: The CCBHC Steering Committee meeting for May will be held on May 28, 2025, at 3 p.m. to accommodate Memorial Day. You must re-register for the new date and time to attend. Register in advance.

Visit the CCBHC Planning Grant webpage or email HCPF_BHBenefits@state.co.us for more information.

The National Correct Coding Initiative

Beginning July 1, 2025, HCPF is requiring RAEs to implement all National Correct Coding Initiative (NCCI) edits. CMS created the NCCI to reduce improper payments stemming from incorrect coding and billing practices. NCCI prevents reimbursement for inappropriate combinations of Current Procedural Terminology (CPT) codes. The following are the three types of NCCI Edits:

• Add-on Code (AOC) edits ensure add-on codes are not billed without a primary procedure code.
• Medically Unlikely Edits (MUEs) prevent inappropriate payments when services are reported with an unusually high number of units of service. 
• Procedure to Procedure (PTP) edits prevent code pairs that should not be reported together on the same date of service. 

For example, for a 45 minute psychotherapy session with a member (procedure code 90834) the Practitioner Services' MUE Value is 2. This means that providing two services to the same date and same member is allowed, but anything over two is denied. The MUE Adjudication Indicator is 3 which means it is a Date of Service Edit, so the edit looks at how many of the same services were done on the same date.

Visit CMS’ NCCI for Medicaid website for more information on NCCI edits. 

Connect with Us

Behavioral Health Provider Engagement Opportunities

Behavioral health providers are encouraged to participate in provider forums, meetings, and office hours. Below are a series of ongoing opportunities available. Many of these sessions require registration to allow for planning based on attendance and to prepare responses and presentations designed to address questions often submitted in advance.

View the full calendar of events on the BHIC webpage.

Forums: Designed to be a space for presentation of information and discussion: 

• New: Serious Mental Illness (SMI) and Serious Emotional Disturbance (SED) Stakeholder Engagement Forum. Second and third month of the quarter on the third Thursday from 12 p.m. to 1 p.m. Register in advance.
• New time: Behavioral Health Hospital & Residential Facility Forum. Quarterly (First month of the quarter) on the third Thursday from 12 p.m. to 1 p.m. Register in advance.
• CCBHC Stakeholder Forum - monthly on the last Wednesday 1:00 PM - 2:00 PM. Register in advance. 
• Independent Provider Network Forum - Quarterly on the 1st Friday 1:00 PM – 2:00 PM. Register in advance. (June, September, and December)
• SUD Forum – Quarterly (first month of the quarter) on the 1st Wednesday 2:00 – 3:00 PM. Register in advance.

Office Hours and Technical Assistance: Designed to be a “drop in” space for quick answers to issues best addressed by a brief discussion:

• New: Independent Provider Network (IPN) Office Hours - Monthly on the 2nd Wednesday 3-4pm. Register in advance.
• Updated: Safety Net and Crisis Office Hours. Monthly on the second Tuesday from 12 p.m. to 1 p.m. Register in advance.
• Supportive Housing Provider TA - Monthly on the last Thursday 2:00 – 3:00 PM. Register in advance. 
• Mental Health Transitional Living Home – Level 2 Office Hours – Monthly on the last Thursday 3:00 – 4:00PM. Advanced registration is not required. Follow this link to attend. 
• Peer Support Office Hours - Monthly on the 4th Thursday 12:00 – 1:00 PM. Register in advance.
• SUD Provider Office Hours - Monthly on the 1st Wednesday 2:00 – 3:00 PM. Register in advance.

Share your feedback, ideas and questions with HCPF at hcpf_bhbenefits@state.co.us