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.
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Update to Colorado’s Timeframe for Alignment with the ASAM 4th Edition Criteria
The Colorado Behavioral Health Administration (BHA) and the Colorado Department of Health Care Policy and Financing (HCPF), along with the substance use disorder (SUD) provider community, are working to align Colorado’s behavioral health systems with the 4th Edition of the American Society of Addiction Medicine (ASAM, 4th Ed.).
To ensure that the relevant behavioral health providers have sufficient time to transition effectively, Colorado’s implementation deadline has been extended to July 1, 2027. Impacted providers are expected to implement transition plans and achieve the necessary milestones for their agency to ensure full alignment with ASAM 4th Edition standards by July 1, 2027.
This is an important transition to ensure individuals are receiving the most appropriate and highest quality of care, in a manner that supports the needs of our communities. Participation in upcoming BHA and HCPF led stakeholder engagement opportunities is highly encouraged to support and inform the transition.
More information will be shared on the adjusted timeline and next steps. Please monitor the BHA’s Laws and Rules webpage or HCPF’s SUD provider webpage for updates.
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Continuous Eligibility Guidance Changes from CMS
On July 17, 2025, the Centers for Medicare and Medicaid Services (CMS) sent state Medicaid programs a letter saying that CMS will no longer approve new or renewed 1115 waivers for continuous eligibility in Medicaid or CHP+.
Continuous eligibility allows certain children or adults to keep their coverage even if their income or household size changes temporarily.
Colorado can no longer move forward with major components of Continuous Eligibility Medical Coverage (House Bill 23-1300), passed in 2023. Colorado was preparing to launch continuous eligibility on January 1, 2026 for:
- Children ages 0–3 for 36 months (up from 12), and
- Adults recently released from state prison for 12 months, regardless of income changes.
These changes were part of Colorado’s approved 1115 waiver for expanding substance use disorder (SUD) services. However, the new CMS policy, issued on July 17, blocks implementation.
We remain committed to finding new ways to support continuous access to care and will continue to advocate for policies that reflect Colorado’s values of equity, compassion, and opportunity for all.
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Accountable Care Collaborative (ACC) Phase III is Live
We are excited to share that, as of July 1, 2025, Phase III of the Accountable Care Collaborative (ACC) is officially live. More information about ACC Phase III, including the new Regional Accountable Entity (RAE) contracts and region map, are available on our website.
Thank you to each and every one of you that has supported this program. This has been a multi-year, stakeholder-informed effort with over 135 stakeholder meetings and more than 5,700 attendees to design the next iteration of this program, and we couldn’t have done it without your help!
Supporting the Transition
While we are thrilled to be reaching this important milestone, we also know that no matter how much you prepare, there will always be unexpected issues that arise.
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Providers: If you experience issues due to the transition or you have questions around contracting, payment, attribution or member care coordination and support, contact your RAE first.
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Members: Members with questions or concerns about this transition can contact Health First Colorado Enrollment or their RAE.
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For Critical Issues: Complete this form if you have been notified of or are experiencing a critical issue due to the transition that could not be resolved through the above steps. Identified issues that may impact a larger number of stakeholders will be documented on this System-Wide Issues and Resolutions Log.
Informational Resources about ACC Phase III
General Resources: Key program information, such as the new region map and Phase III RAE contracts are available on the ACC Phase III webpage.
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Colorado System of Care Potential Provider Forums
Colorado System of Care (CO-SOC) is looking to expand and grow the provider network! This initiative focuses on CO-SOC Enhanced High Fidelity Wraparound (EHFW) using the National Wraparound Implementation Center (NWIC) Model, Enhanced Multisystemic Therapy (EMST) and Enhanced Functional Family Therapy (EFFT). By strengthening the workforce and ensuring program fidelity, this collaboration aims to enhance services to our most vulnerable children and youth, empowering them to lead healthier, more fulfilling lives. While specifically targeting agencies/providers who are wanting to join the CO-SOC, these forums are open to anyone! No registration is needed. To learn more, please visit the Intensive Behavioral Health Services for Medicaid (IBHS) website.
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Why NWIC for Enhanced High Fidelity Wraparound?
NWIC supports states, communities, and organizations, to implement Enhanced High Fidelity Wraparound (EHFW). The work is tailored to build sustainable local capacity to provide model-adherent EHFW, thereby increasing positive outcomes for children and their families. NWIC’s training and coaching support is designed to build sustainability in a state or community for the local wraparound workforce. The Title IV-E Prevention Services Clearinghouse lists Intensive Care Coordination Using High Fidelity Wraparound/HFW as a promising practice specific to the NWIC Model.
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What is Multisystemic Therapy?
MST is an intensive, evidence-based intervention designed to address the complex factors contributing to behavioral barriers in youth aged 12-17. It operates within the youth’s natural environments – home, school and community – to promote positive behavioral change and prevent out-of-home placements. Learn more on the MST Services website and the Title IV-E Prevention Services website.
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What is Functional Family Therapy?
Functional Family Therapy (FFT) is an evidence-based, short-term family counseling intervention aimed at youth aged 11-18 who exhibit behavioral or emotional challenges. FFT is an intensive home-based treatment model. FFT follows a structured, five-phase model focusing on engagement, motivation, relational assessment, behavior change and generalization. Learn more on the Functional Family Therapy website and the Title IV-E Prevention Services website.
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Advisory Committees
All interested stakeholders are welcome to join the CO-SOC team for the Implementation Advisory Committee, the Statewide Leadership Committee, and the Lived Experience Committee. Please visit the Intensive Behavioral Health Services for Medicaid (IBHS) website for registration information. After registering, you will receive a confirmation email containing information about joining the webinar.
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Want to Know More?
We encourage stakeholders, families and community partners to stay informed. Sign up for the CO-SOC for Children and Youth Behavioral Health newsletter, visit the website for meeting links, agendas, updates and resources, or email us at hcpf_co_soc@state.co.us.
We look forward to working together to ensure that children and youth receive the care and support they need to thrive. Stay tuned for updates as we continue to roll out the Colorado System of Care.
| | FAQs/Clarifications of Coverage and Billing Questions | |
HCPF Seeks Stakeholder Input on Supervision Policy
HCPF is delaying implementation of updates to the Supervision Policy for Medicaid Billable Behavioral Health Services to allow for a period of stakeholder engagement to gather input and provide some much needed clarity on any policy changes.
HCPF has reverted the updated supervision policy to a DRAFT. We apologize for the miscommunication that came with the noticing of the new policy. We are working with the Regional Accountable Entities (RAEs) to update their understanding as well.
HCPF is soliciting feedback between now and August 30 regarding the draft Supervision Policy for Medicaid Billable Behavioral Health Services. Provide written feedback using this Google Form or attend a stakeholder meeting to provide verbal feedback. Please register in advance for one of the two stakeholder meetings using Zoom scheduled for August 6, 2025, from 1 p.m. to 2 p.m. and August 18, 2025, from 5 p.m. to 6 p.m.
Following collection of feedback, a revised policy will be shared. Attestations will not be required until the final policy is posted and takes effect, which we anticipate will be January 1, 2026. Additional information is available on the Behavioral Health web page.
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New Integrated Care Policy Published
The new Integrated Care Policy is now published and available on the Integrated Care Sustainability Policy web page. Visit the web page to download the policy, view Frequently Asked Questions sections for Health Behavior Assessment and Intervention (HBAI), Collaborative Care Model (CoCM), and information for Federally Qualified Health Center (FQHC), and review the Training Resources section for resources such as questions asked during live trainings.
New rates for CoCM and HBAI are also available and can be found on the Provider Rates Fee Schedule web page.
Please note that additional updates were made to the guidelines for billing the HBAI and CoCM codes compared to the HCPF billing system on July 18, 2025.
Email questions to hcpf_integratedcare@state.co.us.
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Updated Auditing and Accounting Guidelines and Cost Report Template Available
The Auditing and Accounting (A&A) Guidelines Committee has completed its work to update the A&A Guidelines and cost report template. The committee consists of a robust group of stakeholders with deep relevant experience who convene annually to evaluate the Guidelines for their applicability to the present circumstances and recommend changes.
The new Guidelines and template have been uploaded to the Behavioral Health Rate Reform web page. Email questions to hcpf_managed_care_behavioral_health_rates@state.co.us
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Discontinuation of SUD Provider Specialty Type 64/477
On July 1, 2024, new Specialty Types (ST) were added under Provider Type (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. Claims with dates of service after December 31, 2025, will be denied when billed by Provider Specialty Type 64/477.
Email questions to hcpf_sudbenefits@state.co.us.
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Reminder: Notification of Colorado Medically Unlikely Edits (CO MUEs)
Effective October 1, 2025, HCPF is applying Colorado specific Medically Unlikely Edits (CO MUEs) and Procedure-to-Procedure (CO PTP) edits for services that do not have National Correct Coding Initiative (NCCI) edits.
More information will be located on the HCPF Behavioral Health Policies, Standards and Billing References webpage.
Email questions to hcpf_sudbenefits@state.co.us.
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Reminder to Providers to Update Licenses, Certifications, Approvals, and Designations
Providers are reminded that all licenses and certifications need to be current and up to date. If a license or certification has expired, you can update the new effective dates in the Provider Portal by following the directions in this quick guide. Please note that this update is in addition to updates made to the Regional Accountable Entities (RAEs). In order to update a provisional license to a full license, you must choose “add a new license” even if the license number is the same. Please use the day after the provisional license expires as the effective date of the new license.
Call the call center at 1-833-468-0362 for assistance.
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Reminder for Providers to Reference the Current Billing Manual
Please make sure that you are using the most up-to-date State Behavioral Health Services (SBHS) Billing Manual by using the manual that is currently on the HCPF SBHS website. This will ensure you have the most accurate billing information.
Email hcpf_sudbenefits@state.co.us with any questions.
| | Other Things Happening in Behavioral Health | |
Mental Health Parity Report
The annual Mental Health Parity Report for State Fiscal Year 2024-2025 was submitted on June 1 as required by C.R.S. section 25.5-5-421. The Department of Health Care Policy and Financing (HCPF) created this year’s annual report utilizing the established process for determining mental health parity compliance based on the federal parity guidance outlined in the Centers for Medicare & Medicaid Services’ Parity Toolkit and in accordance with all state requirements.
The report includes findings from the external quality review audit which evaluates RAE and MCO policies and procedures in operation.
The full Mental Health Parity Report and full external quality review audit can both be found on the parity web page. The parity web page also contains educational resources on mental health parity.
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HCPF Annual Stakeholder Webinar
We invite you to join the Department of Health Care Policy and Financing (HCPF) leaders for our Annual Stakeholder Webinar on August 12 from 9 a.m. to 11 a.m. We will discuss emerging federal threats to Medicaid, state budget challenges, Medicaid cost trend drivers, and priorities for fiscal year 2025-2026. We look forward to your engagement and feedback at this important event. Please register on our website. Webinar materials will be available after the event.
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Reminder: Medicaid Sustainability: Behavioral Health and Managed Care Actions Memo Available
The Medicaid Sustainability: Behavioral Health and Managed Care Actions Memo was prepared by the Department to transparently share expectations for the coming 2025-26 fiscal year to maintain alignment with the Medicaid Sustainability Framework with the Regional Accountable Entity managed care entities. This memo helps frame for all stakeholders, HCPF’s policy strategies to successfully navigate Colorado’s fiscal challenges as well as the evolving Federal Medicaid funding threats. It is critical at this time that HCPF evaluates and monitors the impact of the implemented changes on Medicaid behavioral health cost trends and the shared Medicaid Sustainably framework and goals.
The Medicaid Sustainability Memo can be accessed on HCPF’s Behavioral Health webpage. Email questions to hcpf_bhbenefits@state.co.us.
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Qualified Residential Treatment Program and Psychiatric Residential Treatment Facility Prior Authorization and Nomenclature Stakeholder Meeting and Operational Memo Release
HCPF held a meeting on June 18, 2025, to discuss proposed updates to utilization management and ongoing stay requirements for Qualified Residential Treatment Programs (QRTPs) and Psychiatric Residential Treatment Facilities (PRTFs). The meeting also included upcoming changes to nomenclature for out-of-state providers.
An Operational Memo (OM 25-032) has been released detailing the updates in order to inform counties and providers of changes affecting Medicaid members under 21 years old seeking treatment in QRTPs and PRTFs. Effective November 15, 2025:
- All children and youth being considered for residential treatment (QRTP and/or PRTF) will be required to undergo an Enhanced Standardized Assessment (ESA) for initial Medicaid coverage authorization. This includes Medicaid coverage determinations for children and youth in child welfare or Division of Youth Services (DYS) custody.
- Continuing stay approval will also be required for periods of treatment longer than 30 days.
- The ESA will replace an Independent Assessment.
HCPF delayed the move of QRTP and PRTF treatment services to the Behavioral Health Capitation for children and youth in the custody of child welfare until July 1, 2026. HCPF will instead use the coming year to implement the changes listed in the Operational Memo. Update regulations will go to the Medical Services Board (MSB) in August 2025.
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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.
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Forums: Designed to be a space for presentation of information and discussion:
- 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.
- 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 from 1 p.m. to 2 p.m. Register in advance.
- Independent Provider Network (IPN) Forum. Quarterly on the first Friday from 1 p.m. to 2 p.m. Register in advance. (June, September, and December)
- SUD Forum. Quarterly (first month of the quarter) on the first Wednesday from 2 p.m. to 3 p.m. Register in advance.
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Office Hours and Technical Assistance: Designed to be a “drop in” space for quick answers to issues best addressed by a brief discussion:
- Independent Provider Network (IPN) Office Hours. Monthly on the second Wednesday from 3 p.m. to 4 p.m. Register in advance.
- 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 Office Hours. Monthly on the last Thursday from 2 p.m. to 3 p.m. Register in advance.
- Mental Health Transitional Living Home Level 2 Office Hours. Monthly on the last Thursday from 3 p.m. to 4 p.m. Advanced registration is not required. Follow this link to attend.
- Peer Support Office Hours. Monthly on the fourth Thursday from 12 p.m. to 1 p.m. Register in advance.
- SUD Provider Office Hours. Monthly on the first Wednesday from 2 p.m. to 3 p.m. Register in advance.
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