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

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.

Important Updates About Behavioral Health Crisis Services in Colorado

The 988 Colorado Mental Health Line will become the primary way to connect to free emotional, mental health, or substance use support 24/7, as a result of Colorado legislation, Senate Bill (SB) 25-236. Get connected and learn more at 988Colorado.com.

What does this mean for the Colorado Crisis Services (CCS) line? Starting July 1, 2025, anytime someone contacts the Colorado Crisis Services line at 1-844-493-8255 or via text at 38255, they will be connected to receive services via 988 Colorado.

What are the impacts to the CCS Peer Support Line? Starting July 1, Coloradans in search of peer support services can call 988 to receive support. The peer support line that is currently accessed through Colorado Crisis Services will continue to be available during the consolidation process, however people are encouraged not to delay transitioning to 988.

When can more updates be expected? The 988 Team is providing monthly updates on the 988 Colorado Crisis Services webpage until the transition is complete. Sign-up to receive the monthly 988 Colorado newsletter. Contact the 988 team at 988Colorado@state.co.us with any questions.

Colorado System of Care Implementation Plan Release

The Colorado System of Care (CO-SOC) Implementation Plan Version 1.0 is now available on the Improving Intensive Behavioral Health Services for Medicaid (IBHS) web page.

The Implementation Plan was created as part of the G.A. et al v. Bimestefer (1:21‐cv‐02381) Settlement Agreement regarding Medicaid coverage for children in need of Intensive Behavioral Health Services (IBHS). The Implementation Plan, as outlined in the Settlement Agreement, is HCPF’s plan for implementing a model based on clinical best practices and evidence supported practices for delivering IBHS to Medicaid Members as determined by HCPF in consultation with the Consultant and Plaintiffs’ Counsel.

HCPF deeply appreciates the people of Colorado for their engagement, feedback, and invaluable experiences shared throughout the process of building the Colorado System of Care Implementation Plan. The voices of children, youth, and family stakeholders have been instrumental in shaping this work and the impact will continue to be vital beyond today. HCPF is excited to continue this meaningful collaboration and looks forward to sharing future opportunities together.

All stakeholders, families, and community partners are encouraged to stay informed. Sign up for the Colorado System of Care (CO-SOC) for Children and Youth Behavioral Health newsletter. Visit the Improving Intensive Behavioral Health Services for Medicaid (IBHS) web page for meeting links, agendas, updates and resources. Email questions or comments to hcpf_co_soc@state.co.us.

Updated Supervision Policy for Unlicensed Professionals and Pre-Licensed Clinicians

Medicaid services provided by individual service providers not enrolled in Medicaid must be supervised by and billed under a Medicaid-enrolled provider who is documented as overseeing the member’s course of treatment. Supervision for the purposes of Medicaid billing and rendering of services is distinct from clinical supervision standards for professional licensure under the Department of Regulatory Agencies (DORA).

Effective July 1, 2025, HCPF has published an updated version of the Colorado Medicaid Standards for Supervision of Unlicensed Professionals policy document. An annual attestation form must be submitted to each Regional Accountable Entities (RAEs) the provider is contracted with, affirming the provider is in compliance with this policy. The Attestation for Supervision of Unlicensed Professionals and/or Pre-licensed Clinicians has also been updated, effective July 1, 2025.

Pursuant to the start of ACC Phase III, all providers with licensed clinicians intending to supervise unlicensed professionals and/or pre-licensed clinicians that fall under the guidelines of this policy must submit the updated attestation to each contracted RAE by September 1.

Subsequent to the submission of the initial attestation, this attestation must be submitted to each contracted RAE annually, no later than January 1 of each calendar year supervision may be rendered by the attesting organization. More information is available on the Behavioral Health Policies webpage under Medicaid Supervision Policy.

Benefits Spotlight

Supporting Substance Use Disorder 3.2 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. One way that HCPF and the Behavioral Health Administration (BHA) are supporting 3.2 Withdrawal Management (WM) providers through this transition is by offering a Provider Ambassador Program. HCPF and BHA have contracted with Health Management Associates (HMA) who is currently facilitating this program which provides resources and direct technical assistance to 3.2-WM providers to prepare for the ASAM 4 transition. If you are a 3.2-WM provider and would like to participate in this program, please visit HCPF’s Substance Use Disorder (SUD) web page to sign-up for upcoming webinars and office hours. Previously recorded webinars and resources will be posted on the web page starting in July. You can also reach out to HMA directly using this Feedback and Technical Assistance Form.

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

FAQs/Clarifications of Coverage and Billing Questions

The National Correct Coding Initiative

Beginning July 1, 2025, HCPF is requiring RAEs to implement all National Correct Coding Initiative (NCCI) edits. The Centers for Medicare and Medicaid Services (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. 

Beginning October 1, 2025, HCPF is instituting Colorado-specific MUEs and PTPs. HCPF will communicate the details of these edits in July. 

Visit the CMS NCCI for Medicaid web page for more information on NCCI edits.

July 1 Updates to Medicaid Billing for Peer Support Services 

In response to budget adjustments authorized by the state legislature, HCPF is updating the services that can be billed for when delivered by a Peer Support Professional, in addition to the providers that can bill for services delivered by a Peer Support Professional. Peer Support Professionals are encouraged to continue to participate in team-based treatment, however, their individual contributions are limited as outlined below.

Effective July 1, 2025, HCPF is limiting the codes that can be billed for individual contributions by Peer Support Professionals to the following: H0038: Self-help/Peer Services and H0023: Behavioral Health Outreach Service. 

HCPF is limiting the providers that can bill for H0038: Self-help/Peer Services to the following provider types:

• Comprehensive Safety Net Providers - Provider Type (PT) 78 / Specialty Type (ST) 887
• Substance Use Disorder Clinics - PT 64 / ST 371
• Recovery Support Services Organizations - PT 89/ST 889

Additionally, Peer Support Professionals can only deliver H0023: Behavioral Health Outreach Service when employed by the above provider types.

Effective July 1, 2025, Colorado MUEs (CO MUEs) for H0038 and H0023 are as follows:

• H0038: Self-help/peer services - 12 units per day (3 hours)
• H0023: Behavioral Health Outreach Service - 8 units* per day (2 hours) (*Please note: The NCCI MUE for H0023 is 1, 15 minute unit per day. HCPF will continue to review this policy)

Service billed in excess of the CO MUE will have a denial message regarding the MUE limit being exceeded; providers have a right to appeal and submit any necessary clinical documentation, in order to determine if more units should be allotted.

Additionally, Peer Support Professionals may deliver services within their scope as part of a multidisciplinary team for individuals with behavioral health needs. The relevant list of team-based services is posted on the Behavioral Health Policies webpage under Updated Peer Support Policy.

These policy updates are reflected in the July 2025 edition of the State Behavioral Health Services Billing Manual. Email hcpf_peerservices@state.co.us with any questions.

July 1 Updates to Medicaid Billing for Supportive Housing Services

Health First Colorado (Colorado’s Medicaid program) is implementing important changes regarding reimbursement for Supportive Housing Services. This is in alignment with the implementation of Colorado’s Health-Related Social Needs (HRSN) 1115 Waiver services. Effective July 1, reimbursement for H0043 (Supportive Housing, per diem) and H0044 (Supportive Housing, per month) will transition to the fee-for-service (FFS) payment method and will only be available to agencies enrolled as a Supportive Housing Provider (Provider Type 89/208). This applies to claims for dates of service beginning July 1, 2025. Please note that HCPF’s fiscal agent, Gainwell, is working to make the relevant system changes for this. HCPF will inform providers once the system is ready to process claims.

HCPF offers Provider Training regarding FFS billing. The next Beginner Billing Training is scheduled for July 10, 2025, and registration is available via Zoom. Additional billing resources can be found on the Submitting a Professional Claim quick guide.

HCPF’s Supportive Housing Services webpage is updated to reflect these changes and answer frequently asked questions. For questions, contact us via email at hcpf_housing_supports@state.co.us or attend the Supportive Housing Office Hours.

Discontinuation of Specialty Type 64/477

Since July 2024, new Specialty Types (ST) have been available under Provider Type (PT) 64 (Substance Use Continuum) that align with BHA Endorsements for each ASAM level of care. This allows HCPF and RAEs to accurately track network adequacy for all SUD levels of care.

ST 477 is not associated with an ASAM level of care and is therefore being discontinued. Once all SUD Continuum providers have added the necessary ASAM level of care Specialty Type(s), ST 477 will be end-dated in the system.

Please ensure that your PT 64 enrollment includes a Specialty Type for each ASAM level of care endorsement on your BHA license. To add a Specialty Type to your PT 64 enrollment, please submit a maintenance request through Gainwell. HCPF’s Provider Maintenance webpage explains how to submit a maintenance request. The list of ASAM level of care Specialty Types can be referenced on HCPF’s Find Your Provider Type webpage under Substance Use Disorder Continuum.

Correction for content mentioned in April newsletter: HCPF will deny claims with dates of service after December 31, 2025, when billed by Provider Specialty Type 64/477.

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

Other Things Happening in Behavioral Health

Medicaid Sustainability: Behavioral Health and Managed Care Actions Memo

In June, HCPF sent the Medicaid Sustainability: Behavioral Health and Managed Care Actions Memo to transparently share expectations for the coming 2025-26 fiscal year to maintain alignment with the Medicaid Sustainability Framework with the RAE 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 web page. Contact hcpf_bhbenefits@state.co.us with any questions.

Diagnostic Classification of Mental Health and Developmental Disorders of Infancy and Early Childhood (DC:0-5™)

BHA, in partnership with HCPF and the Department of Early Childhood, has published a new memorandum regarding the Diagnostic Classification of Mental Health and Developmental Disorders of Infancy and Early Childhood (DC:0-5™). Behavioral health provider organizations and clinicians who utilize the DC:0-5™ should be aware of updates from our agencies regarding billing and reimbursement. Learn more by visiting BHA's Memos page.

Stakeholder Engagement Forum: 1115 Serious Mental Illness and Serious Emotional Disturbance Demonstration 

Please join us for the Serious Mental Illness (SMI) and Serious Emotional Disturbance (SED) Stakeholder Engagement Forum. This will be a monthly forum 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.

Certified Community Behavioral Health Clinic Planning Grant Stakeholder Engagement and Feedback Opportunities

BHA and HCPF 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 public stakeholder engagement opportunities or provide input directly through the CCBHC Feedback Survey:

• CCBHC Stakeholder Forum. Monthly on the last Wednesday from 1 p.m. to 2 p.m. Register in advance. 
• CCBHC Steering Committee. Monthly on the last Monday from 3 p.m. to 4 p.m. Register in advance. 
• Prospective Payment System and Finance Subcommittee. Monthly on the third Wednesday at 2 p.m. Register in advance.
• Certification and Provider Readiness Subcommittee. Monthly on the first Tuesday at 2 p.m. Register in advance. 
• Quality Measure Data Management Subcommittee. Monthly on the third Tuesday of each month at 2 p.m. Register in advance.

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: 

• 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.

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.

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