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!
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Rural Health Transformation Project Now Accepting Applications for $160M in funding for Rural and Frontier Colorado
The Colorado Rural Health Transformation Project (RHTP) team is pleased to announce that our Request for Application (RFA) is live on the RHTP web page. Applications must be submitted by 11:59 p.m. on August 3, 2026.
Visit the new “RFA Applicant Guidance” section of the web page where resources are provided for potential applicants including guidance documents, templates, recordings of webinars, and Frequently Asked Questions.
Contact hcpf...@state.co.us with any questions.
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Prospective Payment System (PPS) State Directed Payment (SDP) Update Meeting on August 3
The Colorado Department of Health Care Policy and Financing (HCPF) is holding a webinar on Monday, August 3, regarding updates to the State Directed Payment (SDP) policy for the Comprehensive Safety Net Provider (CSNP) Prospective Payment System (PPS).
The webinar will be a follow-up to recent communication announcing the Fiscal Year 2026–27 SDP policy updates. HCPF will provide additional information on the policy, discuss implementation considerations, and answer questions. This meeting is intended to provide an opportunity for open discussion regarding the updated payment methodology, implementation timelines, and expectations moving forward.
Meeting Details
- Date: Monday, August 3
- Time: 1:30 p.m. to 2:30 p.m.
- Register Here
Safety net providers, organization leaders, and stakeholders are encouraged to attend and participate. Questions or topics can be submitted in advance to hcpf_bh...@state.co.us.
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New Grant Opportunities for Comprehensive Safety Net Providers
The Substance Abuse and Mental Health Services Administration (SAMHSA) has recently released several new Notice of Funding Opportunities (NOFOs) aimed at supporting the Certified Community Behavioral Health Clinic (CCBHC) model. This could be a great opportunity for organizations interested in joining a future CCBHC cohort for the State of Colorado under the Colorado CCBHC Medicaid Demonstration or are looking for opportunities to further expand their support of those seeking care of their communities.
Please note that applications for these grant opportunities supporting the CCBHC model are due August 17, 2026.
Visit the SAMHSA Grant Announcements page to review the full details, eligibility requirements, and deadlines for these grant opportunities. Explore these resources to see how they might support your organization’s commitment to expanding access to high-quality behavioral health care.
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Behavioral Health Administration Upcoming Perinatal Substance Use Disorder Training
Are you a maternal, infant, or early childhood professional who wants to better understand perinatal substance use and effectively support families who may be struggling? Join in-person on September 10, 2026, from 8:30 a.m. to 2:30 p.m. at the Colorado Department of Public Health and Environment’s (CDPHE’s) Glendale campus for the highly regarded training:
Connecting the Dots: Understanding the Intersection between Perinatal Mental Health and Substance Use
This interactive training will provide practical tools to support individuals, parent–child dyads, and families with skill, sensitivity, and evidence-informed care. Lunch will be provided, and continuing education credits will be offered for the training.
See the training registration page for additional details and to sign up.
| | New FAQs/Clarifications of Coverage and Billing Questions | |
Update: Implementation of New Limits on Support Services
Starting August 1, 2026, new policies focusing the utilization of Support Services will be implemented. This includes daily limits and same day billing limits related to codes outlined in the table below. Annual limits for Support Services will not be implemented as previously proposed. Specifically, annual limits will NOT be applied to procedure codes H0038, H2014, and T1017. This is an update to the Medically Unlikely Edits (MUEs) and Procedure-to-Procedure (PTP) policy shared in the June Health First Colorado Behavioral Health Updates newsletter.
HCPF appreciates the collaboration and partnership of providers and stakeholders as we work together to address increasing and unsustainable utilization while preserving access to high-quality behavioral health services. We recognize these changes may require operational adjustments, and we remain committed to working with our partners to identify balanced, sustainable solutions that support members, providers, and the long-term viability of the Medicaid program. We encourage providers and stakeholders to continue participating in provider forums and public meetings and to share feedback by email as we move this work forward.
Regional Accountable Entities (RAEs) will enforce the new Colorado MUE and PTP edits below starting August 1, 2026.
| | | Code | Service | CO MUEs Limits | CO PTP | | H0036 | Functional Family Therapy (FFT) or Community Psychiatric Supportive Treatment (CPST), 15 mins | 4 units per day | Cannot be billed on the same day as H0037, H0038, H2014 | | H0037 | Functional Family Therapy (FFT) or Community Psychiatric Supportive Treatment (CPST), per diem |
| Cannot be billed on the same day as H0036, H0038, H2014 | | H0038 | Self-help/peer services | 12 units per day | Cannot be billed on same day as H0023, H0046, H2014, H2015, H2016, H2017, or H2018 | | H0045 | Respite care services, not in the home, per diem |
| Cannot be billed on same day as S5150, S5151, T1005 | | H0046 | Drop-In Center | 16 units per day | Cannot be billed on same day as H0038, H2014, H2030 | | H2014 | Skills training and development | 12 units per day | Cannot be billed on the same day as H0038, H2015, H2016, H2017, or H2018 | | H2023 | Supported Employment, 15 mins | 16 units per day | Cannot be billed on same day as H2024, H2025 | | H2024 | Supported Employment, per diem |
| Cannot be billed on same day as H2023, H2025, H2026 | | H2025 | Ongoing Support to Maintain Employment, 15 mins | 16 units per day | Cannot be billed on same day as H2023, H2024, H2026 | | H2026 | Ongoing Support to Maintain Employment, per diem |
| Cannot be billed on same day as H2023, H2024, H2025, H2031 | | H2030 | Mental Health Clubhouse Services, 15 mins | 16 units per day | Cannot be billed on same day as H0046, H2031 | | H2031 | Mental Health Clubhouse Services, per diem |
| Cannot be billed on same day as H2030 | | H2032 | Activity Therapy, 15 mins |
| Cannot be billed on same day as G0176 | | S5150 | Unskilled Respite Care, Not Hospice, 15 mins | 16 units per day | Cannot be billed on same day as S5151, T1005 | | S5151 | Unskilled Respite Care, Not Hospice, per diem |
| Cannot be billed on same day as S5150, T1005 | | T1005 | Respite care services, 15 mins |
| Cannot be billed on same day as H0045, S5150, S5151 | | T1017 | Targeted Case Management | 4 units per day | Cannot be billed on the same day as H0006 | | | |
Clinical Oversight and Medical Necessity:
The Rendering Provider overseeing a member’s treatment remains responsible for determining:
- Appropriate level of care
- Medical necessity
- Whether services are aligned with a member’s diagnosis and individualized treatment plan
Extended or intensive use of supportive services may indicate the need for a higher level of care. In alignment with the Behavioral Health Administration (BHA) rules and best practice standards, supportive services remain integral to team-based treatment models such as:
- Assertive Community Treatment (ACT)
- Intensive Outpatient Programs (IOP)
- Partial Hospitalization Programs (PHP)
Services Not Impacted:
These limits apply only to services covered under the Capitated Behavioral Health Benefit. They do not change benefits available through:
- 1115 Health Related Social Needs (HRSN) Waiver
- 1115 Reentry Waiver
- Home and Community-Based Services (HCBS) Waivers
The Colorado Medically Unlikely Edits and Procedure to Procedure (CO MUEs and CO PTP) policy is found on the Behavioral Health Policies, Standards, and Billing References web page.
Email questions or comments to the hcpf_bh...@state.co.us.
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Clarification on Billing Requirements for Services Delivered Under Oversight of a Rendering Provider
In accordance with Medicaid billing requirements, referenced and described in the Health First Colorado Behavioral Health Rendering Provider Oversight (RPO) Policy, pre-licensed clinicians and unlicensed professionals are only able to deliver Medicaid reimbursable behavioral health services under the oversight of a Rendering Provider who holds a valid active license in Colorado. Only licensed practitioners of the healing arts may enroll with Health First Colorado (Colorado’s Medicaid program) as a provider. Therefore, to reimburse for care delivered by unlicensed or pre-licensed individuals, behavioral health services must be billed under a Rendering Provider. There is no change to this policy.
Use of Modifier U9 - Effective July 1, 2026
For dates of service beginning July 1, 2026, billing providers will be required to utilize Modifier U9 on all claim lines submitted for behavioral health services delivered by a pre-licensed clinician or an unlicensed professional. HCPF decided to postpone the requirement to include identifying information regarding the service provider to January 2027, based on provider feedback.
National Provider Identifier (NPI) for Pre-Licensed Clinicians and Unlicensed Professionals - Effective January 1, 2027
Effective January 1, 2027, all service providers delivering behavioral health services, including pre-licensed clinicians and unlicensed professionals, will be required to have an Individual NPI number. NPI numbers are obtained through the National Plan and Provider Enumeration System (NPPES) website.
For dates of service beginning January 1, 2027, when a behavioral health service is delivered by a pre-licensed clinician or unlicensed professional, the service provider’s NPI must be listed in Box 19 on the claim. The use of Box 19 applies to billing providers who utilize the CMS 1500 claim form.
Questions may be submitted to hcpf_bh...@state.co.us.
| | Policy Change and Update Reminders |
Additional Detail: Changes to Billing Provider Eligibility for Supportive Services Delayed to August 2026
The Provider Type 25- Non-Physician Practitioner Group (PT 25) and Provider Type 16- Clinic Practitioner (PT 16) enrollments do not allow HCPF to differentiate between providers who primarily deliver behavioral health services and those who primarily deliver medical or integrated care services. To address this, Provider Type 77 - Behavioral Health Group (PT 77) was created effective January 1, 2024, to create more network specificity for group practices who deliver behavioral health services.
As part of HCPF’s Supportive Services Sustainability Strategy actions, effective August 1, 2026, PT 25 and PT 16 claims will be denied when billed for certain behavioral health supportive services and team-based behavioral health services in fee for service (FFS) or to the Regional Accountable Entities (RAEs).
The list of impacted codes includes: H0004, H0023, H0025, H0036, H2014, H2023, H2024, H2025, H2026, H2027, H2032, S5150, S5151, S9445, S9453, S9454, T1017, H0035, H0037, H0039, H0040, H2012, H2033, S9480, T1005, H2021, H2022, H2001, H2015, H2016, H2017, H2018, H0045, 90876, 97535, 97537.
Provider Enrollment resources can be found on the Provider Enrollment webpage.
Providers enrolling as PT 77 have two options:
Option 1: Obtain a New Organizational National Provider Identifier (NPI) (Type II)
This option generally results in a smoother and faster enrollment process. It also allows HCPF to backdate the enrollment effective date by up to 10 months, when applicable.
Steps for this option: Apply for a new Type II NPI through the NPPES website. New NPIs are typically issued within 10 minutes to 1 hour.
Once the new NPI has been received, visit the Provider Enrollment web page and begin the enrollment process under the appropriate provider type. If the application is complete and accurate, enrollment may be processed within approximately 5 business days.
Option 2: Retain Your Current NPI and Request Disenrollment
This option may disrupt claims processing and typically takes longer to complete.
Note that the disenrollment process can take up to 30 days. Once the NPI has been fully disenrolled, it may be re-enrolled under the correct provider type.
If providing Evaluation and Management (E/M) services, keep the PT 16 or PT 25 and use option 1 to also enroll as a PT 77.
Contact hcpf_bh...@state.co.us with any questions.
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National Provider Identifier (NPI) Required for all Service Providers Delivering Behavioral Health Services, Effective January 1, 2027
Effective January 1, 2027, all service providers delivering behavioral health services, including pre-licensed clinicians and unlicensed professionals, will be required to have an Individual NPI number that will be listed on the claim. An NPI number is obtained through the National Plan and Provider Enumeration System (NPPES) website.
Contact hcpf_bh...@state.co.us with any questions.
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Sunsetting 97535, Self-Care/Home Management Training, and 97537, Community/Work Reintegration Training
Procedure codes 97535, Self-Care/Home Management Training, and 97537, Community/Work Reintegration Training, are sunsetting, effective July 1, 2026, and will no longer reimburse for these procedure codes. Refer to the State Behavioral Health Services Billing Manual for other training procedure codes.
Contact hcpf_bh...@state.co.us with any additional questions.
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Discontinuation of State Directed Payments for Behavioral Health Essential Safety Net Services in a Bedded Facility
Effective July 1, 2026, the Department of Health Care Policy and Financing (HCPF) will no longer set directed payments for behavioral health essential safety net services in a bedded facility. This means HCPF will no longer set a minimum rate that Regional Accountable Entities (RAEs) must meet or exceed for payment. Directed payments for Mobile Crisis Response (MCR) services and Opioid Treatment Programs (OTPs), as well as targeted population directed payments will remain in place until further notice.
RAEs may negotiate provider rates based on quality and network needs. Validated cost reports for Crisis Stabilization Unit (CSU) and Acute Treatment Units (ATU) information will continue to be collected which may be used during rate negotiations.
This policy update will be reflected in Appendix D of the July 2026 edition of the State Behavioral Health Services Billing Manual.
Email hcpf_bh...@state.co.us with any questions.
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Updated Location: Neurological / Psychological Testing Codes – Fee Schedule
Beginning September 1, 2026, Neurological / Psychological Testing codes will be available only in the Health First Colorado Fee Schedule on the Provider Rates and Fee Schedule webpage and will no longer be located on the behavioral health fee schedule. Use this fee schedule when referencing Behavioral Health Neurological/Psychological Testing codes.
Contact hcpf_bh...@state.co.us with any questions.
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Final Policy Published: Clarification on Scope of Behavioral Health Peer Recovery Groups
In March 2026, HCPF published a draft policy to clarify the scope of Behavioral Health Peer Recovery Groups. The policy outlines criteria that must be met for services facilitated by Behavioral Health Peer Support Professionals in a group setting to be covered by Health First Colorado (Colorado’s Medicaid program).
A final version of the policy has been published on the Behavioral Health Peer Support Policy section of the Behavioral Health Policies webpage. We appreciate everyone that took time to give thoughtful input on this policy.
Email hcpf_pee...@state.co.us with any questions.
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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 Behavioral Health Initiatives and Coverage Office webpage to register or review what offerings are available.
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