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JUNE 2026
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At Colorado Access, caring for you and your success is our top priority as you serve our shared members. This monthly Provider Update serves as a highlight of important information and resources to help you as a contracted provider with us. |
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Benefits, Billing, and Code Updates |
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New Required Modifier for Behavioral Health Services Delivered Under Oversight of a Rendering Provider
Effective July 1, 2026, billing providers must use Modifier U9 on all claims submitted for behavioral health services delivered by a pre-licensed or an unlicensed professional under a rendering provider. This policy is a state requirement and applies to all regional accountable entities (RAEs), including Colorado Access.
The modifier signals that the service was provided by a clinician who cannot independently bill Medicaid and that the required oversight was in place.
For Colorado Access billing questions, contact claimsresearch@coaccess.com. For Medicaid policy questions, contact hcpf_bhbenefits@state.co.us.
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Provider Enrollment Changes for Supportive Services Effective August 1
A policy change requiring enrollment as Provider Type 77 was announced in the April Health First Colorado Behavioral Health Updates newsletter. This requirement will be implemented on August 1, 2026.
The Provider Type 25- Non-Physician Practitioner Group (PT 25) and Provider Type 16- Clinic Practitioner (PT 16) enrollments do not allow the Department to differentiate between providers who primarily deliver behavioral health services and those who primarily deliver medical or integrated care services.
Provider Type 77- Behavioral Health Group (PT 77), was created effective January 1, 2024, to define more network specificity for group practices who deliver behavioral health services.
Providers who deliver behavioral health supportive services and team-based behavioral health services must enroll as PT 77 in order to continue billing for those services beginning on August 1, 2026.
The list of impacted codes will be published here in the Updates/News section.
More information will be published in a future edition of the State Behavioral Health Services Billing Manual.
Email hcpf_bhbenefits@state.co.us with any questions regarding this guidance.
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New Billing Policies for Supportive Services Starting August 1, 2026
Starting August 1, 2026, HCPF is implementing new billing policies for some supportive services codes.
Supportive services are wrap-around, non-clinical services that can be part of a multidisciplinary approach to substance use disorder (SUD) or mental health treatment. They are not intended to replace treatment or to be provided at the same intensity or duration as outpatient clinical services.
Supportive Service Billing Changes as of August 1, 2026
These new Colorado Medically Unlikely Edits (MUEs) and Procedure-to-Procedure (PTP) edits address concerns about inappropriate utilization and unsustainable cost growth.
New Colorado MUEs and PTP Edits Effective August 1, 2026: |
| Code |
Service |
CO MUEs Limits |
CO PTP |
| H0038 |
Self-help/peer services |
12 units per day; 512 units per fiscal year |
Cannot be billed on same day as H2014, H2015, H2016, H2017, or H2018 |
| H2014 |
Skills training and development |
12 units per day; 24 units per fiscal year |
Cannot be billed on the same day as H0038, H2015, H2016, H2017, or H2018 |
| T1017 |
Targeted Case Management |
4 units per day; 64 units per fiscal year |
Cannot be billed on the same day as H0006 |
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View the full chart here.
These limits apply only to services covered under the Capitated Behavioral Health Benefit. They do not apply to the 1115 Health Related Social Needs (HRSN) Waiver, the 1115 Reentry Waiver, or Home and Community-Based Services (HCBS) Waivers.
Why These New Billing Policies?
Costs associated with these services have continued to grow despite policy and program integrity changes made during the last year. These new measures are part of HCPF’s broader efforts to address unsustainable Medicaid cost growth, which has been further complicated by federal fiscal changes under H.R. 1 (the One Big Beautiful Bill Act).
Clinical Oversight and Medical Necessity
The Rendering Provider overseeing a member’s treatment remains responsible for determining the appropriate level of care, medical necessity, and 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), and Partial Hospitalization Programs (PHP).
For more information, please contact hcpf_bhbenefits@state.co.us or clinical@coaccess.com.
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Behavioral Health Peer Recovery Groups: Final Policy Updated May 15, 2026
Services facilitated by behavioral health (BH) Peer Support Professionals in a group setting must meet the following criteria to be covered by Health First Colorado (Colorado’s Medicaid program).
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BH Peer Support Professionals facilitate Peer Recovery Groups using their lived experience to help members build recovery skills, condition management strategies, and community resource connections. Key components include:
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Structured, didactic knowledge transfer relevant to the behavioral health diagnosis and treatment plan of the group members.
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Use of motivational interviewing skills and strategies to support member participation and engagement in problem solving strategies to support members in achieving recovery goals and improving treatment outcomes.
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In alignment with CCR 502-1 (Chapter 4.2.1) Peer Recovery Groups must not exceed 12 members receiving services.
Other groups, such as recovery resident house meetings and mutual support groups like NA and AA, are outside the scope of Medicaid billable services.
Rendering providers must ensure BH Peer Support Professionals do not provide services that compromise the dynamic of a peer-to-peer relationship or that are outside the scope of providing recovery-focused services.
In alignment with 2 CCR 502-1 (Chapter 3.2C), activities that are outside of the scope of a peer support professional include, but are not limited to:
Read more here.
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Colorado System of Care: Intensive Behavioral Health Services for Children and Youth
Health First Colorado is expanding and improving the implementation of the Colorado System of Care (CO-SOC) to include intensive in-home and community-based mental health services and intensive care coordination for Health First Colorado members under the age of 21. The improved services will be provided in the most integrated and least restrictive setting. See the CO-SOC Provider Fact Sheet for details.
We are looking to expand and grow the CO-SOC provider network for services to the most vulnerable children and youth. On Wednesday, June 17, 2026, 1:30 p.m. to 3:00 p.m. MT, HCPF will hold a forum on Zoom about CO-SOC. A national expert, Dr. Rick Shepler, will present on the Colorado Intensive Home-Based Treatment (CO-IHBT), a framework for delivering intensive mental health services to youth with serious emotional disabilities. HCPF will talk about the CO-SOC philosophy, the partnership with the RAEs, and the opportunities for funds to support expansion through the Workforce Capacity Center at Colorado State University.
The forum is open to anyone. Agencies or providers who want to join the CO-SOC are especially encouraged to attend. No registration is needed. Join the June 17 forum. Contact hcpf_co_soc@state.co.us with any questions.
Referrals for CO-SOC are through the RAEs. If you have questions or would like Colorado Access to review a member for CO-SOC eligibility, please contact the Colorado Access care coordination team at 844-307-3135 (State Relay: 711) or make an online referral at carecoordinationreferral.coaccess.com. |
Billing for Neurological/Psychological Testing
The correct, current billing requirements for psychological evaluation and testing services are described below. (Note: The HCPF announcement sent in February 2026 included inaccurate and unclear information.)
The following Current Procedural Terminology (CPT) codes are the only codes that apply to neurological/psychological testing: 96130, 96131, 96136, and 96137.
When billing these codes to Colorado Access or any other Regional Accountable Entities (RAE), providers do NOT use the SC modifier. If you bill these codes as fee-for service without the SC modifier, the claim will deny and direct you to bill the RAE.
Use the SC modifier only when billing these codes for payment under fee-for-service or to Rocky Mountain Health Plans PRIME or Denver Health Medical Plan.
For more information, see the HCPF’s June Provider Bulletin. Contact hcpf_bhbenefits@state.co.us with questions. |
Some Institutional Claims Incorrectly Denying for Federally Qualified Health Centers
Federally Qualified Health Center (FQHC) institutional claims that include revenue code 900 and certain procedure codes are incorrectly posting Explanation of Benefits (EOB) 3361 – “Service billed is carved out of managed care and should be billed as Fee-for-Service (FFS).”
HCPF is working on a resolution, and all impacted claims will be reprocessed in June upon implementation. Contact Greta Brubaker at Greta.Brubaker@state.co.us with any questions. |
Dollar Limits Removed from Child Health Plan Plus (CHP+) Benefits as of July 1, 2026
Starting July 1, 2026, Child Health Plan Plus (CHP+) benefits will no longer have a dollar limit. This change affects three benefits: durable medical equipment (DME), organ transplants, and vision hardware (eyeglasses).
The $2,000 dollar limit for DME has been removed, and the $1 million lifetime limit on transplants has also been removed. There is no other change to these services, and they are still available to members based on medical necessity.
Members no longer have a $150 dollar limit for eyeglasses. Instead, the vision benefit covers one pair of prescribed eyeglasses per year from an in-network provider, and prior authorization is required for contact lenses or replacement glasses.
For questions or assistance with finding in-network providers, please contact us at 800-511-5010 (State Relay: 711). |
Claims Tips |
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New! Claims 101 Training Available from Colorado Access
Colorado Access is offering a new learning module, Claims 101: Essential Principles and Rules for Accurate Medical Billing, through our Learning Management System (LMS). This self-paced, downloadable training introduces the essentials of health care claims billing for providers working with Colorado Access. Please note that this training does not provide direct billing guidance.
The training may be a helpful refresher for current staff and a good introductory overview for new team members or providers who are new to the Colorado Access network.
If you already have access to the LMS, you can self-enroll in the course and complete the training at your convenience. If you need access to the LMS or LMS support, please contact providernetworkservices@coaccess.com.
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Submitting Claims for the Aetna Medicare D-SNP
Some of our dual eligible members have their Dual Special Needs Plan (D-SNP) with Aetna. Aetna shared the following billing information for providers who deliver services to these members:
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Medicaid is the payer of last resort, so bill Medicare (Aetna) first. Bill HCPF, the state Medicaid agency, for your patient’s deductible and coinsurance amounts (This is a “crossover claim.”) You may not bill D-SNP members for Medicare copays, coinsurance, or deductibles (balance billing). If Medicare and Medicaid don’t cover the full amount, you must accept the payment as payment in full.
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To submit crossover claims (for Medicare cost-sharing) to Medicaid, you must enroll with the state. However, you do not have to become a participating provider with Medicaid just to submit crossover claims.
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Aetna offers a personal interdisciplinary care team for members. If your patients have an Aetna D-SNP and have a care coordinator there, encourage them to connect their Aetna care coordinator with the Colorado Access care coordination team, so we can work together.
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Members with a Dual Eligible (Medicare-Medicaid) Special Needs Plan
A Dual Eligible Special Needs Plan (D-SNP) is a type of Medicare Advantage plan designed to support the unique needs of people who qualify for both Medicare and Medicaid (also known as “dual eligibles”). The D-SNP is the primary payer for these members.
D-SNPs manage Medicare benefits only. Dual eligible members are assigned to a regional accountable entity (RAE) for their Medicaid benefits with Health First Colorado, just like other Health First Colorado members. D-SNPs care managers can work with the RAE to coordinate care across both coverages.
Not all dual eligible members who qualify for a D-SNP choose to sign up for one. But it can be a good option for people who want the extra benefits of a Medicare Advantage plan, such as vision, dental, and hearing care.
If your patient has a D-SNP and loses Medicaid eligibility, they can stay on the D-SNP for up to six months. If they don’t regain Medicaid eligibility or enroll in a new plan before that time, they will be disenrolled from the D-SNP and go back to original Part A/B Medicare.
For questions or support for patients with a D-SNP, contact the Colorado Access care coordination team at 844-307-3135 or refer a patient to our care coordinators at carecoordinationreferral.coaccess.com. |
Training and Assistance |
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Colorado Access Behavioral Health Town Halls
Please join us for our monthly Behavioral Health Provider Town Hall Meetings, where we share updates, provide information and training, and answer your questions.
Register for the Town Hall Meetings here.
For questions, contact the Behavioral Health team at clinical@coaccess.com.
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Resources for Managing the Risk of Heat-Related Illnesses
The Colorado Department of Public Health and Environment (CDPHE) maintains a heat-related illness dashboard to track emergency visits and hospitalizations from heat-related causes in near real-time. The state has also created the Colorado Heat Risk Forecast to help you and your patients anticipate heat-related illnesses and create heat action plans. For questions and more resources, contact Tori Bloom from the CDPHE climate and health team at tori.bloom@state.co.us.
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Eligibility and Enrollment
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Health First Colorado Eligibility Changes Due to H.R. 1
Colorado Access is working with The Department of Health Care Policy and Financing (HCPF) to help providers and members understand and respond to eligibility changes resulting from the federal H.R. 1 law (the One Big Beautiful Bill Act). New federal rules will mostly affect members ages 19 to 64.
Some lawfully present immigrants ages 19 to 64 will lose Health First Colorado (Colorado's Medicaid program) coverage on October 1, 2026. This includes refugees and asylees, people granted humanitarian parole, and others. For details see Health First Colorado’s website about changes to eligibility due to H.R. 1.
The state is mailing letters to members who may no longer be eligible for benefits as of October 1, 2026. The letter encourages members to complete medical appointments and fill prescriptions before October 1, and ensure that their information is updated so they can stay updated.
Other adults will be affected by work requirements and more frequent renewals starting in early 2027. In addition, every member of a household will have different renewal dates.
HCPF is sharing messaging toolkits to help RAEs, providers, and community organizations keep members informed through this change. Access the H.R. 1 communication toolkits here. Please help us to raise awareness. The most important action members can take is to keep their contact information updated so the state can reach them with essential and timely information.
If you have questions about these eligibility changes, we are here to help. Call us at 800-511-5010 (State Relay: 711). |
News and Announcements |
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Quality of Care Submission Process Is Changing July 1
To improve the Quality of Care Concern (QOC) submission experience for providers, we are introducing a new, streamlined process. Starting July 1, 2026, all QOC submissions will transition from the current fillable PDF to a new secure online submission form. This update is designed to make submitting QOCs faster, easier, and more reliable.
What’s Changing
Instead of downloading and emailing a PDF, providers will complete a brief online form. The form mirrors the existing QOC fields, so the information required will not change. Once submitted, your QOC will be automatically routed to the Quality team for timely review and investigation.
What You Need to Do
The online form will be accessible at https://www.coaccess.com/providers/forms/ starting on 7/1, where the PDF submission form is currently linked. Complete all required fields and select Submit to send your concern directly to the Quality team.
Need Support?
Refer to the Colorado Access Provider Manual for QOC reporting requirements. For questions about the new submission process or a specific QOC you submitted, please email QOC@coaccess.com.
Colorado Access asks providers to submit required documentation for QOCs within 10 business days of receiving the request. All records and information shared for the purposes of QOC reviews are maintained as confidential in accordance with applicable federal and state laws, including peer review protections. We appreciate your partnership in supporting high-quality care for our members. |
Non-Emergency Medical Transportation Update: Statewide Broker Transition
Non-Emergent Medical Transportation (NEMT) is a benefit of Health First Colorado (Colorado Medicaid program) that provides transportation to and from medically necessary services for members who have no other way to get there.
In the past, service providers have depended on the county, but the state is transitioning to a single statewide broker model to create a consistent statewide process, improve member safety and experience, and reduce fraud, waste, and abuse. MediDrive has been selected as the statewide broker.
Effective July 1, the statewide broker will serve the nine-county Denver metro area: Adams, Arapahoe, Boulder, Broomfield, Denver, Douglas, Jefferson, Larimer, and Weld counties. Other counties will be transitioned to the statewide broker throughout the fall.
Members may have extra challenges booking rides during this transition month of June. Colorado Access does not schedule or book rides, but we can help members. If members need help using the NEMT benefit, please have them call Colorado Access at 800-511-5010 (State Relay: 711). |
Colorado Selected for the Certified Community Behavioral Health Clinic Medicaid Demonstration
Colorado has been selected as one of ten states to participate in the next cohort of the Certified Community Behavioral Health Clinic (CCBHC) Medicaid Demonstration Program. This model builds on Colorado’s existing Comprehensive Safety Net Provider (CSNP) framework and supports statewide efforts to improve timely access to quality mental health and substance use disorder services.
Participation in the demonstration program is expected to deliver significant benefits for Colorado’s behavioral health system, including expanded access, stronger crisis care systems, alignment with national standards, and enhanced federal funding support. For more information, see the press release from HCPF. |
Member Rights and Responsibilities
Colorado Access members have rights, such as the right to request and receive a copy of their medical records and be treated with respect and recognition of their dignity and right to privacy. They also have responsibilities, such as working with providers, being respectful to providers and staff, and keeping scheduled appointments. For a full list of member rights and responsibilities, go to coaccess.com/members/services/rights/.
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