On September 29, the Colorado Department of Health Care Policy and Financing (HCPF) held a virtual stakeholder meeting to share information about proposed emergency rules for Pediatric Behavioral Therapy (PBT) providers. These rules are needed right away to keep children in Health First Colorado (Colorado’s Medicaid program) safe and to make sure they continue receiving high-quality care.
In July 2025, the U.S. Department of Health and Human Services Office of Inspector General (OIG) reviewed PBT services in Colorado. The audit found that some Registered Behavior Technicians (RBTs) who provide Applied Behavioral Analysis (ABA) therapy were not meeting national standards for training and supervision. If Colorado does not fix this, the state could lose federal Medicaid funding. Federal dollars pay for about half of all PBT services. Other states that failed to meet these requirements had to repay millions of dollars.
This emergency rule is needed to:
- Set clear standards that follow federal requirements.
- Protect children by making sure all staff who provide PBT services are properly trained, certified, and supervised.
- Avoid financial risks that could reduce federal funding for Colorado’s program.
We know these changes may feel stressful for families and providers. However, these requirements are necessary to keep children safe, protect Colorado’s Medicaid program, and make sure families can keep accessing these important services. The emergency rule allows the Department to act quickly now, while we continue working with providers and families on permanent rules.
Meeting Materials
Unfortunately, a technology issue resulted in no video recording of the September 29, 2025 stakeholder meeting. We apologize for this mistake and recognize that it limits your ability to review and share the information and continue to dialogue with us. All questions and feedback were captured in a log that was submitted to the Medical Services Board (MSB). We remain committed to meaningful, ongoing engagement on this topic.
Here is a recording of the same presentation and the conversation we had at the Early and Periodic Screening, Diagnostic, and Treatment (EPSDT) Advisory/Children’s Services Steering Committee Meeting held on September 26, 2025.