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Safety Net and Crisis Services

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Safety Net Services

Safety net services are licensed and regulated by the Behavioral Health Administration (BHA). The behavioral health safety net system serves priority populations and complies with the safety net no refusal requirements, ensuring that priority populations receive access to the care that they need. Learn more from the Safety Net Fact Sheet or book a BHA support session.

The Department of Health Care Policy & Financing (HCPF) developed a strategic vision to:

  • Expand the provider network
  • Create opportunities for providers to offer additional services
  • Improve the quality of care
  • Obtain alternative funding to foster a more sustainable provider system

Major elements of the safety net include:

Safety Net Providers

HCPF developed a distinct Comprehensive Safety Net Provider and also an Essential Safety Net Approval Status that can be attached to a variety of HCPF provider types. Safety Net Providers contract with RAEs to deliver safety net services.

Comprehensive Safety Net Provider

Comprehensive Provider (defined in §27-50-101(11) as a Comprehensive Community Behavioral Health Provider) - A licensed behavioral health entity or behavioral health provider approved by the BHA to provide care coordination and the all of the following behavioral health safety net services, either directly or through formal agreements with behavioral health providers in the community or region: 

  • Emergency and Crisis Behavioral Health Services
  • Mental Health and Substance Use Outpatient Services
  • Behavioral Health High-Intensity Outpatient Services
  • Care Management 
  • Outreach, Education, and Engagement Services
  • Mental Health and Substance Use Recovery Supports
  • Outpatient Competency Restoration
  • Screening, Assessment, and Diagnosis, Including Risk Assessment, Crisis Planning, and Monitoring to Key Health Indicator

Essential Safety Net Provider

Essential Provider (defined in §27-50-101(13) Essential Behavioral Health Safety Net Provider) - A licensed behavioral health entity or behavioral health provider approved by the BHA to provide care coordination and at least one of the following services:

  • Emergency or crisis behavioral health services
  • Behavioral health outpatient services
  • Behavioral health high-intensity outpatient services 
  • Behavioral health residential services 
  • Withdrawal management services 
  • Behavioral health inpatient services 
  • Integrated care services 
  • Hospital alternatives or 
  • Additional services that the BHA determines are necessary in a region or throughout the state

Emergency and Crisis Behavioral Health Services are a required service of Comprehensive Safety Net Providers. Emergency and Crisis Behavioral Health Services may become Essential Safety Net Providers.

Check out the Safety Net Provider Medicaid Enrollment Resource Scenarios document for more information on the process of Medicaid enrollment across service locations.

Learn more about the development of the Behavioral Health Safety in the forum archive in the Resources section below.

Frequently Asked Questions

Comprehensive Provider FAQ

Q: Can my agency enroll with HCPF as both a Comprehensive Safety Net Provider and an Essential Safety Net Provider?
A: Yes, a provider agency may enroll as both a Comprehensive Provider (PT 78) and an Essential Provider depending on the scope of services being provided and with appropriate licensure and approvals by the BHA.

Q: As a Comprehensive Provider, will my organization need new National Provider Identifiers (NPIs) for each physical location? 
A: Comprehensive Providers must enroll as Provider Type 78 for each address included on the BHA Comprehensive Approval. HB 18-1282 requires newly enrolling and currently enrolled organization health care providers (not individuals) to obtain and use a unique NPI for each service location and provider type enrolled in the Colorado interChange. Learn more at the HCPF provider enrollment webpage.

Q: As a Comprehensive Provider, will my agency be able to be both the Billing Provider and the Rendering Provider on claims?
A: No, Comprehensive Providers can only act as the Billing Provider and Pay-To Provider. The individual licensed practitioner delivering or supervising the service must be listed as the Rendering Provider on the claim.
Per HIPAA 837 encounter requirements, HCPF is not allowed to vary Medicaid billing requirements from the standards described in the 837 Implementation Guide.

According to the Technical Report Type 3 (TR3), which provides implementation instructions for electronic transactions under HIPAA, the rendering provider's information must be included if the rendering provider differs from the billing provider. If the rendering provider is the same as the billing provider, only the billing provider's information should be sent, and the rendering provider's details should be omitted.

Additionally, 42 CFR 455 Subpart E 455.410 (b) stipulates: The State Medicaid agency must require all ordering or referring physicians or other professionals providing services under the State plan or under a waiver of the plan to be enrolled as participating providers.

Q: Will Comprehensive Providers be required to have notes co-signed when an unlicensed clinician or other direct care practitioner provides the service and the licensed provider is listed as the rendering provider on the claim?
A: No. HCPF does not require a supervising clinician to co-sign documentation. HCPF provides the following guidance regarding Service Documentation Standards in the State Behavioral Health Services Billing Manual: A clinical note must include the “...provider’s dated signature and relevant qualifying credential. A title should be included where no credential is held.”

Q: How are Comprehensive Providers (PT 78) reimbursed?
A: Comprehensive Providers are reimbursed via prospective payment system (PPS), which is a payment model that pays providers a standard rate for any qualifying encounter with a patient, regardless of what or how many specific services were rendered.  This data is used to calculate a provider-specific PPS rate that reflects the actual costs of delivering services. New comprehensive providers will receive a “statewide PPS” rate until their cost reporting can be completed. Current Comprehensive Provider rates are published in the SBHS Billing Manual, Appendix D.

Q: Are RAEs required to contract with Comprehensive Providers? 
A: RAEs are required to offer contracts to all willing and qualified Federally Qualified Health Centers (FQHC), Comprehensive Providers, Behavioral Health Providers, Rural Health Clinics (RHC), and Indian Health Care Providers located in the contract region.

Q: If an outpatient service included in the PPS list is provided by a Comprehensive Provider at a residential setting (i.e. psychological evaluation in an SUD residential program), how would this be reimbursed?
A: There are no changes to billing and coding rules related to services paid at a per diem rate.  This means that providers must still comply with billing practices in a residential setting and verify what is included/excluded in the per diem rate.  If a service is included in the rate then a component service cannot be billed separately.  Please see the respective coding page for more details.

If a service can be billed outside of a residential per diem and is provided by the staff at the Essential Provider, then it is billed by the Essential Provider for reimbursement as negotiated with the MCE. 

Component services provided at an Essential Provider (Residential, CSU, etc.) cannot be billed by the Comprehensive provider unless the practitioner is not affiliated with the Essential Provider setting.

Q: How can issues with Managed Care Entities contracting or reimbursement be relayed to HCPF?
A: Providers having challenges with claims, denials, conflicting guidance between MCEs, or other concerns, should submit a Provider Escalation Form. HCPF will log the concern and forward it to the appropriate Managed Care Entity for a response. This process helps HCPF identify common issues, trends, and systemic challenges experienced by providers.

Essential Provider FAQ

Q: Is there a specific Provider Type and Specialty Type Essential Safety Net Providers (Essential Providers) when enrolling in Medicaid?
A: There is not a distinct Provider Type or Specialty Type for Essential Providers.  However, there are certain providers who are eligible to become Essential Providers. Please refer to the State Behavioral Health Billing Manual APPENDIX L: MEDICAID BILLING PROVIDER TYPES for the types of providers who are eligible to become Essential Providers. The Essential Provider Type Alignment Guide may also help providers determine what BHA Essential Provider approval letter is allowed for each HCPF Provider type. A BHA Essential Approval letter can be added to a HCPF provider enrollment through the portal as an attachment during initial enrollment or as an update a current enrollment through a maintenance request.  

Q: What is the difference between an Essential Safety Net Provider/Essential Provider and an Essential Community Provider?
A: An Essential Safety Net Provider, also known as an Essential Provider, is a status obtained through BHA approval, whereas an Essential Community Provider is a designation obtained by the federal government or HCPF directly.  They are completely different programs, though similar in name.

Q: What is the process for an Essential Provider to enroll with HCPF and receive enhanced payment rates?
A: HCPF Enrollment Process Overview:

  1. A Provider gets a BHA Approval letter as an Essential Provider.
  2. A Provider enrolls (or updates enrollment) with HCPF. The services listed on the BHA Essential Approval letter must align with the appropriate HCPF provider type. The Essential Provider Type Alignment Guide may help providers determine what BHA Essential Provider approval letter is allowed for each HCPF Provider type.
  3. The provider must be contracted with an MCE as a safety net provider to receive the enhanced payment. 
    1. MCEs are required to re-contract with existing providers who have secured BHA Essential Approval.
    2. MCEs may choose not to contract with new providers based on network needs, even if the provider has a BHA Essential Approval letter.
  4. Providers will receive the Essential enhanced payment rate based on the effective date of the MCE contract.

Q: How will the MCEs be made aware of an organization’s Essential Provider status with HCPF?
A: HCPF sends a weekly list of all providers with BHA Essential Approval letters attached to their HCPF enrollments. The weekly file includes any changes that were made from the previous weekly file. The list is sent to MCEs every Thursday.  This may occur more frequently in the future based on volume. Providers should also  contact MCEs directly to share their enrollment status as an Essential Provider.

Q: Do providers have to contract with a Managed Care Entity (MCE) to bill and receive payment under the Essential Fee Schedule?
A: Yes.  A provider must be contracted with a MCE to be reimbursed the Essential Fee Schedule rates.  MCEs are required to re-contract with existing providers who are approved as Essential Safety Net Providers.  MCEs may choose not to contract with a new provider, even if they are a BHA approved Essential Provider, based on network needs.

Q: How do Essential Providers contract with MCEs?
A: As we move to ACC Phase III, providers must engage with new RAEs and establish new contracts, which will begin on July 1, 2025.  RAEs are allowed to contract with providers based on network adequacy requirements. RAEs are required to continually monitor access to care to ensure their network meets the needs of its members  , including essential service needs, which may change based on population. Providers are encouraged to work with RAEs to ensure clear understanding of network needs and essential service capacity. 

Q: What reimbursement options are available for Essential Providers?  
A: Essential Providers must be paid at least the rate listed on the Essential Provider Fee Schedule.  MCEs can pay above this rate and there is no reconciliation process required for Essential Provider payments. MCEs can also enter into value-based payment arrangements with Essential Providers, as long as the Essential Provider is reimbursed at least the rate listed on the Essential Provider Fee Schedule.  A provider will receive the Essential reimbursement rate based on the effective date of their contract with the MCE.

Q: Where can I find the Essential Provider Fee Schedule?
A: The rates for all Safety Net Providers are published in the SBHS Billing Manual, APPENDIX D: MEDICAID DIRECTED PAYMENTS. If a service is not listed on the fee schedule, it is not considered an "Essential" service. While organizations may still provide such services, there is no directed payment associated.. Organizations may negotiate a rate with the MCE.

Q: How was the Essential Fee Schedule developed?
A: The fee schedule was developed using data from Medicaid fee schedules, cost reports, historical rates, and rates from several other states. Actuaries and subject matter experts reviewed and adjusted it for reasonableness and accuracy. The Essential Provider Information and Engagement Sessions held in July 2024 provides more information.

Q: Are Federally Qualified Health Centers (FQHC) eligible to become Essential Providers?
A:  Because FQHCs have federally regulated PPS reimbursement parameters, including cost report data tracking, there are limited opportunities for an FQHC to bill for services outside of their encounter rate or under a different payment methodology. FQHCs are allowed to provide most behavioral health essential services and be reimbursed at the BH encounter rate.  Therefore, FQHCs will not be able to enroll with HCPF as an Essential Provider as costs for these services will be considered during existing cost auditing and rate setting processes and will be paid in future encounter rates.

Q: What is the impact of HCPF’s plan to discontinue the use of Provider Type 64/Specialty Type 477?
A: Existing providers with Provider Type 64/Specialty Type 447 should submit a maintenance request to add a specialty type that is most reflective of the services being delivered. The specialty type should align with the provider's BHE endorsements (and Essential Provider approval letter if they choose to become an Essential Provider).  See the Essential Provider Type Alignment Guide to determine what BHA Essential Provider approval letter is allowed for each HCPF Provider type.

Crisis Services

The Department of Health Care Policy and Financing (HCPF) partners with several state agencies to support the behavioral health continuum of care in Colorado. Learn more about the crisis continuum.

Health First Colorado (Colorado’s Medicaid program) benefits cover a range of services when members are experiencing a behavioral health crisis. A behavioral health crisis can happen anywhere, anytime, to anyone. HCPF covers services so that Health First Colorado members have someone to talk to, someone to meet with in-person, a place to go, and transportation to get there.

Community-Based Crisis Services

Community-based services are crisis services delivered to Health First Colorado (Colorado’s Medicaid program) members in the community.

  • 988/Crisis Line is the starting point for members in crisis. Trained professionals provide immediate support, offer recommendations and connect members to further resources via telephone or text. Colorado has one statewide Behavioral Health Crisis Line provider, Solari.
  • Mobile Crisis Response (MCR) is a service where two crisis professionals respond to a member in the community to provide de-escalation and stabilization, crisis assessment and intervention, and coordinate referrals to appropriate resources.
  • In-home crisis respite services offer short-term support in a member’s home setting.

Facility-Based Crisis Services

Facility-based crisis services offer members a place to go to meet with someone in person.

  • Crisis facilities are where members can get a crisis assessment, which can result in safety planning and discharge and/or placement evaluations. Some of these facilities may also be able to support admission to behavioral health residential or inpatient facilities for further treatment.
    • Walk-in Crisis Services are located throughout Colorado and offer in-person crisis support, information, and referrals to any individual in need including to anyone experiencing a self-defined crisis.
    • Withdrawal management facilities, also known as substance use disorder clinics, offer assessment and support for behavioral health crises involving substance use disorders.  There are a range of substance use levels of care based on American Society of Addiction Medicine (ASAM) standards.
    • Emergency departments are ambulatory, also known as outpatient, facilities that provide emergency psychiatric care. 
    • Receiving facilities are behavioral health entities or hospitals that offer assessment and treatment services for individuals with behavioral health needs. These facilities provide short-term and long-term residential or inpatient programs, providing care and support for stays exceeding 24 hours. Learn more about residential and inpatient services.

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