Reforming Colorado’s Behavioral Health System
Colorado is in the process of significant behavioral health system reform with the goal of expanding access to care and enhancing the quality of care delivered to all people in Colorado. As part of this reform, the Department of Health Care Policy and Financing (HCPF; the Department), in partnership with other agencies, has created a vision to:
- Expand the provider network to increase safety net services.
- Create opportunities for providers to add services.
- Improve the quality of care.
- Obtain alternative funding that will lead to a more sustainable provider system.
Major elements of this reform effort include:
- Creation of new safety net provider types - Comprehensive Safety Net Providers and Essential Safety Net Providers.
Alternative payment methodologies. - Development of Universal Contract Provisions (UCP) for behavioral health services.
About This Page
This page features resources and support for behavioral health providers. This includes opportunities to engage, training announcements, training materials, frequently asked questions, and access to additional resources. The page will continue to be updated, including announcements and links to register to attend behavioral health provider trainings so please bookmark this link and check back often!
Safety Net Provider Forum
With the development of the Behavioral Health Administration and related HCPF projects, there will be many upcoming changes to the behavioral health safety net in Colorado. This monthly virtual forum has been created to provide a collaborative learning space for all safety net providers.
Topics will include updates from HCPF, BHA, and HMA regarding implementation of alternative payment methodologies including the impact of payment reform efforts on Medicaid rates and billing, the upcoming implementation of the Universal Contract Provisions, technological and training systems and supports aimed at assisting providers in fulfilling their role under one of the provider types (comprehensive or essential), and the process of developing the new BHASO and RAE regional networks.
Upcoming Provider Forums
Provider Forums take place over Zoom on the last Friday of the month at 10:00 am MST. Complete the Safety Net Provider Forum form to register for one or all of the upcoming forums.
- Forum Archive
June 28, 2024
May 31, 2024
April 26, 2024
March 29, 2024
February 23, 2024
January 26, 2024
December 15, 2023
- Watch the recording
- Meeting Slides
October 27, 2023
August 25, 2023
July 28, 2023
June 30, 2023
- Watch the recording
- Meeting Slides
May 26, 2023
- Watch the recording
- Meeting Slides
Colorado is exploring the Certified Community Behavioral Health Clinic (CCBHC) model. Details of BHA’s & HCPF’s efforts can be found on the CCBHC webpage.
Behavioral Health Provider Training and Technical Assistance
As part of this reform effort, HCPF is investing in Training and Technical Assistance (TTA) for behavioral health providers. Health Management Associates (HMA) has been contracted to provide comprehensive TTA to address the diverse needs and goals of providers. The TTA program is designed for all behavioral health providers, encouraging participation from those currently receiving public funds or considering accessing them in the future. The focus is on expanding benefits and services, improving access to care, and elevating quality.
Sign up here to join the Behavioral Health Reform TTA newsletter and share with your provider network! Click here for an archive of past newsletters.
Access 30+ training recordings for behavioral health providers by visiting the Training Library.
- Upcoming Trainings and Office Hours
Office Hours
Office hours offer the opportunity to drop in and ask questions to our subject matter and clinical experts about any of the conducted trainings.
July
Friday, July 26,2024 at 12 p.m.
August
Friday, August 30, 2024 at 12 p.m.
September
Friday, September 27, 2024 at 12 p.m.
You’re welcome to email us at info@safetynetproviders.com if you have additional topics you would like covered during office hours.
- About the TTA Program
The TTA program includes live virtual and pre-recorded trainings, covering a range of topics tailored to providers' specific needs. TTA will be facilitated by a team of Subject Matter Experts (SMEs), in partnership with state agencies, local and national experts to share tailored knowledge and best practices by topic. The planned training topics fall into two major categories:
Behavioral Health Reform Awareness and Readiness: pre-recorded trainings for current and future providers to build awareness and readiness for significant reform efforts. Topics include:- Understanding State Agency Roles in Colorado Behavioral Health Services
- Roles and Responsibilities of the RAEs & BHASOs
- Medicaid Basics for New Providers
- Introduction to Financial Cost Reports
- Safety Net Licensure Transitions
Safety Net Competency: live virtual trainings to elevate quality and improve capacity across the behavioral health provider community. Topics include:
- Medication Assisted Treatment
- Wraparound Services
- Serving populations with multiple, complex needs
- Innovations in transitions from institutional care to community care
- Removing structural and organizational barriers to access and more!
In addition to the live virtual trainings described above, several trainings in this category will be pre-recorded and made available. Topics include:
- Evidence-based practices
- Harm reduction
- Working with other system partners and more!
To assist providers in implementing changes, additional supports will be created including supplemental resource materials, updated Frequently Asked Questions, and office hours. Supports aim to foster meaningful connections among behavioral health providers to encourage sharing of questions, challenges, ideas, and experiences as part of peer teaching. The ultimate goal is to facilitate organizational change and enhance the overall effectiveness and sustainability of the behavioral health provider system in Colorado.
Currently, trainings and technical assistance will be provided through June 2024.
- Supplemental Training Materials for Providers
Supplemental training materials will be added throughout the TTA program. Please submit a TTA request via our online form if you are looking for a specific resource.
Provider Communication Toolkit
We have developed a communication toolkit in English and Spanish to assist providers in sharing information about the TTA program among your networks to help expand awareness and utilization of the program’s resources. The toolkit includes content and graphics for you to simply copy and paste into your communication channels including social media, e-newsletters, presentations, and more!
Access the toolkit
Frequently Asked Questions
Select the categories below to find answers to questions commonly asked by providers.
- BHA Licensure/Approval
Q: Can my agency enroll in Medicaid as both a Comprehensive Safety Net Provider and an Essential Safety Net Provider?
A: Yes, a provider agency may enroll as both a Comprehensive and an Essential provider depending of the scope of services being provided and with appropriate licensure and approvals by the BHA.Q: I am currently enrolled as a CMHC with HCPF. What steps do I need to take to switch my agency’s enrollment to a Comprehensive Safety Net Provider?
A: Agencies who are currently CMHCs will need to submit a new enrollment with HCPF as a Comprehensive Provider, which is Provider Type 78. The provider will need to have their approval letter from BHA to enroll as a Comprehensive Provider. This new enrollment requires agencies to apply for and submit a new NPI as part of the process. A current CMHC should not disenroll any provider types (e.g., provider types associated with outpatient mental health or substance use disorders services) until all services are paid that were provided under the current CMHC enrollment. An agency may have dual enrollments during the transition period in order to be able to bill as a Comprehensive Provider and still be paid for services provided under their enrollment as a CMHC.Q: What taxonomy should my agency select when applying for new NPIs to support enrollment with HCPF?
A: Agencies should select a taxonomy that best fits with the service array being provided at the specific location.Q: Must my provider organization apply for the BHE licensure prior to seeking approval as a safety net provider?
A: Provider organizations are encouraged to apply for both the BHE licensure and safety net approval at the same time for a more streamlined application and review process. However, this is not required and providers are welcome to apply for one before the other.Q: Is there a fee associated with applying for safety net approval?
A: No, there is not a fee associated with the safety net approval application.Q: My provider organization currently has multiple BHA-issued license(s) and/or designation cycle(s) that do not expire on the same date. When and how do I transition my licensure?
A: You must transition by the expiration date of the earliest cycle. Submit the Letter of Intent and obtain an updated username and access to LADDERS at least sixty (60) days prior to the earliest license and/or designation cycle’s expiration date.- HCPF Enrollment
Q: Is there a specific Provider Type and Specialty Type Essential Safety Net Providers (Essential Providers) when enrolling in Medicaid?
A: No, there is not a distinct Provider Type or Specialty Type for Essential Providers. However, there is a flag that Essential Providers must select in the HCPF Enrollment Portal. Current providers should submit a maintenance request and select “Essential Provider” in the Enrollment Portal. New Providers should enroll as an Essential Provider under the appropriate Provider Type based on your license and then select “Essential Provider” in the Enrollment Portal at the time of enrollment.Q: My agency provides substance use disorder residential services and is currently enrolled as provider type 64 (SUD Residential), do I need to disenroll with HCPF and submit a new enrollment with a new NPI for my service location?
A: Your agency does not need to disenroll and re-enroll with HCPF or submit a new NPI to remain a SUD Residential provider. However, you do need to submit a maintenance request, along with your Essential Provider Approval Letter from the BHA, to ensure proper payment from HCPF as an Essential Provider.Q: My agency is an Essential Safety Net Provider. What do I need to do in order to receive the enhanced reimbursement rate under Medicaid?
A: During Essential Provider enrollment process, you must select the Essential Provider “flag” in the Enrollment Portal which will indicate that you are eligible to receive the enhanced reimbursement rate. In addition, a provider must be contracted with a managed care entity (MCE) as a safety net provider to receive the enhanced payment. Providers will start to be paid the rates indicated on the Essential Provider Fee Schedule after their contract with the MCE is finalized.Q: As a Comprehensive Safety Net Provider (Comprehensive Provider), will my agency be able to be both the Billing Provider and the Rendering Provider on claims?
A: No, Comprehensive Providers will only be able to be the Billing Provider and the Pay-To Provider. The individual licensed practitioner delivering the service, or supervising the staff providing the service, should be listed as the Rendering Provider on the claim.Check out the Safety Net Provider Medicaid Enrollment Resource Scenarios document in the “Resources” section below for more information on the process of Medicaid enrollment across service locations.
Q: Who can I contact for technical support when enrolling with HCPF?
A: For support enrolling with HCPF (and to outreach a Field Rep) - Field Rep for NPIs- Call Gainwell Technologies, HCPF’s fiscal agent, at 1-844-235-2387. Always get the agent's name and Call Tracking Number (CTN) in case you or HCPF need to follow up with Gainwell.
- If Gainwell can't help, submit an online request to HCPF’s Field Rep team here: Regional Provider Support. A Field Rep will reach out to you within two (2) business days. Submitting requests in the system allows HCPF to better track and respond (vs an email to the Field Rep staff).
Q: What process do I need to follow in order to indicate that I am an essential provider while HCPF is updating its system?
A: A Google form is being used as a temporary solution for providers to communicate their status as an Essential Provider. The Enrollment Update Form for Essential Providers has been emailed to providers. HCPF expects that most providers are already enrolled and that this form will be used to note their BHA approval as an Essential Provider. Any non-enrolled provider (e.g., a new crisis stabilization unit) should enroll with HCPF first . The provider can then use this form to note the Essential Provider approval status once they have a standard enrollment.Q: What is the timeline associated with the Enrollment Update Form for Essential Providers?
A: HCPF will validate the information submitted on the form with the provider’s existing enrollment record in the interChange/MMIS and "approve" within 3-5 business days.Q: How will the MCEs be made aware of my Essential Provider status with HCPF?
A: HCPF will send a list of approved Essential Providers to MCEs every Thursday. This may occur more frequently in the future based on volume. Providers should also be contacting MCEs to share their enrollment status as an Essential Provider.Q: What provider information is shared with the MCEs using the manual process for communicating Essential Provider status? What additional information will be requested by the MCEs?
A: HCPF’s list will include a provider's name, address, and NPI numbers. MCEs are expected to request a copy of the Essential Approval letter issued by the BHA that contains the details MCEs will need for contracting such as address and approved services per location, effective dates, and expiration dates.- Safety Net Provider Types
Q: What are the services required to be provided by a Comprehensive Safety Net Provider?
A: Comprehensive Safety Net 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
Q: What services are required to be provided by an Essential Safety Net Provider?
A: Essential 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
Check out the Safety Net Provider Medicaid Enrollment Resource Scenarios document in the “Resources” section below for more information on the process of Medicaid enrollment across service locations.
- National Provider Identifier (NPI)
Q: What steps should my agency take to receive BHA Licensure and Safety Net Provider approval?
A: Review applicable BHA license and approval regulations from 2 CCR 502-1. Visit the LADDERS licensing portal to begin an application. Complete the application for the licensure, designation or approval required and upload any required documentation.Check out the Safety Net Provider Medicaid Enrollment Resource Scenarios document in the “Resources” section below for more information on the process of Medicaid enrollment across service locations.
Q: As a comprehensive safety net provider, will my organization need new NPIs for each physical location as well as an NPI for each distinct mobile crisis team?
A: As a comprehensive safety net provider, you will be creating a new enrollment as a Provider Type 78 for each address included under your Comprehensive approval. A new NPI is required for each new enrollment per Colorado Law. Mobile crisis services are considered a Comprehensive service and would be part of the comprehensive enrollment.- Billing and Reimbursement
Q: My provider agency is not currently licensed and/or designated by BHA and does not have a Behavioral Health Entity (BHE) license with CDPHE. What steps do I need to take to become licensed by BHA as a BHE?
A: If your agency is not currently licensed and/or designated by BHA nor has a BHE with CDPHE, and is interested in or required to pursue this, you will need to become familiar with the updated BHA Provider Rules (effective 1/1/2024) and when ready, submit a Letter of Intent to obtain a username and access to submit an initial application in LADDERS. Your agency will be subject to the updated BHA Provider Rules from the initial point of licensure.Q: My provider agency is currently licensed by CDPHE as a Behavioral Health Entity (BHE). When and how do I transition my licensure?
A: Your agency’s license will transition from CDPHE to BHA on your current BHE’s expiration date. You must submit a Letter of Intent in LADDERS at least sixty (60) days prior to the earliest license and/or designation cycle’s expiration date.Check out the Safety Net Provider Medicaid Enrollment Resource Scenarios document in the “Resources” section below for more information on the process of Medicaid enrollment across service locations.
Q: My provider organization is seeking approval as an Essential Safety Net Provider. Must I 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 new provider even if they are approved Essential safety net provider based on network needs.Q: As an Essential Safety Net Provider, when will I be able to begin receiving the Essential reimbursement rate?
A: A provider will receive the Essential reimbursement rate based on the effective date of the MCE contract.Q: Will provider organizations still submit claims on a Professional claim form (CO-1500/837P) ?
A:Yes, providers will continue to use the CO-1500/837P form to submit claims.Q: My organization is a Federally Qualified Health Center (FQHC), and our rates are based on our Medicaid cost report. Will we be eligible for a different reimbursement for being an Essential Safety Net Provider? If so, is it just a specific provider or all of the behavioral health providers who bill within the FQHC?
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: Can you explain why Comprehensive providers can only be billing providers and cannot function as rendering providers the way CMHCs have done so in the past?
A: HCPF is working to come into compliance with the 837 encounter requirements that are part of federal HIPAA requirements. Per HIPAA, HCPF is not allowed to vary Medicaid billing requirements from those standards as described in the 837 Implementation Guide.Per the Technical Report Type 3 (TR3), which describes implementation instructions for electronic transactions under HIPAA, when the rendering provider is different from the billing provider, the rendering provider is required. If the rendering provider is not different, then you do not send the rendering provider information (only the billing provider details).
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: My organization has providers who are not independently licensed and therefore not enrolled in the Medicaid program. Who can order the services and how must they be supervised? Who should be listed as the rendering provider?
A: As indicated in the State Behavioral Health Services (SBHS) Billing Manual, Medicaid behavioral health services provided by practitioners 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 DORA.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 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: 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 just billed by the Essential provider for reimbursement as negotiated with the MCE.
- Component services provided at an Essential Provider (WM, Residential, CSU, etc.) cannot be billed by the Comprehensive provider unless the practitioner is not affiliated with the Essential setting.
Q: What reimbursement options are available for Essential providers? My organization has held value-based contracts with MCEs in the past, will I now have to accept the fee for service rates listed on the Essential Provider Fee Schedule?
A: Essential Providers must be paid at least the rate listed on the Essential Provider Fee Schedule. RAEs 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.Q: My organization is an Essential Provider considering entering into a value-based payment arrangement with a MCE, how must individual services be reported?
A: Each service would still need to be coded at the claim line level in order to appropriately track the services that were delivered.
General Provider Resources
The following are general provider resources and links to support broader behavioral health reform efforts.
Related Webpages
- HCPF Behavioral Health Reform webpage: Overview of current behavioral health reform projects.
- Behavioral Health Administration Laws and Rules webpage: information about provider rules, technical support session, and more.
- Behavioral Health Administration Providers webpage: information about provider technology office hours, convenings, Universal Contract Provisions, Behavioral Health Entity resources, forms and links.
Resource Materials
- Safety Net Provider Medicaid Enrollment Resource Scenarios
- Behavioral Health Safety Net Provider Fact Sheet
- Safety net provider transition memo from BHA and HCPF
- Reimbursement and engagement with HCPF
- OM 23-077 Joint Operational Memo on Safety Net Provider Timeline
- Community Mental Health Center (CMHC) Attestation Form
- Comprehensive Safety Net Provider PPS Convening Slide Deck, Feb 2024
- Comprehensive Safety Net Provider PPS Code List, Feb 2024
Contact Us
We’re here to help! See the contact information below for specific needs or email hcpf_safetynetforum@state.co.us if you are not sure where to start.
| Pathway | Purpose | Contact |
|---|---|---|
| HCPF | Safety net providers enrollment and billing questions | hcpf_safetynetforum@state.co.us |
| Behavioral Health Administration | Safety net provider Rules and Regulations questions | cdhs_bharulefeedback@state.co.us |
| Health Management Associates | Training or Technical Assistance Questions | info@safetynetproviders.com |