Supportive Housing Services
The Department of Health Care Policy and Financing is working to expand the spectrum of behavioral health services for Health First Colorado (Colorado’s Medicaid program) members. This includes increasing access to supportive housing services for members with behavioral health needs.
What is Permanent Supportive Housing?
Permanent Supportive Housing (PSH) is designed to support extremely low-income people experiencing homelessness who have a disabling condition (either physical or behavioral health) through combining a Permanent Supportive Housing (PSH) voucher (provided by the Department of Local Affairs - Division of Housing) with supportive services and clinical care to assist individuals in obtaining and retaining stable housing.
What Supportive Housing services are reimbursable by Medicaid?
Most services delivered in a supportive housing context are reimbursable by Health First Colorado (Colorado’s Medicaid program) for members who meet social and clinical eligibility criteria. This includes: case management, outreach, housing navigation, leasing navigation, move-in and orientation assistance, skill building, peer services, assistance renewing leases, and assistance renewing vouchers.
Expanding coverage through the HRSN 1115 Waiver Amendment
On January 13, 2025, HCPF was approved by the Centers for Medicare & Medicaid Services (CMS) for an 1115 SUD Demonstration Amendment to cover Health-Related Social Needs (HRSN) services for Medicaid members who meet certain social and clinical criteria.
Colorado has received authority to cover the following HRSN housing services with a phased approach:
- Targeted Case Management for housing supports
- Pre-tenancy navigation services
- Tenancy sustaining services
- One-time transition and moving costs
- Rental assistance and utility assistance
Questions about Medicaid reimbursement for Supportive Housing Services?
Join our monthly Office Hours!
HCPF will host Office Hours weekly from 2 p.m. to 3 p.m. Tuesday 6/12, Wednesday 6/18 and Thursday 6/26 to answer questions regarding Medicaid reimbursement for supportive housing services. There is no structured presentation during Office Hours. Register via Zoom.
Frequently Asked Questions
Click a link below to navigate to that FAQ topic section:
FAQs about Supportive Housing Services for the PSH Population
FAQs about Provider Eligibility and Medicaid Enrollment
FAQs about Member Eligibility Criteria for Supportive Housing Services
FAQs about Supervision & Documentation
FAQs about Billing for Supportive Housing Services
FAQs about Supportive Housing Services for the PSH Population
- What housing-related services can Medicaid cover?
- Colorado’s 1115 Waiver Demonstration authorizes coverage of the following services to be implemented with a phased approach:
- Targeted Case Management for housing supports
- Pre-tenancy navigation services
- Tenancy sustaining services
- One-time transition and moving costs
- Rental assistance and utility assistance
- Effective July 1, 2025, the following services will be reimbursable for providers enrolled as a Supportive Housing Provider (PT 89/208):
- Targeted Case Management for housing supports
- Pre-tenancy navigation services
- Tenancy sustaining services
FAQs about Provider Eligibility and Medicaid Enrollment
- What type of provider can bill for Supportive Housing Services?
Effective July 1, 2025, only organizations enrolled with Health First Colorado as a Supportive Housing Provider (PT 89/208) can bill for supportive housing services (H0043 & H0044) delivered to the PSH population.
- What are the requirements of a Supportive Housing Provider and how does my agency begin the process of enrolling with Medicaid?
Supportive Housing Providers are agencies who have an allocation of Permanent Supportive Housing (PSH) vouchers and who receive an approval letter from the Department of Local Affairs (DOLA) then enroll with Medicaid as a Supportive Housing Provider (PT 89/208).
- As a first step, agencies must fill out an Approval Letter Request Form to request a letter of approval from DOLA’s Division of Housing (DOH).
- If you have questions about Medicaid provider enrollment as a Supportive Housing Provider, please contact: hcpf_housing_supports@state.co.us
- Can an organization have multiple provider type enrollments with Medicaid?
Yes. Organizations can enroll with Medicaid as multiple provider types, as long as they meet the qualifications for each enrollment type.
- Does my organization need a new National Provider Identifier (NPI) number for each Medicaid provider enrollment?
Yes. C.R.S. 25.5-4-420 mandates that all Medicaid billing providers must obtain and use a unique National Provider Identifier (NPI) for each service location and for each provider type enrollment. - My organization has one building where staff have their offices and then we provide services at various locations in the community through a scattered site PSH model. Do we need to have more than one Supportive Housing Provider enrollment?
- The physical location where staff have their primary offices is the address that should be tied to a Medicaid provider enrollment as PT 89/208 - Supportive Housing Provider.
- Services provided at other locations in the community, or in a member’s home, can be billed using the appropriate Place of Service (POS) code.
FAQs about Member Eligibility Criteria for Supportive Housing Services
- What is the eligibility criteria for the Supportive Housing Services covered by the 1115 Waiver?
Individuals must be Medicaid eligible and meet the social criteria, as well as at least one of the clinical criteria:
- Social Criteria for PSH Population: Be 18 years of age or older; Have a disabling condition; Have a history of homelessness or be at risk of homelessness; Must be at or below 30% of the area median income
- Clinical Criteria for PSH Population:
- Behavioral Health Need: A diagnosed behavioral health disorder, according to the criteria of the current editions of the Diagnostic and Statistical Manual of Mental Disorders and the International Statistical Classification of Diseases and Related Health Problems where there is a need for improvement, stabilization, or prevention of deterioration of functioning (including ability to live independently without support) resulting from the presence of a behavioral health condition.
- Chronic Health Condition: One or more chronic conditions including but not limited to those identified in Social Security Act section 1945(h)(2). Examples of conditions can include: diabetes, BMI over 25,cardiovascular disease, respiratory disease, HIV/AIDS diagnosis, hypertension, physical disability (e.g. amputation, visual impairment), cancer, hyperlipidemia, chronic obstructive pulmonary diseases, chronic kidney disease.
- What are the three subpopulations within PSH and what services do they qualify for?
| Subpopulation | Definition | Covered Services |
|---|---|---|
| PSHa | Individuals matched to a PSH voucher within the past 12 months |
|
| PSHb | Individuals eligible for PSH but not yet matched to a voucher |
|
| PSHc | Individuals residing in PSH for more than one year |
|
- How is eligibility for a PSH voucher defined and verified?
The Homeless Management Information System (HMIS) Coordinated Entry System is the standard to confirm eligibility for a PSH voucher. - How does a provider verify that a member meets the clinical criteria for HRSN housing services?
- For the PSH population, clinical criteria are determined initially through self-disclosure of a behavioral health need or chronic health condition during the Coordinated Entry assessment. Once a member is referred to services, a licensed clinician affiliated with the supportive housing provider confirms clinical diagnosis and uses their professional judgment to deem the service to be medically appropriate and in accordance with the member’s diagnosis and treatment plan.
- Supportive Housing Providers can also obtain clinical information from other healthcare providers through a Release of Information (ROI) form. This allows the exchange of protected health information among providers, ensuring that all relevant clinical data is available to support eligibility determinations.
- When does this eligibility criteria take effect?
HCPF has the authority to begin covering Supportive Housing services under the HRSN 1115 Waiver Amendment effective July 1, 2025.
This authority expands the eligible population to include the clinical criteria of chronic conditions, in addition to those with a behavioral health need.
FAQs about Service Providers, Supervision, and Documentation of Supportive Housing Services
- What types of unlicensed services providers can deliver Targeted Case Management and Supportive Housing Services under the supervision of a licensed provider?
Peer Specialist, QBHA, QMAP, Bach Level, Intern, Unlicensed Master’s Level, Unlicensed EdD/ PhD/PsyD, LCSW, LPC, LMFT - What are the supervision requirements for Supportive Housing Services?
All unlicensed professionals must receive supervision from the licensed professional who is listed on the claim as the rendering provider.
Please see the Medicaid Supervision Policy for additional information. - What are the service documentation standards?
Providers have the discretion to design the format of a service note that captures documentation in line with these guidelines and general professional standards for care. Please see the Service Documentation Standards for additional information. - How do providers ensure that all eligible services are in support of a member’s treatment plan?
Ongoing services need to be in alignment with a member's treatment plan. The clinician who provides supervision over the service delivery is responsible for ensuring that services are in support of the member's treatment plan.
FAQs about Billing for Supportive Housing Services
- How do Supportive Housing Providers bill for covered services?
- Beginning July 1, 2025, Supportive Housing Services will be covered through the Fee-for-Service (FFS) reimbursement model.
- Fee-for-Service (FFS) reimbursement provides payment to enrolled providers for each service rendered to Health First Colorado members.
- In the FFS model, providers are paid a predetermined rate for each specific service they provide.
- FFS claims are processed by the Health First Colorado fiscal agent.
- How are Fee-for-Service claims submitted?
Enrolled Health First Colorado Supportive Housing providers can submit claims for services electronically using the Provider Web Portal. - Where can I learn more about Fee-for-Service (FFS) billing?
Visit HCPF’s Provider Training webpage to learn more about FFS billing. - Will any Supportive Housing services continue to be billed through the RAEs after July 1 or will all of these services transition to FFS?
All Supportive Housing Services (H0043 & H0044) will be billed Fee-for-Service, beginning July 1, 2025. - What are the billing codes that Supportive Housing Providers can use to bill for covered services?
| Service | Code | Position 1 Modifier | Position 2 Modifier |
|---|---|---|---|
| Targeted Case Management for Housing Supports | T1017 | U2 | |
| Supportive Housing, per diem - Pre-tenancy navigation services | H0043 | U2 | UA |
| Supportive Housing, per month - Pre-tenancy navigation services | H0044 | U2 | UA |
| Supportive Housing, per diem - Tenancy sustaining services | H0043 | U2 | UB |
| Supportive Housing, per month - Tenancy sustaining services | H0044 | U2 | UB |
Note: The Position 1 Modifier “U2” is used to indicate a member is part of the PSH voucher population. The Position 2 Modifier “UA” or “UB” is used to differentiate between pre-tenancy and tenancy sustaining services.
- When should we switch between billing for Pre-tenancy services vs. Tenancy sustaining services?
- If you are billing for the per month code, use the Position 1 “UA” modifier to indicate Pre-tenancy services up to and including the month in which the member moves into their unit.
- If you are billing for the per diem code, the day that the member moves into their unit is the first day that the Supportive Housing Provider should use the Position 2 “UB” modifier to indicate delivery of Tenancy sustaining services.
- What are the time requirements for the different codes?
- T1017 - Targeted Case Management: Providers may bill up to four units per member per day. Targeted Case Management involves linking the member to the direct delivery of needed services, but it is not itself the direct delivery of a service to which the member has been referred. (Example: Referrals and care coordination between other service agencies or healthcare providers)
- H0043 - Supportive Housing, per diem: Providers may bill H0043 when two hours or more of services are provided to a member in a day.
- H0044 - Supported Housing, per month: Providers may bill H0044 when 15 hours or more of services are provided to a member in a month.
Technical Assistance Resources
To ensure sustainable reimbursement for supportive housing services for agencies involved in the ARPA 3.07 SWSHE grant, HCPF is assisting participating agencies with the process of enrolling as a Medicaid provider. HCPF is using ARPA dollars to fund two technical assistance contractors and has been providing ongoing TA through 1:1 calls and webinars since May 2023, so the housing providers can learn how to consistently bill and document within standard Medicaid requirements.
HCPF has compiled a list of Frequently Asked Questions on transitioning to sustainable supportive housing services through Medicaid and is available to provide 1:1 technical assistance to supportive housing agencies as needed.
Resources for Supporting Medicaid Members with the Renewal Process
As part of wraparound services and care coordination, supportive housing providers are expected to assist members with:
- Filling out Medicaid renewal paperwork to prevent disenrollment
- Completing the reinstatement process to address procedural disenrollments
- Referring members to their MCE for escalation of complex issues
HCPF provided a training on this topic to SWSHE grantees on June 6, 2024. Links to Medicaid renewal resources are included in the training slides and available on the HCPF PHE website.
Learn More about Supportive Housing
Colorado Department of Local Affairs (DOLA)
U.S. Department of Housing and Urban Development (HUD)
Substance Abuse and Mental Health Services Administration (SAMHSA)
Learn More about HRSN 1115 Waiver Efforts
Pending the passage of HB 24-1322, HCPF expects to submit an HRSN 1115 amendment to the Centers for Medicaid & Medicare Services (CMS) in August 2024 to expand housing and nutrition services for certain populations. Learn more on our HRSN webpage.
Reporting on the Statewide Supportive Housing Expansion (SWSHE) Pilot Project: Outcomes and Findings
Statewide Supportive Housing Expansion (SWSHE) Final Report
The Statewide Supportive Housing Expansion (SWSHE) Pilot Project aimed to:
- Expand pre-tenancy and tenancy support services for people experiencing homelessness with the highest unmet health needs, and
- Inform Medicaid policy and systems change to create a more permanent funding source for supportive housing providers across the state
The project achieved both goals and built a solid foundation for expanding engagement between Medicaid and supportive housing providers across the state. The many lessons learned throughout the project are documented in the Final Report.
Research Report by the Urban Institute: Unlocking Medicaid's Potential to Expand Supportive Housing: Findings from Colorado's Statewide Supportive Housing Expansion Project
HCPF contracted with the Urban Institute to conduct an independent evaluation of the SWSHE Pilot Project. The evaluation consisted of implementation and impact studies which analyzed how the program housed and served eligible participants and its impacts on housing and health care utilization and costs over the first year. Findings include increased primary care visits, specialist visits, mental health outpatient visits, and prescription medications among project participants, showing significantly different outcomes between participants and the comparison groups.