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 Supportive Housing?
Supportive Housing is designed to support extremely low-income people experiencing homelessness who have a disabling condition (either physical or behavioral health) through combining a 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 for members with a behavioral health diagnosis, or in cases where the diagnosis has been deferred. 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.
Frequently Asked Questions
- How will supportive housing providers bill for support services?
There are two all-inclusive supported housing codes: H0043 (supportive housing, daily rate) and H0044 (supportive housing, monthly rate). Effective October 2024, these codes will include the services outlined above. Providers will complete claim forms and submit to Managed Care Entities (MCEs) for reimbursement. Colorado’s Managed Care Entities include seven Regional Accountable Entities (RAEs) and two Managed Care Organizations (MCOs).
- Who can bill Medicaid for the revised supportive housing services package as of Oct 1, 2024?
To seek reimbursement for this package of covered services through the codes described above, agencies must secure a letter from the Colorado Department of Local Affairs’ Division of Housing (DOLA/DOH) which identifies their agency as a supportive housing provider overseeing an allocation of supportive housing resources/vouchers. Such entities are qualified to enroll in Medicaid within the Supportive Housing Provider Type and contract with one or more Managed Care Entities (MCEs).
- How are reimbursement rates determined?
HCPF provides a set amount to Managed Care Entities to cover provision of all behavioral health services provided under the Capitated Behavioral Health Benefit. MCEs are responsible to determine, based on member needs in the region, how best to spend the money, considering factors such as number of members using particular services and number of providers available. As part of contracting, MCEs negotiate rates with each provider.
HCPF is updating the supported housing codes (H0043 & H0044) to include the full package of services relevant to supportive housing. HCPF will be setting a benchmark rate to guide MCEs in understanding the state's perspective that factors what similarities and differences exist in Colorado as compared to other states offering similar benefits.
- What is the provider type for supportive housing agencies?
Supportive housing agencies, that participated in the SWSHE pilot project and only deliver non-clinical supportive services, will enroll with Medicaid through a new provider type / specialty type being created for supportive housing providers that is aimed to be effective July 1, 2024.
Agencies that are already enrolled with Medicaid or who intend to employ a licensed clinician and deliver clinical services (in addition to supportive services) will have their provider type reviewed with HCPF on a case by case basis.
- How long does it usually take to enroll as a Medicaid provider and contract with MCE(s)?
Agencies should anticipate it taking approximately 60 days to complete these two processes.
- What are the infrastructure requirements to be a Medicaid provider?
Agencies must obtain appropriate insurance, establish policies & procedures, and contract with or employ a licensed clinician to provide clinical supervision for unlicensed professionals.
- Do supportive housing providers need to purchase a billing system in order to bill Medicaid?
No, supportive housing providers do not need to purchase a billing system. A third party billing company may be used.
- Do supportive housing providers need to employ a full-time clinician?
No, supportive housing providers do not need to employ a full-time clinician, but rather may contract with a licensed clinician for limited hours of clinical supervision.
- Do supportive housing providers need to use an Electronic Health Record (EHR)?
No, supportive housing providers do not need to purchase an EHR. The Homeless Management Information System (HMIS) may be used for documentation.
- What are the requirements for insurance? Do supportive housing providers have to insure the licensed clinicians individually or just carry insurance as an organization?
Providers are required to hold General Liability Insurance. Organizations are responsible to cover employees only, so if you employ the clinician you cover them. If you contract with a clinician, you can have them provide their own insurance.
- What types of unlicensed service providers (ie. professional staff) can deliver billable supportive services?
Unlicensed service providers allowed to deliver Supported Housing service codes include Bachelor’s level, CAS, CAT, clinical intern, Peer Specialist, Unlicensed Master’s Level, and QMAP. More details on service provider requirements can be found in Appendix J of the State Behavioral Health Services Billing Manual.
In consideration of stakeholder feedback, HCPF is exploring the role of case managers, and requirements for serving as a provider in this role.
- Is clinical supervision required if our housing team is not providing clinical services?
Yes, clinical oversight is required for all billed services.
- What are the education, certification, and lived experience requirements for Peer Specialists?
Peer Specialists do not need to hold a Bachelor’s degree. A certification endorsed by the Colorado Provider Association (COPA) is not required, except in the case of employment by a Recovery Support Services Organization (RSSO). Any type of relevant lived experience is allowed.
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.
Upcoming Office Hours:
Each month the HCPF hosts an open office hour to answer SWSHE grantees’ questions about Medicaid provider enrollment and billing for supportive housing services.
Office Hours are held monthly on the last Thursday of the month from 2:00 - 3:00pm.
Register here if you have a question that we can help answer.
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.