Colorado Medicaid Rule Changes (Updated 10/1)
Last updated: October 1, 2026
HCPF is proposing significant updates to Colorado's Pediatric Behavioral Therapy (PBT) requirements. The initial rule reading is scheduled for December 11, 2026, with the final reading scheduled for January 8, 2027. If approved by the Medical Services Board, the rule is expected to take effect March 2, 2027.
What practice owners should do right now
Start obtaining NPIs for all current BTs. You can send this guide to your RBTs.
What Alpaca is doing to prepare
Prepare for BT rostering: Build workflows to roster and enroll individual BTs with Health First Colorado.
Update billing systems: Ensure each individual BT can be identified as the rendering provider on claims.
Track the 45-day certification window: Build processes to track new BTs through the temporary certification period and ensure certification is completed on time. We're also working with the payer to fully understand how we can track whether the BT has started the 45-day certification window with another employer.
Key changes
Individual NPI + Medicaid enrollment for BTs: Every Behavior Technician will need their own NPI and Health First Colorado enrollment and must be affiliated with the billing practice.
BT certification required: BTs must obtain and maintain an accepted certification.
45-day certification window: New, uncertified BTs may have a one-time 45-day temporary reimbursement period while pursuing certification, subject to federal approval and prerequisite requirements.
IMPORTANT: The 45 days follow the BT across employers. So, if a BT is uncertified 30 days with one employer, when the BT goes to a new employer, they only have 15 days left to deliver uncertified services.
Quarterly BT rosters: Practices using the temporary reimbursement pathway will need to maintain and submit required BT roster information, including training and certification status.
Yearly referral updates: PBT must have an order/referral from an eligible Medicaid-enrolled MD/DO, PA, NP, or licensed psychologist before services begin. Referrals may not exceed 12 months.
New age-based service-hour guidelines: 25 hrs/week for ages 18 months–5, 16 hrs/week for ages 6–12, and 10 hrs/week for ages 13–20. These are not hard caps, but requests above these levels will require additional clinical justification and review.