Accountable Care Collaborative (ACC) Phase III Behavioral Health Provider Updates
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What does ACC Phase III mean for me?
The launch of ACC Phase III brings several billing changes for our behavioral health provider network, most of which stem from Colorado Department of Health Care Policy and Financing (HCPF) action.
Existing behavioral health providers do not need new contracts for ACC Phase III unless one of our employees contacts you.
With the launch of ACC Phase III on July 1, 2025, we (Colorado Access) will have just one Regional Accountable Entity (RAE) region – the new Region 4 – but will still cover Denver, Douglas, Adams, and Arapahoe counties. Elbert County will now be part of Northeast Health Partners’ region. We are jointly communicating with members in Elbert County to ensure they are supported during the transition.
Read on to learn about changes to peer, supportive housing, and integrated practice site billing, as well as new direction from the State regarding essential providers and the upcoming implementation of the National Correct Coding Initiative, 1115 waiver services, and the Behavioral Health Administrative Service Organizations. You can also find information below on provider network needs for the soon-to-launch Colorado System of Care.
Thank you for being our providers and our partners. Our provider teams are ready to help answer your questions. Please email us at providernetworkservices@coaccess.com if you need help or have additional questions!
1. Peer services (rates and provider types that can bill)
In response to budget adjustments authorized by the state legislature, the Colorado Department of Health Care Policy and Financing (HCPF) is limiting the providers that can bill for services performed by a peer support professional, in addition to updating the services that can be billed for when performed by a peer support professional. These changes are effective July 1, 2025.
- Only the following provider types will be allowed to bill for peer-performed services:
- Comprehensive Safety Net Providers (PT 78 / ST 877)
- Substance Use Disorder Clinics (PT 64 / ST 371)
- Recovery Support Services Organizations (PT 89 / ST 889)
- Only the following services will be reimbursable when performed by Peer Support Professionals:
- H0038 – Self-Help/Peer Services
- H0023 – Behavioral Health Outreach
- We encourage you to continue to participate in team-based treatment. These services must tie to measurable goals specified on an individualized service plan, in compliance with Centers for Medicare and Medicaid Services (CMS) guidance.
- These policy updates will be reflected in the July 2025 edition of the State Behavioral Health Services Billing Manual. If you have any questions, please email hcpf_peerservices@state.co.us.
2. Supportive housing services policy
In preparation for implementation of the Health-Related Social Needs (HRSN) 1115 Waiver Amendment later this year, reimbursement for the two supportive housing services codes (H0043 and H0044) will be limited to providers enrolled as a supportive housing provider (PT 89/ ST 208), effective July 1, 2025. If your organization manages an allocation of Permanent Supportive Housing (PSH) vouchers, please consider enrolling with Medicaid as a supportive housing provider (PT 89/ ST 208).
3. Integrated care/six-visit rule changing (short-term behavioral health benefit)
The first six visits (short-term behavioral health benefit) that are currently being billed to the State will be billed to the Regional Accountable Entity (RAE) starting July 1, 2025. What this means for integrated behavioral health practices that were utilizing that benefit:
- Please ensure that your behavioral health providers are contracted with the RAE and can bill us directly.
- If you are billing for behavioral health services, the member will need to have a covered diagnosis.
- In addition to the first six visits moving to the RAE, HCPF will be opening Health and Behavior Assessment codes (HBAI) and Collaborative Care Model codes.
- Learn more about these proposed changes here.
4. National Correct Coding Initiative (NCCI) and Essential Safety Net Provider (ESNP) changes
Beginning July 1, 2025, HCPF is requiring RAEs to implement all NCCI edits.
- CMS created the NCCI to reduce improper payments stemming from incorrect coding and billing practices.
- NCCI prevents reimbursement for inappropriate combinations of Current Procedural Terminology (CPT) codes.
- The three types of NCCI edits:
- Add-on code (AOC) edits ensure add-on codes are not billed without a primary procedure code.
- Medically unlikely edits (MUEs) prevent inappropriate payments when services are reported with an unusually high number of units of service.
- Procedure to procedure (PTP) edits prevent code pairs that should not be reported together on the same date of service.
- For example, for a 45-minute psychotherapy session with a member (procedure code 90834) the practitioner services’ MUE Value is 2. This means that providing two services for the same date and same member is allowed, but anything over two is denied. The MUE Adjudication Indicator is 3, which means it is a “date of service edit,” so the edit looks at how many of the same services were done on the same date.
- See the CMS NCCI for Medicaid website for more information on NCCI edits.
Essential Safety Net Provider (ESNP)
Changes to directed payments:
- On April 30, 2025, Health First Colorado (Colorado’s Medicaid program) released an e-newsletter that said RAEs will no longer have to follow the essential safety net provider fee schedule for outpatient services starting July 1.
- The newsletter said: “Effective July 1, 2025, the Department of Health Care Policy and Financing (HCPF) will no longer set directed payments for outpatient behavioral health services, except those for Mobile Crisis Response services and Opioid Treatment Programs (OTPs). Directed payments for services in a bedded facility will remain in place until June 30, 2026. As a directed payment is phased out, RAEs may negotiate provider rates based on quality and network needs.”
- We are currently paying the Health First Colorado-directed payment for ESNP services.
- We only recently learned that there was potential for this change and have not had adequate time to assess if any changes will be made to the current behavioral health fee schedule. Per our contract, any change would require 90 days’ notice. We will communicate with you as soon as we know more.
Behavioral Health Secure Transport (BHST)
Changes to behavioral health secure transportation capitated benefit:
- Behavioral Health Secure Transport (BHST) is currently a fee-for-service benefit billed directly to HCPF. Beginning July 1, 2025, BHST will be included in the capitation and paid by the Regional Accountable Entities (RAEs). This change will require you to contract with the RAEs to bill for payment. See the behavioral health secure transportation benefit for more information.
American Society of Addiction Medicine (ASAM)
ASAM 4th Edition Standards Alignment: Colorado is transitioning to using updated national best practice for behavioral health.
- It is required by law. Section 10-16-104 of the Colorado Revised Statutes (C.R.S.) requires alignment with the most current version of The ASAM Criteria. Section 25.5-5-424, C.R.S. requires use of The ASAM Criteria to align with federal medicaid payment requirements.
- It is a requirement for federal funding eligibility. The 1115 demonstration waiver, overseen by the Department of Health Care Policy and Finance (HCPF), requires alignment with the national standard in order to receive reimbursement for services.
- And most importantly, people in Colorado deserve high quality behavioral health services. The ASAM Criteria has long been recognized as the best practice standard of care, and the 4th ed. provides foundational updates to improve our behavioral health system.
- Additional resources on the transition:
5. Provider Type Guidance
Behavioral health group practices provider type guidance:
- HCPF created Provider Type 77 – Behavioral Health Group, effective January 1, 2024, to create more network specificity for group practices who deliver behavioral health services.
- Many group providers are currently enrolled with Medicaid as a Non-Physician Practitioner Group (PT 25) or a Clinic Practitioner (PT 16).
- The PT 25 and PT 16 enrollments do not allow HCPF to differentiate between providers who primarily deliver behavioral health services, compared to those who primarily deliver medical services or integrated care. Therefore, HCPF issues the following guidance for behavioral health group practices:
- All newly enrolling Medicaid providers that only deliver behavioral health services must enroll as PT 77 – Behavioral Health Group. Current Medicaid providers enrolled as PT 25 or PT 16 that only provide behavioral health services must re-enroll as a PT 77 upon revalidation or when making an update to their enrollment.
Terming substance use disorder (SUD) provider specialty type 64/477:
- On July 1, 2024, new Specialty Types (ST) were added under PT 64 (Substance Use Continuum) to align with BHA endorsements. After this date, you should no longer be enrolled with ST 477. All SUD providers who currently have an ST 477 enrollment must submit a maintenance request through Gainwell to modify your specialty type to align with your BHA Endorsement for level of care. The deadline for SUD providers to submit their maintenance request is June 15, 2025.
6. 1115 Waiver Services
We are awaiting additional details from HCPF on 1115 waiver implementation. The waiver, now called “Comprehensive Care for Colorado,” includes re-entry services as well as health-related social needs services and expanded IMD reimbursement.
- On May 29, 2025, from 10:00 a.m. to 11:15 a.m., HCPF will host a webinar that will give an update on all components of the waiver. Register here for the webinar.
7. Behavioral Health Administrative Service Organizations (BHASO)
The launch of ACC Phase III coincides with the launch of Colorado’s Behavioral Health Administrative Service Organizations, which will manage non-Medicaid behavioral health funding and care coordination in our state. We already work with Signal, which will be the BHASO for Region 4 starting July 1, 2025, to ensure seamless care coordination and provider quality across our networks. You can sign up here to receive notifications about potential contracting opportunities with the BHASO.
8. Colorado System of Care
The state entered into a settlement agreement to develop a system of care for Colorado youth.
- As a result of the settlement, in ACC Phase III RAEs are required to build capacity for specific services including Enhanced MST/FFT, Enhanced High-Fidelity Wraparound (HFW) and Enhanced Standardized Assessments (ESA) to support Colorado youth with complex behavioral health needs.
- Read more about the agreement here. The is currently being called the Medicaid System of Care, though it will likely be rebranded to Colorado System of Care, as it is designed to support all eligible Colorado youth.
- A key component of the settlement will be growing a more robust network of providers to support Colorado youth. HCPF is working to establish a workforce capacity center in the next year, and we are currently recruiting providers to be part of our assessor network. To learn more, sign up for HCPF’s listening sessions and/or their newsletter here.
Changes to the standardized assessment for children and youth:
- In Phase II, children and youth were able to access a standardized assessment, known as an Independent Assessment through the Administrative Services Organization (ASO). This standardized assessment will be known as an Enhanced Standardized Assessment (ESA) in Phase III.
- The ESA is a comprehensive clinical assessment completed by a behavioral health provider to assist in determining appropriate treatment/service recommendations for children, youth, and families. The ESA includes a modified template that has been used in the current Independent Assessment process, the use of the Child and Adolescent Needs and Strengths (CANS) and a new tool, the CANS Decision Support Matrix.
- These assessments will be completed by a provider in the RAE’s network due to this moving under the behavioral health capitated benefit for all youth without human services involvement.
- We are recruiting providers for our assessor network. Please email providerrecruitment@coaccess.com if you are interested in joining.
High-fidelity wraparound services:
- Youth in the system of care will receive high-fidelity wraparound services for intensive care coordination. These providers will adhere to the National Wraparound Implementation Center (NWIC) model and will complete the Child and Adolescent Needs and Strengths (CANS) routinely to guide care planning and service recommendations.
- We are recruiting providers to deliver high-fidelity wraparound services in our region. Interested providers should email providerrecruitment@coaccess.com.
Multi systemic therapy (MST) or functional family therapy (FFT):
- Youth in the system of care will receive either MST or FFT. If you are interested in providing MST or FFT treatment to these youth, please email providerrecruitment@coaccess.com.