FAQ for Colorado Medicaid Families & Providers

On July 18, 2025, the Colorado Department of Health Care Policy & Financing (HCPF) released Policy Memo PM 25-005, which states that only Registered Behavior Technicians (RBTs) may deliver adaptive behavior treatment billed under CPT Code 97153. All ABA providers have until August 31, 2025, to come into full compliance.

COABA supports the new administrative requirement. However, to ensure continuity of care for Medicaid families and avoid disruptions to services in the long term, COABA urges Colorado Medicaid to implement a rolling 120-day grace period for new hires to meet this requirement.

  • QUESTION: Why is COABA concerned about this policy change
  • ANSWER: COABA represents all behavior analytic practitioners in the state of Colorado, and the overwhelming feedback from its members is that this new administrative requirement presents a tremendous administrative burden, and it will negatively impact access to services for Colorado patients with ASD and their families.

  • QUESTION: Are provider organizations prepared to meet the August 31st, 2025 deadline?
  • ANSWER: MAYBE. Some providers with a small number of therapists who have already received their RBT could be prepared to comply with the new administrative requirement on August 31st, 2025. But larger providers who regularly hire and train new therapists will not be prepared to comply with the new administrative requirement. Unfortunately, due to normal turnover and the need to hire increased numbers of therapists to meet the growing demand for services by Colorado families, there will be a certain percentage of trained therapists who are prepared to provide high-quality services, but simply cannot because of this new administrative requirement.

  • QUESTION: Is the standard that an RBT is the minimum requirement for a therapist to provide direct ABA therapy a federal standard?
  • ANSWER: NO. State Medicaid programs can establish state-specific Medicaid requirements for a therapist.

  • QUESTION: Did all other state Medicaid programs that were audited by the OIG have the same standard as Colorado (i.e., that RBT is the minimum standard for providing direct therapy)?
  • ANSWER: NO. Wisconsin and Massachusetts Medicaid do not require therapists to be registered as an RBT. For example, Wisconsin Medicaid requires the following for a “Behavioral Health Technician”:
    • High school diploma or General Educational Development (GED) certificate and 40 hours of training OR
    • Registered behavior technician certification.

  • QUESTION: Do Colorado ABA providers disagree with the standard being applied by the new administrative requirement?
  • ANSWER: NO. Providers broadly agree with the standard that therapists eventually become certified as an RBT. But providers are requesting a rolling grace period so that therapists who have received the necessary training and who have demonstrated sufficient competency may provide direct therapy under the standard supervision of the patient’s BCBA.

  • QUESTION: Are there enough RBTs in the state of Colorado to meet the existing demand for ABA services?
  • ANSWER: NO. There are insufficient RBTs statewide to meet current Medicaid service demands, not to mention other insurers’ needs. If there are 500,000 children on Colorado Medicaid, applying the national autism prevalence rate of 1 in 36 (roughly 3%) means that about 15,000 of these children have ASD. Assuming only half require ABA services, approximately 7,500 children would be in need. As of August 7, 2025, Colorado has 5,589 Registered Behavior Technicians (RBTs), and even if every RBT in the state served only Medicaid patients, which is unlikely given the needs of other payors and populations, Colorado Medicaid would face a shortage of about 2,000 RBTs to meet the demand.

  • QUESTION: Why are providers requesting this rolling grace period?
  • ANSWER: Providers are requesting this rolling grace period because new therapists are being hired every day to meet the urgent need for services for Colorado families. The process to obtain the RBT credential is time-intensive, requiring training, background checks, and competency assessments. Without a temporary allowance, newly hired and fully trained staff cannot begin providing services under guidance from the behavior analyst. This creates immediate service gaps, delaying treatment for children, and forcing families to wait even longer for medically necessary care, at a time when demand already far exceeds available resources.

  • QUESTION: Will the rolling grace period negatively impact the quality of care for Colorado patients and their families?
  • ANSWER: NO. All therapists receive the training required to obtain their RBT before providing care to patients. These therapists are supervised by their BCBA in accordance with the requirements for an RBT. The rolling grace period will solely provide time for therapists to complete the administrative process of applying for their RBT.

  • QUESTION: Can Colorado Medicaid implement the rolling grace period?
  • ANSWER: MAYBE. So far, Colorado Medicaid has not engaged with the provider community to partner on how to properly implement the grace period. The grace period may require legislative action, in which case Colorado Medicaid and the provider community could partner to educate legislators to enact the necessary changes to permit the rolling grace period.

  • QUESTION: Is it true that some providers say the deadline is not a problem?
  • ANSWER: MAYBE. A minority of providers may have provided this response. However, COABA, which represents the ABA provider community, is hearing only concerns. HCPF has provided no data to support assertions that the provider community is prepared for the new administrative rule. In order to provide data, COABA, in concert with the Council of Autism Service Providers (CASP), has surveyed Colorado ABA providers and will be publishing the data and analysis soon.

  • QUESTION: How might this impact my child’s therapy?
  • ANSWER: Providers may not be able to replace staff who leave, or may have to let some staff go who are not certified by the cutoff date. This could mean placing therapeutic services on hold or even increasing wait list times.

  • QUESTION: Has Colorado Medicaid historically reimbursed ABA providers for direct therapy provided by therapists who were trained but had not received their RBT?
  • ANSWER: Yes. Prior to the new administrative requirement issued in July of 2025, and effective August 31, 2025, Colorado Medicaid reimbursed ABA providers for direct therapy provided by trained and supervised therapists who had not received their RBT certification. For this reason, the provider community was surprised that Colorado Medicaid suddenly introduced this impactful new administrative requirement without seeking stakeholder feedback to mitigate the risk of unintentionally limiting access to services for Colorado patients.

  • QUESTION: Did HCPF solicit public comment before implementing this change?
  • ANSWER: No. The requirement was put in place without an opportunity for public comment, leaving providers and stakeholders without a formal venue to discuss implications, challenges, or possible alternatives.

  • QUESTION: Does this RBT requirement apply to all provider types under PBT?
  • ANSWER: Informally, HCPF states that the requirement applies only to RBTs providing ABA services under the supervision of a BCBA. However, this creates inconsistency and uncertainty, as other credentialing bodies, such as the Qualified Applied Behavior Analysis Credentialing Board (QABA), also oversee ABA providers who work in similar capacities.

  • QUESTION: How will HCPF ensure equity across credentialed providers in different modalities under PBT?
  • ANSWER: HCPF covers a range of modalities under PBT, including parent-guided and play-based interventions, some of which, such as RDI, are not supported by evidence. Despite the lack of scientific validation, these non-evidence-based services continue to be funded with taxpayer dollars, even during a budget crisis. At the same time, HCPF is implementing new credentialing requirements that create significant barriers to access for evidence-based ABA services, raising concerns about equity, resource allocation, and alignment with best practices.

  • QUESTION: Has HCPF provided guidance on implementation timelines or support for compliance?
  • ANSWER: NO. As of now, no detailed implementation plan or support resources have been released, leaving providers uncertain about deadlines and the risk of service disruption.

WHAT YOU CAN DO

Speak up: Email your local legislators and members of the Colorado Department of Health Care Policy & Financing (HCPF), voicing your concerns that such rapid changes to Medicaid policy could lead to unnecessary disruption to medically necessary services.

Find your Colorado legislator and write to them here: https://leg.colorado.gov/FindMyLegislator

Email the Governor’s Office: casey.badmington@state.co.us

Contact the Medicaid Director: adela.flores-brennan@state.co.us