Counselors - Peers - Marriage and Family Therapists - Addiction Counselors
Psychologists - Social Workers - Pre-licensure Professionals - Interns
...for a diverse, competent, and sustainable behavioral healthcare workforce.
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Active Concerns (2023)
| Concern | Proposal | Since When |
|---|---|---|
| Commercial lease restrictions on therapy offices | Colorado shall prohibit commercial landlords from restricting commercial spaces to a single mental health office. "Non-compete" rules are more appropriate for retail and limit client access to care. | 2024 |
| MHPAEA Parity Enforcement | As other states have done, since the federal government (CMS) has signaled no interest in pursuing state departments' Medicaid Parity violations, Colorado requires a Parity enforcement mechanism to hear, substantiate and consequence MHPAEA Parity violation. This could be through the Behavioral Health ombuds office, the Attorney General, BHA, or other independent agency that can evaluate Parity violation claims. | 2019 |
| Supervised services in commercial contracts | Medicaid disenrollment (May 2023 extending into 2024 for twelve or more months) will reduce Colorado Medicaid from 1.7 million Coloradans to around 1.1 million. Some of those leaving Medicaid due to higher income will purchase ACA subsidized plans on the Health Exchange. These plans are managed by commercial insurance payers, who may or may not allow supervised services by pre-licensure clinicians under supervision. COMBINE seeks uniformity and allowance for pre-licensure work for both MA graduates and university interns. | 2023 |
| Reimbursement rate stability (Parity) | The rate setting process for medical care is substantially different from that process for mental health care, which violates MHPAEA Parity. | 2019 |
| Inaccurate Network Adequacy reporting | HCPF requires RAEs (Managed Care Entities) to provide network reports quarterly. HCPF is also required to post reports quarterly, publically. Neither RAEs nor HCPF count or report the candidate counselors or university interns that provide care. There is no accurate number that helps understand the capacity of the workforce. A modifier code indicating that the service was actually rendered by a supervised counselor or NPI numbers for pre-licensure staff would help. | 2020 |
| Legislative Oversight | The Colorado legislature holds SMART Act hearings annually. These have devolved into departments offering summary reports of activity with no challenge to the statistics presented. | 2020 |
| Long RAE contracting times | Unlike medical providers, who are ready to work after HCPF "validation," mental health providers must take additional steps, which are contracting with managed care entities (RAEs). RAEs often take longer than the 90 days specified in HCPF - RAE contracts to actually contract. Additionally physicians are privileged by a law requiring commercial payers contract within 60 days. | 2021 |
| Behavioral Health Entity licensing | COMBINE cooperates with the BHA Behavioral Health Authority to create and support rules that make sense for increasing quality of service and safety. Many of our small and solo clinics need appropriate waivers for building zoning and construction codes, and for supervision ratios for university interns and pre-licensure candidates. | 2023 |
| Audit of managed care entities | COMBINE continues to advocate for oversight of the manages care entities. Colorado policy makers and tax payers cannot get even basic information like network capacity and results of care coordination efforts. | 2020 |
| CCAR exemption | The CCAR is an extensive and intrusive survey that was dropped for outpatient Medicaid providers in 2018. The BHA has proposed that outpatient care must participate in the CCAR program. No action is taken based on collected CCAR data, so COMBINE's position is that data from claim forms is sufficient. | 2023 |
| Z code requirements for children | While COMBINE supports gathering actionable data, requiring Z-codes on child Medicaid service claims yields nothing reliable or valid, as many children will be assessed as meeting criteria for many Z-codes. Providers will variably assess children leading to noisy data. | 2023 |
| Exclusion of mental health care from eConsult | HCPF funded a large project enabling communication between health care providers, yet excluded mental health care. | 2022 |
| Support Colorado's Behavioral Health Ombuds Office | The Ombuds office for Behavioral Health is understaffed for the task it's mandated to do. | 2023 |
Timeline, Related Documents, and Released Documents from COMBINE
| Feb 24 2024 | Feb 2024 Parity Comments for HCPF | COMBINE published 2024 Parity Comment in response to HCPF's annual call for comments. |
| Feb 1 2024 | 2024 Senate Bill 93 Continuity of Care | COMBINE took an amend position on SB24-093, which allows for continuity of care when a person moves from Medicaid to another insurance. Mental health care was not included in the draft. |
| Dec 1 2023 | COMBINE requests an open meetings policy from HCPF after public online meetings no longer display participants. | |
| November 28 2023 | COMBINE seeks clarity from CHP+ managers regarding supervised billing. | |
| COMBINE requests HCPF policy regarding stakeholder meetings after an HCPF "stakeholder" meeting (regarding requiring a Z-code for children as a diagnosis) where no participants could see the other participants and Q&A was hidden. | ||
| November 8 2023 |  | COMBINE clinic directors file complaints with Division of Insurance to seek compliance by UnitedHealth (RAE 1, commercial) with DOI directive to allow supervisory billing. |
| November 3 2023 |