February 2025

Legislative Update

With the legislative session underway, CBHC is as always deeply engaged in working to improve behavioral health care in Colorado. We’re actively tracking several bills with behavioral health implications and advocating for important legislation through testimony and direct engagement.   

We are proud to offer our support of HB25-1002: Medical Necessity Determination Insurance Coverage. We testified that we believe this legislation offers an important opportunity to improve transparency by mandating the use of nationally recognized standards for medical necessity determinations in behavioral health, aligning with the existing practices for physical health. 

CBHC supported HB25-1070, enabling electroconvulsive treatment to be used—with parental permission—for minors in clinically indicated situations beyond just life-threatening malignant catatonia. Amy Lyden, clinical coordinator of peer services at Jefferson Center, delivered powerful testimony on behalf of CBHC and NAMI, sharing her personal experience with how ECT positively impacted her life. 

We also support SB25-042, the Behavioral Health Crisis Response Recommendations bill, which will help to strengthen Colorado’s crisis response system by creating an inventory of existing alternative crisis response programs around the state and assessing the reimbursement challenges that impede the expansion of such programs. Such data is essential for determining how to support the creation of more co-response programs, crisis stabilization units and other important interventions. We have recommended amendments to shorten the timeline for the inventory of alternative crisis response programs and reimbursement challenges, and to ensure that providers are included in the research on reimbursement.  

Stay informed about the bills CBHC is tracking this session by visiting our legislative tracker.  

Regulatory Reform

The behavioral health reforms launched by HB 22-1278 were designed to establish a safety net system that ensured access to high-quality care within a framework of accountability and transparency. To accomplish that, BHA devoted about 18 months to developing the rules to govern this new system. Providers and consumer advocates all provided extensive input into the development of this regulatory structure. Inevitably, upon implementation of the resulting 482 pages of rules last year, safety net providers have identified a number of challenges. Indeed, in some cases, there are unintended consequences—e.g., lengthy assessments with non-trauma-informed questions that can trigger individuals—that adversely affect clients’ experience. In addition, the time required to comply with all the rules is contributing to staff frustration, burnout and turnover—worsening access to care. 

To alleviate these issues, CBHC is actively collaborating with the Behavioral Health Administration (BHA) to thoughtfully evolve these regulations to strike a balance between effective oversight and timely, patient-centered care. At this time, we are focused on assessments, crisis trainings, informed consent and clarifying guidelines for no-refusal requirements. We are optimistic that we can develop mutually acceptable resolutions to these issues in a timely fashion. However, some things may require legislative action because of the wording of the underlying statute or philosophical disagreements. We look forward to partnering with BHA and state legislators to ensure that Colorado’s safety net behavioral health system supports, rather than hinders, the delivery of high-quality behavioral health care to Coloradans. 

CCBHC Implementation Planning

Great news! Colorado received the $1 million Certified Community Behavioral Health Clinic (CCBHC) Planning Grant for 2025. CBHC actively supported HB24-1384, which directed the state to apply for the SAMHSA grant. The grant will fund a one-year planning process for a subsequent four-year demonstration. During the demonstration, Colorado Medicaid will receive an enhanced federal matching rate for CCBHC behavioral health services, which represents a critical new funding source. While there is, of course, tremendous uncertainty about future federal Medicaid funding, the CCBHC program has enjoyed strong bipartisan support in Congress since its inception a decade ago. Until there is definitive action to roll back the program, we believe it’s essential for Colorado to continue developing the strongest possible implementation plan. 

Beyond funding, CCBHC’s proven model improves access and outcomes in community behavioral health, as demonstrated in 20+ other demonstration states and by numerous stand-alone CCBHC grant recipients, including eight in Colorado.  

Health Care Policy and Financing (HCPF) and the Behavioral Health Administration (BHA) have initiated the CCBHC Demonstration Planning Grant process and are establishing a CCBHC Steering Committee as well as subject-specific subcommittees to guide this effort.  

Steering Committee members will meet monthly and are expected to attend both the monthly CCBHC Public Forum (held on the fourth Wednesday of each month at 1 p.m.) and one subcommittee meeting. The committee will play a vital role in setting strategic priorities for the grant. 

Subcommittees, comprised of subject matter experts, managed care entities, provider organizations, and individuals with lived experience (particularly those from priority populations), will ensure statewide representation. The subcommittees are: 

• Prospective Payment System and Finance Subcommittee
• Certification and Provider Readiness Subcommittee
• Quality Measure Data Collection and Analytics Subcommittee 

Applications closed February 13th, with committee member selection expected mid-February. The Steering Committee will launch its work at the next CCBHC Monthly Public Forum on February 26th.