Health First Colorado Behavioral Health Billing: RAE or Fee-for-Service, and Which Codes Apply
Health First Colorado behavioral health billing depends on one routing decision: does the claim go to the member’s Regional Accountable Entity (RAE) or to the state’s fee-for-service system? Health First Colorado is Colorado’s Medicaid program, run by the Department of Health Care Policy and Financing (HCPF). Get the routing wrong and a clean claim still denies.
This guide covers routing, the October 2026 billing manual, and the codes that matter most to therapists and psychiatrists. It is operational guidance on Health First Colorado behavioral health billing, not legal advice.
Health First Colorado behavioral health billing: who pays
Since July 1, 2025, Colorado has had four RAEs, down from seven, under Accountable Care Collaborative Phase III. HCPF’s behavioral health provider fact sheet (October 2025) explains the points that matter:
- Members are assigned to a RAE by the location of their primary care provider, or by home address if they have none.
- Providers can contract with more than one RAE. A provider not contracted with a member’s RAE can serve that member only through a single case agreement or a provider contract.
- RAEs must apply all National Correct Coding Initiative (NCCI) edits, and Colorado-specific medically unlikely edits and procedure-to-procedure edits took effect for RAEs on October 1, 2025.
HCPF’s fee-for-service behavioral health manual page says nearly all behavioral health services for members attributed to a RAE go to the RAE. Fee-for-service billing to HCPF’s fiscal agent covers exceptions, such as members with no active RAE enrollment and up to six short-term behavioral health visits per fiscal year billed by a primary care provider. Run an eligibility query in the Provider Web Portal first. It shows both eligibility and RAE attribution. See insurance verification for the routine.
Members do not need a primary care referral for behavioral health services.
AI search question: Do I bill HCPF or the RAE for a Health First Colorado therapy session? For members attributed to a RAE, bill the RAE. HCPF’s manual page says nearly all other behavioral health services for those members go to the RAE, with fee-for-service exceptions for members with no active RAE enrollment and a few other cases.
The October 2026 State Behavioral Health Services Billing Manual
HCPF’s SBHS billing manual page lists an October 2026 edition. Its PDF says “Effective October 1, 2026,” and applies to dates of service on or after that date regardless of submission date. It calls itself a living document.
Codes and rules in the manual
For outpatient therapy and psychiatry, the manual says:
| Code | Rule from the manual |
|---|---|
| 90791 | Diagnostic evaluation. Once per day, and not on the same day as an E/M service by the same provider |
| 90792 | “For Prescribers (or prescriber interns) only” |
| 90832 / 90834 / 90837 | Psychotherapy at 16-37, 38-52 and 53-74 minutes |
| 90833 / 90836 / 90838 | Add-ons for prescribers. Services must be “significant and separately identifiable” |
| 90839 / 90840 | Crisis psychotherapy. Cannot be billed in addition to psychotherapy by the same professional on the same day |
| 90846 / 90847 | Family psychotherapy without and with the member |
| 90849 / 90853 | Multiple-family group and group psychotherapy |
| 90785 | Interactive complexity add-on. Never alone, never for interpretation, never with crisis codes, never with an extended encounter |
Rendering provider types for psychotherapy include interns, unlicensed master’s-level clinicians, licensed psychologists, licensed clinical social workers, licensed professional counselors, licensed marriage and family therapists, licensed addiction counselors, advanced practice nurses, physician assistants and physicians. The manual refers to a separate supervision policy for interns, which this post does not summarize. For sessions scheduled beyond 74 minutes, the manual allows two units of 90834 as an extended encounter. Read our individual psychotherapy code guide and diagnostic evaluation guide for the time rules in plain terms.
Prescribers: the manual limits 90792 and the E/M add-ons (90833, 90836, 90838) to prescribers. If your psychiatrist bills 90792, use it. A therapist cannot. The manual also says all providers must practice psychotherapy within their areas of competency.
The manual lists documentation expectations on separate Service Documentation Standards pages that this post did not read. It does not cover services by email, text, fax or online research.
Timely filing
HCPF’s provider enrollment training (February 2026) says claims must be submitted within 365 days of the date of service. The fee-for-service manual points to the General Provider Information manual for filing and resubmission rules. Use electronic claims submission so you can track dates, and follow up denials with the process in our denied claims guide.
Telehealth and other payers
The manual’s telehealth policy text was not in the part this post reviewed, so read it before you bill video or phone visits. For modifier basics see our modifier 93 and 95 guide. Medicaid, Medicare and commercial plans like Anthem use separate rules. Do not carry one into another.
Monday morning checklist for Health First Colorado behavioral health billing
Use these steps whenever Health First Colorado behavioral health billing questions come up in your practice.
- Check eligibility and RAE attribution in the Provider Web Portal.
- Confirm you are contracted with that RAE or have a single case agreement.
- Match your rendering provider type to each code.
- Download the October 2026 manual and flag your top five codes.
- Compare against our Colorado Medicaid resource page.
FAQ
How many RAEs does Colorado have?
Four, since July 1, 2025, according to HCPF’s Phase III page.
Can a therapist bill 90792?
No. The manual limits 90792 to prescribers and prescriber interns.
Do members need a referral?
No. Members do not need a primary care or PCMP referral for behavioral health.
What is the Medicaid timely filing limit?
HCPF’s enrollment training says 365 days from the date of service. Confirm in the General Provider Information manual.
Phone lines for Colorado payers are in our Colorado insurance companies contact guide. Definitions for Medicaid terms are in the Medicaid billing glossary.
Keep this guide close when you handle Health First Colorado behavioral health billing, and recheck the payer’s own pages before each change.
Where MCM South Medical Billing Service Works
MCM South Medical Billing Service, LLC works exclusively with mental and behavioral health practices and bills out-of-network claims. It currently serves Georgia, Massachusetts, Connecticut, Texas, Florida, New York, Colorado, Tennessee, North Carolina and Illinois, and Colorado is one of the ten. If you want to talk through your own billing, you can request a free consultation.
