Medicaid agency weighs new rules for peer and behavioral-health supports

Colorado’s Department of Health Care Policy and Financing outlined possible limits on Medicaid peer-support and other behavioral-health services at an Oct. 7 legislative commission meeting, including rules for providers and daily use. The commission took no action, the meeting recording shows.

The services include peer support and unlicensed case management or care coordination. Health Care Policy and Financing officials said they can help people with serious mental illness or complex needs navigate housing and transportation and engage with treatment.

Options included requiring certain providers to be certified, limiting daily use or multiple service codes on the same day, and restricting services that are not connected to clinical care. Officials also discussed including some supports in intensive outpatient or other treatment services rather than billing for them separately. They said the goal was to preserve services that help people enter and stay in treatment while addressing use they considered insufficiently connected to clinical outcomes.

A behavioral-health provider and advocacy group told commissioners it supported limits on hours or group size and utilization management for peer support, but opposed reducing the Medicaid waiver pathway for those services. The group’s executive director said peer support should complement, not replace, clinical care.

Commissioners also asked for savings estimates for possible actions in the current year. Health Care Policy and Financing Executive Director Gretchen Hammer said the department was not yet sharing a complete set of estimates because the Governor’s Office of State Planning and Budgeting had asked it to wait, and the department was assessing which proposals would require federal approval, state board action or other authorization. Officials said figures were expected through the regular budget process, including the governor’s budget and the January supplemental process.

Medicaid Director Kristen Bates had cited an actuarial estimate of about $20 million for one example, while noting that estimates depended on assumptions about market response and regional implementation. She did not present that figure as a total for all proposed actions.

Staff said the commission’s December report would identify who is responsible for each recommendation, how success will be measured and how results will be communicated. The report is also expected to describe ways to revisit or change an approach at milestones if it is not working. The commission chair characterized the proposals as ideas under consideration, not decisions by the commission.