Colorado Medicaid ABA Changes in 2027

Will Colorado Medicaid cut my child’s ABA hours in 2027?

Not automatically. The proposed rule adds weekly hour guidelines by age, and they are not hard caps.

The guidelines are part of a new rule for Health First Colorado ABA therapy from the Colorado Department of Health Care Policy and Financing (HCPF). It would start March 2, 2027, if the Medical Services Board approves it.

HCPF’s draft rule says these amounts “are not absolute service limits, hard caps, or presumptive maximums.” It adds: “A request shall not be denied or reduced solely because the requested services exceed an age-based guideline.”

So a request above the guideline gets a closer review, not an automatic no. For school-age children, reviewers will also look at the school schedule.

What happens to the approval my child already has?

It stays in place until it ends.

HCPF’s FAQ says approved services that run past March 2, 2027 “will remain authorized for the remainder of the authorized period.” It adds: “HCPF does not intend to retroactively deny” approved requests.

The new guidelines are used at the next renewal on or after March 2. Approvals last up to six months, so you will see any change at your child’s next renewal after that date.

What changes on December 1, 2026?

Health First Colorado starts reviewing new ABA requests with InterQual, a national set of review criteria.

Policy memo PM 26-003 says the state will “replace the existing state-developed Pediatric Behavioral Therapy (PBT) clinical criteria used for prior authorization review with the applicable InterQual” criteria.

• Requests sent before December 1 are reviewed under the old criteria.
• Providers do not have to send an approved or pending request again because of the switch.
• For children, a request that misses InterQual still gets a full medical-necessity review. The memo says that alone “does not, by itself, establish that the requested service is not medically necessary.”

HCPF says other state Medicaid programs use national criteria like these. Budding Futures files your child’s prior authorization request for you.

Will my child need a new doctor referral every year?

Yes, under the proposal.

HCPF’s FAQ says “a new, dated referral will be required every 12 months.” It must be “valid and documented in the member’s record before services are initiated.”

The person who writes it must be enrolled with Health First Colorado. Doctors can see what the referral needs on our Medicaid ABA referral page.

Tip: put the date the referral was signed on your calendar, so it never runs out between renewals.

Does my child still need an autism diagnosis?

No. Medical necessity decides, not the name of the diagnosis.

Today the state says behavioral therapy is available to children on Health First Colorado “when the service is medically necessary.” Federal rules agree: “A formal diagnosis is not required according to Federal Medicaid rules.”

The proposed rule names autism spectrum disorder and more: “ASD, developmental delay, intellectual disability, or another developmental or behavioral condition.” It also covers children under 3 who are “At Risk for Delay.”

It would ask for a “documented recommendation for PBT services resulting from a Diagnostic Evaluation.” That evaluation checks whether a child meets the criteria for “Autism or another intellectual or developmental disorder,” so it does not have to find autism.

For a toddler in early intervention, the family service plan (IFSP) can count as part of the records.

What changes for the therapists who work with my child?

Behavior technicians would need their own Medicaid enrollment by March 2, 2027.

Each technician would need a National Provider Identifier (NPI) and Health First Colorado enrollment. HCPF’s FAQ says “Providers are encouraged to begin the process of obtaining NPIs now.”

A new technician does not mean a new approval: “A change in the individual rendering provider does not require a new or revised Prior Authorization Request” when the plan stays the same.

Separately, a 2026 Colorado law, HB26-1425, creates the Colorado Behavior Analyst Licensing Board and has the Department of Human Services license ABA clinics. From July 1, 2028, the law says “an individual is prohibited from engaging in or offering the practice of applied behavior analysis unless the individual is licensed” by the board.

At Budding Futures, the same RBT works with your child each week.

What else changes for Medicaid families in 2027?

Back-coverage for new applications gets shorter on January 1, 2027.

Today, Medicaid can cover care “retroactively for up to three months prior to the month of application” (CMS).

For applications made from January 1, 2027, CMS says that window “will be limited to two months prior to the month of application” for children.

If your child may qualify for Health First Colorado, applying before January 1 keeps the longer window.

Health First Colorado’s changes FAQ also covers work requirements and 6-month renewals for state Medicaid members.

Why is Colorado changing the ABA rules?

A federal audit found billing problems, and the state wants more consistent reviews.

A February 2026 federal audit of Colorado ABA payments for 2022 and 2023 said: “We estimated that the State agency improperly paid at least $77,877,293.” It found improper or possibly improper payments in “All 100 sampled enrollee-months,” often because session notes did not fully describe the services provided.

Providers worry about access. After the 2025 rate cuts, one provider leader told CPR News:

Outside voice

If this continues, many clinics like mine, clinics families rely on, will cease to exist in Colorado.

What can parents do now?

Keep your paperwork current and share records early.

1. Check the end date on your child’s current approval, or ask your ABA provider. That is when the new guidelines may first apply.
2. Keep the doctor’s referral current and note the date it was signed.
3. Give your provider school reports, early intervention plans and medical records before the request goes in. HCPF says an appeal “must be based on the information relied on at the time the PAR was decided.”
4. If hours are cut, read the dates on your letter. You generally have 60 days to appeal (HCPF), and 10 days to keep current hours during the appeal (Health First Colorado).
5. Follow updates on HCPF’s rulemaking page.

How Budding Futures helps with the 2027 changes

We handle the Medicaid paperwork, so you can focus on your child.

• Budding Futures is enrolled with Health First Colorado under Provider Types 83 and 84.
• We check your coverage for free and file the prior authorization request.
• Therapy happens where your child lives: in-home ABA therapy anywhere in Colorado, with no waitlist right now.
• The same RBT works with your child each week, and Rachel Blackburn, BCBA writes every treatment plan.
• What we do not do: we do not run a clinic or center.

Call (720) 613-8837 or send the form, and we will tell you what the changes mean for your child.

Rule details come from HCPF’s rulemaking page and its September 2026 draft rule, FAQ and slides, HCPF policy memo PM 26-003, CMS, the Colorado General Assembly, the HHS Office of Inspector General and CPR News. These are outside sources, not affiliated with Budding Futures. The rule is a proposal until the Medical Services Board adopts it, and dates can change. This is general information, not legal advice.