Colorado changes how ABA therapy requests are reviewed on December 1, 2026

If your child gets behavioral therapy through Health First Colorado (Colorado Medicaid), including Applied Behavior Analysis (ABA), the way new requests are reviewed changes on December 1, 2026. What is covered stays the same.

What's changing

Before behavioral therapy starts or continues, your child's provider sends a Prior Authorization Request (PAR). A reviewer decides whether the request shows the therapy is medically necessary.

The Colorado Department of Health Care Policy and Financing (HCPF) put out Policy Memo PM 26-003 on October 14, 2026. Starting December 1, 2026, reviewers will use a national checklist called the InterQual Applied Behavior Analysis Treatment criteria for Pediatric Behavioral Therapies (PBT). It replaces the criteria Colorado wrote itself.

The memo says:

"This change replaces the state-developed clinical review criteria only. It does not replace or modify the PBT benefit"

That is from HCPF Policy Memo PM 26-003.

Requests sent in before December 1, 2026 are reviewed under the criteria in effect when they were sent. Providers do not have to resubmit an existing request just because of this change.

There is also a protection for children under 21. It comes from a federal rule called Early and Periodic Screening, Diagnostic and Treatment (EPSDT). For members under 21, not meeting the InterQual checklist does not, by itself, mean the therapy is not medically necessary. Before a denial, the request must be looked at under the federal EPSDT rules.

Who it affects (and who it doesn't)

This affects children on Health First Colorado who get, or will get, pediatric behavioral therapy, including ABA, when a new request is sent in on or after December 1, 2026.

It does not change the benefit itself, the rules that go with it, who can provide it, or billing. Requests sent in before December 1, 2026 keep the old criteria.

Key dates

• October 14, 2026: HCPF issued the memo.
• December 1, 2026: New requests are reviewed with the InterQual criteria.

What you can do

1. If your child has a request in before December 1, 2026, nothing changes for that request. No need to resubmit.
2. If a new request will go in on or after December 1, 2026, ask your provider if they are ready for the new criteria.
3. If a request is denied, you and your provider can ask for a reconsideration, a peer-to-peer review, or a member appeal.
4. If your child is under 21 and a denial only says the request did not meet the checklist, mention the EPSDT protection when you push back.
5. Keep a copy of every notice you get.

Questions about this change: email HCPF at HCPF_EPSDT@state.co.us.