A new billing requirement is now in effect for behavioral health services provided by pre-licensed and unlicensed clinicians under Health First Colorado. 

What Changed July 1? 

Effective July 1, 2026, pre-licensed and unlicensed clinicians may not independently render reimbursable behavioral health services for Health First Colorado. When these services are provided under the oversight of a rendering provider, modifier U9 must be included on the claim. 

For coding and compliance teams, this means reviewing behavioral health workflows to ensure claims reflect the appropriate rendering provider and modifier requirements. 

The change is particularly important for organizations that rely on pre-licensed or unlicensed clinicians to provide behavioral health services under supervision. Billing processes, claim edits, and documentation workflows should all be reviewed to make sure the new requirement is being consistently applied. 

One Requirement Has Been Postponed 

There is another piece of the policy to keep on the radar. Health First Colorado had planned to require the service provider’s name in Box 19 of the claim. That requirement has been postponed until further notice because of differences in EHR functionality. 

Organizations should therefore implement the U9 modifier requirement now while continuing to monitor Health First Colorado communications for updates regarding Box 19. 

The Takeaway 

July 1, 2026, is the effective date for modifier U9 when applicable. Review behavioral health billing workflows now, and keep an eye on payer updates for the postponed Box 19 requirement. 

Source: Colorado HCPF, June 2026 Health First Colorado Provider Bulletin, Reference No. B2600539.