Colorado Medicaid PT 77 Guide

Last updated: August 25, 2026.

Colorado Medicaid, also known as Health First Colorado, has created a new enrollment category for behavioral-health-only group practices: Provider Type 77 - Behavioral Health Group. For Colorado therapy practice owners, the practical question is whether this affects current Medicaid billing, and what to do next.

The short version: PT 77 matters for behavioral-health-only groups, especially groups currently enrolled as Provider Type 25 or Provider Type 16. But this is not a blanket block on routine outpatient therapy claims: standard psychotherapy codes such as 90791, 90834, and 90837 are not on the impacted list below.

What Changed

Effective January 1, 2024, Health First Colorado created Provider Type 77 - Behavioral Health Group. All newly enrolling Medicaid providers that deliver only behavioral health services must enroll under PT 77.

Existing groups are also affected. A behavioral-health-only group currently enrolled as Provider Type 25, Non-Physician Practitioner Group, or Provider Type 16, Clinic Practitioner, must re-enroll as PT 77 upon revalidation or whenever it makes any update to its enrollment.

Timing depends on what your practice is doing. If you are not making enrollment updates and are not yet due for revalidation, the requirement may not force an immediate enrollment change. But once a behavioral-health-only PT 25 or PT 16 group updates enrollment or revalidates, PT 77 becomes the relevant category.

Which Claims Are Affected Now

According to HCPF’s July 2026 Provider Bulletin B2600540, "Billing Provider Eligibility for Supportive Services Delayed," claims billed under PT 25 or PT 16 are denied, effective August 1, 2026, for a specific list of behavioral health supportive services and team-based services codes. This applies in fee-for-service and when billed to a Regional Accountable Entity, or RAE.

The impacted codes are:

90876, 97535, 97537, H0004, H0023, H0025, H0035, H0036, H0037, H0039, H0040, H0045, H2001, H2012, H2014, H2015, H2016, H2017, H2018, H2021, H2022, H2023, H2024, H2025, H2026, H2027, H2032, H2033, S5150, S5151, S9445, S9453, S9454, S9480, T1005, T1017.

If your practice bills any of these codes under a PT 25 or PT 16 group enrollment, the provider type issue can directly affect payment. In that situation, PT 77 should be an operational priority, not just a future cleanup item.

What This Does Not Mean

Routine outpatient psychotherapy codes, including 90791, 90834, and 90837, are not on the impacted list. So a typical individual or family outpatient therapy practice billing standard psychotherapy codes is not currently blocked by this rule simply because it has not yet re-enrolled as PT 77.

A practice may still need to move to PT 77 at revalidation or with its next enrollment update. But if it is billing only routine psychotherapy codes, this specific August 1, 2026 denial rule may not be the immediate reason claims are affected.

How To Check Whether This Applies To You

1. Confirm whether your group is behavioral-health-only. If it delivers only behavioral health services, PT 77 is the group enrollment category Health First Colorado created for that situation.

2. Confirm whether your group is currently PT 25 or PT 16. Do not infer this from paid claims alone. Check the HCPF/Gainwell Provider Web Portal or review a recent enrollment letter.

3. Check whether you bill any impacted codes. If you are PT 25 or PT 16, behavioral-health-only, and billing the listed supportive services or team-based services codes, prioritize the PT 77 enrollment path.

There is one important exception for groups that also provide E/M services. A group that provides E/M services can keep its PT 16 or PT 25 enrollment and additionally enroll as PT 77 under a separate NPI.

Your Options For Becoming PT 77

HCPF’s guidance describes two main paths:

• New Type II NPI. Obtain a new Type II NPI through NPPES and enroll that NPI as PT 77. This is generally the smoother and faster route. The effective date can sometimes be backdated up to 10 months.

• Disenroll and re-enroll the existing NPI. Disenroll the existing NPI, then re-enroll it as PT 77. HCPF describes disenrollment as a 30-day process.

For many behavioral-health-only groups, the new Type II NPI path may be easier to coordinate. For groups that also provide E/M services, keeping PT 16 or PT 25 and adding PT 77 under a separate NPI may fit the HCPF guidance better.

Practical Next Steps

Confirm your current provider type in the HCPF/Gainwell Provider Web Portal or a recent enrollment letter. Identify whether your group is behavioral-health-only or also provides E/M services. Review whether you bill any of the impacted supportive services or team-based services codes. If you are PT 25 or PT 16, behavioral-health-only, and billing impacted codes, prioritize PT 77. If you are not billing those codes, track PT 77 for revalidation or your next enrollment update.

Questions about the requirement can be sent to [email protected].

Bomi Health helps therapy practices manage billing and credentialing work like this with a clear, practical process. The PT 77 transition is manageable, but it is worth checking your enrollment now so you know whether it is an immediate claims issue or a future revalidation step.

Sources

HCPF July 2026 Provider Bulletin B2600540, "Billing Provider Eligibility for Supportive Services Delayed"; ACC Phase III behavioral health provider guidance.