Supervisory Billing Modifier Required for Medicaid claims (7/1/26)
New Required Modifier for Services Delivered Under Oversight of a Rendering Provider - Effective July 1, 2026
As noted in the Health First Colorado Behavioral Health Rendering Provider Oversight (RPO) Policy, pre-licensed clinicians and unlicensed professionals are not able to independently deliver Medicaid reimbursable behavioral health services because they do not hold a valid active license in Colorado. In order to reimburse for care delivered by these individuals, their services must be billed under a Rendering Provider.
Effective July 1, 2026, billing providers will be required to utilize Modifier U9 on all claims submitted for behavioral health services delivered by a pre-licensed clinician or an unlicensed professional. Additionally, the service provider’s name must be entered in Box 19.
Email hcpf_bhbenefits@state.co.us with any questions.