Behavioral and Primary Health Integration Project

Colorado’s legal and regulatory landscape is inadequate to support a transformation to integrated health care in this state.  The fragmented professional and facilities licensing laws, reimbursement regulations, building codes, and other public health provisions reflect a bygone era when health care was delivered in silos and patient care ignored population-wide needs and efficiencies.  Statutory provisions currently regulate providers without reference to their collaboration with other professionals.  Legal obligations are contradictory and uncoordinated.  Regulations that define Colorado’s current payment system operate as affirmative barriers to integrated care.  In short, Colorado law is inconsistent with creating a health care system dedicated to the triple aims of improving population health, improving the patient experience, and reducing costs.  This report concludes that without comprehensive legislative and regulatory reform, integrated care models will lack the legal infrastructure needed to succeed in Colorado.

The Colorado Health Equity Project completed a report summarizing the major legal issues that must be addressed to ready our state for integrated care.   Our analysis concluded with a proposal for comprehensive legislative reform project to accomplish these changes:

  • Unify Fragmented Regulatory Oversight of Mental Health, Behavioral Health, And Substance Use Disorder Providers
  • Clarify Privacy and Confidentiality Rules Under HIPAA and Colorado Law
  • Reconsider Federal “Carve Out” Reimbursement for Mental Health Care
  • Reconsider Diagnosis Requirement for Mental Health Reimbursement
  • Critically Evaluate Behavioral Health Organization Infrastructure
  • Remove “Same Day Billing” Restrictions
  • Align Professional Licensing Laws, Professional Duties, and Regulatory Obligations
  • Coordinate Conflicting Health Facilities Building and Construction Codes
  • Simplify, Clarify, and Coordinate Providers Eligible for Reimbursement