Colorado - Transitional Assistance Services — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-09-09
The Colorado Department of Health Care Policy and Financing (HCPF) administers Transition Setup (Specialty Code 681) and Transition Coordination (Specialty Code 683) services through the Brain Injury (BI), Community Mental Health Supports (CMHS), Elderly, Blind, and Disabled (EBD), and Spinal Cord Injury (SCI) waivers.
Approval to bill for these one-time set-up costs and coordination activities requires enrollment through the Colorado interChange Provider Web Portal. Agencies seeking to provide the coordination component must first be approved by HCPF as a designated Transition Coordination Agency (TCA) before an enrollment application is accepted.
1. Service Definition and Scope
In Colorado, transitional assistance is divided into two distinct Medicaid specialties: Transition Setup and Transition Coordination. These services are designed to assist Health First Colorado members in moving from an institutional setting, such as a nursing facility, into a community-based home.
Transition Setup covers the actual one-time expenses required to establish a basic household, while Transition Coordination covers the case management and logistical planning required to execute the move safely.
- Service Name: Transition Setup (Specialty Code 681) and Transition Coordination (Specialty Code 683)
- Target Population: Health First Colorado members residing in institutions who are transitioning to community living
- Covered Expenses (Setup): Security deposits, utility setup fees, essential furnishings, and one-time moving expenses
- Covered Activities (Coordination): Identifying housing, arranging community services, and developing a comprehensive transition plan
- Waiver Applicability: Brain Injury (BI), Community Mental Health Supports (CMHS), Elderly, Blind, and Disabled (EBD), and Spinal Cord Injury (SCI) waivers
2. Regulatory and Oversight Agencies
The Department of Health Care Policy and Financing (HCPF) is the single state Medicaid agency responsible for overseeing HCBS waivers and enrolling providers for Transition Setup and Coordination.
While the Colorado Department of Public Health and Environment (CDPHE) licenses many HCBS providers, Transition Setup and Coordination are non-licensed services overseen directly by HCPF and coordinated through local Case Management Agencies (CMAs).
- Medicaid Agency: Colorado Department of Health Care Policy and Financing (HCPF) (https://hcpf.colorado.gov)
- Licensing Agency: Colorado Department of Public Health and Environment (CDPHE) (https://cdphe.colorado.gov)
- Enrollment Portal: Colorado interChange Provider Web Portal (https://colorado-hcp-portal.gainwelltechnologies.com)
- Training Platform: Train Learning Management System (https://www.train.org/colorado)
3. Gatekeeping Prerequisites: Who Can Even Apply
Colorado does not allow open enrollment for Transition Coordination without prior state designation. Agencies must meet specific structural preconditions before submitting an application to the fiscal agent.
Transition Setup providers do not require the same agency designation but must be enrolled HCBS providers who receive direct authorization from the member's Case Management Agency (CMA).
- Designation Requirement: Transition Coordination (Specialty 683) requires prior approval and designation as a Transition Coordination Agency (TCA) by HCPF
- Case Management Agency (CMA) Authorization: Transition Setup (Specialty 681) expenses must be authorized and coordinated through the member's designated CMA via a Prior Authorization Request (PAR)
- Training Prerequisite: An HCBS Provider Training Course certificate from the Train Learning Management System must be completed and attached to the initial enrollment application
- NPI Requirement: A valid National Provider Identifier (NPI) is required for the specific service location applying for enrollment
4. Licensure and Certification Requirements
Colorado does not license Transition Setup or Transition Coordination under a distinct facility or agency authority. Because these are administrative and financial coordination services rather than direct medical or personal care, they fall outside CDPHE's Health Facilities and Emergency Medical Services Division (HFEMSD) licensure scope.
Providers apply directly to HCPF for Medicaid enrollment without needing a prior state license, though they must maintain standard business registrations.
- CDPHE License: Not required for Specialty 681 (Transition Setup) or Specialty 683 (Transition Coordination)
- CDPHE Letter of Intent (LOI): Not required for these specific non-licensed specialties
- Certification & Transmittal (C&T): Not required prior to initial HCPF approval for Transition Setup or Coordination
- Business Registration: Must be registered and in good standing with the Colorado Secretary of State
5. Medicaid Provider Enrollment
Providers must enroll through the Colorado interChange Provider Web Portal. Each physical service location must be enrolled separately by submitting a separate application and paying the applicable fee.
Providers submit one application for the Home and Community Based Services (HCBS) provider type and select all applicable specialties, such as 681 and 683, without needing separate applications for different waivers.
- Application System: Colorado interChange Provider Web Portal
- Provider Type: Home and Community Based Services (HCBS)
- Specialty Codes: 681 (Transition Setup) and 683 (Transition Coordination)
- Required Attachments: W-9 signed within the last six months, voided check or signed bank letter, and IRS EIN verification (e.g., SS-4 or 147c)
- Revalidation: Required at least every 5 years per 42 CFR 455.414
6. Staffing, Training and Background Checks
Agencies providing Transition Coordination must employ staff who meet HCPF's educational and experiential qualifications for case management and transition planning.
All enrolling providers must undergo enhanced screening, including fingerprint-based criminal background checks, unless they have completed a valid check with Medicare or another state Medicaid agency within the last three years.
- Coordinator Qualifications: Bachelor's degree in a human behavioral science field or equivalent experience as defined by HCPF for Transition Coordination Agency staff
- Background Checks: Fingerprint criminal background check required per 42 CFR 455.434
- Fingerprint Code (IdentoGO): Service Code 25YQG9 for Department of Health Care Policy & Financing - Medicaid
- Fingerprint Code (Colorado Fingerprinting): CBI Unique ID CPACMDCI
- Mandatory Training: HCBS Provider Training Course certificate issued from the Train Learning Management System
7. Documentation, Policies and Records
Providers must maintain rigorous documentation of all transition activities and expenditures to justify Medicaid reimbursement and survive state audits.
For Transition Setup, this means retaining original receipts for every item purchased. For Transition Coordination, it requires detailed service notes mapping to the member's approved transition plan.
- Transition Plan: Must document the specific steps, timeline, and responsible parties for the member's move into the community
- Expense Receipts: Original, itemized receipts for all Transition Setup purchases (deposits, furniture) must be retained
- Service Notes: Coordination activities must be documented with date, time, duration, and a description of the intervention
- Record Retention: Records must be kept for a minimum of six years per HCPF regulations
8. Billing, Rates and Claims
Claims are submitted electronically via the Colorado interChange Provider Web Portal. Transition Setup is billed based on actual incurred expenses up to a maximum limit, while Transition Coordination is billed in time-based units.
Providers must verify current procedure codes, modifiers, and rate limits in the official HCPF Provider Fee Schedule, as these are updated annually.
- Billing System: Colorado interChange Provider Web Portal
- Prior Authorization: All Transition Setup and Coordination services require a Prior Authorization Request (PAR) approved by the CMA
- Setup Limits: Transition Setup expenses are capped at a lifetime maximum per member; providers must consult the current HCPF fee schedule for the exact dollar limit
- Rate Publication: Current rates and procedure codes are published in the HCPF Provider Fee Schedule on the HCPF website
9. Approval Sequence and Timeline
The approval sequence begins with completing mandatory training and, if applicable, securing TCA designation from HCPF. Only then should the provider initiate the portal application.
Once the application is submitted to the fiscal agent, processing is relatively rapid provided all attachments and background checks are perfectly aligned.
- Step 1: Complete the HCBS Provider Training Course on the Train Learning Management System
- Step 2: Obtain Transition Coordination Agency (TCA) designation from HCPF (required for Specialty 683 only)
- Step 3: Submit the HCBS enrollment application via the Colorado interChange Provider Web Portal
- Step 4: Complete fingerprint background checks using the state-specific Medicaid codes
- Processing Time: HCPF's fiscal agent currently processes new applications within eight (8) business days on average
10. Common Denials and Survey Findings
Enrollment applications are frequently returned to the provider (RTP) due to minor clerical mismatches between IRS documents, bank letters, and the portal application.
Post-enrollment, providers often face claim denials or audit findings for billing Transition Setup expenses that fall outside the allowable categories or lacking a CMA-approved PAR.
- Address Mismatch: The address on the W-9 or bank letter does not exactly match one of the addresses listed on the application
- Missing Training: Failure to attach the HCBS Provider Training Course certificate from the Train LMS
- Background Check Failure: Fingerprints submitted without using the correct HCPF Medicaid codes (25YQG9 or CPACMDCI)
- Unapproved Setup Expenses: Billing for non-essential items (e.g., luxury electronics) not covered under Transition Setup rules
- Missing PAR: Submitting claims before the Case Management Agency has officially approved the Prior Authorization Request
11. Key Contacts and Resources
Providers should rely on HCPF's official enrollment pages and the fiscal agent's portal for the most current forms, fee schedules, and training links.
For questions regarding Transition Coordination Agency designation, providers must contact HCPF's HCBS policy staff directly.
- HCPF Provider Enrollment: https://hcpf.colorado.gov/provider-enrollment
- Colorado interChange Portal: https://colorado-hcp-portal.gainwelltechnologies.com
- HCPF HCBS Provider Specialty Codes: https://hcpf.colorado.gov/hcbs-provider-specialty-code-list
- CDPHE Health Facilities Contact: https://cdphe.colorado.gov/health-facilities-licensure-and-certification-contact
See all Colorado services · Colorado Medicaid consulting · book a consultation.