If you run an ABA company in Colorado, you’ve seen the Medicaid bulletin: by August 31, 2025, every tech working under Medicaid must be a certified Registered Behavior Technician (RBT). It’s a huge shift—and it’s clear from private forums and Facebook groups that practices across the state are feeling the pressure.
Here’s What’s Actually Happening:
Providers aren’t just worried about training—they’re scrambling to beat the deadline, get techs scheduled for BACB exams, and hoping the system doesn’t create service gaps for clients. One of the first messages to pop up after the bulletin went out was:
"I'm sure by now...
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That led to immediate concerns about the timeline for compliance :
"Anyone concerned about the timeline? When FL put this into effect, I believe they had three or four months for compliance. I’m very concerned about a lag in response from the BACB once a tech submits for their exam and then how overwhelmed the testing centers in CO will be. How is everyone addressing this? Or better yet, is there a way we can ask for an extension? Even an extra month would be incredibly helpful."
And others pointed out the unique challenges for smaller providers:
"It’s going to be a scramble, especially for rural providers or anyone who can’t get their techs tested quickly."
What the Policy Actually Says
Per the official Medicaid bulletin (link here), by August 31, 2025:
- All techs billing Medicaid must be RBTs (active certification from BACB or another accepted certifying body).
- Providers must verify certification, keep documentation for audits, and stop billing for any uncertified techs after the deadline.
- Staff rosters with Health First Colorado need to be kept current.
COABA’s FAQs add more detail:
- The 30-day “grace period” isn’t retroactive—so services delivered before the rule are assumed compliant.
- If you don’t have enough RBTs, notify HCPF and encourage families to do the same.
- You can use non-RBT techs during the grace period but must move toward full compliance.
- Legal challenges aren’t likely to change things immediately, but the state must ensure adequate access to services.
The Real-World Impact
Providers are worried about the actual logistics:
- How quickly can techs complete the RBT process?
- Are there enough BACB-approved testing slots in Colorado before the deadline?
- What happens if you’re waiting for test results and the deadline passes?
There’s also concern about access to care—especially in regions with existing staffing shortages. As one provider put it:
"We have the staff willing to do the work, but if the system can’t certify them fast enough, it’s the kids who miss out."
What You Can Do Right Now
- Fill out the CASP Provider Survey (link here)—your input will help document the real barriers providers are facing and may support requests for deadline flexibility.
- Contact HCPF and encourage your families to do the same if you expect client care disruptions.
- Keep records of all communications and compliance efforts in case of future audits or policy review.
Bottom Line
This isn’t just about ticking a compliance box—these are real changes with the potential to disrupt services for kids who need them. Most providers want to comply, but timelines and system capacity matter. The more you share your feedback with state agencies and through industry groups, the better the chance for a reasonable approach to rollout and enforcement.
Sources:
- Colorado Medicaid Bulletin: Bulletin 0825_B2500526_0.pdf
- COABA FAQ and updates
- CASP Provider Survey: https://www.surveymonkey.com/r/COMedicaidRBT
- Provider discussions from Facebook groups (paraphrased, anonymized)
