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Committee reviews draft limiting extrapolation audits; members press for provider documentation and look‑back guardrails

April 01, 2026 | 2026 Legislature CO, Colorado


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Committee reviews draft limiting extrapolation audits; members press for provider documentation and look‑back guardrails
A bill draft circulated to the Joint Budget Committee would limit the state's use of extrapolation-based audit techniques for health-care claims to narrow categories and add procedural safeguards for providers.

Bill drafter Kurtz told the committee the revised draft narrows extrapolation to nonemergent medical transportation (NEMT) and pediatric behavioral therapy (PBT) services and prohibits contingency-based contracts for those extrapolation audits.

"One of the changes was ... limiting it to just non emergency medical transportation and the PBT or pediatric behavioral therapy services," Kurtz said, and added the draft prohibits contingency-based contracts for extrapolation audits. He also recommended leaving certain existing statutory language in place to avoid altering unrelated law.

Committee members, including Senator Kirkmeyer and Representative Taggart, pressed for additional guardrails: a look-back period tied to the OIG findings (so audits do not reach back multiple years) and a requirement that the agency furnish a full set of documentation and working materials to providers so they can replicate extrapolation calculations. Kirkmeyer said the lack of documentation in a prior RAC audit led to lawsuits the state lost and urged stronger transparency.

Staff and legal services agreed to work with the department and the committee to refine language on the look-back period, documentation requirements and the State Auditor's reporting duties. The committee did not finalize the bill in floor-ready form; members asked staff to post a redraft after consulting with HCPF and legal services.

Next steps: legal services and HCPF to refine the draft to add agreed safeguards and return to the committee for final approval before introduction.

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