Division of Insurance outlines new MAT reporting template, sets April 1 filing deadline

Tara Smith, behavioral health director at the Colorado Division of Insurance, opened a Feb. 25 webinar explaining the agency’s new reporting template required under amended regulation 4275 and urged carriers to use the version of the rule effective Jan. 30, 2026. "We are transitioning to a new template format this year in terms of an Excel workbook," she said, adding that the behavioral health team (including Jacob Allen and Sarah Ion) will be the contacts for questions.

Jacob Allen, the division’s behavioral health policy advisor, walked through the regulatory background and the reporting mechanics. He said the reporting period for this filing covers the 2025 calendar year (Jan. 1–Dec. 31, 2025) and that templates and supporting documents must be uploaded via the SURF portal by 5:00 p.m. Mountain Standard Time on April 1, 2026. He noted the division is asking carriers to submit separate worksheets by market (for example, individual and small group) but will accept network-level files if carriers prefer and clearly label them.

The webinar listed required supporting materials: public-facing Colorado prescription drug formularies, prior authorization policies and procedures, and documentation of utilization-management protocols. Carriers must indicate when requested documents are confidential and submit those under SURF’s confidential-supporting documents heading with a confidentiality index.

On data elements, the division asked carriers to report directory-based counts of providers listed as offering medication-assisted treatment (MAT) for substance use disorders (SUD) as point-in-time counts (the workbook originally listed March 31 and Dec. 31). After attendee questions about the usefulness of a single-day point-in-time count, the division said it will clarify the instructions to use first-quarter and fourth-quarter counts for beginning- and end-of-year comparisons and will publish that clarification in the template instructions.

The worksheet guidance also requires: listing SUD treatment programs (excluding opioid treatment programs, which have a separate section) and the names of MAT medications available at those programs; reporting the total number of OTP sites and unique providers authorized to dispense methadone; and providing county-level provider counts by SUD category (opioid use disorder, alcohol, tobacco, other). Where data are unavailable, carriers should enter "N/A"; if no providers exist, carriers should enter "zero." The division emphasized that if a provider delivers multiple SUD services, that provider should be counted once and then indicated across relevant SUD categories.

For utilization and enrollment measures, the division asked carriers to report unique enrollees using SUD services (including medical and pharmacy claims), aggregate counts across the calendar year, and the specified point-in-time comparisons (to be clarified as quarter-based). The division said it expects carriers to include both medical and pharmacy claims when counting members using FDA‑approved MAT prescription drugs, and to report unique members rather than counts of drug units dispensed.

Jacob Allen also explained the prescription drug and formulary worksheets: carriers should report total MAT prescriptions filled in the calendar year, average MAT prescriptions per member, and identify any FDA‑approved SUD medications that were subject to utilization-management protocols, providing associated claims and denial counts. A separate worksheet asks carriers to list MAT drugs placed on the lowest-cost formulary tier; only drugs on that lowest tier should be reported there.

The division reiterated that narrative responses to regulatory questions must be original text (not copy-pasted policy language) and that attestation is required about whether prior authorization, step therapy, quantity limits or other utilization-management protocols were applied to FDA‑approved MAT drugs and whether those protocols conform to regulation and statute.

During the Q&A, carriers raised technical questions about counting methodologies. One participant noted that identifying members "using services" for a point-in-time date often requires a lookback window of claims; Jacob Allen said the division will revise guidance to request first- and fourth-quarter counts rather than a single-day snapshot. The agency also confirmed it will accept reporting of prescription drugs whether billed on the medical side or the pharmacy side and will add clarifying language to the instructions and to a public FAQ the division will maintain on its website.

The division said it will post the recording, slides and updated instructions (the current template and instructions are labeled V20) on the ACA annual filing information page and maintain an FAQ running document through the April 1 deadline. The webinar closed with a reminder of the April 1, 2026, SURF submission deadline and contact information for the behavioral health team.

What comes next: carriers should check the DOI’s website for the updated template and instructions, review the attestation and supporting-document headings in SURF, and prepare to submit the requested worksheets and any confidential materials by the April 1 deadline.