Colorado delays full ASAM 4 adoption to allow licensing and provider readiness work
June 29, 2026 | Centers for Medicare & Medicaid Services (CMS), Department of Health and Human Services (HHS), Executive, Federal
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Colorado officials said they will delay full statewide implementation of the American Society of Addiction Medicine (ASAM) Criteria 4th edition to allow more time for licensing, contracts and provider readiness.
Kristen Bates, deputy Medicaid director and Office Director for Medicaid Behavioral Health Initiatives and Coverage at the Colorado Department of Health Care Policy and Financing (HCPF), said Colorado originally planned to adopt ASAM 4 by July 2026 but "it is going to take us at least till July of 2027" after stakeholder feedback and additional regulatory work.
The delay responds to several concrete challenges, Bates said: hundreds of licensing rules must be reviewed and revised to align facility staffing and physical layout with ASAM 4 levels of care; Medicaid reimbursement rates and payment structures tied to ASAM 3 must be updated; and providers, particularly withdrawal-management (formerly ASAM 3.2) programs, need technical assistance to reconfigure services and contracts to operate within managed-care arrangements.
Jennifer Holcomb, behavioral health benefits section manager at HCPF, described Colorado’s outreach and supports for providers: focused listening sessions, joint work with the state Behavioral Health Administration, office hours, and a provider toolkit developed with HMA that includes self-evaluation tools and crosswalks showing how ASAM 3-era services map to ASAM 4 levels. Holcomb said these efforts aim to help providers understand staffing, documentation and facility changes required to meet the new criteria.
Colorado officials also discussed financing constraints. Because Medicaid generally cannot pay for capital projects, the state is exploring use of opioid-settlement funds and other state funds to support facility upgrades that may be necessary for some residential providers to meet ASAM 4 requirements.
The state weighed a phased approach versus a "big bang" adoption and concluded that, for Colorado, sequencing the regulatory, contracting and practice changes and then implementing broadly would work best—hence the additional year to prepare.
Bates and Holcomb told the CMS webinar that the extra time will be used to align managed-care entities, licensing authorities and providers, update contracts and reimbursement approaches, and deliver targeted technical assistance—particularly to programs that provide withdrawal management and to residential providers expected to absorb additional clinical responsibilities under ASAM 4.
Next steps: Colorado will continue stakeholder engagement, publish implementation guidance and maintain technical assistance channels. Contact information for Colorado’s HCPF behavioral health team was provided during the webinar for states or providers seeking more details.
Kristen Bates, deputy Medicaid director and Office Director for Medicaid Behavioral Health Initiatives and Coverage at the Colorado Department of Health Care Policy and Financing (HCPF), said Colorado originally planned to adopt ASAM 4 by July 2026 but "it is going to take us at least till July of 2027" after stakeholder feedback and additional regulatory work.
The delay responds to several concrete challenges, Bates said: hundreds of licensing rules must be reviewed and revised to align facility staffing and physical layout with ASAM 4 levels of care; Medicaid reimbursement rates and payment structures tied to ASAM 3 must be updated; and providers, particularly withdrawal-management (formerly ASAM 3.2) programs, need technical assistance to reconfigure services and contracts to operate within managed-care arrangements.
Jennifer Holcomb, behavioral health benefits section manager at HCPF, described Colorado’s outreach and supports for providers: focused listening sessions, joint work with the state Behavioral Health Administration, office hours, and a provider toolkit developed with HMA that includes self-evaluation tools and crosswalks showing how ASAM 3-era services map to ASAM 4 levels. Holcomb said these efforts aim to help providers understand staffing, documentation and facility changes required to meet the new criteria.
Colorado officials also discussed financing constraints. Because Medicaid generally cannot pay for capital projects, the state is exploring use of opioid-settlement funds and other state funds to support facility upgrades that may be necessary for some residential providers to meet ASAM 4 requirements.
The state weighed a phased approach versus a "big bang" adoption and concluded that, for Colorado, sequencing the regulatory, contracting and practice changes and then implementing broadly would work best—hence the additional year to prepare.
Bates and Holcomb told the CMS webinar that the extra time will be used to align managed-care entities, licensing authorities and providers, update contracts and reimbursement approaches, and deliver targeted technical assistance—particularly to programs that provide withdrawal management and to residential providers expected to absorb additional clinical responsibilities under ASAM 4.
Next steps: Colorado will continue stakeholder engagement, publish implementation guidance and maintain technical assistance channels. Contact information for Colorado’s HCPF behavioral health team was provided during the webinar for states or providers seeking more details.
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