Colorado Medicaid (Health First Colorado) is extremely strict, unique in its ABA coverage rules, and enforces the Behavioral Therapies Benefit (BT) Manual to the letter. Nearly every pend you received follows the same themes:
(1) no academics, (2) no sensory tools, (3) no unproven interventions, (4) everything must be ABA-based and function-based, (5) baseline data is mandatory.

Colorado Medicaid will also deny an entire treatment plan for one goal being non-compliant.

Use this guide to write CO-compliant treatment plans that pass with minimal friction.

1. Colorado Medicaid’s Core Standards (The Rules Everyone Misses)

A. ABA must target medically necessary behavior

Colorado will approve only:

• Maladaptive behaviors with clear safety or functional impact
  (aggression, SIB, elopement, tantrums, difficulty complying)

• Adaptive skill deficits that directly affect functioning
  (communication, following directions, tolerating transitions, completing self-care steps relevant to independence)

Colorado will NOT approve:

• Academic skills

• Study skills

• Organization of school materials

• Literal vs figurative language

• Describing school events

• Planning assignments

• Any goal primarily tied to school success

If it sounds like school, it will be pended or denied.

B. No sensory strategies unless they are functionally equivalent behaviors

Colorado Medicaid excludes:

• Sensory diets

• Weighted lap pads

• Stress balls

• Crash pads

• Heavy work

• Deep pressure

• Yoga breathing

• “Calming objects”

• Fidgets

• Visual coping menus unless they are implemented via ABA procedures

• Any OT-adjacent tools

If you include these, reviewers require:

• Evidence they are ABA procedures (often impossible),
  or the whole plan gets denied.

Safer approach:
Use functionally equivalent behaviors taught with:

• Functional communication training

• Task interruption + choice making

• Tolerance training

• Demand fading

• Reinforcement schedules

• Discrimination training

C. Everything must be tied to a function-based assessment

Colorado requires:

• Clear FBA results

• A stated function for each maladaptive behavior

• A treatment strategy tied directly to the function (escape, attention, tangible, automatic)

Without this, reviewers pend or deny every time.

D. All interventions must be evidence-based ABA procedures

Colorado wants the name of the specific ABA procedure, such as:

• DRA

• DRO

• NCR

• FCT

• Shaping

• Chaining

• Prompting hierarchy

• Errorless teaching

• Reinforcement schedule (FR1, VR3, etc.)

• Skill-based treatment components

• BST for caregivers

If the plan lists strategies like:

• “Use coping skills chart”

• “Take deep breaths”

• “Go to calm-down corner”

• “Perspective-taking practice”

• “Social stories”

…you will get pended unless you frame them as:

• Discrimination training

• Differential reinforcement

• Systematic desensitization

• Tolerance training

• Shaping of emotion labeling

• Teaching functional alternatives

Describe the actual ABA procedures, not the tool.

E. Baseline data is mandatory

This is the biggest reason for pends.

Baseline must include:

• Frequency, duration, or intensity of maladaptive behavior

• Percentage or frequency level for each skill goal

• How baseline was collected

• The assessment tool used (VB-MAPP, AFLS, direct observation)

Colorado will pend or deny the entire plan if baseline data is missing for even one goal.

2. How to Write CO-Compliant Goals

A goal must be:

• Observable

• Measurable

• Function-based

• Tied to an ABA teaching procedure

• Non-academic

• Not mentalistic

Examples of what not to write:

• “Improve problem solving”

• “Increase emotional regulation”

• “Identify size of the problem”

• “Use coping skills”

• “Perspective taking”

• “Reduce overwhelm”

• “Engage in calming strategies”

Instead, convert to something measurable and behavioral:

• “When presented with a difficult task, client will request a break using a 1–2 word phrase in 80% of opportunities.”

• “When frustrated, client will label his emotion using 1–2 words across 3 consecutive sessions.”

• “When denied a preferred item, client will wait quietly for 10 seconds in 4 out of 5 opportunities.”

The “mentalistic” versions get pended every time.

3. How to Write Functional Replacement Strategies (The CO Medicaid Way)

Colorado reviewers want:

• Clear function-based strategies

• No sensory replacements

• No general coping skills statements

Examples that pass:

Escape-maintained behavior

• Teach “break” request via FCT using prompt fading and DRA.

• Use demand fading paired with reinforcement for tolerance.

Attention-maintained behavior

• FCT for attention (“play?”, “look!”).

• NCR attention schedule based on baseline.

Tangible-maintained behavior

• Teach requesting (“toy please”).

• Implement delay tolerance training.

Automatic-maintained behavior

Colorado wants specific functionally equivalent behaviors:

• Teach competing responses through discrimination training

• Reinforce alternative activities that match the sensory function (NOT sensory tools)

Avoid language like “crash pad,” “deep pressure,” or “sensory activity”—these are not ABA procedures.

4. What Colorado Medicaid Considers Non-Allowable

Write this section in your internal training materials verbatim:

Non-Allowable Under CO Medicaid

• Academic goals

• Emotional regulation goals

• Organizational skills

• Homework routines

• Study skills

• CBT-like strategies (perspective-taking, problem size)

• Coping strategies without ABA procedures

• Sensory tools (weighted items, fidgets, crash pad)

• Emotional regulation without objective teaching steps

• Any “mentalistic” or internal-state goal

• Social stories (unless framed as discrimination training)

If it resembles OT, SLP, school-based treatment, or CBT, it will be denied.

5. How to Avoid Every Sensory-Related Pend

Colorado hates sensory goals, but you can reframe them.

Instead of:

• “Use stress ball when frustrated”

• “Access crash pad”

• “Deep pressure”

Use:

• “Teach functionally equivalent motor action to reduce intensity of automatic behavior using task engagement and DRA.”

• “Teach requesting a break and completing tolerance steps during frustration.”

• “Teach discrimination between escalation cues and requesting help.”

This language always passes.

6. Colorado Medicaid's Most Common Pend Themes (Checklist)

Before submitting, confirm your plan meets all 10:

1. All goals have baseline data

2. No academic goals

3. No sensory tools

4. No mentalistic goals

5. Every intervention is an ABA procedure

6. Every maladaptive behavior has a stated function

7. Every strategy is tied to the function

8. Emotional regulation goals are measurable

9. No coping menus without ABA procedures

10. Replacement behaviors are taught using FCT, DRA, prompting, or tolerance training

If you can check all, you’re in the clear.