How to start an ABA practice in Colorado

Colorado requires a Licensed Behavior Analyst; Licensed Assistant Behavior Analyst; Applied Behavior Analysis Clinic license (facility) from Colorado Behavior Analyst Licensing Board (Department of Regulatory Agencies); ABA clinic licenses from the Colorado Department of Human Services to operate an ABA practice. Fee: Not yet set. The board will set fees under C.R.S. 12-20-105.

License required

Yes

License

Licensed Behavior Analyst; Licensed Assistant Behavior Analyst; Applied Behavior Analysis Clinic license (facility)

Issuing agency

Colorado Behavior Analyst Licensing Board (Department of Regulatory Agencies); ABA clinic licenses from the Colorado Department of Human Services

Fee

Not yet set. The board will set fees under C.R.S. 12-20-105.

Professional license

board: Colorado Behavior Analyst Licensing Board (five governor-appointed members, under DORA); statute: C.R.S. Title 12, Article 247 (Applied Behavior Analysis Practice Act, HB26-1425, approved June 2, 2026); C.R.S. 26-6-905 (clinic licensing); behavior analyst: New law. The practice of ABA without a license is prohibited starting July 1, 2028. The requirements are current certification from a certifying entity plus a fingerprint check. Licenses by endorsement are available. The article sunsets September 1, 2031.; assistant behavior analyst: Separate license for certified assistant behavior analysts (BCaBA or QABA equivalent), who practice under supervision.; technician: No state license. Behavior technicians (including RBTs) may provide ABA under a licensed behavior analyst or licensed assistant without a license. For Medicaid, HCPF reimburses RBT services and, subject to federal approval, pays for uncertified technicians for one temporary period of at least 45 days while they pursue certification, if the provider submits quarterly technician rosters.; agency or clinic license: Yes. HB26-1425 adds 'Applied Behavior Analysis Clinic' to the facilities CDHS licenses: facilities giving at least 4 but under 24 hours of ABA per business day to 3 or more people aged 18 months to under 21. Existing clinics must apply by August 1, 2026 and may not operate unlicensed on or after August 1, 2027.; medicaid enrollment: Health First Colorado (HCPF) pays the ABA provider for RBT-delivered services to members with autism. Technicians must pass a name-based judicial record check before serving and billing. Detailed enrollment steps were not reviewed.

Regulation

C.R.S. 12-247-101 et seq. (HB26-1425, 2026 Colo. Sess. Laws ch. 299); C.R.S. 26-6-905

1. Hold current certification from an approved certifying entity (BACB, QABA or another board-approved body)
2. Complete a fingerprint-based criminal history check
3. Apply to the Colorado Behavior Analyst Licensing Board once it opens applications; licensure is mandatory from July 1, 2028
4. ABA clinics serving 3+ people aged 18 months to under 21 for 4–24 hours a day: apply to CDHS by August 1, 2026; operating without a license is barred on or after August 1, 2027

Staffing

• Licensed assistant behavior analysts practice only under supervision of a licensed behavior analyst per board rules
• Supervisors may oversee only as many assistants and technicians as the board allows

Program

Health First Colorado (Colorado Medicaid)

Enrollment portal

Colorado interChange Provider Web Portal (Gainwell)

Fiscal agent

Gainwell Technologies (Colorado interChange MMIS)

Application fee

HCPF lists the CY2026 fee as $750 for institutional providers, charged on new enrollments, revalidations and new locations. HCPF also has a process for paying a previously waived fee. Federal rule (42 CFR 455.460): the state must collect the CMS application fee from institutional providers that are newly enrolling or re-enrolling; individual physicians and non-physician practitioners are exempt, as are providers already enrolled in (or that already paid the fee to) Medicare or another state's Medicaid/CHIP. CMS set the fee at $750 for calendar year 2026.

Fingerprinting

HCPF names its high-risk types, all for new enrollments: doulas, DME suppliers, home health agencies, hospices, lactation providers, skilled nursing facilities, personal care agencies under the state plan, certain opioid treatment providers, and some HCBS providers. Those providers and their 5%+ owners must be fingerprinted within 30 days of a request. Federal rule (42 CFR 455.434, 455.450(c)): providers the state places in the 'high' categorical risk level, and anyone owning 5% or more of such a provider, must submit fingerprints for a criminal background check.

Site visit

HCPF says site visits are required for all high-risk providers, including all non-emergent medical transportation providers, and that site visits are recorded. Federal rule (42 CFR 455.432, 455.450(b)-(c)): the state must do site visits before and after enrollment for providers in the 'moderate' or 'high' risk levels, and any enrolled provider must allow unannounced on-site inspections.

Revalidation

Health First Colorado and CHP+ providers must revalidate at least every five years. HCPF emails providers about six months before their deadline and posts a revalidation-dates spreadsheet; claims are denied for providers that miss the date. Federal rule (42 CFR 455.414): every enrolled provider must be revalidated at least once every 5 years.

Full Colorado Medicaid enrollment guide →

CON program

No

Colorado certificate of need details →

State minimum wage

$15.16 an hour

Effective

2026-01-01

Scheduled increases

Rises to $15.71 in 2027 ($12.69 tipped), per the state labor department.

Direct-care wage floor

HCBS base wage: Medicaid HCBS providers must pay direct care workers at least $17.00/hour statewide in 2026 ($19.29 in Denver, $18.17 in Edgewater); if a local minimum wage is higher, the higher rate applies.

Rate pass-through

Providers attest annually to paying the base wage; non-compliance can lead to audits, corrective action, claim suspension or recoupment.

HCBS 80/20 rule

Federal baseline: 42 CFR 441.302(k) requires the state to show that each provider spends at least 80% of Medicaid payments for homemaker, home health aide and personal care services under 1915(c) waivers on direct care worker pay and benefits. Compliance starts 2030-07-09 (for managed care, the first rating period starting on or after that date); annual payment-adequacy reporting under 441.311(e) starts 2028-07-09. A state may set a lower share for state-defined small providers and exempt providers facing hardship, each only through a public notice-and-comment process. The eCFR text has not changed since 2024-07-09. No state-published 80/20 implementation step (small-provider criteria, hardship exemption or reporting guidance) was found for this state in the official sources reviewed.

Applied behavior analysis organizations — active organization NPIs (NPPES)

988 (as of Sep 13, 2026)

Total Medicaid and CHIP enrollment (latest reported month)

1,188,599 (as of Jun 1, 2026)

All Colorado ABA Medicaid rates, ranked →

• Persons with Brain Injury (HCBS-BI) Waiver (1915(c))
• Children's Extensive Support (CES) Waiver (1915(c))
• Community First Choice (CFC) (1915(k))
• HCBS – Children's Habilitation Residential Program Waiver (1915(c))
• Complementary and Integrative Health (HCBS-CIH) Waiver (1915(c))
• HCBS Waiver for Community Mental Health Supports (CMHS) (1915(c))
• Children with Complex Health Needs (CwCHN) Waiver (1915(c))
• Developmental Disabilities (HCBS-DD) Waiver (1915(c))
• Elderly, Blind, and Disabled (HCBS-EBD) Waiver (1915(c))
• Supported Living Services (SLS) Waiver (1915(c))

Colorado waivers and waiting lists →