
The Colorado Commission on Medicaid met on September 2, 2026. In this series of Policy Perspectives ADVOCACYDENVER is providing this synopsis of this and subsequent meetings as the Commission works toward its goal of creating a sustainable Medicaid program for the state. The Commission will present their final report to the General Assembly and Governor in December.
The Commission continues to seek stakeholder feedback from people who use, provide, pay for, or work in the Medicaid program. If you wish to provide feedback through the long-form survey, click HERE. If you prefer a shorter survey, you can respond HERE.
Agenda & Materials
The meeting agenda and materials can be found here.
The main slide deck for this meeting can be found here.
Recording of the meeting can be found here.
Present for this Meeting:
- Senator Judy Amabile (D), Chair
- Representative Kyle Brown (D), Vice Chair
- Representative Carlos Barron (R)
- Senator Lisa Frizell (R)
- Representative Lindsay Gilchrist (D)
- Senator Barbara Kirkmeyer (R) – Entered meeting at 12 noon. Left @ 4:00 pm.
- Senator Kyle Mullica (D)
- Representative Emily Sirota (D)
- Representative Rick Taggart (R)
Absent:
- Senator Jeff Bridges (D)
Note: The facilitator modified the agenda from what was posted on the Commission website. The summary below represents the modified agenda as included in the meeting slide deck. New for this meeting, the facilitator labeled each section of the meeting as a “Block” (Block A, Block B, etc.).
I. Open and Orient (Block A)
- The meeting began with a review of the agenda for today’s meeting.
- The facilitator identified when the Commission will receive answers to several questions they asked at previous meetings. (See slide 4 of main slide deck.) Some will be answered at today’s meeting and others at future meetings.
- The facilitator reviewed feedback gathered from surveys and office hours on issues relevant to today’s topics. (See slides 5-12 of main slide deck.) Highlights include: o Where to look before cutting care (slide 8): Administrative layers, Contracts and overhead, Duplication in coordination, Look outside the program. o What people call waste (slide 9): Administrative; Fraud, but specifically fraud in billing practices by providers.
▪ Follow-up question: What does HCPF say about provider fraud, as suggested by survey respondents? The facilitator stated that she will get a response to this question from HCPF for a future meeting.
- How are rates set? (Slide 10). o Federal money (Slide 11)—Most survey respondents don’t know about how to obtain more federal dollars. A few respondents made the following suggestions: Administrative claiming; Dual eligibility; Local match; and A disallowance to verify (correcting audit mistakes).
- The facilitator presented several implications for today’s meeting taken from this feedback (Slide 12):
- Listen for the administrative dollar. o Program integrity is not about members.
- The rate is not the only rate.
- Commission members asked for the following information in addition to what is on Slide 12:
- A follow-up on the list of contractors previously given to the Commission. The Commission would like a complete listing of all contracts that HCPF has with subcontractors; what work is included in each contract; contract amount ($$); contract end date, etc. They would also like to
know if any contracts are covering tasks for which the legislature allotted staffing, and, if so, has HCPF retained these staff members?
II. The Money as the Department Describes It (Block B)
- HCPF Interim Executive Director Gretchen Hammer and HCPF Chief Financial Officer Josh Block presented and answered questions from the commission about sources of funding for Medicaid in Colorado.
- Block began the presentation by stating, “This is complicated…” Understanding the sources of funding for various Medicaid functions is not simple. Maximizing the federal funds the state receives is not something that is straightforward. Block continued by stating that at its simplest, Medicaid is a system of paying for services with a mix of federal funds and state funds. Federal funds never come without state funds. State expenditures are necessary to draw down federal dollars.
- Block continued by reviewing the types of state funds available in Colorado. These include: general funds; local funds; provider fees; intergovernmental cash transfers; CHASE fees; cash funds; and on and on. In part because of TABOR, Colorado has many rules that govern what funds can be used and how. Pages 13 of this document includes detailed descriptions of some of these funds. Block stated that all federal funds are actually federal match funds. There is no single federal match rate. The match rate will vary across programs and populations served. Pages 1-2 of this document include further details on this issue.
- Block then turned to discussing provider rates, drawing from pages 3-19 of this document. He went on to explain how provider rates are set. They are not connected to federal match rates, nor is there any single methodology that determines how rates are set. Provider rates are dependent on the type of provider and state and federal laws. HCPF does not have independent authority to set most provider rates. Some are set by the Joint Budget Committee and the General Assembly. Some are cost-based rates (pharmacy and others) or bundled rates (rates for a bundle of services – i.e., a course of chemotherapy). Others use a fee schedule, especially when the provider rate is not defined in statute or some other way. These are not directly connected to Medicare rates. The fee schedule is set by the General Assembly as a practice in CO, but not required. The MSB can also take action to reduce or modify these rates. The Medical Provider Rate Advisory Committee (MPRAC) makes recommendations but cannot set rates on its own. Ultimately, it is up to the General Assembly to take action based on recommendations from MPRAC. MPRAC provides a
structure and expertise for the state to review rates. Senator Amabile asked, “Is
MPRAC necessary? Is this possibly an opportunity to streamline?” Hammer, Block and other members of the Commission responded, “How would we otherwise get an expert insight into provider rates?” Medicaid capitation rates are a form of managed care in which HCPF pays managed care organizations in advance on a per member rate. These must be based on what we actually expect the MCO to spend per patient. Therefore, capitation rates are not under the control of the legislature. The Commission requested that HCPF provide models of potential savings for switching more payments to managed care or capitation. (Editorial note: pages 9-19 of the document for this section is a full listing of provider rate suggestions made by MPRAC between 2023-2025, and what rates were ultimately enacted by the General Assembly. Identifying the most frequent provider types for individuals with disabilities is pretty easy to do in this format. I encourage you to look at the details provided and see how far off the legislature has been from recommendations made for those who serve the disability community.)
- Block then began to explain how HCPF approaches maximization of Federal matching dollars. (See pages 1-2 of this document.) HCPF claims that its program is already built around maximizing federal funds, and its strategy to do so is laid out in the document provided. Maximizing federal match dollars can often require action by the General Assembly or the Medical Services Board. A list of what federal matching dollars are potentially available to states does not exist. At times, accepting federal funds comes with risk. Higher match rates can be (often are) temporary and always require something from the state.
- Members of the Commission closed this portion of the meeting with several questions for Hammer and Block: o Question: The amount of CHASE fee expenditures per member for buy-in members is much higher than for other members also supported by CHASE fees. Why is this? Hammer: The difference lies in the type of services being provided and the type of provider. Services for waiver buyin members are, by design, intended to keep people out of institutions. These services are more expensive but also ultimately save the state money by keeping people out of institutions. Home-based care is expensive. The waiver population in the buy-in program costs the state
25% of what the waiver population that is not in the buy-in program costs.
o Question: How are we judging quality and effectiveness? Hammer: HCPF will come back to share the metrics it uses.
III. How the State Knows the Money Is Spent Properly (Block C)
- HCPF Chief Operating Officer Ralph Choate and a member of his staff presented pages 14-16 of this document to the Commission.
- Choate began by stating that program integrity is not just the responsibility of HCPF’s fraud, waste, and abuse team. Rather, program integrity is everyone’s responsibility. Provider education is at the core of program integrity. After reviewing the handout, the Commission asked several questions: oQuestion: We know that you have these systems in place. Are you adding more things to integrity processes? Are any drawing on new technology? What are some other ways we can improve? Choate: Some additional integrity processes are include in the handouts. He would like additional emphasis on ensuring all who are dual eligible for Medicaid and Medicare, are enrolled in both and that Medicare is always billed first. The Commission would like for HCPF to find a way to better understand how many are eligible for dual enrollment but are not dually enrolled. Ensuring that any third party liable for expenses pays first is another necessary focus to save funds. Providers need to bill third party private insurance or other responsible parties first. Program Program Integrity efforts can now include extrapolation audits thanks to legislation passed in 2026. These audits use a sample of payments for a provider to determine fraud or error rate across all payments to that provider. HCPF can then ask for return of provider payments based on the sample error rate. Question: How do we get an estimate of these savings to use for our budgeting process? Choate: We are working on developing that and will send you our progress so far.
IV. Eligibility Changes and Risks (Block D)
The Commission postponed this section of the meeting because they are behind their anticipated schedule. They want to take advantage of the panelists who are in the room first.
V. The Rural Framework (Block E)
- This section drew primarily from a whitepaper included in today’s handouts. With support and involvement of the Buell Foundation, an Independent Rural Health group has come together and wrote this paper. They are continuing to work together to advance rural health in the state. See pages 2-3 for a listing of who is involved. Buell Foundation CEO Steve ErkenBrack and three other authors presented this section to the Commission.
- Commission members had several other documents related to rural health in their packets today. While they didn’t address these directly, they did inform the overall conversation.
- ErkenBrack began this portion of the meeting by stating that the sustainability of rural health providers is an existential concern for Colorado’s rural communities. The funding problem for rural health providers is acute and there are no quick fixes. The group they have put together is advocating for local autonomy: allow rural providers and the communities they serve to decide which services are most important within a budget. More fee-for-service and service controls will not solve the problem. ErkenBrack estimates that implementing local control in rural areas would take 5 years to fully implement and would have to adhere to existing federal and state regulations. He also suggested that the Commission examine Maryland’s hospital payment system. Maryland uses a public utility funding model for hospitals in which all services receive the same payment regardless of who is paying. Medicaid, Medicare, and private insurance all pay the same amount for the same service. The fee-forservice system does not work in rural communities because it incentivizes rural providers to provide services and target patients that are most profitable, not those that are most needed to ensure healthy communities.
- The Commission asked the Rural Health group to put together recommendations for specific steps to take to implement this idea. The group agreed to do so and will return their answer to the Commission in 6 weeks.
VI. … and Safety Nets (Block E)
- Denver Health CEO Donna Lynne and Lincoln Health (Hugo, CO) CEO Kevin Stansbury presented this portion of the meeting. Lynne prepared a slide deck and a fact sheet for the Commission, though this portion of the meeting was very much an open conversation rather than a presentation.
- Lynne opened by stating that HR1 implications are top of mind for Denver Health. HR1 is estimated to ultimately cause 20,000 Denver Health patients to lose their insurance coverage. Most will become uninsured and the hospital will still need to treat them. Denver Health will maintain all emergency services but will likely need to cut back on its primary care services to many of its patients to balance its budget. Lynne argues that this will end up costing much, much more in the end because people will lose preventative healthcare. Lynne also pointed out to the Commission that Denver Health is the only entity in the state that serves as both a Managed Care Organization and the provider of that care. She said that there are some benefits to this arrangement.
- Stansbury stated that what Lincoln Health does most is primary care and management of chronic conditions. They do this because Lincoln is the only one in its area who does it, not because it’s profitable.
- Both Lynne and Stansbury agree that what is necessary is long-term, fundamental change in how Colorado supports and funds hospitals.
- Lynne stated that commercial insurance providers are a huge problem for Denver Health. Patients covered by commercial insurance are a small portion of Denver Health’s patient mix as compared to most other hospitals in the state. As a result, commercial insurers try to negotiate their rates down and say “You’re not that important to us.” Stansbury says that his small rural hospital has the same problem. He says that some commercial insurers pay Lincoln Health less than what it receives from Medicaid for the same services.
- Lynne says that Denver Health would like to collect on state directed payments that the governor’s office will not allow them to collect from the federal government. The governor argues that doing so would be too risky and would trigger audits and subsequent clawback of funds. Denver Health argues that they could mitigate for these risks. Further, Denver Health would like to use a per diem rate methodology for some services, which they predict will provide them with an additional $500 million in federal funds. Again, the governor’s office will not allow this.
- Both Lynne and Stansbury agree that the state should seriously examine a uniform payment model (the utility model from Maryland) as discussed in the last section of the meeting. Stansbury says that if the state considers going in this direction, a trial in obstetrics would be the right starting point.
The Commission returned to V. Eligibility Changes & Risks (Block D), which it previously skipped.
- HCPF Chief Financial Officer Josh Block returned to present and answer questions. He directed the commission to pages 3-6 of this document and pages 10-11 of this document.
- Block stated that because of HR1 requirements kicking in on October 1, the Hospital Provider Fee income will begin to drop. Additional reductions will occur each year until 2032. Because Hospital Provider Fees are CHASE funds in Colorado, CHASE fees will eventually no longer be sufficient to fund what they are supposed to fund. We will likely reach this point in the next two years. State statute dictates how Colorado will handle this shortfall. Services will be cut or eliminated in an order specified by statute. (The handouts contain details for the anticipated cuts.) Commission members asked BIock for options. Block stated that changing the statute is in the purview of the General Assembly but any changes would also have to conform to federal regulations. Representative Brown requested a more expansive conversation on this issue that includes additional stakeholders, to be held at a future meeting. The Commission also requested additional analysis by HCPF as to what other options for cuts could look like (i.e., percentage cuts across the board as opposed to fully dropping any one category of funding.)
- Representative Taggart requested that at the next meeting HCPF provide its response to the suggestion of implementing uniform provider rates (utility model) brought up in prior conversations today. He also would like information on how Oregon is using the Rural Healthcare Transformation Fund for projects that are not new or innovative. (An assertion made earlier in the meeting is that the fund can be used for existing programs and services (sustainability), whereas HCPF has stated that it must be used for only new programs and services (innovation) per federal rules.)
I. Public Comment (Block F)
- The Commission heard public comment from 16 people. These included Arc of Aurora Executive Director Hanne Railey, CCDC Co-Executive Director Hillary Jorgenson, representatives of several behavioral health provider professional organizations, directors of several behavioral health clinics, a representative of Impacted Caregivers of Colorado, several family caregivers, a host home provider, a DD waiver recipient, and a representative of Colorado Organization for Latina Opportunity and Reproductive Rights (COLOR). Topics covered included:
- Waivers, home and community based services and supports (HCBS), and long-term services and supports (LTSS).
- The buy-in program for waivers o Host homes.
- PETI for those on the DD waiver.
- The Colorado Single Assessment and its revision.
- Transparency about how RAEs are spending funds.
- Provider rates, particularly those for behavioral health services, and the financial “architecture” of Medicaid. Many highlighted how provider rates intersect with the financial viability of clinics and other service providers, as well as access to care for members.
- Immigrant Coloradans who will lose health care coverage by the end of the year as a result of HR 1.
II. The First Recommendation for Consideration (Block G)
- The facilitator asked the Commission for ideas for cost-savings that it may have identified during this meeting. She mentioned that they have identified reducing administrative layers, maximizing the federal match, and dual enrollment. Senator Amabile brought forward that she would like the Commission to consider cost sharing, such as copays for certain services.
III. Close
- Senator Amabile adjourned the meeting at 5:02 pm.

Policy Perspective is a publication of ADVOCACYDENVER. If you have any questions, please contact Paul Baumann, Policy Outreach Specialist, at pbaumann@advocacydenver.org or 303.974.2535.