Colorado Medicaid Denied the Claim: Can You Bill the Client?

Last reviewed: October 7, 2026.

Usually not. Health First Colorado says members cannot be billed for covered services, and a denial caused by a billing error, timely filing, missing prior authorization information or the provider’s enrollment does not change that. You can bill the member only if they were not enrolled on the date of service, or the service is not covered and they agreed in writing to pay before receiving it.

When the client cannot be billed

HCPF’s January 2026 provider bulletin lists the situations where a provider may not bill the member:

• Late eligibility notice. The provider is responsible for checking eligibility on every date of service, even if the client did not mention their Medicaid.

• Provider not enrolled. If you chose not to enroll, you cannot bill the member. You can enroll after the service and submit within the 365-day timely filing window.

• Prior authorization denials. A technical or lack-of-information denial does not mean the service is not covered. Denied portions of a request and visits beyond the authorized amount also cannot be billed to the member.

• Balances after other insurance. When a client has commercial coverage primary and Medicaid secondary, you cannot bill them the difference, or the primary plan’s copay or deductible.

• System-related denials. Billing errors and claims outside timely filing are not reasons to bill the member.

The two cases where you can collect

1. The client was not enrolled in Health First Colorado on the date of service.

2. The service is not covered, the client was told before the service, and they signed a written agreement to pay for it.

If a client later gains eligibility retroactively, the bulletin says to return fees collected for covered services, minus any required copay, and bill Health First Colorado instead. Copays can only be collected when Medicaid is the client’s primary coverage.

What to check before deciding the denial is final

For behavioral health claims, check where the claim went and under whom it was billed. Both are fixable on the provider side, and neither makes the balance the client’s:

• Wrong destination. Most behavioral health services route to the client’s Regional Accountable Entity, not straight to the state fiscal agent. There are exceptions; for example, HCPF routes Denver Health Medicaid Choice behavioral health claims to Colorado Access but sends behavioral therapy to Gainwell. Check the member’s assignment and benefit for the date of service.

• RAE participation. Billing through a RAE needs both Health First Colorado enrollment and a contract with that RAE. Confirm the effective date and whether participation is under the group or the individual NPI.

• Billing entity mismatch. The NPI identifies the clinician and the Tax ID identifies the billing entity. Insurers use both, and a claim filed under a different group or Tax ID than the one on the contract does not land on that contract, even when the clinician is enrolled.

Correct and resubmit those claims rather than moving the balance to the client. If you need to confirm your Medicaid ID and effective date first, see how to find your Health First Colorado provider ID. Group billing rules are covered in Colorado Medicaid PT 77 for behavioral health groups.

Do not hand it to collections

The bulletin also says providers may not send overdue Health First Colorado member accounts to collection agencies unless the bill is for a noncovered service and the member broke a written payment agreement. Pause automatic card charges on a Medicaid client’s account while a denial is being worked.

Frequently Asked Questions

My client has commercial insurance and Medicaid. Can I charge the copay?

No. HCPF says providers cannot bill a member for copays or deductibles assessed by the primary insurance when Health First Colorado is secondary.

Can a signed self-pay agreement cover a denied Medicaid claim?

Only for a service Health First Colorado does not cover, and only if the client was told and signed before the service. It does not cover a denial for a covered service.

I was not enrolled in Medicaid when I saw the client. Can I bill them?

No. You can enroll afterward and submit the claims within 365 days of the service, but you cannot bill the member because you were not enrolled.

Sources

• HCPF provider bulletin, January 2026 (Member Billing)

• HCPF policy statement: billing members who receive retroactive eligibility

• HCPF fee-for-service behavioral health benefit