BT vs RBT: what a behavior technician needs in Colorado

Only in some situations. See the detail below.

As of 2026-10-21, for Health First Colorado, delivery of 97153 requires an RBT per HCPF memo PM 25-005. HB26-1425 (C.R.S. 25.5-4-437(3)) describes a possible temporary reimbursement period for technicians who do not yet hold certification, but it is subject to federal approval and several prerequisites (see state_specific_bt_requirements). Subsection (3)(a) refers to a temporary period of not less than 45 days, while subsection (3)(c) stops reimbursement requests after 45 days without certification until certification occurs. This should not be read as an automatically available hiring grace period; implementation was not verified. The bill text also notes that ABA technicians are permitted to practice without a license, so state professional licensure is a separate matter from certification and from reimbursement eligibility. Commercial-insurance rules for technicians were not researched, and the Medicaid findings cannot establish commercial eligibility.

• Temporary reimbursement is subject to federal approval (C.R.S. 25.5-4-437(3)).
• Employers must submit quarterly rosters of technicians.
• A name-based judicial check is required for each technician.
• The technician must have completed certification training.
• The technician must have completed abuse/neglect-reporting training.
• The temporary period begins only after these prerequisites are met; reimbursement requests stop after 45 days without certification until certification occurs.

As of 2026-10-21, who may deliver adaptive behavior treatment (CPT 97153) is unsettled. COABA reports that HCPF Policy Memo PM 25-005 was released on 2025-07-18 and is retroactively effective to 2025-04-15; these dates come from COABA's account and were not verified against the memo itself. COABA describes the memo as limiting delivery to BACB-certified Registered Behavior Technicians. That exclusive BACB framing is contradicted by HCPF's archived August bulletin, so it should not be treated as settled. COABA's earlier 2025-08-31 compliance deadline was extended to 2025-10-31 (historical). Later deadline changes could not be confirmed from opened sources, and current implementation and federal approval were not verified. HB26-1425 (signed 2026-06-02) requires Medicaid to reimburse ABA services provided by certified behavior technicians, and it recognizes certification from the BACB, QABA, and qualifying board-designated certifiers, not the BACB alone.

It depends. See the condition below.

Technician certification is required in some form, but the categorical 'BACB-certified RBT only' answer is not supported. HB26-1425 recognizes BACB, QABA and qualifying board-designated certifiers. Its bill summary says Medicaid reimbursement for services by certified behavior technicians includes 'one temporary period of not less than 45 days' for technicians pursuing certification. This provision is conditional, and its exact operation was not confirmed. Whether any HCPF emergency PBT rule has its own window was not verified. COABA asked HCPF for a rolling 120-day grace for new hires; that is an advocacy request, not rule.