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HB22-1325 - Primary Care Alternative Payment Models

On May 18, 2022, Governor Polis signed House Bill 22-1325 (HB 22-1325) into law, which directed the DOI to establish aligned parameters for primary care alternative payment models (APMs) to improve health care quality and outcomes in a manner that reduces health disparities and actively advances health equity, and increases the number of Coloradans who receive the right care in the right place at the right time at an affordable cost. Over the course of 2023, the DOI engaged a broad array of stakeholders - including the Department of Health Care Policy and Financing, the Department of Personnel, the Department of Public Health and Environment, the Primary Care Payment Reform Collaborative (PCPRC), and health insurance carriers and providers participating in APMs - in a series of discussions to develop aligned parameters for APMs for primary care services in health benefit plans.  

The DOI adopted Colorado Insurance Regulation 4-2-96 on by December 1, 2023, establishing alignment requirements related to four APM design components: quality measures, patient attribution, risk adjustment, and core competencies. Additional information regarding these requirements, as well as activities related to the ongoing implementation of HB 22-1325, will be available on this website.

        *   *   Primary Care and APM Reporting Guidance - Reporting Template Finalized  *   *  

The Division has finalized the "Primary Care and Alternative Payment Model (APM) Reporting Template", which carriers must use to comply with the primary care and APM reporting requirements found in Amended Regulation 4-2-72 (effective May 30, 2025).

Carriers are required to submit the "Primary Care and APM Reporting Template" to the Division through SERFF on or before September 15, 2025. The Division is currently working with SERFF to create a new “Primary Care and APM” Filing Type that carriers should when submitting filings, and anticipates this will be available as a Filing Type selection early next week. The reporting template is now available in SERFF as of July 21, 2025.

A copy of the final template is also available by clicking on the link below:

Primary Care and Alternative Payment Model (APM) Reporting Template - v7.15.25

Please contact Tara Smith (tara.smith@state.co.us; 720-701-0081) with any questions about primary care and APM reporting requirements.

For questions about the Division's primary care and APM work, and/or if you would like be added to the stakeholder email distribution list for HB 22-1325 implementation, please send your name and contact information to Tara Smith, the Division's Primary Care and Affordability Director (tara.smith@state.co.us).

2024

On August 22, 2024, the Division hosted a stakeholder meeting to discuss propose revisions to Primary Care and APM reporting requirements. The Division's presentation from this meeting can be access by clicking on the following link:

2023

In 2023, the Division, with the support of the Health Care Payment and Learning Action Network (HCP LAN), held a series of stakeholder meetings to obtain input on aligned parameters for quality measures, patient attribution, risk adjustment, and core competencies, pursuant to House Bill 22-1325. Materials from the stakeholder sessions for each topic area can be accessed by clicking on the links below. 

Quality Measure Stakeholder Engagement Group

The aligned APM parameters for primary care must include, per the requirements of HB22-1325, an aligned quality measure set that considers the quality measures and the types of quality reporting that health insurance carriers and providers are engaging in under current state and federal law. In addition, the aligned quality measure set must include quality measures that are patient-centered and patient-informed and address: pediatric, perinatal, and other critical populations; the prevention, treatment, and management of chronic diseases; and the screening for and treatment of behavioral health conditions.

Patient Attribution Stakeholder Engagement

The aligned APM parameters for primary care must include, per the requirements of HB22-1325, utilize patient attribution methodologies that are transparent and reattribute patients on a regular basis. Patient attribution methodologies must also ensure that population-based payments are made to a patient's primary care provider rather than other providers who may only offer sporadic primary care services to the patient, and include a process for correcting misattribution that minimizes the administrative burden on providers and patients. 

Risk Adjustment Stakeholder Engagement

The aligned APM parameters for primary care must include, per the requirements of HB22-1325, include transparent risk adjustment parameters that ensure that primary care providers are not penalized for or disincentivized from accepting vulnerable, high-risk patients. Risk adjustment parameters must also ensure primary care providers are rewarded for caring for patients with more severe or complex health conditions, and patients who have inadequate access to affordable housing, healthy food, or other social determinants of health. 

Core Competencies Stakeholder Engagement

The aligned APM parameters for primary care must include, per the requirements of HB22-1325, include a set of core competencies around whole-person care delivery that primary care providers should incorporate in practice transformation efforts to take full advantage of various types of alternative payment models.