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Health Care Policy & Financing specialist outlines ACC Phase 3 rollout

Health Care Policy & Financing TSAC meeting · April 8, 2026

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Summary

A Health Care Policy & Financing program specialist summarized the Accountable Care Collaborative Phase 3 design and implementation details, including a three-tiered care-coordination model, regional accountable entities (RAISE/RAEs), and incentives for quality outcomes; Phase 3 takes effect 07/01/2025.

Lehi Mitchell, a program specialist on the Accountable Care Collaborative program management team at the Department of Health Care Policy & Financing, said the state moved to ACC Phase 3 effective July 1, 2025, and outlined how the new structure will change enrollment, care coordination and payment flows.

Mitchell said Phase 3 reduces the number of rate regions, assigns members to regional accountable entities (RAEs) that manage behavioral-health capitation and care-coordination functions, and limits the managed care organizations (MCOs) operating in specific counties. "We are now in ACC phase 3 as of 07/01/2025," Mitchell said, adding that the RAEs will contract with behavioral health providers, perform utilization management and support primary care medical providers through value-based payments.

Why this matters: the ACC provides the delivery platform for Health First Colorado (the state Medicaid program). Under Phase 3, the RAEs are expected to strengthen care coordination across physical, behavioral and oral health and to formalize monitoring and accountability through a set of deliverables and performance measures.

Key details Mitchell provided included how members are attributed (claims-based matching to a primary care medical provider or home address when no PCP is selected), the two MCOs operating in limited regions (Elevate in Denver County and PRIME on parts of the Western Slope), and a standardized three-tier care-coordination model. Tier 1 focuses on care navigation and preventive services; Tier 2 targets rising-risk members with proactive interventions; and Tier 3 provides longitudinal, multidisciplinary care management for the highest-risk members, including children eligible for intensive behavioral health services under the Colorado System of Care.

Mitchell highlighted monitoring and incentives as central to Phase 3. RAEs must produce a suite of data feeds, key performance indicators and other deliverables (Mitchell indicated the RAEs submit over 300 deliverables to the department each fiscal year) so the department can track trends and target interventions. RAEs may earn incentive payments for meeting clinical quality measures; Mitchell cited the Behavioral Health Incentive Program (BHIP) as an example tied to follow-up after inpatient or emergency department behavioral-health encounters.

Mitchell also emphasized interagency collaboration and local tailoring: "RAEs are required to work with other agencies, case management organizations and community partners to support shared members and create documented workflows and escalation processes," she said. She noted that the Phase 3 approach is intentionally broad in some respects so RAEs can adapt to different regional needs.

The department said presenters will post the Phase 3 slides and the meeting recording on the HCPCS website and include links to provider contact pages and member-facing resources.

Next steps: providers and stakeholders are advised to review the Phase 3 web page and the department contact pages to identify their RAE/MCE contacts and to monitor forthcoming implementation guidance.