COLORADO · BEHAVIORAL HEALTH

Selling a behavioral health practice in Colorado

Since January 1, 2024, Colorado's Behavioral Health Administration has licensed substance use disorder providers, community mental health centers, and larger behavioral health practices as Behavioral Health Entities with service endorsements. In June 2026, Colorado enacted the Applied Behavior Analysis Practice Act, which will require behavior analysts and assistant behavior analysts to be licensed by July 1, 2028, and also regulates ABA provider entities.

Akim Guennani

By Akim Guennani, Founder · Updated October 2026

Colorado behavioral health at a glance

Behavioral health licensingBehavioral Health Administration (BHA), since January 1, 2024
Who needs BHE licensureSUD providers, CMHCs, and practices with 10+ FTE behavioral health professionals, among others
ABA practitioner licensingRequired by July 1, 2028 under HB 26-1425 (signed June 2, 2026)
Medicaid ABACovered under EPSDT for Health First Colorado members 20 and under

The Behavioral Health Administration and BHE licensing

Rules adopted in December 2023 and effective January 1, 2024 moved Colorado behavioral health licensing to the Behavioral Health Administration. The Behavioral Health Entity structure lets a provider hold one license with different service endorsements, and it replaced the earlier SUD, involuntary treatment, and community mental health center licenses. Providers that must hold BHE licensure include SUD license holders, CMHCs, and practices with 10 or more full-time-equivalent behavioral health professionals.

That 10-FTE threshold matters for growing group practices: a practice that crosses it needs a BHE license, and a buyer will check whether you have one if you should. On a sale, confirm with BHA and counsel what filing your structure requires.

The 2026 Applied Behavior Analysis Practice Act

Colorado's governor signed HB 26-1425 on June 2, 2026, creating the Applied Behavior Analysis Practice Act. Beginning July 1, 2028, behavior analysts and assistant behavior analysts generally must be licensed by the new Colorado Behavior Analyst Licensing Board, with a current certificate from an approved certifying entity and a fingerprint-based background check. The act also regulates ABA provider entities.

For sellers of ABA practices, this is a transition to plan for. Buyers will want to know that your clinicians can obtain licenses on time and how the entity rules will apply to your clinic.

What Colorado buyers underwrite

These items move price the most in Colorado.

Licensing status
BHE licensure where required, and readiness for ABA licensing by 2028.
Clinician stability
Tenure, caseload, and credentials.
Payer contracts
Health First Colorado and commercial contracts.
Documentation
Records that support billing and service endorsements.

Sources

Rules change. This page summarizes public sources as of the review date and is educational, not legal, tax, or regulatory advice. Confirm licensing and change of ownership steps with counsel and the relevant state agency before signing.

  1. 1. Behavioral health licensing, designation and approvals (Colorado Behavioral Health Administration)
  2. 2. Behavioral health law ledger, December 2023 (Greenberg Traurig)
  3. 3. Colorado enacts comprehensive licensing requirements for ABA practitioners and clinics (Benesch)
  4. 4. Early and Periodic Screening, Diagnostic and Treatment (EPSDT) (Health First Colorado)

Reviewed October 2026

Questions Colorado owners ask

Straight answers, before you commit to anything.

Who licenses behavioral health providers in Colorado?+

The Behavioral Health Administration, since January 1, 2024, through Behavioral Health Entity licenses with service endorsements.

Does my group practice need a BHE license?+

Practices with 10 or more full-time-equivalent behavioral health professionals are among those required to obtain BHE licensure, along with SUD providers and CMHCs.

When do Colorado ABA practitioners need a license?+

Under HB 26-1425, signed June 2, 2026, behavior analysts and assistant behavior analysts generally must be licensed by July 1, 2028.

Does Health First Colorado cover ABA?+

Yes, under the EPSDT benefit for eligible members age 20 and under.

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