Reporting Requirements

Who must submit a CoBHRM, when submissions are due, and how to get started

Who is required to complete a CoBHRM?

• All BHA licensed providers. Regardless of payer source.
• All behavioral health providers, regardless of BHA licensure, that serve Medication/Psychiatric Service Only clients. Also regardless of payer source.
• All BHASO contracted providers.
• All providers delivering services that are paid for in any part with public funds, which may include the following:
  • BHA Funds
  • American Rescue Plan Act (ARPA) Funds
  • Medicaid Capitation
  • Medicaid Fee for Services
  • Medicare
  • Any local government funds that do not fully cover the cost of care and/or is subsidized by BHA funds
  • Any other State funds from other Departments such as:
    • Department of Corrections (DOC)
    • Division of Youth Services (DYS)
    • Division of Child Welfare/County Child Welfare (CW)
    • Division of Vocational Rehabilitation (DVR)
    • Child Health Plan Plus (CHP+)
    • Other government funds

The Substance Abuse and Mental Health Services Administration (SAMHSA) requires that BHA collect and report on the data elements in CoBHRM as a requirement of funding. BHA uses this information to monitor service quality, utilization and effectiveness, and to report to the legislature on treatment outcomes and service needs in Colorado. BHA requires completion of CoBHRM in compliance with SAMHSA Federal Guidelines.

See the Combined SU and MH TEDS State Instruction Manual – Version 5.0, section 4.2 and Appendix A. (See TEDS Citations.)

Section 4.2 page 24, Federal Data Collection Authority - Section 505(a) of the Public Health Service Act (42 USC §290aa–4) directs the SAMHSA Administrator to collect data on the number of public and private behavioral health treatment programs and the number and characteristics of individuals seeking treatment through such programs.

Appendix A, page 59, provides additional information on the authority for annual collection of data on mental illness and substance use.

With this, if a client receives any of these types of services, regardless of payer source, a CoBHRM is required to be submitted.

Timing of Data Submissions

When data submissions are due is based upon the type of service or modality.

CoBHRM Service Identifiers/Modalities

For the canonical, coded list of service identifiers see Appendix A — Service Identifiers.

• Acute Treatment Unit (ATU)
• Ambulatory Medical Withdrawal Management
• Ambulatory Medical Withdrawal Management with Monitoring
• Ambulatory Medical Withdrawal Management without Monitoring
• CJS SUD Treatment
• Co-Occurring (CIRCLE)
• Crisis Mobile
• Crisis Respite
• Crisis Stabilization
• Crisis Walk in
• Day Treatment (DAY)
• Differential Assessment (SUD) / Evaluation Only (MH)
• DUI Level I Education
• DUI Level II Education Only
• DUI Level II Therapy and Education
• Intensive Residential (IRT)
• Medically Managed Inpatient Other Than WM (Partial Hospitalization Program)
• Medically Managed Inpatient Withdrawal Management
• Medication /Psychiatric Service Only
• Mental Health Inpatient
• Mental Health Outpatient
• Mental Health Residential
• Minors in Possession Treatment (MIP)
• Opioid Treatment Program (ORT/OTP)
• Psychiatric Hospitalization
• Residential (non-hospital) Withdrawal Management (RDX)
• Strategic Individualized Remediation Treatment (STIRT)
• SUD Intensive Outpatient (IOP)
• SUD Traditional Outpatient (OP and EOP)
• Therapeutic Community (TC)
• Transitional Residential (TRT)
• Youth Post-Crisis Stabilization Services

Timing for Each Type of CoBHRM

Outpatient

1. The CoBHRM admission must be submitted to BHA, by the 6th encounter or within 90 days of the first encounter, whichever comes first, for the service identifiers below.
2. The CoBHRM discharge must be submitted to BHA by the last business day of the following month of the discharge.
3. Service Identifiers:

   1. Mental Health Outpatient

   2. Medication/Psychiatric Service Only

      From: 2 CCR 502-1

      21.190.7 MEDICATION/PSYCHIATRIC SERVICES ONLY AT MENTAL HEALTH CENTERS AND CLINICS [Eff. 11/1/13]

      A. A person qualifies to be classified as receiving medication/psychiatric services only when the agency provides a maximum of three (3) services, in addition to services related to medications, within a six (6) month period of time.

      B. At least annually, a licensed behavioral health professional shall complete and document in the clinical record:

      1. Clinical rationale supporting a medication/psychiatric services only status; 2. An updated assessment; 3. An updated service plan; and, 4. A Colorado Client Assessment Record (CCAR)

   3. SUD Traditional Outpatient (OP and EOP)

   4. SUD Intensive Outpatient (IOP)

   5. CJS SUD Treatment

   6. DUI Level I Education *

   7. DUI Level II Education Only *

   8. DUI Level II Therapy and Education *

   9. Minors in Possession Treatment (MIP) *

   10. Youth Post-Crisis Stabilization Services

4. *Special note regarding all DUI modality CoBHRM records: All DUI CoBHRM records will be submitted directly to BHA, regardless of the provider’s BHASO contract status.

Residential

1. The CoBHRM admission must be submitted to BHA, by the 6th encounter or within 90 days of the first encounter, whichever comes first, for the service identifiers below.
2. The CoBHRM discharge must be submitted to BHA by the last business day of the following month of the discharge.
   1. Mental Health Residential
   2. Day Treatment (DAY)
   3. Transitional Residential (TRT)
   4. Intensive Residential (IRT)
   5. Co-Occurring (CIRCLE)
   6. Therapeutic Community (TC)
   7. Strategic Individualized Remediation Treatment (STIRT)

Emergency Services and OTP

Admissions to the following modalities, which typically do not incur multiple encounters or are services that pose a safety risk to clients, are due to BHA at the time of the first encounter and then at the time of the discharge.

• Mental Health Emergency Services
  • Mental Health Inpatient (Mental Health Involuntary Commitment, 27-65, 72-hour evaluation and treatment, Short-term hold, Long-term hold)
  • Psychiatric Hospitalization
  • Acute Treatment Unit (ATU)
  • Crisis Stabilization (CSU)
  • Crisis Respite
  • Crisis Mobile
  • Crisis Walk in
• Substance Use Emergency Services
  • Emergency Commitment
  • Withdrawal Management
    • Ambulatory Medical Withdrawal Management
    • Ambulatory Medical Withdrawal Management with Monitoring
    • Ambulatory Medical Withdrawal Management without Monitoring
    • Medically Managed Inpatient Withdrawal Management
    • Residential (non-hospital) Withdrawal Management (RDX)
  • Medically Managed inpatient (other than Withdrawal Management)
• Opioid Treatment Program (ORT/OTP)
  • The CoBHRM admission must be submitted at the first encounter and again at the time of discharge.
  • A Central Registry record must also be submitted at the time of admission and discharge.

Differential Assessment (SUD) / Evaluation Only (MH)

This type of CoBHRM record is optional. If used, they should be submitted to BHA by the last business day of the following month.

CoBHRM Data Submission Requirements by Work Flow

Several of these workflows are carried out using CoBHRM transactions. See Transaction Types for how Add, Update, and Replace operations work.

Step Up / Step Down in care.

Admissions and discharges when there is a step up or step down in the level of care, at the same provider.

1. Submit a CoBHRM discharge for the previous modality/service identifier.
2. Submit a new CoBHRM admission with the new modality/service identifier.

Transferring between licensed locations.

Admission and discharges when transferring to another location at the same provider.

1. Submit a CoBHRM discharge from the current location.
2. Submit a new CoBHRM admission under the new location.

Transferring to a different provider.

Clients leaving one provider and being admitted at another provider.

1. Submit a CoBHRM discharge.
2. The new provider will submit an admission under their license based on the timing of the service types above.

Concurrent Services.

Concurrent Services with a Psychiatric Hospitalization. When a client with an open episode is admitted to a psychiatric hospital:

1. Submit a CoBHRM update record changing the service identifier to Psychiatric Hospitalization.
   1. Update the Legal Status to the appropriate type of hold, if applicable.
   2. Update diagnosis code(s) and/or any other data elements that have changed based on this event, if applicable.
2. When the client is discharged from the psychiatric hospital, submit a CoBHRM update record returning the service identifier to the previous service.
   1. Update the Legal Status again, if applicable.
   2. Update diagnosis code(s) and/or any other data elements that have changed based on this event, if applicable.
3. The CoBHRM admission and discharge for Psychiatric Hospitalization is due at the time of the events.

Concurrent Services with all other service identifiers (other than Psychiatric Hospitalization).

1. When clients have an open episode and are admitted into another program or service at the same provider in a modality other than a Psychiatric Hospitalization, submit a separate CoBHRM admission/discharge episode.
2. The CoBHRM admission and discharge records are due to BHA in accordance with the type of service identifier.

Updates.

Annual updates are no longer required.

However, the CoBHRM record must be updated when there is a change in the client’s level of care or other data element(s) collected on the CoBHRM. You will not need to submit a full new record. Just update the data element(s) on the open admission record.

If you need to make a change to any of the data elements on the discharge record, please contact BHA at [e-mail].

No activity.

When there has been no activity in the previous 90 days AND the clinician feels the client will not return or pursue further treatment at this provider, a discharge should be submitted to BHA by the last business day of the following month.

Which clients require a CoBHRM?

For the technical rules governing which records and fields are required for a given client, see Conditional Logic.

• Anyone receiving behavioral healthcare services at a BHA licensed provider, BHASO contracted provider, regardless of BHA license status or payer source.
• Anyone who uses or who has used drugs or alcohol and is in a substance use treatment, withdrawal management or DUI program, regardless of payer source for these services.
• Anyone court-ordered to attend a substance use treatment, withdrawal management or DUI education and/or therapy program, regardless of payer source.
• Anyone required by Child Welfare to be in a substance use treatment, withdrawal management or DUI education and/or therapy program regardless of payer source.
• Adolescents enrolled in Minors In Possession (MIP) Treatment Programs, regardless of payer source.

When a CoBHRM is not required.

• Spouses, friends or relatives of a substance user for whom a substance use problem has not been identified.
• Victims of domestic or physical violence or sexual abuse for whom a substance use problem has not been identified.
• Children under 18 years of age for whom a substance use problem has not been identified, even though the parents or legal guardian have substance use problems.

How do I complete a CoBHRM?

CoBHRM submissions for services contracted through Behavioral Health Administrative Service Organizations (BHASOs) should be submitted directly to BHASOs.

For non-BHASO services, providers can submit using BHA’s secure website: (https://adad.cdhs.state.co.us) for online data entry. If the provider is part of a BHASO network, please submit CoBHRM records to your BHASO in accordance with your BHASO contract.

For questions and/or to request access to TMS CoBHRM, email: [e-mail]

How do I sign up for CoBHRM training?

BHA is working to set up live training sessions and on-demand training videos. Check BHA’s Technology and data systems support page to stay up to date on information and register for trainings as they become available.