Colorado therapy practice guide: PT, OT and SLP

For OT, PT and SLP clinics in Colorado: a board and two offices license the disciplines, the licensing law sets no referral requirement before a patient starts physical therapy, Health First Colorado covers children’s therapy under EPSDT and adults within its own rules, and telehealth follows the patient’s location. Every rule here is quoted from its source.⁠^1,2,3

Who licenses OTs, PTs and SLPs in Colorado?

A board and two offices license the three disciplines in Colorado, and each publishes its own licensing law, rules, renewal cycle and continuing-education requirement.⁠^1,4,5 A clinic that employs more than one discipline keeps three registers, not one.

Physical therapists and physical therapist assistants answer to the Colorado State Physical Therapy Board.⁠^1,21,22,23 Occupational therapists and occupational therapy assistants answer to the Colorado Office of Occupational Therapy.⁠^4,24,25,26 Speech-language pathologists answer to the Colorado Office of Speech-Language Pathology Certification, which certifies them rather than licensing them.⁠^5,27,28,29 A license is a state authorization; a national certification (NBCOT for occupational therapy, the ASHA certificate for speech-language pathology, the NPTE for physical therapy) is a different thing and does not replace it. Compact privileges for practitioners licensed elsewhere are covered under telehealth below.

What does a Colorado license renewal require?

Each regulator sets its own cycle and hours, listed in the table above, and the register template at the end of this page tracks them per clinician.⁠^1,4,5 A renewal missed is a lapse, and the regulator’s own rules say what a lapsed licensee may and may not do; the clinic reads those rules before a clinician’s renewal date passes, not after.

Can a patient see a Colorado PT, OT or SLP without a referral?

State law answers this discipline by discipline, and a payer may still require a referral the law does not. For physical therapy, the Physical Therapy Practice Act requires a license to practice physical therapy and lets a physical therapist make a physical therapy diagnosis within the scope of practice, and it carries no provision that conditions an evaluation or treatment on a physician’s referral; Health First Colorado, as a payer, requires a written order, referral or prescription for the physical and occupational therapy it covers.⁠^2,6 For occupational therapy, the Occupational Therapy Practice Act defines the practice and requires a license to practice it, and carries no provision that conditions an evaluation or treatment on a physician’s referral; Health First Colorado, as a payer, requires a written order, referral or prescription for the occupational therapy it covers.⁠^30,31 For speech-language pathology, the Speech-language Pathology Practice Act defines the practice and requires a state certification (or a Department of Education special services license) to practice it, and carries no provision that conditions an evaluation or treatment on a physician’s referral; Health First Colorado requires a written order, referral or prescription for the outpatient speech therapy it covers.⁠^32,33

The payer’s rule is separate. Medicare pays for outpatient therapy under a plan of care certified by a physician or nonphysician practitioner, and the regulation’s 2025 text lets a signed order or referral on file, with the plan delivered within 30 days of the initial evaluation, stand in for that signature on an initial plan.⁠¹⁵ Health First Colorado’s referral and prior-authorization rules are in the next section. A commercial plan’s rule is in its member contract and provider manual, and the clinic keeps a copy of each.

How does Health First Colorado pay for pediatric and adult therapy?

Health First Colorado is Colorado’s Medicaid program, run by the Department of Health Care Policy and Financing, and a clinic enrolls through its provider enrollment route before it bills.⁠³⁴ For children, the federal EPSDT benefit requires the state to cover services that correct or ameliorate a condition found at a screening, whether or not the state plan covers them for adults.⁠³⁵ Under the EPSDT benefit, every good and service described in Section 1905(a) of the Social Security Act is covered for a child when medically necessary, whether or not the state plan covers it, and medical necessity includes helping the child achieve or maintain maximum functional capacity in one or more activities of daily living.⁠³

Every enrolled member, adult or child, is covered for both rehabilitative and habilitative occupational and physical therapy within a shared soft limit of 48 units per rolling 12 months. Members 21 and over may receive rehabilitative speech therapy, and since July 1, 2025 habilitative speech therapy as well when medically necessary.⁠^7,8 Occupational and physical therapy share 48 units per rolling 12-month period, evaluations and orthotics excluded, before a Prior Authorization Request is required, and units past 48 are not covered without an approved request. Outpatient speech therapy allows 12 sessions in each rolling calendar year before one is required.⁠^36,37 Health First Colorado runs mainly through the Accountable Care Collaborative, whose Regional Accountable Entities administer the capitated behavioral health benefit and coordinate care, while two physical health managed care organizations serve certain areas. The outpatient therapy page says a therapist needs to join a managed care network only to treat members in the Denver Health or Rocky Mountain Health Plan networks.⁠^38,39 The fee schedule is published by the agency, and a clinic reads the current file rather than a remembered rate.⁠⁴⁰

How does Health First Colorado want OT, PT and SLP claims coded?

Health First Colorado’s therapy manuals bill CPT codes with a discipline modifier and a benefit modifier on both the Prior Authorization Request and the claim: GP for physical therapy, GO for occupational therapy and GN for speech therapy, each followed by 97 for rehabilitative or 96 for habilitative therapy, with TL in place of the benefit modifier for Early Intervention services ordered by an IFSP. A member may receive up to five units of physical therapy and five of occupational therapy a day, and physical and occupational therapy assistants cannot enroll, so their services are billed under the supervising therapist’s NPI.⁠^41,42,43,44 The codes, modifiers and authorization forms are the manual’s and change with it, so the clinic reads the current therapy sections before its first claim and records the manual’s page-updated date in the payer register.

Does Health First Colorado pay for therapy in schools?

The School Health Services Program lets school districts and Boards of Cooperative Education Services draw federal Health First Colorado funds for allowable school health services delivered to enrolled children, and requires districts to spend that reimbursement on additional and expanded health services.⁠⁴⁵ A school’s billing is the district’s, under its own program; an outpatient clinic’s claim for the same child is a separate matter with its own eligibility and authorization.

Does Health First Colorado cover therapy by telehealth?

Physical and occupational therapists may deliver Health First Colorado services by telemedicine. Outpatient physical, occupational and speech therapy need a live audio and video connection with the member, and the telemedicine rate is at least the program’s rate for a comparable in-person service.⁠⁴⁶ The telehealth section below covers the state’s own rules for the session itself.

What are Colorado’s telehealth rules for therapy?

A therapist treating a patient by video needs authority to practice where the patient is located at the time of the session, and the federal telehealth site says so plainly: licensure follows the patient’s location, and a compact privilege is one route to it.⁠⁹ The State Physical Therapy Board’s telehealth guidelines say the practice of physical therapy occurs where the patient is located, so a provider must hold a Colorado license to evaluate or treat a patient located in Colorado by telehealth, and that appropriate informed consent should be obtained for a telehealth encounter. The guidelines set no standard of care of their own.⁠^47,48

A compact privilege is not a national license: it is a privilege to practice in the specific member state that issued it, under that state’s licensing law, and a state that has enacted the compact may not yet be issuing privileges, which is why the table names the commission’s current status.⁠¹⁰ Section 10-16-123 bars a health benefit plan issued, amended or renewed in Colorado from requiring in-person contact for services appropriately provided through telehealth, and requires the carrier to reimburse a participating provider for care delivered through telehealth on the same basis as the same service delivered in person.⁠⁴⁹

Which business steps are specific to Colorado?

The entity is registered with the Colorado Secretary of State, and the choice of entity is shaped by the state’s rule on who may own a therapy business.⁠¹⁸ Physical therapists may practice through a professional service corporation, a limited liability company or a registered limited liability partnership under section 12-285-131, organized solely to practice physical therapy through Colorado-licensed physical therapists, with a name containing "professional company" or "professional corporation" and, except as that section allows, only licensed physical therapists as shareholders or members. The occupational therapy and speech-language pathology acts carry no comparable entity provision.⁠¹⁹ State tax registration is with the Department of Revenue, for wage withholding as an employer.⁠⁵⁰ Colorado does not generally tax services, so therapy itself is not taxed, though a charge for an otherwise nontaxable service can fall into the taxable price when it is part of a sale of goods, and a clinic required to collect sales tax on goods it sells to patients must obtain and keep a Colorado sales tax license and file returns.⁠⁵¹ Every Colorado employer with one or more employees, whether part-time, full-time or family members, must carry workers’ compensation insurance, from a commercial carrier or by qualifying to self-insure.⁠⁵² A city or county business license is a local question, answered by the city hall of the clinic’s address. The startup-costs guide carries the budget worksheet these registrations go into.

What record and privacy rules apply in Colorado?

Each Colorado licensing law requires a written plan for the storage, disposal and post-closure disposition of patient records, and Health First Colorado requires its enrolled providers to keep records for seven years, the figure a clinic that serves Medicaid members writes into its policy.⁠^16,17 Two federal periods sit beside it and are often confused with it: Medicare requires 7 years for documentation of orders, certifications, referrals and payment requests, and HIPAA requires 6 years for its own compliance documentation, and neither sets the retention period for the clinical chart.⁠^53,54

Section 25-1-802 requires every patient record held by an occupational therapist or physical therapist licensed under Title 12 to be available to the patient or the patient’s personal representative on a valid signed authorization, and a copy on request and payment of the fee HIPAA allows.⁠⁵⁵ Section 6-1-716 requires a covered entity that maintains, owns or licenses computerized personal information about a Colorado resident to investigate a possible breach promptly and to notify affected residents no later than 30 days after determining that a breach occurred.⁠⁵⁶ Section 19-3-304 requires every person it lists who has reasonable cause to know or suspect child abuse or neglect to report it immediately to the county department, local law enforcement or the child abuse reporting hotline. The list names physical therapists and any public or private school official or employee, but not occupational therapists or speech-language pathologists by title.⁠⁵⁷

Which Colorado rules shape a pediatric clinic?

Early Intervention Colorado provides developmental supports and services to families of children from birth through 2 years of age who have developmental needs, delivered by local agencies, often Community Centered Boards. A doctor, family member, neighbor or child care worker may contact the local program on a family’s behalf, a family may contact it directly, and the program line is 1-888-777-4041.⁠²⁰ A child who turns three moves from early intervention to the school district’s evaluation, and a private clinic’s services run beside both systems rather than inside them. Section 10-16-104(1.4) requires every health benefit plan issued or renewed in Colorado to cover the assessment, diagnosis and treatment of autism spectrum disorders for a child, with treatment including habilitative or rehabilitative occupational, physical and speech therapy as medically necessary, prescribed or ordered by a licensed physician or psychologist. Its dollar limits, deductibles and coinsurance may be no less favorable than those for physical illness generally. Section 10-16-104(1.7) separately requires every individual and group health benefit plan to cover medically necessary physical, occupational and speech therapy for congenital defects and birth abnormalities from a covered child’s third birthday to the sixth, at the greater of the plan’s visits or 20 visits a year for each therapy.⁠^58,59 The autism insurance mandates guide covers how such a mandate meets a plan’s own terms.

Which Colorado rules shape an adult clinic?

Medicare claims from Colorado go to Novitas Solutions, Inc., the Medicare Administrative Contractor for Jurisdiction H, Parts A and B (Arkansas, Colorado, Louisiana, Mississippi, New Mexico, Oklahoma and Texas), whose local coverage articles for therapy are the ones a Colorado clinic reads.⁠⁶⁰ Health First Colorado’s adult therapy rules are in the Medicaid section above. The Division of Workers’ Compensation’s Medical Fee Schedule, Rule 18, sets maximum fees for services on or after January 1, 2026 and requires physical therapy to be billed with the GP modifier, occupational therapy with GO and speech-language pathology with GN, adding CQ or CO when a physical or occupational therapist assistant provides the service in whole or in part.⁠⁶¹

Which associations and directory pages serve Colorado?

The state chapters are APTA Colorado for physical therapy, the Occupational Therapy Association of Colorado for occupational therapy and the Colorado Speech-Language-Hearing Association for speech-language pathology.⁠^62,63,64 On DrSensory, families browse Colorado clinics by discipline on the occupational therapy, physical therapy and speech therapy pages for the state, which the directory builds from the clinic addresses it holds; a clinic appears on the pages of its own address.⁠⁶⁵

Which Colorado cities have DrSensory city pages?

Beyond its three Colorado pages, the directory publishes city pages for 6 Colorado cities, 16 pages across the three disciplines, each listing the clinics whose address is in that city; a clinic appears on the city page of its address without any action of its own, and a city or discipline without a page is reached through the state page.⁠⁶⁵

How many Colorado PT, OT and SLP clinics does DrSensory list?

DrSensory lists 142 PT, OT and SLP clinics in Colorado, on its occupational therapy, physical therapy and speech therapy pages for the state.⁠⁶⁵

Where does each requirement come from, and what does the clinic do?

Which templates does a Colorado launch need?

How might two Colorado clinics plan a launch?

Sources

1. Colorado. Colorado State Physical Therapy Board. Checked October 29, 2026.
2. Colorado Division of Professions and Occupations. Physical Therapy Practice Act, Colorado Revised Statutes 2026, sections 12-285-108 and 12-285-109. Checked October 29, 2026.
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   “(2) Nothing in this section prevents a physical therapist from making a physical therapy diagnosis within the physical therapist’s scope of practice. ... Except as otherwise provided by this article 285, any person who practices physical therapy or who represents himself or herself as being able to practice physical therapy in this state must possess a valid license under this article 285.”
3. Colorado Department of Health Care Policy and Financing. Physical and Occupational Therapy Billing Manual (revisions log through July 20, 2026). Checked October 29, 2026.
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   “All goods and services described in Section 1905(a) of the Social Security Act are a covered benefit under EPSDT when medically necessary as defined at 10 C.C.R. 2505-10, Section 8.076.1.8, regardless of whether such goods and services are covered under the Colorado Medicaid State Plan. For the purposes of EPSDT, medical necessity includes a good or service that will, or is reasonably expected to, assist the client to achieve or maintain maximum functional capacity in performing one (1) or more Activities of Daily Living; and it must meet the criteria set forth at Section 8.076.1.8.b - g.”
4. Colorado. Colorado Office of Occupational Therapy. Checked October 29, 2026.
5. Colorado. Colorado Office of Speech-Language Pathology Certification. Checked October 29, 2026.
6. Colorado Department of Health Care Policy and Financing. Physical and Occupational Therapy Billing Manual (revisions log through July 20, 2026). Checked October 29, 2026.
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   “All PT/OT services must have a written order, referral or prescription by any of the following: Physician (M.D. or D.O.) ... Physician’s assistant ... Nurse practitioner ... An approved Individualized Family Service Plan (IFSP) for Early Intervention PT/OT ...”
7. Colorado Department of Health Care Policy and Financing. Outpatient PT/OT Benefits. Checked October 29, 2026.
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   “All enrolled members are eligible to receive these services. ... Is it still necessary to check an adult’s Benefit Plan to see if they are on the Alternative Benefit Plan (ABP) and would qualify for habilitative PT/OT? No. All members have both rehabilitative and habilitative PT/OT covered. These therapies are both subject to the soft-limit of 48 units of service per rolling 12 months, with an approved prior authorization required to exceed it.”
8. Colorado Department of Health Care Policy and Financing. Speech Therapy Billing Manual (revisions log through July 20, 2026). Checked October 29, 2026.
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   “Adult Policy All Health First Colorado members age 21 and over may receive Rehabilitative speech therapy to treat non-chronic conditions and acute illness and injury. ... Adult Policy All Health First Colorado members ages 21 and over are considered adults. Effective July 1, 2025, Health First Colorado covers adult habilitative speech therapy services for eligible adult members when medically necessary. These services are subject to the same PAR requirements as other speech therapy services.”
9. U.S. Department of Health and Human Services. Getting started with licensure (Telehealth.HHS.gov, last updated February 21, 2024). Checked October 26, 2026.
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   “Health professionals must meet the licensure requirements of the state where they are located and be licensed or legally permitted to practice in the state where the patient is located”. Its companion page, Licensing across state lines (last updated April 30, 2025): “The ability to deliver health care services across state lines varies based on state regulations”; “Prior to an appointment, providers should verify patient location and obtain consent”; “Compacts allow participating health care providers to practice in participating states”.
10. PT Compact Commission. PT Compact Map. “Member States (38): Alabama, Alaska, Arizona, Arkansas, Colorado... [38] Member States: Actively Issuing and Accepting Compact Privileges ...” Checked October 29, 2026.
11. Occupational Therapy Compact Commission. Before You Apply for an OT Compact Privilege. “State / Accepting OTC Applications? ... Colorado / Not Yet ...” Checked October 29, 2026.
12. Occupational Therapy Compact Commission. State Commissioners. “State / Appointed Commissioner / Appointment Date ... Colorado / Zen Mayhugh / Aug. 28, 2024 ...” Checked October 29, 2026.
13. Audiology and Speech-Language Pathology Interstate Compact Commission. Delegate Information. “Colorado / Agency / Appointment Pending / Colorado / Agency / Appointment Pending ...” Checked October 29, 2026.
14. Colorado Division of Professions and Occupations. Speech-Language Pathologists Practice Act, Colorado Revised Statutes 2026, section 12-305-115.5. “(2) With regard to the compact, the director has the following powers and duties: (a) To facilitate Colorado’s participation in the compact ...” Checked October 29, 2026.
15. Code of Federal Regulations. 42 CFR 424.24, Requirements for medical and other health services furnished by providers under Medicare Part B (eCFR, up to date as of October 22, 2026; paragraph (c), outpatient physical therapy, occupational therapy and speech-language pathology services). Checked October 26, 2026.
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    “The individual needs, or needed, physical therapy, occupational therapy, or speech-language pathology services.”; “The services were furnished while the individual was under the care of a physician, nurse practitioner, clinical nurse specialist, or physician assistant.”; “The initial certification must be obtained as soon as possible after the plan is established.”; “Recertification is required at least every 90 days.”; “When it is recertified, the plan or other documentation in the patient’s record must indicate the continuing need for physical therapy, occupational therapy or speech-language pathology services.”; “the therapist has documented evidence that the plan of treatment has been delivered to the physician, NP, PA, or CNS within 30 days of completion of the initial evaluation, the certification does not need to be signed by a physician, NP, CNS, or PA who has knowledge of the case.”; “No references to an order or referral in this subsection shall be construed to require an order or referral for outpatient physical therapy, occupational therapy, or speech-language pathology services.”.
16. Colorado Secretary of State, Code of Colorado Regulations. 10 CCR 2505-10 section 8.130.2, Maintenance of Records (effective October 1, 2026). “Records must be maintained for seven (7) years unless an additional retention period is required elsewhere in Section 8.000 et seq., or in an individual Provider participation agreement.” Checked October 29, 2026.
17. Colorado Division of Professions and Occupations. Physical Therapy Practice Act, Colorado Revised Statutes 2026, section 12-285-121 (sections 12-270-113 and 12-305-118 hold the parallel occupational therapy and speech-language pathology provisions). Checked October 29, 2026.
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    “(1) Each licensed physical therapist responsible for patient records shall develop a written plan to ensure the security of patient medical records. The plan must address at least the following: (a) The storage and proper disposal of patient medical records; (b) The disposition of patient medical records in the event the licensee dies, retires, or otherwise ceases to practice or provide physical therapy care to patients; and (c) The method by which patients may access or obtain their medical records promptly if any of the events described in subsection (1)(b) of this section occurs.”
18. Colorado Secretary of State. Business Organizations. Checked October 29, 2026.
19. Colorado Division of Professions and Occupations. Physical Therapy Practice Act, Colorado Revised Statutes 2026, section 12-285-131. Checked October 29, 2026.
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    “(1) Physical therapists may form professional service corporations for the practice of physical therapy under the "Colorado Business Corporation Act", articles 101 to 117 of title 7, if the corporations are organized and operated in accordance with this section. The articles of incorporation of the corporations must contain provisions complying with the following requirements: (a) The name of the corporation shall contain the words "professional company" or "professional corporation" or abbreviations thereof. (b) The corporation must be organized solely for the purposes of conducting the practice of physical therapy only through persons licensed by the board to practice physical therapy. ... (d) (I) Except as provided in subsection (1)(d)(II) of this section, all shareholders of the corporation must be persons licensed by the board to practice physical therapy and who at all times own their shares in their own right. ... (b) "Corporation" includes a limited liability company organized under the "Colorado Limited Liability Company Act", article 80 of title 7, and a limited liability partnership registered under section 7-60-144 or 7-64-1002.”
20. Colorado Department of Early Childhood. Early Intervention for Infants and Toddlers with Developmental Delays. Checked October 29, 2026.
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    “The Early Intervention Colorado program provides developmental supports and services to families with children birth through 2 years of age who have developmental needs. ... For program information and resources, Early Intervention Colorado or call 1-888-777-4041 ... Local agencies, often Community Centered Boards (CCBs), throughout Colorado are responsible for providing early intervention services in their local service area. Individuals such as a doctor, family member, neighbor, or child care worker may contact the local EI program on a family’s behalf. A family may also contact their local EI program on their own.”
21. Colorado Division of Professions and Occupations. Colorado Physical Therapy Applications and Forms. “All Physical Therapist and Physical Therapist Assistant licenses expire on October 31 of even-numbered years.” Checked October 29, 2026.
22. Colorado Division of Professions and Occupations. Colorado Physical Therapy CPC. Checked October 29, 2026.
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    “CPC requirements do not begin until after the first renewal of a Physical Therapist’s initial license or a Physical Therapist Assistant’s initial certification. ... For physical therapists, completing at least 30 PDA is required. A minimum of 20 of the 30 required hours must be in the Educational Coursework, Fellowships, or Residencies PDA category. For physical therapist assistants, completing at least 20 PDA is required. A minimum of 15 of the 20 required hours must be in the Educational Coursework, Fellowships, or Residencies PDA category. ... Physical Therapists must complete at least 30 PDA during each 2-year license period.”
23. Colorado Secretary of State, Code of Colorado Regulations. 4 CCR 732-1, Rules 1.4(A) and 1.5(A) and (B) (effective November 30, 2025). Checked October 29, 2026.
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    ““General supervision” means the physical therapist is not required to be on site for direction and supervision, but must be available at least by telecommunications. ... a. A physical therapist may supervise up to four individuals at one time who are not physical therapists to assist in the physical therapist’s clinical practice. This limit does not include student physical therapists and student physical therapist assistants supervised by a physical therapist for educational purposes. ... 3. Pursuant to the definitions provided in Rule 1.4(A), a physical therapist shall provide: a. General supervision to a physical therapist assistant. ... c. The physical therapist is responsible for the performance of all services performed by the physical therapist assistant.”
24. Colorado Division of Professions and Occupations. Colorado Occupational Therapy Applications and Forms. “All Occupational Therapist and Occupational Therapy Assistant licenses expire on December 31 of even-numbered years and must be renewed to continue practicing.” Checked October 29, 2026.
25. Colorado Division of Professions and Occupations. Colorado Occupational Therapy CPC. Checked October 29, 2026.
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    “You must complete at least 24 PDA during each 2-year license period. A licensee must complete the required 24 PDA through a minimum of two PDA categories (no more than 12 PDA will be credited in a single PDA category). PDA are equivalent to clock hours. One PDA is equivalent to one clock hour (60 minutes).”
26. Colorado Secretary of State, Code of Colorado Regulations. 3 CCR 715-1, Rule 1.8, Supervision of Licensed Occupational Therapy Assistants and Aides (effective October 30, 2025). Checked October 29, 2026.
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    “The occupational therapist is legally responsible for the performance of the licensed occupational therapy assistant(s) and aide(s) operating under the occupational therapist’s direction and supervision as authorized by section 12-270-104(12), C.R.S. ... C. An occupational therapist must exercise professional judgment when determining the number of personnel the occupational therapist can safely and effectively supervise to ensure that quality client care is provided at all times. ... E. Supervision of licensed occupational therapy assistants shall be accomplished to ensure that: 1. Licensed occupational therapy assistants do not initiate or alter a treatment program without prior evaluation by and approval of the supervising occupational therapist. 2. Licensed occupational therapy assistants obtain prior approval of the supervising occupational therapist before making adjustments to a specific treatment procedure.”
27. Colorado Division of Professions and Occupations. Colorado Speech-Language Pathology Applications and Forms. “All Speech-Language Pathologist certifications expire on November 30 of every year and must be renewed to continue practicing.” Checked October 29, 2026.
28. Colorado Division of Professions and Occupations. Colorado Speech-Language Pathologist CPC. Checked October 29, 2026.
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    “You must complete at least 10 PDA during each one-year certification period. ... A certificate holder must complete the required 10 PDA through a minimum of two PDA categories (no more than five PDA will be credited in any one category), OR all 10 PDA may be earned through the “Coursework” category.”
29. Colorado Division of Professions and Occupations. Speech-Language Pathologists Practice Act, Colorado Revised Statutes 2026, section 12-305-111.5. Checked October 29, 2026.
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    “(2) A speech-language pathology assistant shall practice speech-language pathology only under the direction and supervision of a speech-language pathologist. ... (4) A supervising speech-language pathologist shall determine the appropriate number of speech-language pathology assistants whose practice may be supervised, with a number for supervision of no more than three speech-language pathology assistants per speech-language pathologist. ... (5) Before a speech-language pathology assistant begins to provide independent support to a patient, the supervising speech-language pathologist shall initiate first contact with the patient and prepare a plan of care for the patient. After the establishment of the supervisory relationship, minimum ongoing supervision must include documentation of direct supervision provided by the supervisor for each patient at least every thirty to sixty days, depending on the frequency of the sessions and setting, and the supervisor shall review patient data. ... For medically fragile patients who are acutely ill and in an unstable health condition, the supervisor shall provide one hundred percent direct supervision of the speech-language pathology assistant, which may be through synchronous or live telesupervision.”
30. Colorado Division of Professions and Occupations. Occupational Therapy Practice Act, Colorado Revised Statutes 2026, sections 12-270-104 and 12-270-106. Checked October 29, 2026.
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    “"Occupational therapy" means the therapeutic use of occupations, including everyday life activities with individuals, groups, populations, or organizations, to support participation, performance, and function in roles and situations in home, school, workplace, community, and other settings. ... (1) Except as otherwise provided in this article 270, a person shall not practice occupational therapy or represent that the person may practice occupational therapy in this state without possessing a valid license issued by the director in accordance with this article 270 and rules adopted pursuant to this article 270.”
31. Colorado Department of Health Care Policy and Financing. Physical and Occupational Therapy Billing Manual (revisions log through July 20, 2026). Checked October 29, 2026.
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    “All PT/OT services must have a written order, referral or prescription by any of the following: Physician (M.D. or D.O.) ... Physician’s assistant ... Nurse practitioner ... An approved Individualized Family Service Plan (IFSP) for Early Intervention PT/OT ...”
32. Colorado Division of Professions and Occupations. Speech-Language Pathologists Practice Act, Colorado Revised Statutes 2026, sections 12-305-104 and 12-305-106. Checked October 29, 2026.
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    “(4) (a) "Speech-language pathology" means the application of principles, methods, and procedures related to the development, disorders, and effectiveness of human communication and related functions, which includes providing prevention, screening, consultation, assessment or evaluation, treatment, intervention, management, counseling, collaboration, and referral services for disorders of: ... (1) Except as otherwise provided in this article 305, on and after July 1, 2013, a person shall not practice speech-language pathology or represent or hold himself or herself out as being able to practice speech-language pathology in this state without possessing a valid certification issued by the director in accordance with this article 305 and any rules adopted under this article 305 or a special services license issued by the department of education pursuant to section 22-60.5-210.”
33. Colorado Department of Health Care Policy and Financing. Speech Therapy Billing Manual (revisions log through July 20, 2026). “All Outpatient Speech Therapy services must have a written order/prescription/referral by any of the following: Physician (M.D. or D.O.) ... Physician Assistant ... An approved Individualized Family Service Plan (IFSP) for Early Intervention Speech Therapy.” Checked October 29, 2026.
34. Colorado Department of Health Care Policy and Financing. Provider Enrollment. Checked October 29, 2026.
35. Medicaid.gov (Centers for Medicare & Medicaid Services). Early and Periodic Screening, Diagnostic, and Treatment (Medicaid benefit page). Checked October 26, 2026.
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    “The Early and Periodic Screening, Diagnostic and Treatment (EPSDT) benefit provides comprehensive and preventive health care services for children under age 21 who are enrolled in Medicaid.”; “It is the responsibility of states to determine medical necessity on a case-by-case basis.”.
36. Colorado Department of Health Care Policy and Financing. Physical and Occupational Therapy Billing Manual (revisions log through July 20, 2026). Checked October 29, 2026.
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    “Members may receive up to 48 units of any combination of PT/OT services per rolling 12-month period before a Prior Authorization Request (PAR) is required. Evaluation and orthotic services are not included in this limit. ... Units of service exceeding the initial 48 units are not covered without an approved PAR.”
37. Colorado Department of Health Care Policy and Financing. Speech Therapy Billing Manual (revisions log through July 20, 2026). Checked October 29, 2026.
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    “Effective December 1, 2023, 12 sessions of speech therapy in each rolling calendar year will be available to all members before a prior authorization request is required. One date of service is equivalent to one session, regardless of the number of units billed on one date of service.”
38. Colorado Department of Health Care Policy and Financing. Accountable Care Collaborative Phase III. Checked October 29, 2026.
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    “Created in 2011, the ACC is the primary delivery system for Health First Colorado. Regional Accountable Entities (RAEs) are responsible for promoting member health and well-being by administering the capitated behavioral health benefit, establishing and supporting networks of providers and coordinating medical and community-based services for members in their region. Two physical health managed care capitation plans, referred to as Managed Care Organizations (MCOs), deliver physical health care in certain areas of the state. New contracts with RAEs and MCOs, ACC Phase III, launched July 1, 2025.”
39. Colorado Department of Health Care Policy and Financing. Outpatient PT/OT Benefits. “Enrollment in Managed Care networks is only required if the member being treated is in the Denver Health or Rocky Mountain Health Plan networks.” Checked October 29, 2026.
40. Colorado Department of Health Care Policy and Financing. Provider Rates and Fee Schedule. Checked October 29, 2026.
41. Colorado Department of Health Care Policy and Financing. Physical and Occupational Therapy Billing Manual (revisions log through July 20, 2026). Checked October 29, 2026.
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    “When submitting Rehabilitative Therapy PARs and subsequent claims, CPT codes for PT services must have the GP modifier and the 97 modifier (e.g., 97110+GP+97). CPT codes for OT services must have the GO modifier and 97 modifier (e.g., 97110+GO+97). When submitting Habilitative Therapy PARs and subsequent claims, CPT codes for PT services must have the GP modifier and 96 modifier (e.g., 97110+GP+96). CPT codes for OT services must have the GO modifier and 96 modifier (e.g., 97110+GO+96). Early Intervention PARs and subsequent claims must have the GP or GO modifier plus the TL modifier (e.g., 97110+GP+TL).”
42. Colorado Department of Health Care Policy and Financing. Speech Therapy Billing Manual (revisions log through July 20, 2026). “Modifiers must be included on both the PAR and claim submission. When submitting a PAR for either rehabilitative or habilitative services, the procedure codes must include GN + 96/97 modifiers (e.g., 92507+GN+97).” Checked October 29, 2026.
43. Colorado Department of Health Care Policy and Financing. Physical and Occupational Therapy Billing Manual (revisions log through July 20, 2026). “A daily limit of five (5) units of physical therapy services and five (5) units of occupational therapy services is allowed, whether it is rehabilitative or habilitative. Some specific daily limits per procedure code apply.” Checked October 29, 2026.
44. Colorado Department of Health Care Policy and Financing. Physical and Occupational Therapy Billing Manual (revisions log through July 20, 2026). Checked October 29, 2026.
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    “PTAs cannot enroll with Health First Colorado and cannot place any identifying number on a claim form. Therefore, the supervising PT’s NPI number must be used as the rendering provider number on the claim form for services rendered by the assistant. ... OTAs cannot enroll with Health First Colorado and cannot place any identifying number on a claim form. Therefore, the supervising OT’s NPI number must be used as the rendering provider number on the claim form for services rendered by the assistant.”
45. Colorado Department of Health Care Policy and Financing. School Health Services Billing Manual. Checked October 29, 2026.
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    “The Colorado School Health Services (SHS) Program allows school districts and Boards of Cooperative Education Services (BOCES) to access federal Health First Colorado (Colorado’s Medicaid Program) funds for delivering Health First Colorado allowable school health services to Health First Colorado enrolled children. Reimbursement received by a district through the SHS Program shall be used by the district to provide additional and expanded health services.”
46. Colorado Department of Health Care Policy and Financing. Telemedicine and eConsult Billing Manual (revisions log through July 20, 2026). Checked October 29, 2026.
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    “The reimbursement rate for a telemedicine service shall, as a minimum, be set at the same rate as the medical assistance program rate for a comparable in-person service. ... Physical therapists, occupational therapists, hospice, home health providers and pediatric behavioral therapy providers are eligible to deliver telemedicine services. ... Outpatient Physical, Occupational, and Speech Therapy services must have an interactive audio/visual connection with the member to be provided via telemedicine.”
47. Colorado State Physical Therapy Board. Guidelines for the Appropriate Use of Telehealth Technologies in the Practice of Physical Therapy, Section III.A. Checked October 29, 2026.
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    “Providers who evaluate or treat through telehealth technologies are practicing physical therapy. The practice of physical therapy occurs where the patient is located at the time telehealth technologies are used. Therefore, a provider must be licensed to practice physical therapy in the state of Colorado in order to evaluate or treat patients located in Colorado utilizing telehealth technologies or otherwise.”
48. Colorado State Physical Therapy Board. Guidelines for the Appropriate Use of Telehealth Technologies in the Practice of Physical Therapy, Section III.C. “Appropriate informed consent should be obtained for a telehealth encounter including those elements required by law and generally accepted standards of practice.” Checked October 29, 2026.
49. Colorado General Assembly, Office of Legislative Legal Services. Colorado Revised Statutes 2024, Title 10, section 10-16-123. Checked October 29, 2026.
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    “(2) (a) A health benefit plan or dental plan that is issued, amended, or renewed in this state shall not require in-person contact between a provider and a covered person for services appropriately provided through telehealth, subject to all terms and conditions of the health benefit plan or dental plan. ... (b) (I) Subject to all terms and conditions of the health benefit plan or dental plan, a carrier shall reimburse the treating participating provider or the consulting participating provider for the diagnosis, consultation, or treatment of the covered person delivered through telehealth on the same basis that the carrier is responsible for reimbursing that provider for the provision of the same service through in-person consultation or contact by that provider.”
50. Colorado Department of Revenue. Withholding Tax. Checked October 29, 2026.
51. Colorado Department of Revenue. Sales Tax Guide. Checked October 29, 2026.
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    “Any retailer that is required to collect Colorado sales tax must obtain and maintain a Colorado sales tax license. They must also file returns and remit collected taxes at regular intervals, generally on a monthly basis. ... Colorado does not generally impose sales tax on services. However, sales tax is imposed specifically on telephone and telegraph services, as well as gas and electric service for commercial consumption. Additionally, charges for otherwise nontaxable services may be included in the taxable purchase price of a transaction involving the sale of tangible personal property.”
52. Colorado Department of Labor and Employment, Division of Workers’ Compensation. Employers. Checked October 29, 2026.
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    “Colorado employers are required to carry workers’ compensation insurance if they have one or more employees. This applies to all employers, regardless of whether the employees are part-time, full-time, or family members. ... You can get coverage from a commercial insurance carrier or companies that qualify by applying to become self-insured.”
53. Code of Federal Regulations. 42 CFR 424.516, Additional provider and supplier requirements for enrolling and maintaining active enrollment status in the Medicare program (eCFR, up to date as of October 22, 2026; paragraph (f), Maintaining and providing access to documentation). Checked October 26, 2026.
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    “A provider or a supplier that furnishes covered ordered, certified, referred, or prescribed Part A or B services, items or drugs is required to—”; “Maintain documentation (as described in paragraph (f)(1)(ii) of this section) for 7 years from the date of service; and”; “Upon the request of CMS or a Medicare contractor, to provide access to that documentation”; “The documentation includes written and electronic documents (including the NPI of the physician or, when permitted, other eligible professional who ordered, certified, referred, or prescribed the Part A or B service, item, or drug) relating to written orders, certifications, referrals, prescriptions, and requests for payments for Part A or B services, items or drugs.”.
54. Code of Federal Regulations. 45 CFR 164.316, Policies and procedures and documentation requirements (eCFR, up to date as of October 22, 2026; HIPAA Security Rule; paragraph (b)). Checked October 26, 2026.
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    “Maintain the policies and procedures implemented to comply with this subpart in written (which may be electronic) form; and”; “If an action, activity or assessment is required by this subpart to be documented, maintain a written (which may be electronic) record of the action, activity, or assessment.”; “Retain the documentation required by paragraph (b)(1) of this section for 6 years from the date of its creation or the date when it last was in effect, whichever is later.”.
55. Colorado General Assembly, Office of Legislative Legal Services. Colorado Revised Statutes 2024, Title 25, section 25-1-802. Checked October 29, 2026.
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    “(1) (a) Every patient record in the custody of a podiatrist, chiropractor, dentist, doctor of medicine, doctor of osteopathy, nurse, certified midwife, optometrist, occupational therapist, audiologist, acupuncturist, direct-entry midwife, or physical therapist required to be licensed under title 12 ... must be available to the patient or the patient’s personal representative upon submission of a valid authorization for inspection of records, dated and signed by the patient, at reasonable times and upon reasonable notice. ... (b) (I) (A) A copy of the records, including radiographic studies, must be made available to the patient or the patient’s personal representative, upon request and payment of the fee a covered entity may impose in accordance with the "Health Insurance Portability and Accountability Act of 1996", Pub.L. 104-191, as amended ...”
56. Colorado General Assembly, Office of Legislative Legal Services. Colorado Revised Statutes 2024, Title 6, section 6-1-716. Checked October 29, 2026.
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    “(2) Disclosure of breach. (a) A covered entity that maintains, owns, or licenses computerized data that includes personal information about a resident of Colorado shall, when it becomes aware that a security breach may have occurred, conduct in good faith a prompt investigation to determine the likelihood that personal information has been or will be misused. ... Notice must be made in the most expedient time possible and without unreasonable delay, but not later than thirty days after the date of determination that a security breach occurred, consistent with the legitimate needs of law enforcement and consistent with any measures necessary to determine the scope of the breach and to restore the reasonable integrity of the computerized data system.”
57. Colorado General Assembly, Office of Legislative Legal Services. Colorado Revised Statutes 2024, Title 19, section 19-3-304. Checked October 29, 2026.
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    “(1) (a) Except as otherwise provided by section 19-3-307, section 25-1-122 (4)(d), C.R.S., and paragraph (b) of this subsection (1), any person specified in subsection (2) of this section who has reasonable cause to know or suspect that a child has been subjected to abuse or neglect or who has observed the child being subjected to circumstances or conditions that would reasonably result in abuse or neglect shall immediately upon receiving such information report or cause a report to be made of such fact to the county department, the local law enforcement agency, or through the child abuse reporting hotline system as set forth in section 26-5-111, C.R.S. ... (2) Persons required to report such abuse or neglect or circumstances or conditions include any: ... (l) Public or private school official or employee; ... (q) Physical therapist ...”
58. Colorado General Assembly, Office of Legislative Legal Services. Colorado Revised Statutes 2024, Title 10, section 10-16-104(1.4). Checked October 29, 2026.
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    “(C) Habilitative or rehabilitative care, including, but not limited to, occupational therapy, physical therapy, or speech therapy, or any combination of those therapies. ... (b) (I) All health benefit plans issued or renewed in this state must provide coverage for the assessment, diagnosis, and treatment of autism spectrum disorders for a child pursuant to this subsection (1.4). ... (c) Treatment for autism spectrum disorders shall be prescribed or ordered by a licensed physician or licensed psychologist. ... (e) Except as otherwise provided in paragraph (b) of this subsection (1.4), the coverage required under this subsection (1.4) shall not be subject to dollar limits, deductibles, or coinsurance provisions that are less favorable to an insured than the dollar limits, deductibles, or coinsurance provisions that apply to physical illness generally under the health benefit plan.”
59. Colorado General Assembly, Office of Legislative Legal Services. Colorado Revised Statutes 2024, Title 10, section 10-16-104(1.7). Checked October 29, 2026.
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    “(1.7) Therapies for congenital defects and birth abnormalities. (a) After the first thirty-one days of life, policy limitations and exclusions that are generally applicable under the policy may apply; except that all individual and group health benefit plans shall provide medically necessary physical, occupational, and speech therapy for the care and treatment of congenital defects and birth abnormalities for a covered child from the child’s third birthday to the child’s sixth birthday. (b) The level of benefits required in paragraph (a) of this subsection (1.7) shall be the greater of the number of such visits provided under the policy or plan or twenty therapy visits per year each for physical therapy, occupational therapy, and speech therapy.”
60. Centers for Medicare & Medicaid Services. Who are the MACs: A/B MAC Jurisdiction H (JH). “Contract Awardee: Novitas Solutions, Inc., contract number 75FCMC19C0018 ... JH processes FFS Medicare Part A and Part B claims for Arkansas, Colorado, Louisiana, Mississippi, New Mexico, Oklahoma, and Texas ...” Checked October 29, 2026.
61. Colorado Secretary of State, Code of Colorado Regulations. 7 CCR 1101-3, Rule 18, Medical Fee Schedule (effective January 1, 2026). Checked October 29, 2026.
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    “Pursuant to § 8-42-101(3)(a)(I) and § 8-47-107, the Director promulgates this Medical Fee Schedule to review and establish maximum fees for healthcare services falling within the purview of the Workers’ Compensation Act of Colorado. This Rule applies to services rendered on or after January 1, 2026. ... (8) Speech-language therapy/pathology or any care rendered under a speech-language therapy/pathology plan of care shall be billed with a GN modifier. ... (i) Physical therapy or any care provided under a Physical Therapist’s plan of care shall be billed with a GP modifier. Occupational therapy or any care provided under an Occupational Therapist’s plan of care shall be billed with a GO modifier. (ii) Services provided in whole or in part by a Physical Therapist Assistant shall be billed with a CQ modifier. Services provided in whole or in part by an Occupational Therapist Assistant shall be billed with a CO modifier.”
62. APTA Colorado. APTA Colorado (the state association's site). Checked October 29, 2026.
63. the Occupational Therapy Association of Colorado. the Occupational Therapy Association of Colorado (the state association's site). Checked October 29, 2026.
64. the Colorado Speech-Language-Hearing Association. the Colorado Speech-Language-Hearing Association (the state association's site). Checked October 29, 2026.
65. DrSensory. Occupational therapy clinics in Colorado, with the physical therapy and speech therapy pages for the state (the directory's state pages, built from the addresses it holds). Checked October 29, 2026.
66. DrSensory. Clinic Directory Pricing. “Claiming your listing is free. The subscription is $349.99 a year or $29.99 a month for your first location, and $99.99 a year or $9.99 a month for each additional location, not per therapist.” Checked October 30, 2026.

Medical disclaimer. This page is for general educational purposes and does not constitute medical advice, diagnosis, or treatment. It is general guidance on running a therapy clinic in Colorado, not legal, compliance, billing or financial advice. Rules change; the clinic confirms each with its source before acting on it.