Landmark Legislative Year for the CO APCD

In 2010, legislators and other supporters signed the Colorado All Payer Claims Database (CO APCD) legislation to address the need for data to drive improvements in health care. When I started with CIVHC two years later, as the first test claims were coming in, our team knew the database would support understanding cost, health, and quality of care in Colorado for a variety of purposes and audiences, but we didn’t fully envision the impact it would end up having on informing and implementing health care policy.

Fast forward 10 years, and policymakers and change leaders now recognize the CO APCD as a valuable data source to help discuss and develop potential legislation. It began in 2019, with the passing of the Out of Network Surprise Billing and Investments in Primary Care bills which marked the first time the CO APCD was named in legislation as an ongoing source of information critical for implementation and evaluation. The most recent 2022 legislative session was another hallmark year and more than doubled the number of legislative bills using the CO APCD as a key analytic source.

Legislation the CO APCD is Supporting

  1. HB 22-1370 – Coverage Requirements for Health Care Products

What the bill does: This bill requires health insurance payers in Colorado to follow specific guidelines regarding prescription drug coverage, including requiring that all prescription drug rebates that payers receive be used to directly reduce health care costs for employers and consumers.

CO APCD role: Beginning in 2023, CIVHC is required to work with the Department of Health Care Policy and Financing (HCPF) to produce an annual public report that analyzes drug rebates, by payer, and prescription drug tier. This reporting will enhance drug rebate data currently available in CIVHC’s Affordability Dashboard.

  1. SB 22-068 – Provider Tool to View the CO APCD

What the bill does: Enables providers in Colorado to review health care payments as submitted by payers to the CO APCD.

CO APCD role: On an annual basis starting in January 2023, the bill requires CIVHC to produce an online tool enabling users to review allowed amounts (plan and patient paid amounts) submitted to the CO APCD by commercial health insurance payers, Medicare, and Medicaid. The data must include the three most recent years available and provide prices for Current Procedural Terminology (CPT) and Healthcare Common Procedure System (HCPCS) codes at the 25th, 50th, 60th, and 75th percentile. Further breakouts are required by specialty, inpatient, and outpatient services and by region (county and Division of Insurance (DOI) region).

  1. HB 22-1325 – Primary Care Alternative Payment Models

What the bill does: This bill builds upon the work of the Investments in Primary Care bill (HB 19-233), and requires the Division of Insurance (DOI) to work with HCPF, the Department of Personnel and Administration (DPA) and the Primary Care Payment Reform Collaborative to establish rules for commercial health payers to follow in establishing primary care alternative payment models (APMs). The DOI is also responsible for establishing APM-related quality measures for primary care, and an aligned approach to value-based payments for all payers.

CO APCD role: With establishment of HB 19-233 in 2019, CIVHC has been producing an annual report for the Primary Care Payment Reform Collaborative to use in their annual recommendations to the DOI. The data includes reporting total primary care spending as a percent of all medical spending, and the percent spending for primary care that is paid for through an APM. With the passage of the new HB 22-1325, CIVHC will be required to report additional quality metrics for primary care APM, which will be established by DOI.

  1. SB 22-040 – Actuarial Reviews Health Insurance Mandate Legislation

What the bill does: This bill enables an actuarial review for any new proposed legislation that may require a new benefit coverage or change current coverage requirements for health insurance benefits. On an annual basis, before November 1st, the DOI is required to contract with an actuarial firm to review up to six bills that will be introduced in the next legislative session. The actuarial report must include how the bill will impact several key areas including number of Coloradans impacted, effect on premiums and out-of-pocket costs, and potential health benefits.

CO APCD role: The bill lists the CO APCD as a potential data source for the actuarial reviews.

  1. HB 22-1278 – Behavioral Health Administration

What the bill does: This bill establishes a new Behavioral Health Administration (BHA) that will reside in the Colorado Department of Human Services (CDHS). The BHA is charged with creating a coordinated behavioral health system that effectively addresses the behavioral health needs of Coloradans. Specific BHA duties outlined in the bill include:

  • monitoring and tracking behavioral health provider performance,
  • creating a safety net system for those in high need,
  • establishing regional behavioral health administrative services organizations (BHASOs),
  • managing licensing of providers and create network standards,
  • developing an advisory council, and
  • establishing a Veteran suicide prevention pilot program in El Paso County.

CO APCD role: In November 2021, CDHS submitted a Plan for the Behavioral Health Administration Creation that identifies the CO APCD as a data source for HCPF to leverage to collect, report, and measure the behavioral health system in Colorado. In addition, the CO APCD is noted as a source for state agencies to use in data sharing specific to:

  • use of evidence-based practices,
  • access to care and quality,
  • program and financial reporting, and
  • program deliverables and requirements.

It’s been exciting to watch the growth in the use of the CO APCD over the past ten years, especially related to legislative discussions and implementation of bills aimed at improving aspects of health care affordability, access and outcomes for Coloradans. If you or your organization has potential legislation that could be informed by or supported with CO APCD data, please contact us at

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