Colorado’s health care landscape is undergoing a significant transition as the Colorado Department of Health Care Policy and Financing (HCPF) rolls out a series of sweeping updates to its Medicaid programs, waiver systems, and long-term services and supports (LTSS). Designed to address budget adjustments, program sustainability, and regulatory alignment, the changes impact everything from paid family caregiving hours and home and community-based services to therapies, residential costs, and the waitlist for developmental disability supports.
As families, participants, and providers navigate these evolving regulations, state agencies and case management organizations are working to clarify how the adjustments will affect daily care. To help individuals understand the complex terminology surrounding these updates, resources such as acronym guides are available through community advocacy channels in both English and Spanish.
At the center of these changes are Program Approved Service Agencies (PASAs), which are residential providers and agencies authorized to deliver Medicaid-funded services, and HCPF, the state agency responsible for managing Health First Colorado (Medicaid), Child Health Plan Plus (CHP+), and other initiatives supporting low-income, aged, and disabled residents.
Case Management & Navigating System Changes
With numerous updates taking effect across multiple programs, participants frequently turn to their case managers for clarity. Case managers are equipped to provide individual explanations of how these systemic modifications directly impact participants and their loved ones. Whether addressing questions about specific waivers, service hours, or financial obligations, case managers serve as the primary bridge between state policy and participant implementation.
Questions often arise regarding the timing for enrollment in long-term support pathways. For instance, families frequently ask at what age developmental professionals recommend placing a child on the Developmental Disabilities (DD) Waiver waitlist. While there is no single recommended age given the diverse needs of each child, the earliest a child can be placed on the DD waiver waitlist is age 14. Families are strongly encouraged to consult with their case manager to determine the timing that best aligns with their child’s unique circumstances and long-term support goals.
Waiver programs across the state are also experiencing targeted adjustments. While the Supported Living Services (SLS) Waiver has no specific overarching program changes, participants should note that specific services previously housed under SLS—specifically Personal Care, Homemaker, and Health Maintenance Activities (HMA)—have transitioned to Community First Choice (CFC). Consequently, these services are now subject to CFC soft-cap limitations. Similarly, the Children’s Extensive Support (CES) Waiver has seen adjustments specifically impacting Community Connector services, including revised unit limits and age-appropriateness criteria. Despite these shifts, children’s waivers and dedicated support services for children remain fully available.
Broader healthcare budgeting is also intersecting with these administrative updates. As of April 16, 2026, the state budget has impacted occupational therapy through a rate reduction alongside other Medicaid services. Pediatric Behavioral Therapy (PBT) and associated providers are similarly navigating shifts tied to additional across-the-board budget reductions. In the realm of specialized care, equine-related services are being removed from Home and Community Based Services (HCBS), though hippotherapy currently remains part of the Medicaid State Plan through Health First Colorado, with further details outlined in official HCPF guidance fact sheets.
Community First Choice (CFC) Services and Soft Caps
The integration of Community First Choice (CFC) services represents a major structural shift for participants receiving personal care supports. CFC encompasses essential services such as Personal Care, Homemaker, and Health Maintenance Activities (HMA). Although these services operate outside of individual waivers, they are available across multiple waiver types.
To manage resource allocation, the state has instituted annual and weekly limits for CFC services governed by a "soft cap." In this context, a soft cap refers to a defined annual limit on service utilization. If additional hours are deemed medically necessary for a participant, their case manager is authorized to request an exception by following established state administrative procedures.
Caregiver Hours & Family Caregiving Policies
Some of the most closely watched updates involve paid family caregiving and attendant support structures. The state is implementing a phased cap on paid weekly hours per caregiver to standardize service delivery. Under the new schedule, the maximum allowable paid hours per caregiver per member will shift over time: up to 84 hours per week per member beginning July 1, 2026; up to 70 hours per week per member starting January 1, 2027; and up to 56 hours per week per member effective July 1, 2027.
Regarding potential exceptions to these caregiver hour caps, operational guidance from the state is still forthcoming. Once the state releases further information on exception protocols, case managers will disseminate the details to impacted families.
Family caregiving rules also dictate specific limits for specific roles. Legally Responsible Persons (LRPs), such as parents of a minor or the spouse of a participant, are authorized to provide a maximum of 5 hours per week of homemaker services per member. If a member has two LRPs providing services, each may provide 5 hours weekly, totaling 10 hours per week per member. Other family members who are not LRPs may also provide homemaker services through alternative service delivery models, such as Consumer Directed Attendant Support Services (CDASS). Furthermore, an adult sibling may provide homemaker services provided they meet all underlying program and eligibility requirements.
A strict operational boundary applies to dual roles within In-Home Support Services (IHSS) and CDASS. An individual serving as an Authorized Representative (AR) for a member cannot simultaneously serve as a paid attendant or family caregiver for that same member. Those who receive conflicting information are advised to verify program-specific compliance rules directly with their case manager.
When care needs exceed what a single caregiver can provide under the new caps, case managers can assist by discussing alternative caregiver arrangements and exploring options within program rules. This assistance may include supplying lists of eligible provider agencies or completing a Request for Proposal (RFP). An RFP includes an individual profile outlining required services and is shared with eligible provider agencies to gauge availability. Families can also browse and connect with local providers by creating an account on the Wayfinder platform. Crucially, case managers are authorizing service hours based on current guidelines and rules in effect as of April 1, 2026, rather than historical approval totals.
Income, Benefits, and Cost Participation
Financial eligibility and cost-sharing policies continue to intersect with Medicaid rules, particularly concerning disability benefits and care payments. Both Social Security Disability Insurance (SSDI) and earned income are counted as monthly income. However, questions regarding whether "Difficulty of Care" payments count as wages for SSDI purposes depend heavily on individual circumstances. Participants and caregivers are advised to review state guidelines and consult their fiscal management service or provider agency, referencing official HCPF informational memos on Difficulty of Care and Community First Choice.
Residential cost-sharing through the Participant Engagement and Trust Income (PETI) system is also subject to specific administrative rules. PETI payments are directed to the provider agency rather than the Case Management Agency, and requirements vary based on the specific waiver and living arrangement. To determine the exact portion of a participant’s monthly income required to pay for residential services, HCPF is developing a DD waiver PETI assessment tool for case managers.
If a Program Approved Service Agency (PASA) is unable to collect PETI payments, decisions regarding service continuity rest with the provider agency, which must adhere to strict regulatory requirements regarding proper notice before terminating services for any reason. Individuals enrolled in the Medicaid Buy-In Program are exempt from PETI requirements. While questions regarding zero-premium categories and overall enrollment definitions are guided by HCPF documentation, the finalized DD waiver PETI assessment tool will be published directly to the HCPF provider rates and fee schedule webpage once completed.
Community Connector Services, Residential Settings, and Travel
Community Connector services are experiencing renewed oversight regarding approved activities and utilization limits. Activities must satisfy specific inclusion and setting requirements and remain age-appropriate, with case managers available to verify qualifying criteria. Adjustments to Community Connector hours are being instituted by HCPF to ensure service availability across the broader community, though an exception process remains available for participants whose community engagement needs exceed standard limits.
In the realm of residential support, host home funding reductions have not been integrated into current sustainability changes. A previously proposed budget adjustment affecting specific Individual Residential Services and Supports (IRSS) settings has been temporarily paused. Nevertheless, Host Home Providers (HHPs) remain subject to any broad rate reductions that may impact the wider state budget.
Regarding travel and administrative maintenance, family caregivers and participants planning out-of-state travel must confirm arrangements with both their case manager and service provider to ensure that core waiver requirements, including mandates for in-person service delivery, continue to be met. Participants must also complete an annual Level of Care Certification to maintain their Long-Term Services and Supports (LTSS) benefits. Individuals who receive notices from Medicaid are advised to contact the office listed on the notification immediately and follow up with their case manager.
For those navigating unmet needs, there is no strict limit on the number of unmet needs requests that can be submitted annually, though funding thresholds apply depending on the specific service and program. Case managers handle the submission of these requests and provide guidance if a participant approaches service thresholds. Community advocacy groups and resource lists published through state policy pulse updates offer additional avenues for engagement. Participants with individualized questions are encouraged to start with their case manager, who can provide direct support or connect them with the appropriate state resources and provider agencies.
