Colorado made a significant structural change on July 1, 2025: personal care, homemaker services, and related attendant supports moved from 1915(c) HCBS waiver programs into the Community First Choice state plan benefit. CFC is an entitlement — eligible members receive services without a waitlist. The EBD Waiver is not going away, but personal care is gradually transitioning out of it through June 2026 as waiver members reach their Continued Stay Review. For home care agencies, this changes the billing pathway, expands the eligible population, and eliminates the waiver slot constraint for personal care specifically.
Community First Choice (CFC) is Colorado's 1915(k) Medicaid State Plan benefit, implemented July 1, 2025. It is administered by the Colorado Department of Health Care Policy and Financing (HCPF). CFC covers personal care, homemaker services, health maintenance activities (skilled tasks like medication administration), personal emergency response systems, home-delivered meals, remote support technology, and community transition supports.
CFC is an entitlement. A member who meets institutional level of care requirements and is enrolled in Health First Colorado (Colorado's Medicaid program) receives CFC services without a waitlist or slot cap. This is a fundamental expansion of access compared to the prior waiver-only structure for personal care, which required waiver enrollment even though the EBD Waiver itself had no waitlist for most services.
Colorado is an FFS (fee-for-service) state for long-term care services — there are no MCOs managing HCBS services. Authorization comes from the Case Management Agency (CMA). Claims go to Colorado's Medicaid system (interChange) through HCPF's billing process.
Agencies provide personal care and homemaker services directly to CFC members. The Case Management Agency assesses the member's needs, develops the service plan, and authorizes services. The agency delivers services, caregivers use EVV to record visits, and the agency bills Colorado Medicaid through the interChange system.
A Class A or Class B Home Care Agency license from CDPHE is required for hands-on personal care services under CFC. Enrollment as a Colorado Medicaid provider is required before billing.
CFC also offers In-Home Support Services (IHSS) — a participant-directed model where members control who provides their care, including qualified family members. CDASS (Consumer Directed Attendant Support Services) is the self-direction model where members hire, train, and manage their own attendants with agency clinical oversight.
For home care agencies, participating as an IHSS agency means supporting participants in hiring and managing their own workers while the agency handles clinical oversight, compliance, and EVV. This creates a different revenue and staffing model than agency-directed care — both can coexist in a single agency's Colorado operations.
Transition year: July 2025 – June 2026. EBD Waiver members transition to CFC for personal care, homemaker, and related services at their scheduled Continued Stay Review (CSR). Until the CSR, those services remain under the waiver and are billed with waiver procedure codes. After the CSR, those services move to CFC and are billed with CFC codes. Providers must bill based on the current authorization — waiver billing for pre-CSR services, CFC billing after. Billing the wrong codes after transition will result in denials.
Services that remain in the EBD Waiver even after CFC transition include adult day health care, alternative care facility services, home accessibility modifications, life skills training, non-medical transportation, and wellness education. These waiver-only services continue under the EBD Waiver indefinitely for enrolled members. Personal care and homemaker are the services moving to CFC — not the full EBD Waiver service array.
From July 1, 2026, personal care and homemaker will no longer be available through the EBD Waiver at all — they will be CFC-only. New members seeking these services after July 2025 access them through CFC rather than requesting EBD enrollment.
| Service | Before CSR (EBD Waiver) | After CSR / New Members (CFC) |
|---|---|---|
| Personal Care | EBD Waiver procedure codes, waiver billing | CFC procedure codes, CFC billing |
| Homemaker | EBD Waiver | CFC |
| Health Maintenance Activities | EBD Waiver (where available) | CFC (newly available to more members) |
| Adult Day, Home Modifications | EBD Waiver | EBD Waiver (stays in waiver) |
The Case Management Agency is your entry point. CMAs handle functional assessments for both CFC and EBD Waiver. Members contact their local CMA to request an assessment. The CMA develops the service plan, authorizes services, and connects the member with enrolled providers. Building relationships with CMAs in your target counties is how referrals are generated in Colorado — the CMA is the care plan authority and authorization source.
License before enrollment: Obtain a CDPHE Class A or B Home Care Agency license before beginning Medicaid enrollment. The license is the prerequisite for enrolling as a Colorado Medicaid provider through the HCPF provider enrollment portal.
EVV: Colorado uses an open EVV model. Providers choose their own EVV system, which must integrate with Colorado's state EVV aggregator. Colorado's state EVV system is accessed through HCPF's EVV infrastructure. Required data elements per visit: service type, member identity, date, location, caregiver identity, start and end times. Colorado does not use HHAeXchange as a statewide system — verify current aggregator integration requirements with HCPF before onboarding an EVV vendor.
CFC launched July 1, 2025, and moved personal care, homemaker, and related attendant services from HCBS waiver programs to a Medicaid State Plan entitlement. Because it is a state plan benefit, there is no waitlist — eligible members receive services without a slot cap or interest list. For agencies, this expands the accessible client population and eliminates waiver enrollment as a prerequisite for personal care access. The billing pathway also changed — CFC services use CFC procedure codes, not EBD Waiver codes. EBD Waiver members transition to CFC for these services at their Continued Stay Review through June 2026.
No. Colorado's long-term care and HCBS programs are fee-for-service, administered by HCPF. There are no MCOs managing personal care or waiver services. Authorization comes from the Case Management Agency. Claims go directly to Colorado Medicaid through the interChange system. This is different from MLTSS states like Texas or Indiana where claims go to MCOs. Colorado's FFS structure means a simpler billing pathway — one payer, one claims system — but also means your referral relationships must be built with CMAs rather than MCO care coordinators.
Yes, through the IHSS and CDASS self-direction models. Under IHSS, a member can hire a qualified family member (including legally responsible persons like parents, in certain circumstances) as their attendant. CDASS provides similar flexibility with the member managing their own care budget and employment. Legally responsible persons — such as a parent providing care to an adult child — can be paid for services that go beyond typical parental responsibilities. CFC removed the prior CNA license requirement that had been a barrier for some family caregivers, expanding access. For agencies, this creates an opportunity to participate as the IHSS employer-of-record, handling compliance and EVV while the member directs their own care.
Colorado agencies managing CFC and EBD Waiver billing simultaneously — with different procedure codes, different authorization timelines, and CMA relationships across multiple counties — need clean operational infrastructure from the start. CareBravo delivers scheduling, EVV compliance, authorization tracking, and claims as completed work.