Colorado Medicaid Changes in 2025: Badass Insights You Need to Know for the Road Ahead
Many have asked about potential impacts on Colorado Medicaid and waivers due to state budget issues and funding priorities. I don't have a crystal ball, however I can guarantee that change is inevitable, always! This article will inform you about three big changes happening in Colorado, and offers my Badass insights so you’ll be in-the-know.
ONE: Big Changes to Colorado First Choice
What is Community first choice (CFC)? The state website CFC page shares: Community First Choice (CFC), also known as 1915(k), is an optional Medicaid program that allows states to offer select home and community based attendant services and supports to eligible members on the State Plan, expanding these long-term care services to more Health First Colorado (Colorado's Medicaid Program) members.
Your Badass (that’s me!) is concerned with three things about the CFC roll out: 1) the approval process using the new tool; 2) whether services will be hard to get approved; and lastly, 3) whether workforce capacity can support the demand. As we know, change sends a tsunami of impacts and it always impacts the members adversely. But knowing about it is really important.
This change will move the three in-home support services (IHSS) from the Medicaid waivers over to the state plan (that is the reason they call CFC a 1915(k) waiver, a change approved by federal partners). This means a person won’t need to be on a Colorado Medicaid waiver to access these three IHSS services: personal care, homemaker and health maintenance services. A Medicaid member who is determined to be disabled by the state via ARG group will be able to get IHSS by contacting a home health agency. Please remember this important caveat: currently, Medicaid income earned by a live-in caregiver is only IRS Federal tax exempt eligible when the member is enrolled in a waiver.
There are several incentives for the state to implement Community First Choice. This is a final part of the 2008 Affordable Care Act (aka Obama care), believe it or not! The concept is that not everyone needs case management that one gets on a waiver. Also, the additional process of waiver enrollment takes time and slows down access to services. This often costs more, like being in a nursing home rather than living at home with in-home support.
And the last piece, follow the money: CFC implementation provides Colorado a 6 percentage point increase in Federal matching payments for CFC service expenditures. So they get 56% match for these services. Once implemented, Colorado will get a federal match of 56 cents for every 50-cent budget investment rather than the norm of a 50-cent match for other Medicaid services. So you can bet the state will be pushing this program!
People who have a Certified Nursing Aide (CNA) approved services can continue to be paid for service through the state plan that way. CNA nursing services are based on scope of practice with the nurse practice act and related assessment tools. This is a medical service and no direct changes are planned.
The Task Worksheet: CFC Direct Care Services Calculator will be the new tool for determining approved CNA service hours. There are several concerns regarding this tool that you should be aware of!
From the state: The new Community First Choice (CFC) Direct Care Services Calculator will be used as a tool to establish service needs for homemaker and personal care services within agency-based care settings, In-Home Support Services (IHSS), and Consumer-Directed Attendant Support Services (CDASS).
There is great and valid concern about the use of this new tool to determine the IHSS service needs. The two recent meetings about this in the Fall of 2024 have audio, agenda, and presentation HERE. Also, the overlap with the IHSS services may create confusion and gray areas that will need to be resolved.
The move of the three IHSS services to the state plan for billing has upside in that it isn’t being billed against the waiver service plan, so that frees up those who have service annual plan limits (SPALS) on their waivers. However because a waiver cannot duplicate a service, basic homemaker service will only be available under IHSS. There will be a lot of gray areas requiring clarification as these services tend to overlap.
My Badass recommendation: we must all stay vigilant and get involved in state CFC public meetings which are posted HERE. There will be major system disruption and likely loss of services, including income to families as the grey areas of overlap may reduce approved services depending on this new assessment tool. If you have CNA services, it might be wise to stick with those until the bumps are smoothed out.
TWO: Children’s Habilitation Residential Program (CHRP) Waiver Expansion
The Children’s Habilitation Residential Program (CHRP) waiver will expand and additionally cover youth members with Serious Emotional Disorders (SED), and those members will not be required to have an intellectual and or developmental disability. Why? This expansion is part of a lawsuit settlement which provides a path for youth with serious emotional disabilities to access Medicaid via a waiver.
My Badass prediction is there will be an explosion of enrollments under this new SED criteria. There are so many issues with the existing CHRP waiver, which were discussed at the November 5, 2024 HCPF meeting that the Badass requested, and the audio is under stakeholder meetings HERE.
A major part of this lawsuit settlement is the creation of a new Intensive Behavioral Health Services (IBHS). It will include intensive in-home and community-based mental health services. There are upcoming public meetings and past meeting information HERE.
My Badass recommendation: this is a positive development, but your input is critical, so attend upcoming meetings! The takeaway is that HCPF is inserting an entirely new population of youth into an existing IDD waiver that is chock full of issues already, and this was an easy ‘solution’ to resolve the lawsuit. It does offer some opportunity to improve CHRP, and develop more robust choices with wrap-around services from more PASAs due to higher enrollment. The new Intensive Behavioral Health Services (IBHS) development is also positive, but community input is important!
THREE: Two Children’s Waivers Combined into a New Waiver
The state is combining two of the children’s waivers (Children with Life Limiting Illness and Children's HCBS) into one waiver called the Children with Complex Health Needs (CwCHN) waiver. During 2025 and 2026, members will transition from C-HCBS to CwCHN at the time of their annual Continued Stay Review. Once all members are enrolled in the new CwCHN waiver, the prior waivers will be discontinued. This combination is linked to CFC because the IHSS will be in the state plan rather than in waiver service plans for C-HCBS members.
My Badass recommendation: If these waivers affect you, embrace this change, because this combination of waivers makes sense. The staggering of enrollment, along with annual service plan recertification, will likely spread out the impact on case management agencies so that they can provide better service.
Federal changes are currently unknown, but are also important, and I will be monitoring them. Join the NDC Community to get regular Badass policy updates on both state and federal Medicaid changes that could affect you!
If you’re currently exploring getting your disabled loved one on a Colorado Medicaid waiver, or you already have a waiver, consider a membership in our program, Roadmap for the Waiver Journey. It’ll help you apply for a waiver, or better utilize an existing waiver, and keep you updated as waiver rates and policy changes occur over the lifetime of your enrolled loved one.
You can learn more about waivers and how we can help by attending one of our upcoming Live Info Sessions, see more info below!
