So much info to process, the Badass is gonna break it down for you!

Even I was super overwhelmed with all the information coming down from HCPF. Hours of reading, linking and roller coaster of feelings .Since I am a recovering teacher, meaning I am always gonna be educating, this is my attempt to simplify and put all links to the source, HCPF, in one newsletter. Then the advocate in me offers you some ways to share your story and voice to make them see and them hear the impacted people!!!

Big Hat Tip to Family Voices Colorado for summary of much of the info below!

I added in a few more of the memos and for all of them, of course, some of my thoughts as well for a Badass spin from Maureen.

HCPF released five new department Memos on 1/15/2026 that explain important proposed changes to certain Medicaid in-home supports and waiver services. And they had issued two more memos in first days of January. Some changes are already in effect (like the updated service calculator used by case managers), and several bigger changes are scheduled to start April 1, 2026 (pending CMS approval).

Badass Reminder: The department did withdraw their proposed slashing of the Movement (aka music) Therapy item. This was a result of intense community reaction, so TAKE HEART! These are not yet implemented and we can keep showing up and speaking up.

But the state MUST FIND COST SAVINGS. So, if you want to maintain a service, help our State Legislators to find another place to reduce expenditures. Ideas? Get involved in sharing your story to our elected leaders!

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Updated direct care service calculator + “age-appropriate” standards OM Operational Memo HCPF 26-001 Age-Appropriate Task Standards 1/15/26

What:​
HCPF updated the tool (“Direct Care Services Calculator”) that case managers use to decide how many hours/units of Personal Care, Homemaker, and Health Maintenance Activities (HMA) a member can receive. For children, the calculator now more directly applies “age-appropriate” expectations, meaning services should only cover needs that go beyond what’s typical for a child of the same age, and if a family member is providing the care, it must meet the definition of extraordinary care. What families may notice: case managers may ask for more specific documentation, especially for HMA (skilled tasks), and homemaker and personal care for children under 6 is described as something HCPF expects to be very rare (but not totally prohibited!)
​

When: Effective as of December 22, 2025. Case Managers should be completing revisions as soon as they identify services authorized beyond age-appropriate task standards.

Exceptions Process:​
To exceed age-appropriate standards, a supervisor at the Case Management Agency must approve the exception and sign off on a written justification.

If any of these changes results in a reduction/denial, families should request and receive a Notice of Action from their case management agency explaining appeal rights.

Badass Reaction:

I cry ableism out loud on their “age-appropriate” expectations. Do read the full memo in button below. They do provide examples that qualify as extra ordinary. I do encourage all to present the facts of their situation in a detailed written format, take some data over a few days to share. DO involve supervisor. DO insist on a written reduction of services.

And don't sign any service plan until you feel informed and understand your rights and present your situation clearly!

IRSS Rate Alignment in the DD Waiver (HCPF OM 26-002) 1/15/26

What:​
If your family member receives Individual Residential Services and Supports (IRSS) in the DD Waiver, HCPF is clarifying which residential settings qualify for which IRSS billing rate. The big change: only “Staffed Homes” will bill the higher IRSS rate, while Host Homes, Family Homes, and other shared living settings will bill the lower IRSS rate. Families should talk with their provider agency and case manager to confirm which setting category applies to their living situation.

When:​
All service plans whose year starts April 1-Nov 1 will be revised at their annual renewal (CSR) and all service plans whose year starts Dec 1-March 1 will be revised at a quarterly meeting with the case manager sometime between April 1 and November 30.

Exceptions Process:
​No exceptions process is in place for this change.

Badass Reaction: First off, it is insulting to everyone to call this a "rate alignment". It is a cut. The good news is HCPF's linguistic gymnastics are not tricking people.

I am floored that the put this out on January 15 after the HCPF Medical Service Board declined to pass the emergency rule packet pertaining to this change. The arrogance of the department overstepping procedure is reflective of things we are seeing on our federal level. This behavior is dangerous and could be interpreted as the department staff making their own rules and violating legal requirements. They insist families follow rules but they make up their own?

Also to insinuate that host home providers or family caregivers are living it large for $5-9 an hour for the 24/7 care that they provide is insulting. Clearly they do not respect the backbone of HCBS residential providers.

The level of disregard is a red flag. Keep watching. Be involved. Go to meetings online or in person. Write emails. Do read the full memo in button below.

New annual “soft caps” for Personal Care, Homemaker, and Health Maintenance Activities (HCPF OM 26-003) 1/15/26

What:​
HCPF will apply annual unit limits (“soft caps”) for the below services.

• Personal Care: 10,000 units/year (approx 48 hours per week)
• Homemaker: 4,500 units/year (approx 21 hours per week)
• HMA: 19,000 units/year (approx 91 hours per week)

When: ​
All service plans whose year starts April 1-Nov 1 will be revised at their annual renewal (CSR) and all service plans whose year starts Dec 1-March 1 will be revised at a quarterly meeting with the case manager sometime between April 1 and November 30.

Exception Process:​
If a member’s assessed needs truly exceed these limits, the case manager can submit an exception request following the new form linked in the memo with supporting documentation.

If any of these changes results in a reduction/denial, families should receive a Notice of Action from their case management agency explaining appeal rights.

Badass Reaction: I call BS on soft caps. All this CFC calculator work load is dumped on low paid case managers at the case management agencies continues to destroy morale. Every supervisor will have inquires from hundreds of Medicaid members, when they have other workload as well.

The confusion and feeling that disabled people in Colorado are not wanted or appreciated is palpable. Remember when we are frustrated that this is a state and department systems level issue. The case managers and supervisors are not the enemy. I worry they will throw in their towels en masse, harming us even more.

Do read the full memo in button below. They do provide examples that qualify as extra ordinary. I do encourage all to present the facts of their situation in a detailed written format, take some data over a few days to share. DO involve supervisor. DO insist on a written reduction of services.

Focus energy on learning and presenting your case in an effective way to case manager and supervisor. "How can we together do this exceptions request well"?

And don't sign any service plan until you feel informed and understand your rights and present your situation clearly! Do use the exceptions process. Do ask for a notice of action and exercise your appeal rights. Do not give up.

New limit when Homemaker is provided by a legally responsible person (HCPF OM 26-004) 1/15/26

What:​
When Homemaker is provided by a legally responsible person (a parent of a minor child or a spouse of an adult), the paid homemaker limit will decrease:

• From 10 hours/week to 5 hours/week per member, per legally responsible person
• A member can have up to two legally responsible people paid, and each can provide up to 5 hours/week

Members may receive more homemaker hours, but hours above these caregiver caps would need to be provided by other, non legally responsible person, caregivers.

When: ​
All service plans whose year starts April 1-Nov 1 will be revised at their annual renewal (CSR) and all service plans whose year starts Dec 1-March 1 will be revised at a quarterly meeting with the case manager sometime between April 1 and November 30.

Exception Process:​
There are no exceptions to this limit and this change does not trigger a Notice of Action/appeal rights (because it’s a caregiver-payment limit, not an “authorized hours” limit).

Badass Reaction: Ummmm, a limit is a reduction of services. This is forced volunteerism as they know the homemaker pay is far too low to attract a non family or spouse for these services. The department knows that the workforce capacity for this service and how the hours work and thus the expenditure would be lower. And that somehow things will get done. Or if they don't, could impact health and welfare and cause other billable needs.

Cost savings can be found elsewhere. Home maker is a critical service that keeps one at home and out of expensive institutions.

Penny wise and pound foolish! I call this out! Now read the memo. And put your feelings into actions that can mitigate the cuts. How about we look at some belt tightening at HCPF? Seriously we cannot fairly balance the budget with HCBS cuts!

Community Connector changes in CES/CHRP waivers (HCPF OM 26-005) 1/15/26

What:​
HCPF is changing Community Connector in the CES and CHRP waivers:

• Rate decreases to $7.71 per 15-minute unit (outside Denver County) and $7.83 (Denver County)
• Minimum age requirement: 6 years old (school-aged)
• Annual unit limit cut in half: from 2,080 units (520 hours) to 1,040 units (260 hours) per plan year

When:

• Rate decrease - April 1, 2026 for everyone
• Age requirement - April 1, 2026 for everyone
• Annual unit limit change - All service plans whose year starts April 1-Nov 1 will be revised at their annual renewal (CSR) and all service plans whose year starts Dec 1-March 1 will be revised at a quarterly meeting with the case manager sometime between April 1 and November 30.

Exceptions Process:

• Rate change - no exceptions allowed
• Age requirement - no exceptions allowed
• Annual unit cap - If a member’s assessed needs truly exceed these limits, the case manager can submit an exception request following the new form linked in the memo with supporting documentation.

If any of these change results in a reduction/denial of authorized services, families should receive a Notice of Action from their case management agency explaining appeal rights.

Badass Reaction: Great job reducing the one rate that had a living wage in Colorado! Now our highest acuity members cannot attract highly skilled caregivers who can build critical skills for adult community living. This is a 15% rate reduction.

The thing that makes me wanna throw something is that their entire evaluation of the services that have grown is to cut them and cap them and limit them instead of with a leadership curiosity say "what is it about that service that is good, what need is it filling, how can we learn here".

Medicaid will pay for our loved ones' entire lifespan. Early investment in quality care reduces costs down the line.

Before COVID, my son could not get his needs met in school. So we create our own home and community based learning program for five years. Many of our kids are not supported in a school setting. The access to the community is critical.

For most of our non-school years, I used my entire CES service plan limit (about $50k back then) for community connector. It had no cap or limit. Our son learned skills from a masters level educator. She could not work for the proposed rate, substitute teaching would pay more. Now he is in high schoo, some semesters in general ed half the day! I know that would not have happened without years of skill building. And soon he will live in his own apartment with supports. This would not have happen without skill building that my son was able to access.

Penny wise, pound foolish and clearly punishing everyone for the MOST HELPFUL AND MEANINGFUL service in two of our three kids waivers.

I WANNA SCREAM!!

Now look at the action opportunities below to voice your stories and concerns in meetings and by emailing Joint Budget Committee members!!

POLICY MEMO Health Maintenance Activities (HMA) Documentation Requirements PM 26-001) HCPF 1/5/26

What is HMA?

​https://hcpf.colorado.gov/community-first-choice-option​

Routine and repetitive health-related tasks furnished to you in the community or in your home, which are necessary for health and normal bodily functioning that a person with a disability is unable to physically carry out. This service may include helping you with health care tasks related to care for the skin, nails, or mouth, dressing, feeding, toileting, exercise, transferring, medical management, or respiratory care.

​

In the transition to Community First Choice (CFC), the Colorado Department of Health

Care Policy & Financing (HCPF) has identified frequent gaps in required HMA

documentation. Missing or outdated documents limit a Case Manager’s ability to verify

skilled care needs and to authorize services appropriately within the Person-Centered

Support Plan (PCSP). To address these issues and support stakeholder compliance,

HCPF has developed a new HMA Member Checklist and updated the CFC HMA

Documentation Guide.

​

Members or their representatives must provide medical documentation to the Case

Manager in preparation for the LOC Screen.

Health Maintenance Activities (HMA) Documentation Requirements

​https://bit.ly/49qoPPK

Members and Case Managers are advised to use the

CFC HMA Documentation Guide https://drive.google.com/file/d/1aOgnz2QjqQIo5x2fZXxH4aQN7tQnL4ng/view?usp=sharingand

And HMA Documentation Checklist

​https://drive.google.com/file/d/19ZnC3IDo4G2Rv_tc-tAwGES4hKJ1RYy4/view​

If documentation to support HMA tasks fails to meet the standards necessary for determining or supporting HMA authorization, Case Managers shall complete a Long-Term Care Notice of Action (LTC NOA) for a denial or reduction in

services

How: This memo has clear language on this MEDICAL service. They want more doctor documentation so read this memo carefully.

Also review the links for the documentation requirements and checklist.

Print out and in collaboration (remember your case managers are swimming in this cesspool of confusion with us) ask your CM to walk through with you. Ideally you prepare all your info using these items before so you can share what you believe you need and have communicated with medical documentation.

Badass Reaction: What a mess. The Nurse Assessor program wasted millions of dollars (ARPA covid money I believe but do your research). The contractor separated from their. work on it after corrective action plans and such.

So now, who gets to determine services? A case manager who is not required to be a nurse or have specific medical training.

I want to cry or scream in rotation. Instead I am taking action and I hope you will too.

Read the memo, document the heck using the the links and items above.

Informational Memo Difficulty of Care and Community First Choice (HCPF IM 26-001) 1/7/2026

On December 12, 2025, HCPF received a favorable decision from the IRS on this

request. The IRS indicated that payments for select Direct Care CFC Services to Live-

in Caregivers can be considered DOC payments excludable from federal income tax

under § 131 of the Internal Revenue Code. The Private Letter Ruling grants the

following:

(1) Medicaid payments made under CFC to a Live-in Caregiver for extraordinary

care (i.e. care that is related to an individual’s disabilities) that are

provided by an individual, whether related or unrelated, who resides in the

same home as the Care Recipient will be treated as Difficulty of Care

payments excludable from the gross income of the provider under § 131 of

the Internal Revenue Code.

(2) Live-in Caregiver is not required under section 6041 or 6051 to report these

payments as wages subject to income tax.

(3) Live-in Caregiver may treat payments to providers as excludable payments

described in Notice 2014-7, such provider agencies or Financial Management

Services contractor

​

Live-in Caregiver means the person who may have certain income qualify as Difficulty

of Care payments for specific Community First Choice (CFC) services to a Care

Recipient.

SEE MEMO FOR FULL DETAILS
​

Badass Reaction: Nothing like them taking credit as a win when they failed to file the request for this IRS determination in advance like all the other states who implemented CFC. So they stressed so many people out waiting for this private letter. So, yea, good. But did it have to be this hard?

HCPF meetings reviewing it all 1/21 and 1/22

The Department of Health Care Policy and Financing (HCPF) will host two informational one-hour webinars to share updates on the Medicaid Sustainability Initiatives and their impact on providers. These sessions will be held on Wednesday, January 21, 2026 @ 11 am, and Thursday, January 22, 2026, at 2:30 pm. All Home and Community Based Services (HCBS) and Community First Choice (CFC) Medicaid providers are encouraged to attend one of the scheduled webinars.Topics Covered:

• Individual Residential Services and Supports (IRSS) Rate Alignment - (remember this info was out before the Medical Services Board Meeting)
• HCBS (CFC) Soft Caps
• Utilization of Task Standards and Age Appropriate Guidelines
• Health Maintenance Activities (HMA) Documentation Requirements
• Weekly Caregiver Hours Cap
• Weekly LRP Homemaker Cap
• Community Connector Age and Unit Limits

HCPF staff and subject matter experts will be available during each session to answer questions. In addition, a Google Form has been created for submitting feedback and questions. The Department will compile all responses to develop a Frequently Asked Questions (FAQ) document, which will be posted on the HCPF LTSS website.

Legislative Hearings- Listen/Testify in person or live or submit written comments
Wednesday, January 28, 2026

Yes, you can testify on anything related to HCPF at this once a year meeting. You also can learn a lot by tuning in and listening live or even the recording later (same link below)

It is a long commitment, JBC Joint Meeting with the House and Senate Health and Human Services CommitteesPursuant to Joint Rule 25 (d) & Title 2-7-203 (3) (b) 2025 C.R.S., and Pursuant to Title25.5-10-207.5 (2), 2025 C.R.S.

Upon Adjournment- this means when the legislators are done with their floor work in their chambers. This is hard to predict but to be safe, it could end as early as 9:45 since it is early in their session year.

Inside Capitol- room 271 off elevators, Old State Library.
​
This Joint Committee will Meet to Review the Status of Waiting Lists for Persons with Intellectual andDevelopmental Disabilities (inside Capitol- room 271 Old State Library)
​
Then move back to JBC Hearing rooms across street
JBC Meetings are held in the

JBC Hearing Room, 3rd Floor Legislative Service Building

200 East 14th Avenue Denver

​
Consideration of Agency Supplemental Request Comebacks for the Department ofHealth Care Policy and Financing, and Meet as Necessary to Finalize SupplementalRequests and Package Bills

​
1:30 – 5:00 Continuation of Upon Adjournment Agenda –

SEE JBC CALENDAR for FREQUENT REGULAR updates https://content.leg.colorado.gov/sites/default/files/JBC%20Schedule_40.pdf​
​
​Streaming link or to find recording https://sg001-harmony.sliq.net/00327/Harmony/en/View/UpcomingEvents/20251215/74​
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​Sign up to testify in person or remote or submit written comment HERE https://www.leg.state.co.us/clics/clics2025A/commsumm.nsf/NewSignIn.xsp​

JBC Hearing for the Department of Health Care Policy and Financing, continued from earlier in month, Tuesday Jan 20, participate live or remotely

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​Tuesday, January 20, 2026 from 2-5p

NOW is the PERFECT time to write an email to the JBC Members. Schedule it to arrive on Monday so it is in their inbox. To be most effective, do short bullet points or paragraphs and include a picture. Offer up your story and impact of these proposed cuts/caps/limits. Put some math and numbers in there to show how much of these are Penny wise and Pound foolish. Lastly, empathize with their impossible situation and GIVE IDEAS for other cuts (staff allocation reductions at executive branch departments (including HCPF which has grown since COVID). They have to have a way to save costs!

​
This hearing is a continuation from January 5 that ran out of time AND produced more questions from JBC committee members that need to be answered. You learn a LOT by listening or attending (I will be there in person, join me!!)

Here are the legislators emails to cut and paste:
​judy.amabile.senate@coleg.gov,kyle.brown.house@coleg.gov, jeff.bridges.senate@coleg.gov,rick.taggart.house@coleg.gov,barbara.kirkmeyer.senate@coleg.gov,emily.sirota.house@coleg.gov​

​

That 440 page meeting document includes presentation slide decks https://content.leg.colorado.gov/sites/default/files/FY2026-27_hcphrg.pdf​

​
Audio from that meeting Jan 5 available at https://sg001-harmony.sliq.net/00327/Harmony/en/View/Calendar/20260105/-1

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2:00 – 5:00pm Approximately Tuesday, January 20, 2026

Hearing for the Department of Health Care Policy and Financing

(Eric Kurtz, Emily Pope, Tom Dermody)

Legislative Services Building B

200 East 14th Avenue Denver

You can listen in here and listen to past meeting audio recordings

​https://sg001-harmony.sliq.net/00327/Harmony/en/View/Calendar/20260120/-1 ​

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Once the hearing starts, new related documents will appear here, newest show at the top. https://content.leg.colorado.gov/content/budget?title=&field_budget_doc_type_target_id%5B561%5D=561&field_budget_doc_type_target_id%5B571%5D=571&field_date_start=2025-11-01&field_date_end=2026-10-31​

What else can you do now to feel more empowered and informed?

• Badass Reaction: We are stronger together and can impact the decision makers. Join Today for Action steps!
• Breathe, plan, advocate, breathe again, plan some more, and keep breathing.
• Then take action. To learn more, JOIN THE FREE ONLINE COMMUNITY FOR ADVOCACY ACTION. Button below.
• Put key dates on your radar: Your annual waiver/CFC renewal date, April 1, 2026 (planned start date for several changes), and November 30, 2026 (deadline for all plans to reflect the new limits). Note these are in future and you do not have to accept changes in your service plan/access to units until then. Don't sign anything until you understand it and are not accepting reductions "voluntarily".
• At your next Monitoring/CSR meeting, ask your case manager to walk through together to ensure your needs are documented in the calculator accurately and thoroughly.
• Collect documentation from medical providers for all tasks you believe should be considered "skilled" following the HMA documentation guidelines.
• If your family will likely exceed a new limit, be informed of the process and work with your case manager to exercise your rights. If something does not seem right, don't agree or sign until you have done your due dilIgence.
• If your family relies only on a legally responsible person being paid for Homemaker, start planning now for how to cover homemaker needs beyond the new 5-hour/week limit.
• Watch for any Notice of Action letters (and request for it if not offered). Also quickly respond quickly to preserve your appeal rights!

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Learn about Roadmap Program Feb 4 @7p Free virtual info session

Wednesday February 4, 2026 at 7p

You can NO LONGER AFFORD to put off getting or learning more about how to maximize a Colorado Medicaid waiver!

Ready to take control of your disability journey?

Let Maureen and NDC be your guide. Come for a free info session to learn more.

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