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Case Management News

New Case Management Related Memos 

Find all memos on the Memo Series webpage.

PM 25-003- Sunsetting of Remote Assistance and Limited Authorized Representative Flexibilities

The purpose of this Policy Memo is to inform Eligibility Sites (county departments of

human/social service and Medical Assistance (MA) Sites, and Eligibility Application

Partners (EAP) of the sunsetting of flexibilities that were allowed by the Centers for

Medicare and Medicaid Services (CMS) during the COVID-19 Public Health Emergency

(PHE) and subsequent unwinding period.

OM 25-059 - Revised Nurse Assessor and Skilled Care Acuity Assessment Implementation

The purpose of this Operational Memo is to provide information and guidance to

members, Home Health Agencies (HHAs), Case Management Agencies (CMAs),

advocates and other interested stakeholders of the implementation of the Nurse

Assessor and Skilled Care Acuity Assessment beginning Aug. 1, 2025. The use of the

Nurse Assessor and Skilled Care Acuity Assessment will streamline how members are

assessed for skilled care services including Private Duty Nursing (PDN), Long-Term

Home Health (LTHH) (excluding LTHH Therapies), and Health Maintenance Activities

(HMA).

OM 25-058 - Nursing Facility Discharge Roles and Responsibilities

The purpose of this Operational Memo is to provide resources and guidance on the

steps that should be taken to ensure Members transitioning to the community from

institutional settings have access to Home and Community Based Services (HCBS) upon

discharge. The Memo also clarifies existing regulations and guidance regarding the

roles and responsibilities for Case Management Agencies (CMA), Institutional Settings,

Transition Coordination Agencies (TCA) and County Department of Human Services

(DHS) and Eligibility Sites when a Member is transitioning to the community.

OM 25-057 - Community First Choice (CFC) Program Implementation (This memo supersedes HCPF OM 25-026)

The purpose of this Operational Memo is to inform Health First Colorado (Medicaid)

applicants and Members, Home and Community-Based Services (HCBS) waiver

Members, Case Managers, Case Management Agencies (CMAs), and Providers about the

upcoming implementation of the new Colorado First Choice (CFC) program, effective

on July 1, 2025. This memo supersedes HCPF OM 25-026 to highlight updated guidance

around CFC enrollments for Case Managers and members, specifically for members

who experience a significant change in condition and/or who experience a denial for

Long-Term Home Health (LTHH) services.

OM 25-056 - 90-Day Reconsideration Period for Members Enrolled in Long-Term Services and Supports Receiving Long-Term Care or Buy-In Eligibility Terminations

This Operational Memo provides guidance to Case Management Agencies (CMAs) on

procedures and responsibilities for members enrolled in Health First Colorado LongTerm Care (LTC), Buy-In for Working Adults with Disabilities (WaWD), and Buy-In for

Children with Disabilities (CBwD) who are terminated after their 60-day extension but

reinstated during their 90-day reconsideration period.

OM 25-054 - Community Advisory Committee

The purpose of this Operational Memo is to provide Case Management Agencies (CMAs)

with an overview of the purpose and intent of the Community Advisory Committee

(CAC) as well as introduce the new CAC Meeting Minutes Template and corresponding

operational guidance.

IM 25-025 Community Connector Service Rate Change in CES & CHRP Waivers

The purpose of this Informational Memo is to inform Members, families, Case Management Agencies, and Provider Agencies of a rate reduction for the Community Connector service under the Children’s Extensive Supports (CES) waiver and the Children’s Habilitative Residential Program (CHRP) waivers. 

IM 25-023 - Case Management Agency Contact by DOJ Agreement Monitor

The purpose of this memo is to inform Case Management Agencies and Case Managers

that the Monitor for the state’s voluntary Department of Justice Settlement

Agreement may be reaching out for member specific information or interviews.

IM 25-022 - Public Notice for Fall 2025 1915(c) Waiver Amendments

The Colorado Department of Health Care Policy & Financing (HCPF) invites the public

to comment on proposed waiver amendments to nine (9) of Colorado’s Home and

Community-Based (HCBS) waivers:

• Brain Injury (BI)

• Elderly, Blind, and Disabled (EBD)

• Children with Complex Health Needs (CwCHN)

• Children’s Extensive Supports (CES)

• Developmental Disabilities (DD)

• Children’s Habilitation Residential Program (CHRP)

• Supported Living Services (SLS)

• Community Mental Health Supports (CMHS)

• Complementary and Integrative Health (CIH)

IM 25-020 - Organized Health Care Delivery System (OHCDS) Updates for Case Management

The purpose of this Informational Memo is to notify case managers, service providers,

members, families, and other interested stakeholders of existing requirements

pertaining to billing under the Organized Health Care Delivery System (OHCDS) model

and the allowable services. This memo also announces that Extraordinary Cleaning has

been added to the list of services allowable under the OHCDS model.

MSB Rules Affecting Case Management

Code of Colorado Regulations

Medical Services Board Webpage

Final Adoption by Consent Agenda-Proposed Effective Date 9/30/25

MSB 25-01-25-B Revision to the Medical Assistance Rule concerning Rapid Reintegration, Section 8.7200

The purpose of this rule revision is to add an additional proactive initiative to advance Members’ access to Home and Community Based Services (HCBS).

This rule revision is necessary to ensure compliance and consistency in providing individuals with information about supports and services in a timely basis. These changes would allow the opportunity for more individuals to transition to the community faster and help others avoid undesired nursing facility admission. The rule revision will target individuals who are already determined to be at the nursing facility Level of Care and seeking admission into a skilled nursing facility.

Currently there is minimal documentation to show that individuals seeking skilled nursing facility admission are being offered or provided with information regarding community living options, supports and services during the Level of Care screening. The Case Management Agency is currently not required to complete a transition plan if the individual expresses interest in community living at the time of the Level of Care screen.

The rule is being revised through 8.7200 Case Management requirements; Rapid Reintegration will align with new Care and Case Management system updates to the Level of Care Screen and Case Management Redesign goals to provide community options to members at the time of nursing facility admission. Rapid Reintegration will be an additional step for Case Management Agencies to complete (unless the individual opposes community living). Thus, creating an opportunity for a timelier transition and referral process (if applicable). Rapid Reintegration will also reduce the number of steps (3 steps) the current community transition system has, it will bypass the need for Options Counseling when an individual has expressed interest in living options outside of a nursing facility.

Rapid Reintegration will include the completion of a set of questions to identify and document any barrier(s) that the individual might have or has for a successful and safe transition.

The Case Management Agency (CMA) will be responsible for completion of the barrier questions, completion of appropriate referrals to Transition Services, and/or other applicable agencies (as needed), contacting Regional Accountable Agencies, a Mitigation plan (if applicable), and a Post Reintegration survey. Rapid Reintegration will be considered complete when the individual resides outside of the skilled nursing facility. It is important to note that the individual may choose whether they want to revisit community living options in six months or if the individual prefers Nursing Facility services, the Case Manager still needs to confirm they offered community living options as an alternative to Nursing Facility/Institutionalized Care.

CMAs will receive funding for the completion of Rapid Reintegration plans through CMA contracts. System generated reports will be required to issue payments. Rapid Reintegration will be implemented on January 1, 2026.

Rule Contents: These rules include general case management definitions and functions of a Case Management Agency. 

MSB 25-02-06-A Revision to the HCBS Rule Concerning Home Modification, Section 8.7525.c

A 2024 Budget Amendment, BA 7-2024 allowed for the current lifetime cap of $14,000 per member on the following waivers Brian Injury (BI), Complementary and Integrative Health (CIH), Community Mental Health (CMHS) Elderly, Blind and Disabled (EBD) waivers to now reset at the waiver life cycle. Currently, these waivers have a life-time funding limit for home modifications that is $14,000 over the entire time a member on the waiver. This rule change is necessary to update the funding limit section within the regulations. While the rule change would be effective upon the adoption of this rule, the effective date of the funding change would be at the renewal of each waiver, as outlined below:

• Complementary and Integrative Health (CIH) waiver – July 1, 2025
• Brain Injury (BI) Waiver - January 1, 2027
• Community Mental Health Supports (CMHS) Waiver - January 1, 2027
• Elderly Blind and Disabled (EBD) Waiver – January 1, 2027 

Initial Approval Agenda-Proposed Effective Date 11/14/25

MSB 25-01-28-C Revision to Rule concerning Community Health Workers/Community Health Representative Services, Sections 8.125, 8.126, 8.200.2.D & 8.799 

Community Health Worker/Community Health Representative (CHW/CHR) services are provided as preventative health services to prevent disease, disability, and other health conditions or their progression; to prolong life; and promote physical and behavioral health and efficiency. This rule is necessary to align HCPF’s rules with the state plan and C.R.S. § 25.5-5-334. Additionally, it is necessary to add these important provider types to rule.

MSB 25-05-14-A Revision concerning Health-Related Social Needs, Section 8.545

Revision to the Medical Assistance Act Rule concerning Health-Related Social Needs,

Section 8.545

The proposed rule codifies the Health-Related Social Needs (HRSN) services approved by the federal Center for Medicare and Medicaid Services (CMS) in the Department’s Section 1115 demonstration waiver. HRSN are social and economic factors impacting a person's overall health and well-being. For example, this might include a person's ability to access stable housing or nutritious food.

Colorado House Bill 24-1322 (HB 24-1322) “Medicaid Coverage Housing & Nutrition Services” added a study focusing on housing and nutrition HRSN service feasibility. The legislation also authorized the Department to seek federal authority to expand certain housing and nutrition related services, if determined to be feasible.

Authorized by HB 24-1322, the Department submitted an HRSN Section 1115 amendment to the CMS to cover HRSN, which was approved on January 13, 2025. The services covered in the proposed rule reflect those authorized in the approved Section 1115 amendment. 

MSB 25-04-17-A Revision to Alternative Care Facility Staffing Requirements, Section 8.7403 & 8.7506.F

In order to create efficiencies, OCL proposes to revise two areas of regulations: removal of the staffing ratio for Alternative Care Facilities and revising the certification process for Provider Agencies to allow for the initial certification and survey process to be conducted virtually.

The Department of Public Health and Environment (CDPHE) has regulations for Assisted Living Residences which dictate standards for staffing that are appropriate for member care. Currently, HCPF regulations expand on the minimum staffing requirements for Alternative Care Facilities under 8.7506.F. The staffing requirements outlined in 8.7506.F are outdated and often do not match the needs of the members served at the setting. Rather, Alternative Care Facilities should ensure that staffing meets the needs of their members they serve at the time, which is consistent with the regulations set forth by CDPHE.

In addition to eliminating the specific staffing ratio, HCPF proposes to allow for the provision of a virtual initial certification survey conducted by CDPHE. Current regulations under 8.7403.A state that onsite reviews of the Provider Agency will be completed by the Department or its agent as part of the certification process. HCPF proposes to change references of “on-site” reviews to “initial” reviews, as not all reviews are required to be completed on-site. This change will allow for reviews to be completed virtually, thereby expediting the certification process for CDPHE and Provider Agencies, allowing for faster access to appropriate services for members, and more efficiently using CDPHE resources. 

Case Management Policy: Questions and Answers

Q: Can a member continue to receive waiver services if they move into a Qualified Residential Treatment Program (QRTP)?

A: Yes, a member can continue to receive waiver services while living at a QRTP as this is not considered an institution (see "Institution" definition in 8.7100.A.39) and therefore is not duplicative of waiver services.

Q: If waiver services are paused due to a placement in a Qualified Residential Treatment Program (QRTP) do case management agencies continue to complete monitoring, PMPM and annual CSR's? Are these activities billable if waiver services are paused?

A: Waiver services do not need to be paused for placement in a QRTP as long as the placement is in the state of Colorado. Therefore, all case management activities such as monitoring, PMPM and CSR's would continue as scheduled, billable activities. If the QRTP placement is out of state, the members HCBS benefit would remain open as outlined in OM 25-027.

Q: If a cert span/service plan lapses while a youth is living at a Qualified Residential Treatment Facility (QRTP), do we hold the CSR or do we let it lapse and complete a new enrollment 100.2 and obtain a new PMIP when the youth is preparing for discharge?

A: If the QRTP placement is in the state of Colorado, the service plan should not lapse and the CSR should be held as scheduled. If the QRTP placement is out of state, the members HCBS benefit would remain open as outlined in OM 25-027.

Q: Are Case Managers required to issue an LTC NOA when a Member voluntarily transitions from an HCBS waiver to a Nursing Facility?

A: There is no LTC NOA requirement when a member requests to transition from a HCBS waiver to a NF placement. PASRR Level II LTC NOA requirements will still apply.

Q: Are Case Managers required to issue an LTC NOA when a Member voluntarily transitions from one HCBS waiver to another?

A: Maybe; Members enrolled in HCBS waivers that voluntarily transition from one waiver to another do not require an LTC NOA unless the transition is based on Targeting Criteria. For example, when a Member enrolled in HCBS-CES ages out and enrolls in HCBS-DD the Case Manager shall issue an LTC NOA for denial of the HCBS-CES waiver selecting the "you do not meet the Target Group Criteria for this program" reason. 

Please Note: If you are unable to find the answer to your question in any of the existing resources, e.g. rules, memos, guides, Case Management Q&A Webpage, CMA leadership, etc., please have your supervisor or a member of leadership submit the question to the Case Management Inbox.

CFC CSR Member Letter

We want to take this opportunity to remind CMAs to send the CFC CSR Member Letter to Members at CSR scheduling. The letter explains CFC in plain language and can help make the conversation during CSR easier to navigate.

• CFC - Letter at CSR for Current Members
• CFC - Letter at CSR for Current Members - Spanish

Related Benefits & Services News

State SLS and CFC Implementation Reminders

With Community First Choice (CFC) Implementation effective July 1, 2025, members active in the State General Fund program State SLS must be assessed annually for HCBS waiver eligibility and CFC services at their scheduled Continued Stay Review (CSR).   

• If a member qualifies for Health First Colorado Medicaid and is functionally eligible using the ULTC 100.2 assessment, they can receive CFC services. These include personal care, homemaker services, PERS, medication reminders, and remote support technologies.

• If a State SLS enrolled member is not eligible for Health First Colorado Medicaid and does not meet Level of Care eligibility to enroll in CFC services or HCBS waiver services, they will continue to be allowed to receive the State SLS services that are authorized in their current State SLS Person Centered Support Plan (PCSP) as long as they continue to meet all State SLS eligibility requirements outlined in 10 CCR 2505-10 8.7560. However, State SLS services must reflect the service changes made through CFC outlined below. 

State SLS is subject to the new service definitions found in 10 CCR 2505-10 8.7500. Case Managers should ensure that authorizations for tasks are under the appropriate service for these members to ensure the tasks for Personal Care, Homemaker, and Extraordinary Cleaning align. Below are a few key changes to those services:

• Personal Care
• Removed tasks: Money management, menu planning/shopping, and appointment management are no longer available under Personal Care on the SLS waiver.
• New location: These tasks are now included in the CFC Homemaker benefit.
• New task added: Acquisition, Maintenance, and Enhancement of Skills (AME)

• Homemaker
• New task: Banking/money management, menu planning/shopping, and appointment management are tasks under the Homemaker benefit. 
• New task added: Acquisition, Maintenance, and Enhancement of Skills (AME) task

Note: Enhanced Homemaker will no longer be available on the SLS waiver. The habilitative tasks within Enhanced Homemaker are encompassed in the new task under Homemaker and Personal Care titled Acquisition, Maintenance, and Enhancement of Skills (AME). The cleaning tasks within Enhanced Homemaker are encompassed in a new service called Extraordinary Cleaning. 

• Extraordinary Cleaning
• New Benefit: The extraordinary cleaning tasks of Enhanced Homemaker are included in a new service called “Extraordinary Cleaning”. Extraordinary cleaning is only available through the SLS waiver, State SLS, and the CES waiver.
• Extraordinary Cleaning includes specialized cleaning to keep a person’s home safe and hygienic. It uses commercial-grade products and follows infection control procedures. 

What Case Managers Need to Do:

• At a member’s CSR, assess all State SLS members for HCBS and/or CFC eligibility and outcome should be documented in the member’s record in MedCompass.
• Use the updated service definitions in 10 CCR 2505-10 8.7500.
• Ensure authorizations for Personal Care, Homemaker, and Extraordinary Cleaning follow the new guidelines.
• Update State SLS Person Centered Support Plan (PCSP) accordingly.
• Refer to the HCBS-SLS and CFC Provide Rates Fee Schedule.
• Upload completed State SLS PCSP to the member’s record in the MedCompass Document Management Center.

HCPF OM 25-042 State Supported Living Services Program (State SLS) and Community First Choice Program (CFC) 

HCPF OM 25-026 Community First Choice (CFC) Program Implementation

HCPF OM 25-039 Extraordinary Cleaning Waiver Benefit 

Email any questions to Maria Klickna, HCBS Benefit Specialist

Updated Direct Care Service Calculator (DCSC) for Adults and Children

We want to inform you of recent updates made to the Direct Care Services Calculators (DCSC) for Adults and Children. Effective August 1, 2025, use of the Interim Direct Care Services Calculator should have been discontinued to align with the implementation of the Nurse Assessor Program. Case Managers should use the final version of the DCSC, which was updated on August 12, 2025.

Updates to the Direct Care Services Calculator for Adults and Children include:

• Updated service definitions
• Corrections to calculation formulas
• Addition of the HMA Attestation Tab

Please ensure you are using the most up-to-date DCSC available on the Long-Term Services and Supports Case Management Forms and Tools page. 

If you have any questions or concerns, please contact the Participant-Directed Programs Unit.

Other News

At-Risk Diversion Pilot Program

The second list for the At-Risk pilot program was distributed on August 15, 2025. The Care and Case Management (CCM) system will import the list generated by the methodology QUARTERLY on the 15th. 

• The list is designed to run on the 15th every quarter in CCM, regardless of weekends or holidays at 12:55 AM EST and will be visible in CCM on the 16th.
• Once the list has been processed, the CCM system will notify the assigned CM regarding the members assigned to them: it will include At-Risk Alerts and At-Risk Tasks.

At-Risk Alerts in CCM: will be system generated when a member has been identified as At-Risk. 

At-Risk Tasks in CCM: The assigned CM will receive a system generated task when a member has been identified as At-Risk. There are two types of tasks At-Risk Initial Outreach and At-Risk Ongoing Outreach. 

At-Risk Initial Outreach Tasks: when the member has been identified as At-Risk for the first time and outreach needs to occur within 10 business days - Invoices are due on 15th of following month for these contacts (September 15th).

At-Risk Ongoing Outreach Tasks: when the member was identified the previous quarter (last list was March 2025) and outreach needs to occur within the next 90 days (this should be completed at the next scheduled contact).

• As outlined in contract requirements, CMs are responsible for contacting each listed member within the specified time frames defined above.

At-Risk Diversion Assessment: CMs are responsible for completing the At-Risk Assessment in CCM for ALL ACTIVE HCBS members that are identified as "At-Risk". The At-Risk Assessment is documentation of activities completed by the CM, this includes outreach outcomes, referrals, and facilitation to services, supports, and resources that were provided to the member. The At-Risk Diversion Assessment will substitute for any required activity log notes (additional activity log notes are optional). 

• At-Risk Outreach is only for members who are living in the community, if the member is in a NF, ACF, hospital, or deceased; no outreach is required but the at-risk assessment in CCM needs to be completed.

Targeted Case Management -Transition Coordination (TCM-TC) Diversion Referrals: should be completed by the CM in CCM only if needed and the member has agreed to TCM-TC Diversion Services.

For additional guidance, refer to the new job aids located in the CCM Google Drive–the At-Risk Diversion checklist, At-Risk Diversion Assessment, and Creating Referrals to the Transition Coordination Agency–for these processes within the CCM.

At-Risk Diversion Training: All new CMs that are responsible for conducting At-Risk outreach are required to complete the “At-Risk Diversion” web-based training.

• Updated At-Risk Diversion Information - April 2025
• At-Risk Diversion Training - December 2024
• Webinar Recording
• At Risk Diversion Web-based Training - October 2024

Office hours are encouraged but not required. Office Hours will be virtual via Zoom and will occur on the third Tuesday of each month from 2 to 3 p.m. Register in advance on Zoom. It can also be found on the OCL Stakeholder Engagement Calendar. 

For additional information on At-Risk Diversion and Escalations, visit the Nursing Facilities Diversion Projects Page. The In-Reach Team Project Feedback form is available to provide feedback, ask questions, and report issues and/or concerns outside of traditional meetings.  

• If you have questions or concerns, please do not hesitate to contact Victoria Lewis, HCPF In-Reach Coordinator.

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