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| | New Case Management Related Memos | | |
Memo Series Webpage
OM 26-005 – Updates to Community Connector Rate, Policy, and Limits in the Children’s Extensive Supports (CES) & Children’s Habilitative Residential Program (CHRP) Waivers
Effective Jan. 15, 2026. This Operational Memo informs Members, families, provider agencies, and Case Management Agencies (CMAs) about changes to the Community Connector benefit, including a revised reimbursement rate, updated policy guidance, and limits within the CES and CHRP waivers.
These updates impact service authorization, budgeting, and exception requests. Case Managers should ensure authorizations align with the revised limits and follow updated exception processes when members require services beyond established thresholds.
OM 26-006 – Nursing Facility (NF) and Intermediate Care Facility with Intellectual Disabilities (ICF-IID) Compliance and Post Payment Reviews
Effective January 1, 2026. The purpose of this Operational Memo is to outline compliance expectations and post-payment review requirements for Nursing Facilities (NF) and Intermediate Care Facilities for Individuals with Intellectual Disabilities (ICF-IID). This includes guidance related to audits, Personal Needs Account reviews, PASRR reviews, and other provider monitoring activities.
This memo clarifies oversight processes to ensure regulatory compliance and proper billing practices. Case Managers should understand these review processes, particularly when coordinating with facility-based providers or supporting members residing in NF or ICF-IID settings.
OM 26-007 – 2026 Federal Poverty Level (FPL) Guidelines & Updated Income Charts
Effective April 1, 2026. The purpose of this Operational Memo is to provide updated 2026 Federal Poverty Level (FPL) Guidelines and revised income charts for Medicaid and CHP+. This memo outlines new income eligibility standards and includes the April 2026 Medicaid and CHP+ Income Charts for use by eligibility partners and county departments.
These updates ensure accurate eligibility determinations based on current federal poverty thresholds. Case Managers should be aware of these changes when supporting members with eligibility-related questions, redeterminations, or transitions between programs.
IM 26-001 – Difficulty of Care and Community First Choice
Effective January 7, 2026. The purpose of this Informational Memo is to provide guidance regarding Difficulty of Care (DOC) payments and their interaction with Community First Choice (CFC) services. The memo outlines federal guidance related to IRS Notice 2014-07, clarifies when certain Medicaid waiver payments may be excluded from taxable income, and provides additional state-specific guidance, including reference to the Colorado Private Letter Ruling.
This memo supports providers, live-in caregivers, IHSS attendants, CDASS attendants, agencies, and Financial Management Services contractors in understanding the tax treatment of qualifying payments. Case Managers should be familiar with this information to appropriately respond to member and caregiver questions regarding Difficulty of Care payments and Community First Choice services but are not responsible for providing tax advice.
IM 26-002 – Public Notice for 2026 1915(c) Waiver Amendments
Effective July 1, 2026. The purpose of this Informational Memo is to notify HCBS Waiver Members, providers, and stakeholders of the public notice and comment period for proposed 2026 amendments to multiple 1915(c) Home and Community-Based Services (HCBS) waivers. These amendments impact waivers including CI, CES, CHRP, CHCBS, CMHS, CwCHN, DD, EBD, and SLS and will be submitted to the Centers for Medicare & Medicaid Services (CMS) for approval.
This memo provides transparency regarding upcoming waiver changes and outlines opportunities for stakeholder engagement. Case Managers should be aware of proposed changes that may affect waiver services, eligibility, provider requirements, or service definitions and direct interested members and families to public comment opportunities as appropriate.
| | MSB Rules Affecting Case Management | | |
Code of Colorado Regulations
Medical Services Board Webpage
Emergency Adoption – Effective Date 04/01/26
MSB 25-11-06-B Revisions to HCBS Benefits & Community First Choice (CFC), Sections 8.7500 and 8.7600
HCPF adopted emergency rule changes establishing annual service limits (“soft caps”) within the Person-Centered Support Plan (PCSP) year for key direct care services and creating a formalized exception process. These changes are part of Medicaid sustainability efforts and directly impact how HCBS case managers authorize and monitor services.
New annual limits include:
- Personal Care: 2,500 hours per PCSP year
- Health Maintenance Activities (HMA): 4,750 hours per PCSP year
- Homemaker: 4,500 fifteen-minute units per PCSP year
- Community Connector (children only): 1,040 units per PCSP year
- Legally Responsible Person (LRP) Homemaker: 260 hours annually per LRP
Services may exceed these limits only through a Department-defined exception process requiring clear documentation of medical necessity, health and safety risk, and why typical authorization standards are insufficient. The rule also tightens criteria for Community Connector, clarifies that services must not duplicate other supports, and reinforces documentation standards tied to assessed need.
Final Adoption – Effective Date 04/14/26
MSB 25-09-03-B Revisions to Mental Health Transitional Living Homes (MHTLH), Sections 8.7532 A–G
This rule transfers the licensing and certification oversight authority for Mental Health Transitional Living Homes within the Community Mental Health Supports (CMHS) Waiver from the Colorado Department of Public Health and Environment (CDPHE) to the Behavioral Health Administration (BHA).
The change aligns certification authority with Colorado’s behavioral health system restructuring and updates regulatory language to reflect BHA as the responsible entity for oversight and certification.
Initial Approval – Proposed Effective Date 05/15/26
MSB 25-07-01-E Repeal of Comprehensive Life Review Requirement, Section 8.7202.B
This rule removes the Comprehensive Life Review requirement from Case Management Agency intake, screening, and referral regulations. The requirement no longer reflects current operational practice and has not been consistently required in recent years.
MSB 25-07-02-B Repeal of 8.607.2 Determination of Developmental Disability and Relocation to 8.7202.D: Determination of Developmental Delay and Intellectual and Developmental Disability
The Department removed Determination of Developmental Delay and Intellectual and Developmental Disability requirements from the former 8.600 rules and relocated them to Section 8.7202.D within the HCBS Case Management rules. As part of this revision, the Department updated outdated terminology and references, clarified documentation and professional signature requirements, established clear timelines for submitting documentation and completing determinations, clarified who may request a determination including Legally Authorized Representatives, and standardized notification and recordkeeping requirements. These updates are administrative in nature and intended to improve consistency and transparency for applicants, Case Management Agencies, and providers.
| | Case Management Questions and Answers | | Next Home Modification Office Hours | |
We are pleased to offer the upcoming Home Modification Office Hours for case managers. These office hours are designed to provide detailed information about the Home Modification benefit around process and regulations. Participants will also have the opportunity to ask questions and receive clarification on processes, policies, and best practices to support effective case management.
Next Home Modification Office Hours
Wednesday, March 4· 2:00 – 3:00pm
Register here
| Related Benefits & Services News | Direct Care Services Soft Caps and Protective Oversight Exception Requests Reminders | |
Community First Choice (CFC) Direct Care Services exception requests are now being accepted for services with start dates of 4/1/2026 and later that exceed the established soft caps. Protective Oversight exception requests for all service start dates are being accepted. To submit an exception request, please go to the Home and Community-Based Services State Review and Exceptions Requests webpage.
When submitting a request, please note the following:
- Clearly explain how the member’s needs are extraordinary and justify approval of services beyond the Task Standard. Provide detailed task justifications that describe the specific tasks requested, including the amount of time, frequency, and duration needed to safely meet the member’s needs.
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Supervisor review and approval are required before submission. Before approving, supervisors should confirm that all required documentation has been uploaded to the Care and Case Management (CCM) system, including Health Maintenance Activities (HMA) documentation, if applicable.
- For children’s cases: utilize Age-Appropriate Task Standards when determining and justifying service needs. Clearly outline why the need is outside of a typical responsibility of a parent or how it qualifies as extraordinary care.
- To help ensure a timely review, fully complete the Direct Care Services Calculator, include detailed task justifications, and upload into CCM.
- If the length of task justification exceeds the size limits of the justification text boxes on the DCSC, please upload the Excel version of the DCSC to CCM or upload a supplemental documentation page.
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If service hours are necessary to ensure the member’s health and safety, and exceed the established soft caps, Case Managers should submit an exception request for review and approval. Services should not be reduced to the soft cap maximum solely to align with the cap when documentation supports the need for additional hours.
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Protective Oversight exception requests are submitted separately from the CFC Direct Care Services exceptions, which are to be used for Homemaker, Personal Care, and Health Maintenance Activity services. Requests that are submitted incorrectly will be Administratively Denied.
As a reminder, all Home and Community Based Services Exceptions can be accessed here.
| | Community Connector Exception Requests Reminders | | |
Community Connector exception requests are now being accepted under the new 1,040-unit annual cap for certification start dates or service plan revision effective dates of April 1, 2026, and later.
Please keep the following reminders in mind when submitting a request:
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Clearly justify the exception. Explain how the Member’s needs are extraordinary for community engagement and why services beyond the Age-Appropriate Guidelines are necessary and describe why the need is outside a typical parental responsibility.
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Provide a detailed community engagement calendar. Include the specific activities requested and the time, frequency, and duration needed to safely meet the Member’s needs, along with supporting justification.
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Confirm coordination and documentation. Ensure that all appropriate supporting services have been utilized, that Community Connector is not duplicating any waiver or non-waiver services or supports, and that required documentation has been uploaded to CCM.
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Support timely review. Ensure the form is fully completed and respond to any Requests for Information within five business days.
As a reminder, all Home and Community Based Services Exceptions can be accessed here.
| | Health Maintenance Activities (HMA) Documentation | | |
This is a reminder that HMA services must meet the documentation requirements outlined in Policy Memo 26-001. Case records must clearly support the member’s assessed need, demonstrate how services relate to health and safety, and align with the approved service plan.
To ensure compliance:
Thank you for helping ensure HMA services are well-documented and policy-aligned.
| | Join HCPF March 4, 2026 for a Cover All Coloradans Update | |
The Colorado Department of Health Care Policy and Financing (HCPF) invites you to register for a webinar on March 4, 2026, from 1 to 2:30 p.m. where we will provide updates on Cover All Coloradans. There will be time for questions throughout the webinar.
Meeting date and time: Wednesday, March 4, 2026, from 1 to 2:30 p.m. (MST)
- Intended Audiences: Advocacy groups, members, community organizations, and other impacted communities
- Closed captioning and Spanish interpretation will be available.
Registration and location: the meeting will be virtual via Zoom. Register in advance or at the start of the webinar. Once you register, you will receive a unique link to join the meeting. It is tied to your registration and will not work for anyone else.
You can learn more about HB22-1289 Health Benefits for Children and Pregnant Persons and view a recording of the webinar on the Cover All Coloradans webpage.
Meeting Accommodation and Language Access Notice
Auxiliary aids and services for individuals with disabilities and language services for individuals whose first language is not English may be provided upon request. Please notify the meeting organizer Ryan Lazo at ryan.lazo@state.co.us, or the Civil Rights Officer at hcpf504ada@state.co.us, at least one week prior to the meeting to make arrangements.
| | Nursing Facility Diversion Projects: At-Risk Diversion and Rapid Reintegration | | |
At-Risk Diversion and Rapid Reintegration Initiatives
The Department of Health Care Policy and Financing (HCPF), in collaboration with stakeholders, has developed enhanced programs to strengthen transition and diversion efforts across Colorado. These initiatives support Health First Colorado Medicaid members who are living in the community and identified as “At-Risk” of institutional care, as well as Members who express interest in transitioning from a nursing facility to community living at the time of nursing facility admission.
The goal of At-Risk Diversion and Rapid Reintegration is to strengthen members’ access to home and community-based services (HCBS), provide early intervention, and support smooth transitions to community settings or to support safety within the community whenever possible. These initiatives also promote informed choice, independence, and successful community living. Through these efforts, Members may receive:
- Education about community living options
- Information on available resources and supports
- Access to community-based services and transition services
- Housing-related assistance
- Support from Transition Coordination Agencies (TCAs), when appropriate
Office Hours and Open Forum available for Case Managers: these optional meetings are designed to provide a collaborative space to discuss At-Risk Diversion and Rapid Reintegration initiatives. During these sessions, participants may ask questions, raise concerns, discuss challenges, receive clarification, and guidance.
At-Risk Diversion Office Hours / Work Group
When: Third Tuesday every other month
Time: 2: 00 p.m. -3: 00 p.m.
A calendar invitation with a registration link is available for participants; At-Risk Diversion registration link
Rapid Reintegration Office Hours / Work Group
When: Third Tuesday of each month
Time: 11:30 a.m. – 12:15 p.m.
A calendar invitation with a registration link is available for participants; Rapid Reintegration registration link
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: victoria.lewis@state.co.us.
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Palco will begin to transition from its third‑party Fiserv AuthentiCare to Palco’s proprietary EVV solution, Connect. Connect is a fully compliant EVV platform that meets all requirements of the 21st Century Cures Act and HCPF’s EVV Provider Choice Specifications, capturing the six required data points while offering enhanced flexibility, accessibility, and security.
Colorado stakeholders are already familiar with Connect as the long‑standing online timesheet portal, and this transition simply adds EVV functionality through an easy‑to‑use mobile application with both Standard and Offline modes, ensuring reliable use in rural and low‑connectivity areas. Connect also supports Interactive Voice Response (IVR) for attendants who cannot use the mobile app, and offers multilingual capabilities, HIPAA‑compliant encryption, GPS‑based location validation, and robust system monitoring.
Case managers should expect a smooth transition for members and attendants, supported by Palco’s established processes for system updates, issue tracking, and user assistance, and training.
CDASS participants, case managers, and other interested stakeholders can sign up for training on the Palco training webpage for the following dates:
- Thursday, February 19, 2026 10-11 AM MST
- Tuesday, February 24, 2026 1-2 PM MST
- Thursday, February 26, 2026 10-11 AM MST
- Tuesday, March 3, 2026 12-1 PM MST
- Thursday, March 5, 2026 12-1 PM MST
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For user access to CCM/Bridge/PEAKPro, complete a 3rd Party System User Access Request Form, including required signatures from agency management, and submit to HCPF_OCLSystemApplications@state.co.us.
For MEUPS password resets, email commit_helpdesk@gainwelltechnologies.com.
To request assistance for CCM, Bridge, or PEAKPro system issues, call the CCM Support Center 1-888-235-6944 or complete the CCM Support Request Form. Also see: FAQs and Known Issues pages.
If you have a question about the CCM system, please contact the monitored inbox hcpf_cmasystemsupport@state.co.us.
For SIS, ISLA, Support Level Review (SLR) and Support Level Mismatch related questions, please contact the appropriate inbox below:
Questions from members, legal guardians, other family members, and providers
Risk Factor related questions or edits and SL Mismatch related questions
Completed SLR Request forms, ISLA Assessor questions, SIS Online login issues, Bridge syncing issues (transmittals needed), and general SIS/ISLA questions from CMAs/ISLA contacts
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