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Case Management News

New Case Management Related Memos 

Memo Series Webpage

PM 26-001 -  Health Maintenance Activities (HMA) Documentation Requirements

Effective Dec. 22, 2025. The purpose of this Policy Memo is to clarify the regulatory documentation requirements for Health Maintenance Activities (HMA) through Consumer-Directed Attendant Support Services (CDASS) and In-Home Support Services (IHSS). It provides operational instructions to Case Managers and introduces updated tools intended to

improve consistency, accuracy, and transparency in HMA assessments and

authorizations. 

OM 26-001 -Direct Care Services Calculator and Age-Appropriate Task Standards

Effective Jan. 15, 2026. The purpose of this Operational Memo is to provide clarification and implementation guidance regarding Age-Appropriate Task Standards, task definitions, maximum allowable service hours, and the use of the Direct Care Services Calculator (DCSC) for members receiving Homemaker, Personal Care, and/or Health Maintenance Activity (HMA) services. These updates are intended to improve statewide consistency in service authorization, ensure age-appropriate alignment of tasks, and support equitable service delivery across service delivery options to include Agency-Based services, In Home Support Services (IHSS), and Consumer-Directed Attendant Support Services (CDASS).

OM 26-002 -Individual Residential Services and Supports (IRSS) Rate Alignment Guidance

Effective April 1, 2026. The purpose of this memo is to notify Case Managers, Provider Agencies, Members, and families of updates to the Individual Residential Services and Supports (IRSS) benefit under the Developmental Disabilities (DD) waiver and to outline the actions required for the implementation of the IRSS Rate Alignment. This update clarifies IRSS setting types and aligns rates with the appropriate delivery model, as will be described in the updated IRSS definition within 10 CCR 2505-10 8.7542.B.

OM 26-003 -Implementation of Soft Caps on Personal Care, Homemaker, and Health Maintenance Activities (HMA) 

Effective Jan. 15, 2026. The purpose of this Operational Memo is to inform Members, families, advocates, provider agencies, and Case Management Agencies (CMAs) of the implementation of new annual service unit limits (“soft caps”) for Personal Care, Homemaker, and Health Maintenance Activities (HMA). This memo outlines the details for the soft caps, expectations for CMAs and providers, and the exception process available for Members who require services above the established limits. 

OM 26-004 - Implementation of Caregiver Limits on Homemaking Services Provided by Legally Responsible Persons 

Effective Jan. 15, 2026. The purpose of this Operational Memo is to inform Members, families, advocates, provider agencies, caregivers, and Case Management Agencies (CMAs) about the new caps on weekly caregiving hours for Homemaker Services provided by Legally Responsible Persons (LRPs). 

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 upcoming changes to the Community Connector benefit, including a revised reimbursement rate, a new minimum age requirement, a reduced annual unit limit, and clarified authorization and exception requirements.

MSB Rules Affecting Case Management

Code of Colorado Regulations

Medical Services Board Webpage

Final Adoption-Effective Date 03/02/26

MSB 25-07-02-A Revision to the Medical Assistance Act Rule concerning Removal of Long-Term Care Single Entry Point from Section 8.300 

HCPF is removing the term "Long Term Care Single Entry Point" from the title of the rule. As of July 2024, Colorado no longer utilizes Single Entry Points; instead, all such functions are now carried out by Case Management Agencies. There are also no longer any Home and Community-Based Services (HCBS) case management related rules in this section, as they have been moved to 8.7000.

MSB 25-11-23-C Revisions to the Direct Care Direct Care Services Calculator and Protective Oversight definitions, Sections 8.7502.K & 8.7538.C.1 

HCPF has revised the definition of Direct Care Services Calculator (DCSC) and Protective Oversight. The DCSC has always included task definitions and times (formerly

called Norms, now called Standards); by including this specific language in regulation, it

improves HCPF’s ability to enforce compliance.

• Direct Care Services Calculator means a tool used by a Case Manager or vendor to indicate the number of hours of Attendant services a Member needs for each covered personal care services, homemaker services, and health maintenance activities. Case Managers must utilize the Task Standards for Adults and the Age-Appropriate Task Standards for Children provided by the Department to establish appropriate service authorization for members. 



• Protective Oversight means providing line of sight supervision requiring intervention to prevent harm when a member’s disability, memory, or cognitive functioning-related behaviors or impairment place the member, others, or property at risk. Protective Oversight shall not be authorized for purposes of companionship, childcare, general supervision, reassurance, emergency or crisis intervention, or routine monitoring that is not necessary to address a disability-related safety risk. Protective Oversight shall not include restrictive practices unless a documented Rights Modification per 8.7001.A.17. is in place prior to the provision of services. Protective Oversight shall only be approved when there is documented evidence of risks requiring regular and predictable intervention within the last year. The members’ service plan must include the frequency, scope and duration of intervention required. Protective Oversight alone cannot be the sole reason for the visit/services.

Initial Adoption Agenda-Proposed Effective Date 04/14/26

MSB 25-09-03-B Revision to Mental Health Transitional Living Homes, Sections 8.7532 A. through G

This rule change transfers the licensing and oversight authority for the certification of Mental Health Transitional Living Homes (MHTLH), within the Community Mental Health Supports (CMHS) Waiver, from the Colorado Department of Public Health and Environment (CDPHE) to the Behavioral Health Administration (BHA).

Case Management Questions and Answers

Case Management Q&A Webpage

Case Management Policy

Q: Does uploading documents to the member's record in the CCM system qualify as TCM?

A: No, only reviewing Member-specific documentation qualifies as TCM. Uploading documentation and any other strictly administrative activity is not billable as TCM. 

Q: Can Case Managers copy and paste emails into Activity Logs?

A: No, copying and pasting emails into Activity Logs often leaves out important context, such as the nature of the issue, key details, outcomes, and any required follow-up actions. Instead, Case Managers should summarize correspondence in their own words and ensure the summary includes all relevant information, including the nature of communication, specific details, outcomes, and any follow up actions, if applicable. 

Q: Does documenting the PCSP in the CCM system qualify as TCM? 

A:  It depends on the situation, what activities the case manager completed, and how it was documented in the activity log itself. To be reimbursable, the key components are: 

• The activity log is member specific,
• The activity that occurred is clearly outlined, and 
• Any follow-up actions are documented. 

If a CMA is completing a support plan with a member, that would be an allowable ongoing case management activity. Finalizing the support plan, entering it into the system, and sending it to the member for signature would also be allowable-this would be the case for both HCBS or SGF programs. CMA's should ensure the activity logs contain the required elements outlined in the TCM Fact Sheet to avoid potential issues in the future when reviews are initiated. 

With that, HCPF will be revising the existing contract language for ongoing case management for FSSP, State SLS, and OBRA-SS to better clarify what is a reimbursable activity. This will be shared with the CMAs in the coming months to solicit feedback and for a July 1, 2026 implementation date.

Q: Can you document multiple case management activities in a single Activity Log? 

A: Case Management Activities that should be completed separately and documented as such are as follows: 

• Completion of the Level of Care Screen,
• Completion of the Person Centered Support Plan,
• Monitoring Contacts and,
• Targeted Case Management (TCM) activities.

However, multiple TCM activities, as outlined in 8.7202.Z.1(c), could be documented in one Activity Log if they occur on the same day. 

Q:  What documentation is needed to verify current mental health diagnosis for members on the CMHS waiver, since a PMIP is no longer required? 

A: If the Professional Medical Information Page (PMIP) received upon enrollment outlines a qualifying mental health diagnosis as outlined in 8.7101.F.2 (a)(ii), by a qualified medical provider, no further verification is required.

Supported Employment

Q. Should a Member close their DVR case so they can access HCBS-Supported Employment (SE) services through the HCBS-DD or HCBS-SLS Waivers? 

A. No, it is a federal expectation that DVR-SE be used before HCBS-SE services. Closing the case would not only end the Member’s access to DVR support but also put them at risk of not being able to access HCBS-SE.

Q. Can HCBS-Job Coaching be added to a Member’s Service Plan if an HCBS-SE Provider does not have a current authorization for DVR-Job Coaching through DVR-SE? 

A. Yes, if a Member needs immediate access to support at work and there is a delay or disruption to DVR-Job Coaching authorizations, HCBS-Job Coaching may be authorized. It is the Supported Employment (SE) provider’s responsibility to utilize the correct funding stream. This means that once a DVR-Job Coaching authorization is received, the SE Provider must use DVR-SE funding rather than HCBS-SE. The SE Provider should also keep the Case Manager informed of any delays in DVR-SE authorizations to ensure that, if additional adjustments to the service plan are needed, they can be made.

Q. Can HCBS-Job Development be added to a Member’s Service Plan if an SE Provider does not have a current authorization for DVR-Job Search and Placement through DVR?  

A. Yes, if a Member is eager to start their job search and there is a delay or disruption to DVR-SE authorizations, then HCBS-Job Development may be authorized.  It is the SE provider's responsibility to utilize the correct funding stream. This means that once a DVR-Job Development authorization is received, the SE Provider must use DVR-SE funding rather than HCBS-SE. The SE Provider should also keep the Case Manager informed of any delays in DVR-SE authorizations to ensure that, if additional adjustments to the service plan are needed, they can be made.

Q. Can HCBS-Job Development and HCBS-Job Coaching be authorized in a Member’s Service Plan while DVR-SE authorization may be delayed because of new review processes?

A. If appropriate parameters are met, then Case Managers can authorize a limited number of HCBS-SE units to promote continuity of care while DVR is using cost containment measures.

• The Member needs either support in their current job or they are seeking employment.
• The Member must have an open case with DVR and have an Individual Plan for Employment (IPE).
• The SE Provider has indicated that DVR authorizations are in process, and there has been a delay or disruption to DVR covering the necessary supports for the Member. 

Q. How should Case Managers determine what is an appropriate amount of HCBS-Job Coaching?

A. The SE Provider should provide the Case Manager with the following information:

• The Member’s start date on their Job
• The Job tasks the Member is proficient at, and those Job tasks the Member is still learning
• The Member’s work hours
• The expected amount of support needed
• The SE Provider’s plan to promote the Members' independence
• The SE Provider requests submitted to DVR for services to support the Member, and the status of those requests.
• Based on these factors, the Case Manager and the SE Provider can determine the amount of units needed. A Member’s Individual Plan for Employment (IPE) through DVR-SE should be the primary funding source, and the authorization of HCBS-SE while the Member has an IPE is only meant to be a backup in the event of delays or gaps in DVR-SE service authorization. The case manager should monitor the Members' progress with DVR during their quarterly monitoring visits to ensure the right amount of HCBS-SE services are authorized.

Q. How should Case Managers determine what is an appropriate amount of Job Development? 

A. Similar to determining HCBS-Job Coaching, the case manager will work closely with the SE Provider to identify the Member’s needs. The SE Provider should be able to outline the specific support they will provide the Member with in their job search.  Job Development includes activities such as:

• Assessing strengths/interests
• Completing applications
• Coordinating/negotiating with employers
• Helping the Member prepare for interviews.
• The SE Provider can project how many units may be needed, and this may be added to the Member’s Service Plan. Once there is a DVR authorization in place to cover this support, the SE Provider must use DVR-SE funding rather than HCBS-SE.

Q. What if a Member does not have an active DVR-SE Individual Plan for Employment (IPE)? 

A. If a Member does not yet have an approved IPE through DVR-SE, then the Case Manager may authorize HCBS-Job Development, or if the Member has found a job, HCBS-Job Coaching may be added to the Service Plan. The SE-provider should utilize HCBS-SE services until the IPE is active. The Case Manager must confirm that a referral to DVR for services has been made before authorizing HCBS-SE services. The goal is to ensure the Member is not waiting to start their career journey while DVR is working on the Member's eligibility for DVR-SE services.

Q. Who is responsible for keeping track of hours/ and authorizations 

A. It is appropriate for the Case Manager to remind the SE Provider that it is their responsibility to use DVR-SE funding first and to ensure that HCBS-SE services are used second. It is expected that the SE provider documents all requests to DVR for services and the communications they have had with DVR. If DVR has rejected a request for DVR-SE services because it does not believe the service is needed, HCBS-SE cannot be utilized. The HCBS-SE provider will need to work with DVR to identify the appropriate service and support for the Member, and keep the Case Manager informed.

Division of Regional Centers (DRC) Updates and Information

The Division of Regional Centers is a collection of group homes integrated into the community, operated by the State of Colorado. There are three Regional Centers in Colorado: Grand Junction Regional Center, Pueblo Regional Center, and Wheat Ridge Regional Center. These group homes are short-term residential settings for adults with intellectual and developmental disabilities (I/DD) who need additional support to stabilize and return to community residential settings.

Recent Announcements:

• Transition Coordination Agency (TCA) Launch: DRC is finalizing the launch of its TCA to offer more comprehensive transition services for individuals leaving a regional center. Further details will be communicated soon.
• Public Fact Sheets: DRC has developed public fact sheets. Case Management Agencies (CMAs) are encouraged to share both these fact sheets and the DRC website with members, their families, and support teams.
• General Fact Sheet (pdf)
• Admission Fact Sheet (pdf)
• Community Support Team Fact Sheet (pdf)
• Transition Coordination Agency Fact Sheet (pdf)
• Overview of Services for Adults with IDD (pdf)

Clarifications on Processes:

• Community Support Team (CST)
• A CST referral is not required for a CMA to submit a Support Level Review (SLR) request.
• A CST referral is not required for a CMA to submit an emergency request for the HCBS-DD waiver.
• The primary role of a CST consultation is to provide recommendations aimed at mitigating the risk of regional center admission and helping members stabilize in the community.
• Admission to Regional Centers
• There is no waitlist for regional center admission.
• Regional centers are not locked facilities; they are group homes located in community neighborhoods with 24/7 onsite staffing.
• Prior to admission, the CMA must have explored reasonable, safe community placement options (both local and statewide referrals), and determined community providers are unable to meet the member's identified needs.

Questions or Support:

For general inquiries, please contact the Community Services Team at the Division of Regional Centers at cdhs_drcinquiries@state.co.us.

Determining Eligibility Gaps (POI and EMS)

Individuals who are approved for LTSS benefits but cannot receive HCBS services due to a Period of Ineligibility (POI) or cannot receive HCBS or CFC services because they only qualify for Emergency Medical Services (EMS) are reflected in PEAKPro and the CCM. 

For step by step instructions (with screenshots) you may review the CCM Newsletter that was sent on December 17, 2025 and then again on January 7, 2026.

Related Benefits & Services News

HCBS-CHRP SED Physician Attestation Form Update

Please note the HCBS-CHRP SED Physician Attestation Form has been updated as of January 26, 2026, to more clearly state that the form must be submitted with required supporting clinical documentation from the treating licensed mental health professional to support eligibility determination. Case Manager must ensure they are using the most current version of the form.

New HCBS-SLS Exception Form

Effective February 1, 2026, a new Google Form will replace the fillable PDF form for the SLS Exceptions process. The form will be available on the SLS Exceptions Website. Case Managers are requested to begin using this form for any requests moving forward. The old form will not be accepted after February 27th, 2026. The purpose of this new form is to reduce errors, ensure the correct application is being utilized, and provide a consistent platform for Case Managers to use.

Case Managers will need to create a PDF version of the Google Form to upload to Qualitrac as a part of the SLS Exception process. To do this, Case Managers will receive an email copy of the submitted form to the email provided. Case Managers will need to open the email, select Print, then Print to PDF. This will provide Case Managers with a PDF version of the form to upload to Qualitrac. 

Case Managers will be notified of upcoming Office Hours for questions and additional training when available. If there are questions, please contact hcpf_hcbs_questions@state.co.us.

PAR Entry for CDASS Members

PALCO:

Beginning in July 2025, Palco implemented an automated process between its CMP system (portal for case managers) and the Gainwell system. This automation enables PARs entered in the Gainwell Bridge to be transmitted directly to Palco through a nightly EDI file. Each night’s file includes all PARs submitted that same day.

The Gainwell system experienced a small issue that prevented some PARs from transferring correctly, which required Palco to temporarily request PAR information manually from HCPF staff which created small delays in PAR approval for some CDASS members. This issue has since been fully resolved as of 1/7/2026.

Going forward, all PAR data entered into the Bridge will be automatically transmitted to Palco with no manual intervention needed. Case managers continue to no longer need to enter PAR information separately in Palco’s portal. Please ensure that all PAR data entered in the Bridge is accurate and entered timely; Palco members’ budgets will rely only on this data in Bridge.

Public Partnerships (PPL):

PPL is working with HCPF to establish an automated process with the Gainwell system so CDASS member PARs no longer need to be entered into PPL’s portal system. Until this automation is in place for PPL, case managers continue to need to enter PAR data in the Bridge and in PPL’s BetterOnline Portal. Please visit PPL’s website or email cocdasscasemanagement@pplfirst.com for PAR entry instructions.

Other News

Next Member Correspondence Improvements Quarterly Meeting is February 19, 2026

The Colorado Department of Health Care Policy and Financing (HCPF) hosts Member Correspondence Improvements stakeholder meetings focused on improving communication with Health First Colorado members. Stakeholders, providers, and community members are invited to collaborate and provide feedback on proposed changes to member letters and correspondence processes.

The session originally scheduled for January 15, 2026, which was planned to focus on implementation of work requirements and six-month renewal frequency as required in H.R. 1, has been postponed until February 19, 2026, from 12 to 1 p.m. This decision allows additional time to interpret federal guidance from the Centers for Medicare and Medicaid Services.

HCPF is committed to ensuring the appropriate staff and subject matter experts are available for this work. In early January, many HCPF staff will be supporting presentations to the Joint Budget Committee, and postponing the meeting will help ensure meaningful participation. 

Meeting date and time: Thursday, February 19 from 12 to 1 p.m. 

Registration and location: The meeting will be held virtually via Zoom with live Spanish and ASL interpretation provided. Register in advance or at the start of the webinar. Once registered, participants will receive a unique Zoom link to join the meeting. The link is tied to individual registration and cannot be shared.

If you are unable to attend, email hcpf_stakeholders@state.co.us to request a recording.

Launch of Ask-A-Nurse Program

Based on some of your feedback and request for resources, we are excited to announce the launch of the Ask-A-Nurse Program, a new but temporary support available to Case Managers.

Beginning January 14, Case Managers will have access to registered nurse consultation to help support Health Maintenance Activities (HMA) and members with complex medical needs, including those receiving Long-Term Home Health (LTHH) or Private Duty Nursing (PDN) services.

Program Dates:

January 14 – February 13 

Through this program, nurses are available to:

• Clarify skilled vs. unskilled services
• Help interpret clinical documentation and provider input
• Support complex or atypical cases
• Assist with communicating service limits and coordination across programs

The Ask-A-Nurse Program is consultative in nature for case managers. Nurses do not conduct assessments, provide member-facing services, or make eligibility or authorization decisions.

How to Access Support:

Case Managers may submit questions or requests for consultation by emailing:

CO_CM_Support@Telligen.com

Hours of operation are Monday through Friday, 9:00 AM – 5:00 PM (MT).

We encourage Case Managers to use this resource during the pilot period and share feedback to help inform future program development.

At-Risk Diversion

At-Risk Diversion focuses on strengthening community-based services for people with disabilities by expanding access to home and community-based services and connecting individuals to housing supports (as needed). The goal is to ensure Health First Colorado (Colorado's Medicaid Program) Members can receive needed care and services in their communities and avoid unnecessary institutional placement.

Each quarter, the Health Care Policy & Financing Department (HCPF) identifies Medicaid Members who may be at risk of institutionalization. A list of these “At-Risk” Members is generated in the Care and Case Management System (CCM) to support timely outreach and diversion planning. The At-Risk list runs automatically in CCM on the 15th of each quarter at 12:55 a.m. EST, regardless of weekends or holidays. The list is distributed in CCM on the 15th and made available to Case Management Agencies (CMAs) via SharePoint on the following business day of the quarter.

• Next list distribution: February 15, 2026

The Care and Case Management System (CCM) generate two types of At-Risk tasks for assigned Case Managers:

• At-Risk Initial Outreach
• Outreach must be completed within ten (10) business days
• At-Risk Ongoing Outreach
• Outreach must be completed within ninety (90) days

In accordance with contract requirements, Case Managers are responsible for contacting each identified Member within the required timeframe and completing the At-Risk Diversion Assessment in CCM within ten (10) business days of the completed outreach activity. Any referrals to Targeted Case Management – Transition Coordination (TCM-TC) Diversion Services must also be completed in CCM within two (2) business days.

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.

Rapid Reintegration and Rapid Referral

Program Start Date: January 1, 2026

Rapid Reintegration (RR) helps Health First Colorado (Colorado's Medicaid Program) Members move from nursing facilities to community living as quickly and smoothly as possible when they express interest in living in the community. Rapid Reintegration streamlines the current community transition processes by reducing steps, and it focuses on timely access to the support and services Members require to live successfully in a community setting. Rapid Reintegration begins when a Medicaid Member who is being assessed for Initial Nursing Facility Level of Care (LOC) indicates interest in community-based living options. From that point, coordinated efforts are initiated to support an efficient and person-centered transition. 

Case Management Agencies (CMAs) play a key role in the Rapid Reintegration process by supporting expedited referrals (Rapid Referrals) to the Transition Coordination Agency (TCA), service coordination, and transition planning when appropriate. Case Managers provide education and counseling to help Members understand the community-based services for which they may be eligible, as well as their options for receiving services in either a nursing facility or a community setting. The goal of Rapid Reintegration is to ensure Members receive consistent, timely support that promotes independence, choice, and successful transitions to community living. 

Rapid Reintegration Office Hours / Work Group

When: Third Tuesday of each month

Time: 11:30 a.m. – 12:15 p.m.

First Office Hours/Work Group: February 17, 2026 

This is an optional, open meeting designed to discuss the Rapid Reintegration process and address questions, issues, and concerns. A calendar invitation with a registration link is available for participants; 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.

EVV and CFC: What Case Managers Need to Know

As members start or transition to Community First Choice (CFC), Electronic Visit Verification (EVV) requirements continue to apply to Personal Care and Homemaker services.

EVV must be documented for all EVV-required services a member receives. When a member is authorized for and receives both Personal Care and Homemaker, EVV must be captured for each service, even if this requires multiple call-ins and call-outs during a single visit.

Caregivers call in when a service begins and call out when the service ends or when a different EVV-required service begins. Visits that include more than one EVV-required service, such as Personal Care and Homemaker, may result in multiple EVV records.

An exception applies for In-Home Support Services (IHSS) and Consumer Directed Attendant Support Services (CDASS). For these service models, which include Personal Care, Homemaker, and Health Maintenance Activities, EVV is captured under a single EVV service group (IHSS or CDASS) rather than separately for each service type. As a result, multiple call-ins and call-outs are not required when different services are provided during the same visit.

If EVV is not captured for each authorized service, issues such as claim denials and the need to correct EVV records may occur. Case Managers are not responsible for EVV collection or dissemination of EVV information. However, if a case manager converses about EVV with members, caregivers, or providers, please ensure that communication aligns with the requirements stated above.

Service separation under CFC

Effective July 1, 2025 with the launch of CFC, providers are no longer able to bill Personal Care and Homemaker services together. For EVV, this means if the Personal Care attendant includes some Homemaker Services, these services must remain separate in EVV collection.

If there are any EVV questions, please reach out to evv@state.co.us 

If there are any CFC questions, please reach out to hcpf_cfc@state.co.us

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