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CDASS Colorado: How Consumer Directed Attendant Support Services Work

CDASS Colorado: How Consumer Directed Attendant Support Services Work

Your parent qualifies for Medicaid home care, but the assigned agency sends a revolving door of strangers. CDASS flips that dynamic entirely — your parent (or their Authorized Representative) becomes the legal employer, choosing exactly who provides care and when.

Consumer Directed Attendant Support Services is one of two participant-directed care models funded through Health First Colorado. Since July 2025, CDASS operates under the Community First Choice (CFC) state plan benefit, which shifted core attendant services out of the Elderly, Blind, and Disabled (EBD) waiver into a broader entitlement framework. Current EBD waiver participants transition to CFC during their annual Continued Stay Review.

How CDASS Works: Your Parent as the Employer

Under CDASS, the Medicaid participant or their designated Authorized Representative acts as the Employer of Record. That means full responsibility for recruiting, hiring, training, scheduling, and — if necessary — terminating care attendants.

A state-contracted Financial Management Services (FMS) provider handles the administrative side: tax withholdings, payroll processing, workers' compensation, and budget tracking. Your parent directs the care; the FMS handles the paperwork.

Who can be hired: Spouses and family members over age 18 can serve as paid attendants. The one exception: parents of minor children cannot be paid caregivers for their own child under CDASS rules.

Skilled tasks allowed: CDASS attendants are exempt from the Nurse Practice Act. Under the participant's or Authorized Representative's direct instruction, attendants can perform health maintenance tasks like catheter care, wound care, and medication administration — tasks that would normally require a licensed nurse.

CDASS vs. IHSS: Which Model Fits Your Family

CDASS and In-Home Support Services (IHSS) both let families choose their own caregivers, but the employment structure differs significantly.

Feature CDASS IHSS
Employer of Record Participant or Authorized Representative Licensed home care agency
Payroll and taxes FMS provider handles Agency handles
Workers' comp liability Through FMS Through agency
Clinical support None built in Agency RN conducts assessment and trains caregivers
Who can be hired Family 18+, spouses (not parents of minors) Family, spouses, and parents of minors
Best for Families comfortable managing employment Families wanting agency backup and clinical oversight

IHSS is often the better choice for families who want to select their own caregivers but prefer to avoid the legal and administrative liabilities of acting as an employer. An agency Registered Nurse conducts a clinical assessment, develops the care plan, and provides hands-on training for complex medical tasks.

Caregiver Hour Caps: The 2026-2027 Phase-In

Colorado's Department of Health Care Policy and Financing (HCPF) has introduced phased weekly limits on how many hours a single caregiver can be paid for one participant:

  • July through December 2026: Maximum 84 paid hours per week per caregiver
  • January through June 2027: Maximum 70 hours per week
  • July 2027 onward: Maximum 56 hours per week

These caps limit hours per individual caregiver, not total authorized care hours. If your parent is authorized for 100 weekly hours, the excess beyond the cap must be staffed by a secondary caregiver unless HCPF approves a formal exception.

Additionally, homemaker services provided by Legally Responsible Persons are capped at 7 hours per week per household.

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How to Get Started with CDASS

  1. Confirm Medicaid eligibility through your county Department of Human Services (single applicant asset limit: $2,000; income cap: $2,982/month gross)
  2. Contact your regional Case Management Agency (CMA) to request a functional Level of Care assessment
  3. Complete the CFC enrollment — your CMA case manager will walk you through CDASS versus IHSS options during the Person-Centered Support Plan development
  4. Select your FMS provider and begin the attendant recruitment process

The Colorado Care Decision Guide walks through this entire process step by step, including the CMA contact directory, assessment preparation checklist, and budget management templates for both CDASS and IHSS models.

Exception Process for Complex Care Needs

If your parent has extraordinary clinical needs, lives in a rural area with workforce shortages, is transitioning from a facility, or is receiving end-of-life care, you can request an exception to the weekly hour cap. Only the CDASS participant (as employer) or the IHSS provider agency can submit the request. Your CMA case manager provides a mandatory clinical necessity attestation, but HCPF retains sole approval authority.

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