Memory Care Licensing in Colorado: What Families Need to Know

Colorado Doesn't Have a "Memory Care" License

This is the single most important regulatory fact for families evaluating memory care in Colorado: the state does not issue a separate license for memory care facilities. Every community that markets itself as offering "memory care" operates under the same Assisted Living Residence (ALR) license issued by the Colorado Department of Public Health and Environment (CDPHE).

What this means practically is that "memory care" is a marketing designation, not a regulatory category. Two facilities can both call themselves memory care communities while operating under very different staffing models, training standards, and physical security arrangements — because the label itself carries no standardized requirements beyond what the ALR license demands.

The protections that do exist come from specific state regulations about secured environments, staff training mandates, and preadmission requirements. Knowing what those regulations actually say puts you in a much stronger position during facility tours.

Class A vs. Class B — The Licensing Tiers

Colorado divides ALR licenses into two classes:

Class A licenses cover small residential facilities with up to 8 beds. These are typically converted homes or small purpose-built residences in residential neighborhoods.

Class B licenses cover larger facilities with 9 or more beds. Most dedicated memory care wings and standalone memory care communities fall under this category.

Both classes must meet the same core ALR standards — the distinction is primarily about size, staffing ratios, and physical plant requirements. Larger Class B facilities face more detailed regulatory oversight for emergency systems, common spaces, and medication management infrastructure.

What SB22-079 Requires for Dementia Training

Senate Bill 22-079 established mandatory dementia-specific training for all direct-care staff in licensed ALRs. This is the closest thing Colorado has to a memory care regulatory standard, and it applies across the board — not just to facilities marketing themselves as memory care.

Under SB22-079, direct-care employees, administrators, and frequent volunteers must complete state-standardized training that covers:

• Cognitive communication techniques
• Managing behavioral changes associated with dementia
• Emergency procedures specific to cognitively impaired residents
• Person-centered dementia care principles

CDPHE audits compliance with these training records during unannounced annual inspections. If a facility can't produce training documentation for its staff, they're out of compliance.

When touring a facility, ask: "Can you show me your SB22-079 compliance records?" A well-run operation will have these readily available. A vague answer — "oh, all our staff are trained" — without documentation should raise a flag.

Secured Environment Standards

For facilities that house residents who cannot safely self-direct (the functional definition of someone needing memory care), Colorado mandates specific physical and staffing standards:

Delayed-egress doors and alarms. Exit doors in secured units must be equipped with magnetic locking systems, delayed-egress devices, or alarms integrated into staff notification systems. Emergency override procedures must be clearly documented and tested.

At least one trained staff member on the secured unit at all times. This is a minimum — better facilities exceed it significantly, but the regulatory floor is one.

Secured outdoor areas. The facility must provide a continuous outdoor courtyard with comfortable seating and weather protection, allowing residents to go outside without risking unsupervised departure. This is a requirement, not an amenity — if a secured unit doesn't have an accessible, enclosed outdoor space, they're not meeting the standard.

Bedroom and bathroom standards. Single-occupancy bedrooms must be at least 100 square feet (for buildings constructed after July 1, 1986). Double-occupancy rooms must be at least 120 square feet, with a maximum of two residents per bedroom. The facility must provide at least one full bathroom (toilet, sink, shower with grab bars and slip-resistant surfaces) for every six residents.

Preadmission Assessments and Ongoing Reviews

Before a resident moves into a secured memory care unit, Colorado requires a comprehensive preadmission assessment. This assessment must document:

• A clinical need for a secured environment (high wandering risk, spatial disorientation, behaviors dangerous to self or others)
• The resident's cognitive functioning level
• Physical and behavioral needs that the facility must be equipped to handle

These assessments must be updated at least every six months to confirm the resident still meets criteria for a secured unit. If they've stabilized to the point where a secured environment is no longer clinically justified, the facility must document that and potentially transition them to a less restrictive setting.

On the other side, facilities are prohibited from admitting or retaining residents who need 24-hour skilled nursing care, consistently refuse prescribed medications, or exhibit behaviors the facility's staffing can't safely manage. This is important: a memory care ALR is not a nursing home, and residents whose needs exceed the ALR standard must be transitioned to a skilled nursing facility.

The Dementia Disclosure Form — Coming October 2027

Colorado has mandated a standardized Dementia Care Services Disclosure Form that all facilities will be required to provide to families, but this mandate doesn't take effect until October 1, 2027.

When active, this form will require facilities to disclose:

• Their specific dementia therapies and programming
• Staff-to-resident ratios in the secured unit
• Exact criteria for admission, transfer, and involuntary discharge

Until that date, none of this information is proactively provided. Families must ask for it themselves during tours, and facilities aren't required to present it in a standardized format. This is why going into a tour with a structured question list matters — you're compensating for a disclosure requirement that doesn't exist yet.

How to Evaluate a Facility Without the Disclosure Form

Until October 2027, ask these questions directly:

1. What is your staff-to-resident ratio during the day? At night?
2. What specific dementia training has your staff completed, and when was it last updated?
3. What are your criteria for involuntary discharge?
4. Do you hold ACF certification for Medicaid waiver residents?
5. Can I see your most recent CDPHE inspection report?
6. What happens if my parent's needs exceed what your ALR license allows?

CDPHE inspection reports are public record. You can also search CDPHE's online database for a facility's licensing status, inspection history, and any enforcement actions.

The Colorado Dementia & Memory Care Guide includes a facility tour audit checklist built around Colorado's regulatory requirements — 15 questions organized by licensing, training, physical security, and discharge policies so you can evaluate every community against the same objective standards.

See more Colorado guides →