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Community First Choice Colorado: What Changed for Aging Parents in 2025

If your aging parent receives home care services through Health First Colorado's Elderly, Blind, and Disabled (EBD) waiver, everything about how those services are delivered changed in 2025. The Community First Choice (CFC) program took over personal care, homemaker services, and several other home-based supports — and the transition affects everything from how family caregivers get paid to what your parent's care plan looks like.

What Community First Choice Is

CFC is a Medicaid state plan option (not a waiver) that Colorado implemented on July 1, 2025. It moves core home- and community-based services out of the EBD waiver and into a consolidated statewide program.

Services that migrated to CFC include:

  • Personal care — bathing, dressing, toileting, mobility assistance
  • Homemaker services — meal preparation, laundry, light housekeeping, shopping
  • Personal emergency response systems (PERS) — medical alert devices
  • Home-delivered meals

The EBD waiver still exists but now covers specialized services that CFC doesn't absorb — adult day services, home modifications, non-medical transportation, and respite care. If your parent's care plan includes both types of services, they'll receive some through CFC and others through the EBD waiver simultaneously.

How the Transition Works

Current EBD waiver members don't need to re-apply. The transition happens automatically during each member's scheduled Continued Stay Review (CSR), which occurs between July 1, 2025, and June 30, 2026. At the CSR, the Case Management Agency (CMA) case manager converts the applicable services from the waiver to CFC.

For new applicants, CFC eligibility is determined as part of the standard Medicaid long-term care assessment. The parent must meet Nursing Facility Level of Care (NFLOC) criteria and qualify financially for Health First Colorado.

What This Means for Family Caregiver Pay

CFC preserved and in some cases expanded the ability for family members to be paid as caregivers. Colorado allows family members — including adult children and spouses — to provide paid care through two consumer-directed models:

CDASS (Consumer Directed Attendant Support Services) — the parent or their Authorized Representative acts as the employer of record, managing an allocated monthly budget and setting caregiver wages. Wages typically range from $17 to $22 per hour. Colorado is one of the few states that allows spouses to be hired and paid under CDASS.

IHSS (In-Home Support Services) — a Medicaid-certified home care agency serves as the formal employer, handling payroll taxes and administrative paperwork. Family members can provide up to 40 hours per week of personal care services under this model.

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The LRP Cap You Need to Know About

CFC introduced strict rules for Legally Responsible Persons (LRPs) — defined as the parent of a minor child or the legal spouse of an adult member. If a spouse is providing care under CFC:

  • Homemaker tasks are capped at 7 hours per week (364 hours annually). This includes meal preparation, laundry, and shopping — tasks the state considers part of normal spousal responsibility.
  • Total paid hours are capped at 56 per week under any combination of CDASS and IHSS.
  • All personal care and Health Maintenance Activities (HMA) must be clinically justified through HCPF's Direct Care Services Calculator (DCSC) tool.

Adult children caring for a parent are not classified as LRPs and don't face the homemaker cap — but all care hours still require clinical documentation.

Navigating the CMA System

Since July 1, 2024, Colorado replaced its legacy Single Entry Points (SEPs) and Community Centered Boards (CCBs) with 20 regional Case Management Agencies (CMAs). The CMA is your single point of contact for:

  • Initiating a functional needs assessment
  • Establishing or modifying a Person-Centered Support Plan (PCSP)
  • Coordinating the CFC/EBD waiver transition
  • Managing consumer-directed care budgets

Finding the correct CMA for your parent's county is the first step. Each CMA serves a defined geographic region — Jefferson County Human Services covers Jefferson and Clear Creek counties, Rocky Mountain Human Services covers Denver, and Developmental Pathways handles Douglas, Arapahoe, and Elbert counties.

What to Do If Your Parent Is Transitioning

If your parent is currently on the EBD waiver and hasn't had their CSR yet, their services continue unchanged until the review. At the CSR, your CMA case manager will walk through which services move to CFC and update the care plan accordingly.

If you're managing a parent's legal authority through a financial or medical power of attorney, the transition doesn't change your legal standing — but you may need to sign updated service agreements under the CFC framework.

The Colorado Power of Attorney & Guardianship Kit covers how the CMA system, CFC program, and legal authority documents work together — including how to designate an Authorized Representative for CDASS if your parent can't direct their own care.

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