EBD Waiver Colorado: Eligibility, Services, and the CFC Transition

The Elderly, Blind, and Disabled waiver is Colorado's primary Medicaid program for keeping aging parents out of nursing homes. It funds home care, assisted living, adult day services, and participant-directed models like CDASS and IHSS — all designed to let your parent stay in the least restrictive setting possible.

But the EBD waiver is in the middle of a structural transition. Since July 2025, Colorado has been shifting core attendant services from the waiver into the Community First Choice (CFC) state plan benefit. Understanding what's changing — and what stays the same — matters for every family navigating the system right now.

Functional Eligibility: The Level of Care Standard

To qualify for the EBD waiver, your parent must meet the Nursing Facility Level of Care (NFLOC) standard. A certified case manager from your regional Case Management Agency (CMA) conducts an on-site evaluation using the Level of Care Screen.

The threshold: Your parent must need assistance with at least two out of six Activities of Daily Living — bathing, dressing, toileting, transferring, mobility, and eating. The assessment determines whether they functionally qualify for nursing facility placement or for supportive home and community-based services.

Financial Eligibility: Colorado's Income Cap

Colorado is an income-cap state with no spend-down path. For 2026:

• Asset limit: $2,000 in countable resources (single applicant)
• Income limit: $2,982 per month gross (300% of the Federal Benefit Rate)
• Over-income applicants must establish a Qualified Income Trust (Miller Trust) — there is no alternative

For married couples, spousal impoverishment protections shield the community spouse's separate income entirely. The Community Spouse Resource Allowance protects up to $162,660 in combined assets, with a guaranteed minimum of $32,532.

What the EBD Waiver Covers

The EBD waiver authorizes a range of services designed to prevent or delay nursing home placement:

• Personal care (bathing, dressing, grooming, mobility assistance)
• Homemaker services (meal prep, light housekeeping, laundry)
• Adult day services at certified facilities
• Alternative Care Facility (ACF) services — Medicaid's term for assisted living placement
• Respite care to give family caregivers temporary relief
• Non-medical transportation to medical appointments
• Personal Emergency Response Systems (PERS)
• Home-delivered meals
• Participant-directed care through CDASS or IHSS

The Community First Choice Transition

Here is what shifted on July 1, 2025: core attendant services — personal care, homemaker support, PERS, electronic monitoring, and home-delivered meals — moved from the EBD waiver into the CFC state plan benefit.

What this means for your parent: If they are currently on the EBD waiver, these services transition to CFC during their annual Continued Stay Review (CSR). The waiver itself does not disappear — it continues to fund services that CFC does not cover, such as ACF (assisted living) placement, adult day services, and specialized medical equipment.

Why this matters: CFC is a state plan benefit, not a waiver with enrollment caps. This gives eligible participants a stronger entitlement to services. But the transition also introduces new administrative steps during the annual review, and families need to understand which services now fall under which program.

How to Access the EBD Waiver

1. Get the PMIP signed. Your parent's physician must complete and sign the Professional Medical Information Page, which provides medical certification of the need for long-term support
2. Contact your regional CMA. Colorado has 20 service areas managed by 15 designated agencies. Your CMA initiates the functional assessment
3. Complete financial eligibility through your county Department of Human Services
4. Develop the Person-Centered Support Plan with your CMA case manager, which outlines authorized services, care hours, and provider selections

The Colorado Care Decision Guide maps this entire pathway, including CMA contact directories by county, assessment preparation checklists, and the CDASS versus IHSS comparison framework for participant-directed care.

See more Colorado guides →