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Community First Choice Option

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CFC in Colorado

Community First Choice (CFC), also known as 1915(k), is an optional Medicaid program that allows states to offer select home and community based attendant services and supports to eligible members on the State Plan, expanding these long-term care services to more Health First Colorado (Colorado's Medicaid Program) members.  

Promoting self-direction, relocation out of institutions, and person-centered practices are significant goals of CFC. Members will have the option to self-direct their attendant care services or to receive services through an agency. CFC gives members access to service delivery models that allow them to control their own budget, select and dismiss their attendants, and provide training for the people who provide their care. By expanding these options, members will experience greater choice and control over how they receive services. 

Furthermore, the CFC option provides a 6 percentage point increase in Federal matching payments to states for CFC service expenditures. With the authority from Senate Bill 23-289, Colorado is currently working to implement CFC by July 1, 2025. The Department of Health Care Policy and Financing (HCPF) plans to submit the State Plan Amendment to the Centers for Medicare and Medicaid Services (CMS) in the Summer of 2024. 

The following is a draft summary of service delivery options and services proposed under CFC. 

  • Service Delivery Options: Members can choose to self-direct Personal Care, Homemaker, and/or Health Maintenance Activities through In-Home Supports and Services (IHSS) or Consumer Directed Attendant Support Services (CDASS). Alternatively, members can access Personal Care and Homemaker services through an agency. 
     
  • Services: 
    • Personal Care (Providers must have a Class A or Class B License, view this policy memo for more information)
    • Homemaker 
    • Health Maintenance Activities 
    • Acquisition, Maintenance, and Enhancement of Skills (AME) 
    • Personal Emergency Response Systems and Medication Reminders 
    • Transition Setup 
    • Home Delivered Meals 
    • Remote Supports and Remote Supports Technology 

By July 1, 2025, these services will be moving from the Home and Community Based Services (HCBS) Waivers into CFC.  Existing waiver members will be able to access the above services through CFC while still being able to access any remaining needed services through their waiver. CFC does not preclude members from utilizing services across other HCBS and State Plan authorities, including 1915(c) waivers, as long as there is no duplication of those services.

Please view the Colorado Community First Choice (CFC) vs. Adult Home and Community-Based Services (HCBS) Waivers Comparison Chart and the Colorado Community First Choice (CFC) vs. Children’s Home and Community-Based Services (HCBS) Waiver Comparison Chart

Who is eligible?

CFC does not create a new Health First Colorado eligibility group. Members eligible for CFC are individuals who are eligible for Health First Colorado benefits under the State Plan and meet the institutional level of care. An institutional level of care refers to an individual who has needs that require services in their home and community to keep them from long-term care placement in a nursing home, hospital, intermediate care facility for individuals with intellectual disabilities, or an inpatient mental health facility. Institutional level of care is determined by the state prescribed level of care eligibility assessment.

HCBS waiver members are eligible to enroll in CFC if there is an assessed need for CFC services. To remain on the HCBS waiver, the member must continue to meet the eligibility requirements for the HCBS waiver and receive one waiver service per month to maintain waiver eligibility. Some members will only be eligible for CFC and not a waiver. 

What is the timeline for CFC implementation?

What is the timeline for CFC implementation? 

  • May 2022: Ongoing: CFC Council reviews Department proposals during monthly meetings for included services, settings, transition plans, rules and regulations, and other program details.
  • January to May 2023: CFC Legislation (Senate Bill 23-289) 
  • Summer/Fall 2024: Submit State Plan Amendment to the Centers for Medicare and Medicaid Services  
  • Spring 2025: Submit Rules and Regulations for Medical Services Board approval 
  • July 1, 2025: CFC is active and available to eligible members 
  • July 2025 through 2026: Members transition to CFC at the time of their Continued Stay Review 
  • Fall 2026 through January 2027: Complete HCBS Waiver actions with the Centers for Medicare and Medicaid Services to remove CFC services from the waivers  
  • Fall 2026 through January 2027: Submit Rule and Regulations to remove CFC services from the HCBS Waivers 

Wellness Education Benefit

Visit the Wellness Education Benefit webpage for more information.

Children with Complex Health Needs (CwCHN) Waiver

  • The Children with Complex Health Needs Waiver will be a new waiver for children that encompasses the current Children’s Home and Community Based Services (CHCBS) waiver members and the Children with Life-Limiting Illness (CLLI) waiver members. The services on the new CwCHN waiver will be the same as the current CLLI waiver services with the addition of the Wellness Education Benefit. Additionally, eligibility will be expanded to capture both the CHCBS and CLLI Waiver populations. Members who currently receive IHSS through the CHCBS waiver will receive the benefit through CFC. 

    This waiver is pending federal approval. For more information, email hcpf_cfc@state.co.us 
     

Timeline for the CwCHN waiver, changes to the CHCBS waiver, and CFC

  • May 1, 2024 - The Wellness Education Benefit is available to CHCBS waiver members.
  • July 1, 2024 - The Case Management Benefit is moved to an administrative function rather than a monthly waiver service on the CHCBS waiver. Visit the Case Management Redesign website for more information.
  • Summer 2025 - The CHCBS waiver will merge with the CLLI waiver and be renamed the Children with Complex Health Needs Waiver (CwCHN). Eligibility criteria will be expanded and all CLLI waiver benefits will be available on the merged waiver.
  • 2025 through 2026 - Members will transition from CHCBS to CwCHN at the time of their Continued Stay Review. All waiver members will have access to CFC in this time period.
  • Summer 2026 - The CHCBS waiver concludes as all members will have been transitioned to the CwCHN waiver.
     

Contact Us

 Submit Questions or Feedback

Email more extensive feedback or questions to hcpf_cfc@state.co.us. If you have limited access to the internet, call Adam Tucker at 303-866-5472 for assistance.