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Colorado Senior Care Costs in 2026: EBD Waiver and Alternative Care Facilities

Published 2026-02-27

A source-backed Colorado guide to the EBD waiver, Case Management Agency application path, Alternative Care Facility services, Community First Choice transition, and assisted-living oversight.

Colorado separates the Medicaid waiver decision, the case-management process, the Alternative Care Facility service package, and the state assisted-living license. A provider quote only becomes useful after those pieces are matched to the same person and location. This guide explains that Colorado-specific path without presenting an unsupported statewide private-pay average.

Who the EBD waiver serves

Health First Colorado’s Elderly, Blind, and Disabled waiver supports people who need long-term services in a community setting instead of institutional care. The state identifies two principal age groups:

  • people age 65 or older with a functional impairment; and
  • people ages 18 through 64 who are blind, have a physical disability, or have a diagnosis of HIV or AIDS.

Applicants must meet a nursing-facility level of care and the financial rules for the program. The current HCPF page lists countable-resource limits of $2,000 for a single applicant and $3,000 for a couple, along with separate income and eligibility requirements. Those figures can change, so use the state page during the application rather than relying on a copied threshold.

Approval is not based on age or diagnosis alone. The functional assessment, financial determination, living arrangement, and need for an authorized waiver service all matter.

The Colorado application path

Colorado routes waiver access through regional Case Management Agencies.

If the person already has Health First Colorado, HCPF directs the person to contact the local Case Management Agency to start the EBD process. If the person is not enrolled, the first step is a Health First Colorado application, followed by contact with the Case Management Agency for the waiver assessment.

The Case Management Agency is responsible for more than paperwork. It evaluates functional eligibility, develops and updates the person-centered service plan, authorizes services within program rules, and helps identify qualified providers.

Bring the following to the first case-management conversation:

  • proof of current Health First Colorado status or the pending application;
  • medical and functional information showing where help is needed each day;
  • the current living arrangement and the proposed setting;
  • names of informal caregivers and services already in place; and
  • any facility proposal or discharge deadline affecting the care plan.

Ask which decision is still pending: Medicaid financial eligibility, nursing-facility level of care, waiver enrollment, or provider authorization. Each can affect timing differently.

Alternative Care Facilities are a defined waiver service

The EBD waiver lists Alternative Care Facilities (ACFs) as a service option. HCPF’s EBD and related waiver provider manual describes Alternative Care Services as a package delivered in a state-certified ACF. The package can include personal care and homemaker help such as bathing, dressing, mobility, medication reminders, routine cleaning, meal preparation, laundry, and shopping, when those services are in the member’s plan.

An ACF is not simply any building that markets itself as assisted living. The residence must satisfy Colorado’s assisted-living licensing requirements and the additional Medicaid certification and enrollment requirements for the waiver service.

Before choosing a location, ask the Case Management Agency to confirm:

  1. that the site is certified as an ACF for the relevant program;
  2. that the provider is active and accepting members;
  3. which services are included in the authorized ACF package;
  4. whether another provider will deliver any service outside that package; and
  5. what housing and personal-expense obligation remains with the member.

Community First Choice changes the service map

Colorado’s EBD page explains that several services historically delivered through waivers have been moving to Community First Choice during members’ scheduled continued-stay reviews. Those services include categories such as homemaker, personal care, personal emergency response, and certain participant-directed options.

This does not mean the member loses EBD eligibility or that every service is automatically replaced. It means the authorization source shown on an older plan may not match the current plan. Ask the case manager which items are now authorized through Community First Choice and which remain EBD waiver services, especially when comparing an old invoice or planning a move.

Colorado also offers delivery models such as Consumer Directed Attendant Support Services (CDASS) and In-Home Support Services for eligible services. Those options are not interchangeable with the residential ACF package. A resident should not assume that a self-directed service budget follows unchanged into an ACF.

What to separate in a Colorado facility quote

Request an itemized agreement that distinguishes:

  • room, meals, and basic housing;
  • the Alternative Care Services package billed under Medicaid;
  • services authorized through Community First Choice or another provider;
  • medication administration or nursing beyond the included package;
  • deposits, assessments, supplies, and transportation;
  • the effect of a reassessment or temporary absence; and
  • charges that continue if Medicaid authorization is interrupted.

Have the Case Management Agency compare the proposed services against the current person-centered plan. A facility’s private-pay service tier may use different labels from the state authorization, so match tasks and frequency rather than names alone.

Colorado assisted-living license and complaint checks

The Colorado Department of Public Health and Environment’s Assisted Living Residences page explains the state license and links the governing standards. Colorado defines an Assisted Living Residence as a setting for three or more unrelated adults that provides room and board, personal services, protective oversight, social care, and regular 24-hour supervision, but not regular 24-hour medical or nursing care.

That boundary is a useful placement question. Ask whether the resident’s current nursing needs fall within the residence’s licensed capability and whether outside health providers are required.

CDPHE also provides a health-facility complaint process. Anyone with knowledge of a concern can file, including a family member. The department says it investigates quality of care, resident rights, and safety concerns and prioritizes reports based on actual or potential harm.

Check the facility’s state license and ACF certification separately. A licensing complaint belongs with CDPHE; a dispute about waiver eligibility, case management, or authorization follows Health First Colorado’s grievance and appeal route.

Colorado-specific action list

  1. Apply for or confirm Health First Colorado coverage.
  2. Contact the local Case Management Agency for the EBD functional assessment.
  3. Confirm current financial and nursing-facility-level criteria with the agency.
  4. Review which services are EBD and which are now Community First Choice.
  5. Limit the residential search to licensed sites with active ACF certification when Medicaid ACF services are required.
  6. Reconcile the person-centered plan against the facility’s itemized agreement.
  7. Keep the HCPF authorization, resident agreement, and CDPHE license information together.

Questions that expose cost gaps

For the Case Management Agency

  • Which program authorizes each service in the current plan?
  • Is the proposed residence certified as an Alternative Care Facility?
  • Will moving change the service plan or delivery model?
  • What member payment or housing obligation applies at this site?

For the residence

  • Which tasks are included in the ACF Medicaid service package?
  • Which services require an outside agency or private payment?
  • Can the residence meet the resident’s needs within its assisted-living license?
  • How do temporary absences, reassessments, and rate changes affect the invoice?

Official sources


Match the EBD plan, Community First Choice authorizations, and ACF agreement before moving. Compare Colorado care options on SLINQ →