July 2025 Town Hall FAQs

Are current HCBS participants required to move to CFC?

Yes, if the participant is utilizing one of the services that are transitioning to CFC, they will transition, but there should not be any change in services.

This is primarily a back-end change that Case Managers will handle during the individuals’ annual service planning process. This affects everyone on a waiver accessing these services, except those on a DD waiver. 

What is CFC?

CFC is a new way of authorizing, delivering, and paying for certain services that have previously (mostly) only been available under Medicaid Waivers, including services like personal care and homemaker.

With CFC, more people can access care without needing to qualify for Medicaid waiver programs like SLS, CES, or EBD (while still needing to meet level-f-care criteria). More information is available in HCPF’s CFC FAQ.

Will the process from referral to beginning services become shorter?

The process for referral could possibly be shorter if someone is only seeking CFC enrollment and not Long-Term Care Medicaid Waiver Enrollment. CFC-only enrollment does not require extra documents (medical documents, additional applications) to meet targeting criteria in order to qualify. 

Is there a flow chart anywhere that identifies what goes under CFC and what goes under which waivers?

Please see the comparison charts located under Department Guidance on HCPF’s website.

Who was previously ineligible before CFC but is now eligible?

Prior to CFC, individuals had to meet specific targeting criteria for a Medicaid waiver in order to qualify. For example, the CES waiver has targeting criteria that requires a child to need frequent intervention during the day and nighttime hours.

For current CFC services, an individual only needs to have eligible Medicaid and meet functional eligibility.

How does this program impact tasks that are currently under a Certified Nursing Assistant’s (CNA) responsibilities?

Through CFC, an individual is able to choose a provider to provide skilled and unskilled services without needing a CNA license. An individual may have a CNA and In-Home Support Services through CFC as long as services are not duplicative.

Does CFC change the tax exemption status of live-in caregivers?  Public Partnerships, LLC (PPL), the Financial Management Service Provider for CDASS, states that CFC is not a waiver, resulting in a loss of tax exemption. Is this true?

HCPF is still waiting for guidance from the IRS on this topic. Please reference the informational memo, IM 25-018, by visiting HCPF's 2025 Memo Series Communication page or by searching “IM 25-018” on HCPF's website for additional information.

Will CFC free up some of the spending of the CES waiver budget because some of the services will be moving to CFC?

Yes, it would allow for more space in the CES waiver, as the CFC services would not come out of the CES plan.

What are "Attendant Based Services" under CFC?

Attendant Based Services are people in your life who can help with activities of daily living such as personal care, bathing, dressing, cleaning your house, grocery shopping. Within CFC, Consumer-Directed Attendant Support Services (CDASS) allows you to hire an attendant to support you.

The member or authorized representative can support with finding a provider. CFC services do not require having a licensed/skilled nurse or CNA, so you can hire someone you trust and know to help you. 

What are the pay rates for CFC ?

Pay rates can be found through HCPF’s Community First Choice Fee Schedule.

What is the "Nurse Assessment" being added to the 100.2 process for children receiving CFC and CES Waiver services during their annual renewal?

The Nurse Assessor process is a new process in which a licensed nurse will do a virtual or in person call to assess if skilled services are needed. Then they will submit a service recommendation to the CMA to help figure out what services are needed. This process will launch on 08/01/2025 and CMAs are currently being trained.

What is the Interim Support Level Assessment (ISLA)?

The ISLA is the interim tool being used from what was previously the Supports Intensity Scale (SIS) assessment. This is only for members newly enrolling into SLS/DD, which are adult I/DD waivers. This determines a support level to support the members with funding and services needed.

More information can be found on HCPF’s website.

Is the ISLA using a similar scale to the SIS (levels 1-6)?

Yes, ISLA will still use a similar scale. However, HCPF is still working on the official algorithm, and it has not been publicly shared as of now. HCPF will have more information soon.

Currently the SIS/ISLA level determines a cap of individual services received and a Service Plan Authorization Limits (SPAL). Will SPAL will no longer exist?

SPALs will no longer exist but service caps do still exist. The ISLA does not set service caps; instead, it establishes reimbursement rates for certain services covered under the SLS and DD waivers.  

All service rates are determined by HCPF. Pay rates can be found through HCPF’s Community First Choice Fee Schedule

How long will an existing SIS Assessment Support Level be effective?

A person’s support level will be effective until the new Colorado Single Assessment (CSA) comes into place and then it will be assessed on an annual basis once a year. 

If a member has a SIS score, but is working toward an increased score, what needs to happen?

Contact your Case Manager and let them know the support level does not meet the needs of the member and you would like to request a support level review (SLR). They will assist with that process which involves sending a request to HCPF for approval or denial.

Residential reimbursements are also based off tiers. Does that mean individuals will all have a different rate, not based on a tier? 

Residential rates will still be based on tiers or support levels. Support levels determined by the SIS will remain in place. The new ISLA is also based on levels 1-6. Service plan authorization limits (SPAL) have been removed for the SLS waiver, but service caps are still in place.