Overview of the Community First Choice Program
CFC is a new statewide Colorado Medicaid program beginning July 1, 2025: Colorado’s Community First Choice (CFC) Program is a suite of long-term services and supports for CO residents who are elderly or disabled and require care equivalent to that which is provided in a nursing home. Intended to delay and prevent the need for institutionalization, assistance with Activities of Daily Living (ADLs) and Instrumental Activities of Daily Living (IADLs) is provided. This includes personal care assistance (i.e., bathing, dressing, toileting, and eating) and homemaker services (i.e., preparing meals, light housecleaning, and laundry). Other benefits might include help with health related tasks (i.e., wound care), personal emergency response systems, medication reminder systems, and home delivered meals. For persons transitioning from a nursing home facility back into the community, CFC will cover some of the associated expenses, such as the security deposit and utility setup fees.
CFC program participants can receive personal care assistance, homemaker services, and health maintenance activities via a provider agency, or alternatively, they have the option to self-direct their own care. Two participant-directed options are available: In-Home Support Services (IHSS) and Consumer-Directed Attendant Support Services (CDASS). Both options allow program participants to hire a friend or relative, including an adult child or spouse, to provide them with care.
IHSS program participants work with a licensed IHSS agency who assists them in managing their budget. The agency also takes on all employer responsibilities, such as verifying caregiver capability, background checks, setting the caregiver payrate, withholding taxes, and issuing paychecks. On the other hand, CDASS program participants are the “employer”, managing their own budget and deciding their caregiver’s rate of pay. A financial management services agency handles the financial aspects of employment responsibilities, such as background checks, tax withholding, and caregiver payments. For both service delivery options, program participants who cannot self-direct their own care can have a representative do so on their behalf.
Program participants can live in their own home, the home of a friend or relative, a certified foster care home, or an alternative care facility (assisted living residence).
CFC services are an entitlement; meeting the state’s Medicaid eligibility requirements guarantees one will receive benefits. In other words, there is never a wait list to receive CFC benefits.
The Community First Choice Program is a Medicaid State Plan Option that was created by the Affordable Care Act (ACA). It is a 1915(k) State Plan Amendment. In Colorado, Medicaid is called Health First Colorado.
The Community First Choice (CFC) Option, established by the Affordable Care Act, allows states to provide limited Home and Community Based Services (HCBS), such as personal care assistance, via their state’s Regular Medicaid Plan. Previously, states mainly provided HCBS via 1915(c) Medicaid Waivers, which limit the number of participant enrollment slots. Therefore, wait lists commonly exist. In contrast, CFC benefits are available via a state’s Regular Medicaid Plan, which does not limit the number of program beneficiaries. This means the availability of HCBS via the CFC Option is open to anyone who meets the eligibility criteria.
Benefits of the Community First Choice Program
CFC program participants are allotted a budget with which to purchase Home and Community Based Services. Follows are ways in which one might spend their budget.
– Acquisition, Maintenance, and Enhancement of Skills (AME) – i.e., personal hygiene, money management, menu planning
– Health Maintenance Activities – i.e., wound care, tracheostomy care, blood pressure monitoring
– Home Delivered Meals
– Homemaker Services – housecleaning, laundry, meal preparation, shopping for basic necessities
– Medication Reminder Systems
– Personal Care – assistance with daily living activities, such as bathing, dressing, mobility, eating, toileting, transferring, mobility
– Personal Emergency Response Systems – Medical alert devices
– Remote Supports / Remote Supports Technology
– Transition Setup – to assist persons transitioning from a nursing home to a community setting. Will cover a security deposit, utility setup fees, basic kitchen items, bedding, and furniture.
Eligibility Requirements for CO’s Community First Choice Program
The CFC suite of long-term care services is for CO residents of all ages who are eligible for Health First Colorado. Persons can simultaneously receive benefits from a HCBS Medicaid, Waiver, like the Elderly, Blind and Disabled Waiver. However, program participants of Specified Low-Income Medicare Beneficiary, Qualified Medicare Beneficiary, Child Health Plan Plus, and the Program for All Inclusive Care of the Elderly (PACE) are not eligible for CFC. Additional eligibility for Health First Colorado and CFC follows.
Financial Criteria: Income, Assets & Home Ownership
Income
In 2025, the individual applicant income limit is $967 / month. For married couples, with both spouses as applicants, each spouse can have a monthly income up to $967. When only one spouse is an applicant, the individual income limit is used and the non-applicant’ spouse’s income is disregarded. Furthermore, monthly income from the applicant spouse can be transferred to the non-applicant spouse as a spousal income allowance, also called a Monthly Maintenance Needs Allowance.
In Colorado, there is a minimum income allowance, set at $2,555 / month (eff. 7/1/24 – 6/30/25), which is intended to bring a non-applicant spouse’s monthly income up to this amount. There is also a maximum income allowance, which in 2025, is $3,948 / month. While this potentially allows a non-applicant spouse a higher income allowance, the exact amount one can receive is dependent on their shelter and utility costs. However, a Spousal Income Allowance can never push a non-applicant’s total monthly income over $3,948. This Monthly Maintenance Needs Allowance is intended to ensure the non-applicant spouse does not become impoverished.
Assets
In 2025, the asset limit is $2,000 for a single applicant. For married couples, with both spouses as applicants, the asset limit is $3,000. When only one spouse is an applicant, the assets of both spouses are still limited, as Medicaid considers the assets of married couples to be jointly owned. The non-applicant spouse, however, is allocated a larger portion of the assets to prevent spousal impoverishment. In this case, the applicant spouse can retain up to $2,000 in assets and the non-applicant spouse can keep up to $157,920 as a Community Spouse Resource Allowance.
Some assets are not counted towards Medicaid’s asset limit. These generally include an applicant’s primary home, household furnishings and appliances, personal effects, and a vehicle.
Assets should not be given away or sold under fair market value prior to applying for long-term care Medicaid. This is because CO Medicaid has a 60-month Look-Back Rule for applicants of long-term Home and Community Based Services. Violating this rule results in a Penalty Period of Medicaid ineligibility.
Home Ownership
The home is often the highest valued asset a Medicaid applicant owns, and many persons worry that Medicaid will take it. For CO Medicaid eligibility purposes, the home is exempt (non-countable) in the following circumstances.
– The applicant lives in the home or has Intent to Return, and in 2025, their home equity interest is no greater than $1,097,000. Home equity interest is the current value of the home after subtracting any debt against it. Equity interest is the portion of the home’s equity value that is owned by the applicant.
– The applicant has a spouse living in the home.
– The applicant has a child under 21 years old living in the home.
– The applicant has a disabled or blind child of any age living in the home.
More on the potential of Medicaid taking the home.
Medical Criteria: Functional Need
An applicant must require a Nursing Facility Level of Care (NFLOC) to be eligible for CFC. A Level of Care (LOC) Eligibility Determination Screening Instrument is utilized to determine one’s level of care need. To meet a NFLOC, an applicant must require assistance with a minimum of 2 out of 6 Activities of Daily Living (ADLs). The 6 ADLs are toileting, bathing, dressing, transferring, mobility, and eating. Persons with cognitive (memory) deficits or behavioral issues (i.e., wandering), which are common in persons with Alzheimer’s Disease or a related dementia, are also taken into account. If there is a need for moderate supervision related to cognition and / or behavior, this may qualify one as requiring a NFLOC. A diagnosis of dementia in and of itself does not mean one will meet the level of care need.
Qualifying When Over the Limits
Having income and / or assets over Medicaid’s limit(s) does not mean an applicant cannot still qualify for CO Medicaid. There are a variety of Medicaid planning strategies that can be used to help persons who would otherwise be ineligible to become eligible. Some of these strategies are fairly easy to implement, and others, exceedingly complex. Below are the most common.
Persons with income over the limit who are accessing CFC via the Elderly, Blind and Disabled Medicaid Waiver can become income-eligible by depositing “excess” income into a Miller Trust. Also called a Qualified Income Trust, income deposited into this type of trust no longer counts as income for eligibility purposes.
When persons have assets over the limits, one option is to “spend down” assets. Examples include paying off debt, making home improvements, such as updating heating and plumbing, and purchasing pre-paid funeral and burial expense trusts called Irrevocable Funeral Trusts. There are many other options when the applicant has assets exceeding the limit.
Inadequate planning or improperly implementing a Medicaid planning strategy can result in a denial or delay of Medicaid benefits. Professional Medicaid Planners are educated in the planning strategies available in Colorado to meet Medicaid’s financial eligibility criteria without jeopardizing Medicaid / Health First Colorado. There are also planning strategies that not only help one meet Medicaid’s financial criteria, but also protects assets from Medicaid’s Estate Recovery Program, preserving them for family as inheritance. These strategies often violate Medicaid’s 60-month Look-Back Period, and therefore, should be implemented well in advance of the need for long-term care. However, there are some workarounds, and Medicaid Planners are aware of them. For these reasons, it is highly suggested one consult a Certified Medicaid Planner for assistance in qualifying for Medicaid when over the income and / or asset limit(s).
How to Apply for CO’s Community First Choice Program
Before You Apply
Prior to submitting an application for CFC services, applicants need to ensure they meet the Medicaid eligibility criteria in Colorado. Applying when over the income and / or asset limit(s) will be cause for denial of benefits. The American Council on Aging offers a Medicaid Eligibility Test to determine if one might meet Medicaid’s eligibility criteria.
As part of the application process, applicants need to gather documentation for submission. Examples include copies of Social Security cards, Medicare cards, life insurance policies, property deeds, pre-need burial contracts, bank statements up to 60-months prior to application, and proof of income. A common reason applications are delayed is required documentation is missing or not submitted in a timely manner.
Application Process
In order to access Community First Choice’s suite of long-term care benefits, one must be eligible and enrolled in CO Medicaid / Health First Colorado. Persons can apply online at Colorado PEAK, in-person at one’s local CDHS office, by calling the Department of Health Care Policy & Financing at 800-221-3943, or by submitting a completed paper application.
Persons can apply for CFC services & supports beginning July 1, 2025. Current Health First Colorado beneficiaries who are not receiving Home and Community Based Medicaid Waiver services, should contact their local Case Management Agency to initiate the application process for CFC benefits.
Current Health First Colorado beneficiaries who are receiving Home and Community Based Medicaid Waiver services can enroll in CFC at the time of their annual eligibility redetermination, also called a continued stay review.
More about CFC. The Colorado Department of Health Care Policy and Financing (HCPF) administers Community First Choice.
Approval Process & Timing
The Medicaid / Health First Colorado application process can take up to 3 months, or even longer, from the beginning of the application process through the receipt of the determination letter indicating approval or denial. Generally, it takes one several weeks to complete the application and gather all of the supportive documentation. If the application is not properly completed, or required documentation is missing, the application process will be delayed. In most cases, it takes between 45 and 90 days for the Medicaid agency to review and approve or deny one’s application. Based on law, Medicaid offices have up to 45 days to complete this process (up to 90 days for disability applications). However, despite the law, applications are sometimes delayed even further.