Key Takeaways
- Colorado's weekly caregiver limit caps how many hours one caregiver can be paid for one member each week. It phases in over a year, not all at once.
- Phase 1 (84 hours/week) closed July 31, 2026. HCPF continues reviewing submitted requests on a rolling basis through August 31, 2026.
- Phase 2 (70 hours/week) opens November 1–30, 2026, for members receiving more than 70 hours/week from a single caregiver without an approved exception.
HCPF just published a new Tips for Submitting a Strong Exception Request resource to help agencies prepare stronger Phase 2 submissions. - Only a provider agency or CDASS employer can file the exception request — a caregiver or family member cannot submit it directly. That makes your choice of agency a practical factor in how many hours you can keep.
Why Does This Policy Exist?
The weekly caregiver limit didn't appear in isolation. It's one piece of a broader set of Medicaid sustainability initiatives HCPF has been rolling out since 2025, following the Governor's August 2025 executive order and subsequent HCPF budget actions. Those initiatives responded in part to new fiscal pressure at the federal level: after Congress passed H.R. 1 (the One Big Beautiful Bill Act) in July 2025, changes to federal Medicaid funding contributed to a significant state budget shortfall, and HCPF has been reassessing multiple LTSS programs as a result.
That said, HCPF's own stated rationale for the 56-hour weekly caregiver cap specifically is safety and care quality, not budget. The department has described the limit as a response to situations where a single caregiver was working well beyond what's sustainable, in some cases over 100 hours a week, with the goal of reducing caregiver burnout and the risk to a member if their one caregiver becomes unavailable. The exception process exists precisely to keep that safety standard from becoming a rigid rule when a member's documented needs call for continuity with one caregiver.
What Is Colorado's Weekly Caregiver Limit?
What is the weekly caregiver limit? It's an HCPF rule capping the hours one caregiver can be paid to provide one Medicaid member each week, phasing from 84 hours (mid-2026) down to 56 hours (mid-2027). It doesn't cut a member's authorized care, hours above a caregiver's limit must come from an additional caregiver, unless the agency successfully requests an exception.
Why Did HCPF Publish New Exception Request Guidance?
As Phase 1 came to a close on July 31, 2026, HCPF released a new tips resource for provider agencies and CDASS employers. According to HCPF's guidance, the update reflects common themes HCPF identified while reviewing submitted exception requests. Essentially, patterns behind which requests moved smoothly and which needed extra back-and-forth.
The tips resource emphasizes that a strong request should clearly show:
- The specific clinical, behavioral, communication, or safety needs that make continuity with one caregiver necessary
- The risks to the member if care is split across multiple caregivers
- Why additional caregivers can't be safely trained or added in the required timeframe
- What alternatives were considered and why they didn't work
HCPF also flagged documentation that, on its own, tends to fall short. For example, general statements about staffing shortages, caregiver preference, or a member's comfort with their current caregiver, without member-specific detail behind them.
What Are the Weekly Caregiver Limit Phases?
| Phase | Hour Threshold | Submission Window | HCPF Review Period |
|---|---|---|---|
| Phase 1 | More than 84 hrs/week | July 1–31, 2026 (closed) | Through Aug 31, 2026 |
| Phase 2 | More than 70 hrs/week | Nov 1–30, 2026 | Through Dec 31, 2026 |
| Phase 3 | More than 56 hrs/week | May 1–31, 2027 | Through Jun 30, 2027 |
HCPF has stated that submitted requests are reviewed on a rolling basis; specific review-period end dates haven't been published in the guidance available for this article.
If a member goes over the limit outside a phase window — say, after a recertification or a change in condition — the agency can submit as soon as the need is identified; it doesn't have to wait for the next window.
What Are the Exception Categories?
An exception is only granted if a member's situation fits one of four categories, backed by documentation:
- Extraordinary clinical acuity — complex diagnosis, medical fragility, and a documented risk that isn't reasonably reduced by PPE
- Workforce access barriers — rural/frontier location, specialized skill needs, or an uncommon-language requirement, with documented recruitment attempts that didn't succeed
- Transitional or stabilization periods — a recent hospital discharge, a post-crisis stabilization window, or active recruiting/training after losing a caregiver
- End-of-life circumstances — continuity with a primary caregiver that's clinically appropriate near the end of life
For the full walkthrough of each category, the documentation involved, and what happens after a request is submitted, see our 56-Hour Caregiver Cap Exception Process guide.
This isn't a shortcut list. HCPF built the exception process around the member's documented needs, not around what a caregiver or family would prefer. That's why the guidance is explicit that general staffing shortages, caregiver preference, or a member's comfort with their current caregiver aren't enough on their own. An exception exists to protect continuity of care when it's clinically or functionally necessary, not to preserve a schedule. Understanding that logic is more useful than memorizing the categories, because it's the same standard HCPF applies to every request it reviews.
Why Does This Matter If You're Choosing a Caregiving Job?
If you're a family or professional caregiver, this rule touches your paycheck directly. Since only your agency can file the exception request, you can't submit it yourself — an agency's follow-through on paperwork, documentation, and deadlines is part of whether you can keep hours above the phased cap with the member you already care for.
At Caregivers First Choice, that's part of why we built our own step-by-step guide to the exception process — so caregivers and families can see exactly how it works and what it takes to file a strong request.
Frequently Asked Questions
Does the weekly caregiver limit reduce a member's approved care hours?
No. It limits how many hours one caregiver can be paid for one member per week. A member's authorized hours and budget don't change — hours above the cap need to come from an additional caregiver, unless an exception is approved.
Who can submit a Weekly Caregiver Limit Exception Request?
Only the provider agency or CDASS employer. A member or family caregiver cannot file it directly. For Community First Choice members, the agency also coordinates with the case manager, who completes a required attestation.
When does Phase 2 of the weekly caregiver limit start?
The Phase 2 submission window runs November 1–30, 2026, covering members receiving more than 70 hours/week from a single caregiver without an approved exception. HCPF review continues through December 31, 2026.
What happens if a provider misses a submission window?
Per HCPF's guidance, if an exception request isn't submitted during the required phase, the provider may be subject to compliance actions. If a provider identifies the need after the window closes, HCPF advises submitting the request as soon as the need is identified.
What documentation does a strong exception request need?
Member-specific clinical, behavioral, or safety documentation tied to one of the four exception categories, an explanation of risks if the exception is denied, and a clear backup staffing plan. General statements about staffing shortages or caregiver preference aren't considered sufficient on their own.
Can care continue while an exception request is under review?
Yes. Once a request is submitted, it enters pending status, and the caregiver isn't required to follow the weekly limit until HCPF issues a determination.
Where can I find HCPF's official guidance?
The tips resource, submission checklist, and other implementation materials are posted on HCPF's Long-Term Services and Supports Training webpage under the Weekly Caregiver Limit section.
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