⚠️ 2026 REGULATORY UPDATE:
Per (MSB) 25-11-06-B, all Health Maintenance Activities (HMA) are now governed by the Direct Care Services Calculator (DCSC). Documentation must now align with specific Task Standards that set maximum time limits for skilled care.
Key Takeaways (TL;DR)
- HMA Defined: Skilled tasks (like bowel care, wound care, or ventilator support) that would typically require a nurse but are performed by a family caregiver.
- The Soft Cap: HMA is limited to 4,750 hours per year (~91 hours per week) before an exception is required.
- The Calculator: The Direct Care Services Calculator (DCSC) is now the mandatory tool used to determine your authorized hours.
- Task Standards: Every task (e.g., "Dressing with skilled skin care") now has a state-mandated maximum time limit.
- Clinical Necessity: Documentation must prove why a task is "Skilled" rather than "Personal Care."
What are Health Maintenance Activities (HMA) in Colorado?
Health Maintenance Activities (HMA) are routine, repetitive health tasks, such as wound care, ventilator management, or specialized feeding that a person with a disability cannot physically do themselves. Because these are considered skilled care, Colorado's Community First Choice (CFC) program requires specific medical documentation from a Licensed Medical Professional to authorize a family caregiver to be paid for these tasks.
Why Does My Documentation Keep Getting Denied?
Under the new SB 25-11-06-B rules, the most common reason for service denials is a "gap" between your daily logs and the mandatory Task Standards.
When you go through your Level of Care (LOC) Screen, your description of care must align with the Direct Care Services Calculator (DCSC). If your records are outdated—older than one year for a child or three years for an adult—the Department of Health Care Policy & Financing (HCPF) cannot verify the skilled nature of the task. Without this proof, your Case Manager may be forced to approve the task as "Personal Care" only, or deny the hours entirely.
The HMA "Master List": Tasks That Require Skilled Documentation
To receive authorization for the care you provide, you must document the specific intervention level. Below are the common categories and how they are evaluated under the 2026 Task Standards:
| Task Category | What Needs to be Documented | Why it Counts as "Skilled" |
|---|---|---|
| Skin & Wound Care | Detail of wounds, treatment required, and prescription creams. | Risk of infection or inability to apply meds independently. |
| Feeding/Eating | Gastrostomy tube schedules or syringe feeding. | Physiological swallowing problems or choking risks. |
| Bladder/Bowel | Use of catheters, colostomy care, or bowel programs. | Tasks that go beyond simple toileting assistance. |
| Medication Assist | Cognitive or physical limitations requiring hands-on help. | Managing meds when clinical judgment isn't required but help is. |
| Respiratory Care | Oxygen flow adjustments, nebulizers, or ventilator care. | Use of complex respiratory equipment. |
Important for Parents: For children, documentation must explain how the care is "above and beyond" the Age-Appropriate Task Standards typically expected for a child of that same age.
The 4,750-Hour Annual Soft Cap
Per Section 8.7523.D, HMA is now subject to an annual limit of 4,750 hours per year.
- The Limit: This averages to approximately 91 hours per week.
- The Exception: If your loved one requires more than 4,750 hours annually, an exception request must be submitted 30 days prior to your plan renewal. This request triggers a mandatory review by a Registered Nurse (RN) or a Case Management Supervisor to ensure the care is necessary to avoid institutionalization.
3 Pillars for Stronger HMA Submissions
- Use the Official Checklist - Your Case Manager should provide you with the HMA Member Documentation Checklist. This is your roadmap. Don't guess what the state needs; follow the checklist task-by-task to ensure every "skilled" minute is accounted for.
- Check Your Dates - Before your LOC Screen, ensure every medical record is current. If a treatment plan is older than the 1-year (child) or 3-year (adult) limit, it must have a recent review date (e.g., "Reviewed July 2025") from your doctor.
- Align Your Expertise - When you speak with your Case Manager, use the same language found in your medical records. If your doctor's note says "Stage 2 wound" and you describe it as "a little scratch," it creates a discrepancy.
How We Support Your Household
The shift toward task-based calculations and strict annual caps is a significant transition for Colorado families. We view our role as your clinical advocate in this process.
- Life Experience Recognition: We recognize that a family member managing a complex disability is an expert. We are the only Colorado agency that credits your Life Experience as Work Experience, allowing you to move into higher pay tiers to offset the new hour limits.
- Bureaucracy Management: We handle the complex documentation requirements and the multi-tier review process, allowing you to focus on providing care.
- Rate Transparency: We operate with low overhead to ensure the highest possible percentage of the Medicaid dollar stays within your household.
Sources & Regulatory References
- Rule SB 25-11-06-B (10 CCR 2505-10 8.7523): HMA Exclusions & Limitations
- HCPF Policy Memo 26-001: Health Maintenance Activities Documentation Requirements
- Direct Care Services Calculator (DCSC): Official Task Standard Resources
- Section 8.7607.A: CFC Direct Care Services Exception Process
Frequently Asked Questions
What if my HMA documentation is missing?
If you can't provide current documentation, the task risks not being approved as HMA. However, it may still be approved as Personal Care, though this may change your authorized hours.
Can I keep my current services while I look for documents?
If you already have HMA services, they can usually be carried over for a few days into a new authorization while you obtain the necessary paperwork.
Who counts as a "Licensed Medical Professional"?
For HMA purposes, this includes a Physician (MD/DO), Physician Assistant (PA), or Advanced Practice Nurse (APN) including Nurse Practitioners (NPs).
Does an IHSS agency help with this?
Yes! In-Home Support Services (IHSS) agencies are encouraged to help you gather this documentation. At Caregivers First Choice, we make this "admin" side invisible for you.
What is the Direct Care Services Calculator (DCSC)?
This is a tool used by Case Managers, specifically for children, to determine how much care is "age-appropriate" versus "skilled".



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