Colorado Medicaid Group Rate Rule: Where Things Stand

Colorado Medicaid Group Rate Rule: Where Things Stand

Colorado's proposed Medicaid group rate rule, MSB 26-04-15-A, is still in draft form, and HCPF narrowed it further in the version released ahead of Final Adoption, targeted for October 9. The Colorado Department of Health Care Policy and Financing (HCPF) held its Initial Review before the Medical Services Board on September 11, 2026, and the latest draft tightens the rule's core definition in a way that matters directly to how it applies in a shared household. Once finalized, it could change how caregivers are paid for hours spent serving two or more family members in the same home. Some of what follows could still shift before the vote. If you care for one Medicaid member, none of this touches you. If you care for two of your own family members in the same household under the same authorization, here's what's changed and what's settled.

Who This Actually Affects

Most family caregivers enrolled through Caregivers First Choice care for a single person: a parent, a spouse, a child, or a sibling. That relationship isn't touched by this rule. The rule targets a narrower situation: one caregiver serving two or more Medicaid members in the same home during the same continuous stretch of care. Picture a mother in Jefferson County caring for her two sons, both authorized for IHSS Personal Care under Community First Choice (CFC). If she's delivering the same service to both boys during the same Time Span, that's Group Rate territory. If she's doing Homemaker tasks for one son and Personal Care for the other at the same time, HCPF's own examples confirm individual rates still apply, because they're different services.

What Counts as the Same Time Span

This definition just got more precise, and the change favors caregivers in shared households.

Under the earlier draft, a Time Span began the moment a caregiver started serving any member in the home and didn't end until the caregiver finished with every member there. The latest draft changes both ends of that window. A Time Span now starts only once the caregiver is actually serving two or more members, not from the moment care begins with the first one. It ends either when the caregiver finishes with everyone, or the moment care drops back down to fewer than two members within a billable unit, whichever comes first.

What that means in practice: if you spend the first hour of a shift with one family member alone, then your second family member's care starts and overlaps or alternates with the first, only that overlapping stretch counts as the Time Span. The solo hour before it isn't swept in. Alternating between two people who are both receiving the same service during that overlapping window still counts as one Time Span. What ends it: finishing with everyone, dropping back to one member, or switching to a different kind of service.

When the Rule Does, and Doesn't, Apply

HCPF's September 11 hearing examples still hold, and the new Time Span language formalizes the clearest one directly into the rule text.

• One caregiver alternating the same service between two members throughout a shared stretch of time falls inside the Group Rate criteria. That's the core case.
• One caregiver providing Homemaker to one member and Personal Care to another during the same stretch doesn't. Different services mean the criteria aren't met, same household, same caregiver, same hour.

A caregiver who fully completes one member's service before starting a separate period for the other isn't in a shared Time Span either. The revised definition now says this directly: once service to a second member stops within a billable unit, the Time Span ends. Sequential, one-at-a-time care in a household with two members doesn't automatically trigger the Group Rate just because both members live there.

Your Care Plan Stays Tied to Your Own Needs

This is new in the latest draft, and it's worth knowing if you're a family caregiver worried about a housemate's needs spilling into your own authorization. HCPF added explicit language requiring Case Managers to keep service authorizations individualized to each member's specific assessed need, and specifically states those authorizations "should not be altered or influenced by another member receiving the same service within the same location." Your hours get decided by your family member's own needs, not adjusted because someone else in the home also receives care from you.

Case Managers are also now required to document, in the member record, whether a Group Rate or individual rate is anticipated. That's a paperwork change on the agency and Case Management Agency side, not something that falls on you.

The Rule Is Still Moving

Final Adoption is six days out as of this writing, targeted for October 9, 2026, with a proposed effective date of November 30 and a federal State Plan Amendment targeted for January 1, 2027. HCPF has revised this draft at least twice already based on feedback from caregivers and providers, most recently tightening the Time Span definition and adding the authorization-independence language above. Caregivers First Choice has been tracking this through both the September 11 hearing and the October redline, and we'll update this page again once the Board votes.

What This Could Mean for Reimbursement

The current draft sets the Group Rate at no less than 50 percent of the individual rate per member, not a flat 50 percent. That's a floor, not a fixed final number, and HCPF's stated intent is for providers to be paid the same as, or more than, they'd get serving one person. Reimbursement and caregiver wage are two different things regardless of where the final number lands. Whether your pay changes for shared-time hours will depend on how your agency structures wages around whatever the final reimbursement figure turns out to be.

Caregivers First Choice caregivers with a multi-member household situation can reach out to us by calling/texting (303) 800-7081 with questions. We don't have every answer yet either, but we're tracking this closely.