Self-Direction and FMS in Colorado

All states: self-direction map

Colorado self-direction at a glance

Last verified against state sources: 2026-10-13.

Which Medicaid programs in Colorado offer self-direction?

Colorado has two participant-directed options: Consumer-Directed Attendant Support Services (CDASS) and In-Home Support Services (IHSS). Both are run by the Department of Health Care Policy and Financing (HCPF), and since July 1, 2025 both are delivered under Community First Choice, a Medicaid state plan option. In CDASS the member is the legal employer and manages a monthly budget. In IHSS the member picks and directs the attendants, but a licensed agency is the employer.

• Consumer-Directed Attendant Support Services (CDASS): serves children and adults on Health First Colorado (Colorado's Medicaid program) who meet an institutional level of care and have an assessed need for Personal Care, Homemaker or Health Maintenance Activities. HCPF's Participant-Directed Programs Unit runs it, local Case Management Agencies handle enrollment, and Consumer Direct Colorado provides training. The member, or an Authorized Representative, has both employer authority and budget authority. The member manages a monthly CDASS allocation and sets attendant wages.
• In-Home Support Services (IHSS): serves the same group of children and adults, for the same three services. HCPF runs it, and IHSS-approved licensed home care agencies deliver it, with training from Consumer Direct Colorado. The member or Authorized Representative selects, schedules and directs the attendants, family included. The agency is the legal employer and makes the hiring decision, so employer authority is shared in practice. We did not find a member-controlled budget described for IHSS. The state describes budget management only for CDASS.
• CDASS and IHSS through HCBS waivers (older authority, being phased out): before Community First Choice, these options were delivered through 1915(c) waivers. PPL's Colorado page still lists CDASS under the Brain Injury, Community Mental Health Supports, Complementary and Integrative Health, Elderly, Blind and Disabled, and Supported Living Services waivers. HCPF moved waiver members to Community First Choice at their Continued Stay Review, starting in July 2025. The same FMS and employer rules apply. We did not find how many members, if any, still receive these services under a waiver.

Employer authority means the member recruits, hires, schedules and supervises the workers. Budget authority means the member also manages a set amount of money for the service. A member cannot combine CDASS with IHSS or with agency attendant services. IHSS can be combined with agency services, and IHSS members can switch agencies at any time through their case manager. HCPF describes both options on its Participant-Directed Programs page and explains the move to the state plan on its Community First Choice page.

Who handles financial management services (FMS) in Colorado?

Two state-contracted vendors handle financial management services for CDASS: Palco, Inc. and Public Partnerships, LLC (PPL). Both work as fiscal/employer agents, which means the vendor runs payroll and taxes while the member or Authorized Representative stays the legal employer of the attendants. Members choose between the two and can switch four times a year. IHSS has no FMS vendor at all.

A fiscal/employer agent (F/EA) is the organization that handles the paperwork side of being an employer. The state-branded CDASS FMS FAQ says the FMS obtains the employer's federal tax ID number, runs payroll and taxes, issues W-2s, provides workers' compensation coverage, tracks the budget and supplies the EVV technology.

• Legal employer in CDASS: the member, or the member's Authorized Representative, is the employer of record. The FMS acts as the employer's agent.
• Legal employer in IHSS: the IHSS agency. It handles payroll, training, skills checks and backup care for every attendant, family members included, while the member or Authorized Representative directs the care.
• Choosing and switching: CDASS members pick Palco or PPL. HCPF's CDASS policies and resources page says a change of FMS takes effect on the 16th of March, June, September or December, with transfer paperwork due to the new FMS by the 1st of that month.
• How the FMS is paid: the state pays each FMS a per member per month fee ($103.21, according to the June 2026 FMS FAQ). That fee is separate from the member's allocation.

The FMS also enforces the budget. The FMS FAQ says spending from 100 to 109.99 percent of the monthly budget is tolerated, spending from 110 to 129.99 percent can trigger an overspending episode, and the FMS denies anything over 129.99 percent. CDASS employers set attendant wages within the budget. Colorado overtime applies after 40 hours in a week or 12 hours in a day or shift for the same employer, and the FMS calculates it.

Who can be a paid caregiver under self-direction in Colorado?

Family members can be paid attendants in both CDASS and IHSS. That includes legally responsible persons, which Colorado defines as the parent or guardian of a minor child or the member's spouse (including a qualifying common-law spouse). Two limits apply: a legally responsible person can be paid for no more than 7 hours of Homemaker per member per week, and every caregiver has daily and weekly caps on paid hours.

• Services family can be paid for: Homemaker, Personal Care and Health Maintenance Activities, under both CDASS and IHSS, according to HCPF's Community First Choice FAQ.
• Homemaker limit for legally responsible persons: 7 hours per member per week, in effect since June 13, 2026 (HCPF OM 26-042).
• Per-caregiver caps: one caregiver cannot be paid for more than 16 hours a day. Since July 1, 2026 one caregiver cannot be paid for more than 84 hours a week of Homemaker, Personal Care and Health Maintenance Activities combined (HCPF OM 26-043). The weekly cap is scheduled to drop in 2027, as described below.
• Relative Personal Care: this is no longer a separate service under Community First Choice. Family members now provide ordinary Personal Care, under the rules above.
• IHSS hiring: because the IHSS agency is the employer, it makes the hiring decision. An agency may decline a family member whose skills it cannot confirm.

We did not find a rule on whether an Authorized Representative can also be a paid attendant, or on any limits for legal guardians of adults. Ask the member's case manager or HCPF's Participant-Directed Programs Unit before relying on either arrangement.

One tax point matters to live-in family caregivers. HCPF's informational memo IM 26-001 (January 7, 2026) says that, after an IRS private letter ruling dated December 2025, payments for certain Community First Choice direct care services qualify as Difficulty of Care payments for live-in caregivers. CDASS attendants claim the exclusion through their FMS.

Does EVV apply to self-directed workers in Colorado?

Yes. Electronic visit verification (EVV) is required in both CDASS and IHSS. CDASS attendants use the EVV system supplied by the member's FMS vendor, and IHSS attendants use the system their agency chose. Live-in caregivers in both options can qualify for an exemption.

• CDASS: the FMS vendor provides the EVV system. HCPF's EVV FAQ says a member who wants a different EVV system changes FMS vendor at quarterly open enrollment. The employer must approve EVV records before timesheets go to the FMS for billing. PPL's Colorado page says its attendants use the Time4Care mobile app or a telephone option. We did not find which EVV product Palco uses for Colorado CDASS, so ask Palco directly.
• CDASS strikes: a monthly EVV match rate of 79 percent or lower earns the employer a strike. Strikes reset each February 15. Five strikes in a year means removal from CDASS for 365 days.
• IHSS: the IHSS agency chooses either the free state EVV solution from Sandata or its own system that feeds the Sandata aggregator. IHSS claims without a matching EVV record are denied.
• Live-in exemption: HCPF's EVV program manual says live-in caregivers in CDASS and IHSS are eligible for the live-in caregiver exemption. In CDASS the employer of record completes the exemption form and the FMS keeps it.

One question could not be confirmed. We did not find a statement on whether a CDASS attendant's paycheck is held back for a shift that has no verified EVV record. The sources describe strikes against the employer, not a rule about the attendant's pay. Ask the member's FMS vendor or HCPF's Participant-Directed Programs Unit at HCPF_PDP@state.co.us.

What is changing next for self-direction in Colorado?

The weekly cap on paid hours for one caregiver is scheduled to drop from 84 to 70 hours on January 1, 2027, and to 56 hours on July 1, 2027. The cap covers Homemaker, Personal Care and Health Maintenance Activities combined, and it applies in both CDASS and IHSS. Members who rely on one attendant for long weeks, often a family member, will need more than one caregiver to cover the same hours.

The schedule comes from HCPF's Community First Choice FAQ (updated July 1, 2026), which describes HCPF OM 26-043. The 16 hour daily limit stays in place. For how exceptions are requested, read the memo itself in HCPF's 2026 memo series or ask the member's case manager.

A second item is still in progress. HCPF's Community First Choice timeline shows the department finishing its waiver actions with the federal Medicaid agency (CMS) and submitting rules to remove the Community First Choice services from the HCBS waivers, with a window that runs from late 2026 into early 2027. That timing is HCPF's plan and is not final. Once it is done, CDASS and IHSS would be delivered under Community First Choice only. We did not find a statement on whether any self-directed service will remain under a waiver afterward.

Colorado self-direction sources

• HCPF: Participant-Directed Programs
• HCPF: CDASS policies and resources
• HCPF: Community First Choice option
• HCPF: Community First Choice FAQ (updated July 1, 2026)
• HCPF: Electronic Visit Verification frequently asked questions
• HCPF: Electronic Visit Verification program manual
• Consumer Direct Colorado: CDASS FMS FAQ (updated June 2026)
• Consumer Direct Colorado: CDASS and IHSS FAQ
• Public Partnerships (PPL): Colorado CDASS

Related reading

• Self-Directed Medicaid Home Care Services in 2026
• Understanding Self-Direction and FMS
• Self-Direction Fiscal Intermediary: A Guide for Participant-Directed Care
• Why Do Self-Directed Participants Choose Your FMS as Their Fiscal Intermediary?
• Self-direction in every state (map)
• Colorado EVV requirements

Other states with a choice of FMS vendors

Alaska, Georgia, Idaho, Kentucky, Louisiana, Maryland, Minnesota, North Carolina, Texas, Utah. See every state on the self-direction map.

Page history

• October 13, 2026: Page rewritten and checked against state sources.

This page is a reference, not legal advice. State rules change, so confirm details with the state before you act on them.

Ankota provides software for FMS organizations and agencies that support self-direction. If you would like to talk through your program, contact Ankota or read more about Ankota's self-direction and FMS software.