Colorado’s IDD service system is administered through the Department of Health Care Policy and Financing and the Colorado Department of Human Services Division for Developmental Disabilities, in partnership with Community Centered Boards across the state. For IDD providers billing through Health First Colorado, 2026 brings active transition across several parts of the system, including the rollout of Community First Choice, ongoing waiver amendments, children’s waiver consolidations, and continued waitlist pressure on the DD waiver. Here is what providers need to understand.
Colorado’s IDD Waiver Structure
Colorado operates four primary Medicaid waiver programs relevant to IDD providers:
The Developmental Disabilities waiver, known as HCBS-DD, serves adults with intellectual and developmental disabilities who require 24-hour supervision and the most intensive level of community-based support. The DD waiver is Colorado’s most comprehensive IDD waiver and currently the only adult HCBS waiver with an active statewide waiting list. As of 2026, that waiting list remains a significant challenge. The estimated cost to end the DD waiver waiting list is substantial, and the state’s legislative and budget discussions continue to address how to expand access.
The Supported Living Services waiver, known as HCBS-SLS, serves adults with IDD who require support but do not need 24-hour supervision. The SLS waiver has a waiting list of approximately 2,400 or more individuals as of 2026. SLS services include residential supports, community access, supported employment, and other community-based services that enable adults with IDD to live in the community without institutional care.
The Children’s Extensive Support waiver, known as HCBS-CES, serves children with developmental disabilities or delays who have the most intensive support needs. The CES waiver operates with a concurrent 1915(b)(4) authority.
The Children’s Habilitation Residential Program waiver, known as CHRP, serves children and youth with developmental disabilities. As part of a 2025 waiver expansion tied to a lawsuit settlement, CHRP now also covers youth with serious emotional disorders who do not have an IDD diagnosis, inserting a new population into what had been an IDD-specific waiver. Providers serving children under CHRP should be aware that their program population may be expanding.
The Community First Choice Transition
The most operationally significant change for Colorado IDD providers in 2025 and 2026 is the transition of certain attendant-type services from HCBS waivers to Community First Choice, known as CFC. CFC is not a waiver. It is a Health First Colorado benefit program authorized under the state plan, designed to work alongside waivers for members who need long-term care.
During the period from July 1, 2025 through June 30, 2026, members on the EBD, SLS, and DD waivers are transitioning to CFC for attendant-type services at the time of their scheduled Continued Stay Review. Other waiver services such as day habilitation and residential habilitation remain under the waiver. This means that for many clients, the billing destination for some services has changed from the waiver to the CFC state plan benefit, while other services for the same client continue to bill through the waiver.
For providers, this creates a client-level billing complexity that requires tracking which services for each client are billing through CFC and which are billing through the relevant waiver. Billing coordinators who apply the same billing logic to all services for a client enrolled in SLS without distinguishing CFC services from waiver services will generate billing errors. The service-by-service distinction between CFC and waiver billing must be correctly applied to each client at each billing event.
Data from fiscal year 2025 to 2026 will reflect CFC in state reporting, which means providers should expect their payer mix documentation to reflect this transition in annual reports and audit communications from HCPF.
The Children’s Waiver Consolidation
On July 1, 2025, Colorado merged two children’s waivers into a single new program. The Children with Life-Limiting Illness waiver and the Children’s HCBS waiver were consolidated into the Children with Complex Health Needs waiver, known as CwCHN. During 2025 and 2026, members are transitioning from the former waivers to CwCHN at the time of their annual Continued Stay Review.
For providers who served children under either of the merged waivers, billing now occurs under the CwCHN structure rather than the previous waiver identifiers. Billing coordinators should confirm that their system configurations reflect the correct waiver identifiers for children who have completed their Continued Stay Review transition. Submitting claims under the former waiver identifiers for transitioned members will result in denials.
Additionally, the Children’s HCBS waiver was terminated on June 30, 2026. Any member still associated with that waiver identifier after the termination date is either on CwCHN or in a transition that requires coordination with their CCB.
Community Centered Boards: The Colorado-Specific Provider Relationship
A critical operational context for IDD providers in Colorado is the role of Community Centered Boards, known as CCBs. Unlike most states where case management is handled through Medicaid-contracted case management agencies, Colorado routes IDD waiver intake, waitlist management, case management, and service coordination through CCBs. For providers serving clients on the DD or SLS waiver, the CCB is the operational relationship that manages eligibility determinations, service authorizations, and case management, not a direct state agency relationship.
This means that authorization changes, service plan modifications, and eligibility updates for Colorado IDD waiver clients flow through the relevant CCB rather than directly through HCPF. Providers who need to initiate an authorization renewal or address a service plan change coordinate with the client’s CCB rather than submitting directly to the state. Understanding which CCB serves each client and maintaining current contact relationships with those CCBs is a prerequisite for effective billing management in Colorado.
What Colorado IDD Providers Need From Their Billing System
The CFC transition, the children’s waiver consolidation, and the ongoing DD waiver waitlist dynamics create specific requirements for any billing platform serving Colorado IDD providers.
Service-level billing routing: The system must support distinguishing CFC services from waiver services for the same client and routing each correctly rather than applying uniform billing logic to all services for a waiver-enrolled member.
Waiver identifier currency: As waiver identifiers change through consolidations and transitions, the billing system must reflect current identifiers for each client at each service date. Claims submitted under outdated waiver identifiers will be denied.
Authorization tracking through CCB relationships: Colorado’s CCB-administered authorization structure requires billing staff to understand the authorization management process as it flows through CCBs rather than through a direct state payer relationship.
State-specific compliance updates: Colorado’s active waiver transition environment means billing requirements are changing more frequently than in stable waiver environments. A billing platform that maintains Colorado-specific billing logic at the vendor level reduces the burden on agency staff to identify and implement each change independently.
Vertex Systems expanded its Colorado IDD billing support in 2025 as part of the platform’s state-specific expansion. Connect with the Vertex team to discuss Colorado-specific billing support and what the platform looks like for providers navigating the 2026 transition environment.
