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Quarterly Report #11
Implementation of the American
Rescue Plan Act of 2021, Section
9817
Enhancing Colorado’s Home and Community-Based Services
System through an Enhanced Federal Match
May 1, 2024
Submitted to: The Joint Budget Committee
Quarterly Report
January 2024 – March 2024
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Colorado Spending Plan Quarterly Report
to the Joint Budget Committee
Table of Contents
Key Takeaways 3
Introduction 3
Budget Overview 8
Project Overview 12
Timeline and Next Steps 34
Appendix 1: Project Descriptions & Updates 36
1. Strengthen the Workforce & Enhance Rural Sustainability 36
2. Improve Crisis & Acute Services 47
3. Improve Access to HCBS For Underserved Populations 50
4. Support Post-COVID Recovery & HCBS Innovation 60
5. Strengthen Case Management Redesign 73
6. Invest in Tools & Technology 79
7. Expand Emergency Preparedness 94
8. Enhance Quality Outcomes 95
9. Administration & Oversight 105
Appendix 2: Resources 106
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Key Takeaways
The Department of Health Care Policy & Financing (HCPF) continues to make
significant strides towards meeting the milestones for implementation of our 61
initiatives outlined in our ARPA HCBS spending plan. Please note, one project was
cancelled over this past quarter, moving our total initiatives from 62 to 61. This
abbreviated quarterly report includes an update on HCPF’s implementation efforts.
Projects that have had a change in their scope or budget over the past quarter are
further described in Appendix 1. All new content added to the appendix is colored in
blue font for easy identification. Since our last quarterly report, HCPF has:
● Engaged stakeholders by hosting a general webinar and 39 project-specific
meetings, and published 3 newsletters to inform about, and gain input on, the
Department’s ARPA HCBS projects;
● Initiated grantee monitoring for four grant programs with an external vendor to
ensure compliance with federal and state regulations;
● Completed three of six workshops as part of a new EDIA workshop series for
internal staff working on ARPA HCBS projects;
● Executed a total of 1,340 grantee agreements with individuals, providers, and
non-profit organizations across 26 large-scale grant, pilot, and community
funding initiatives.
● Two grant programs under projects 4.08 Respite Grant Program and 6.13
Connect CMAs to ADT Data, successfully completed all grant activities.
Introduction
The Colorado Department of Health Care Policy & Financing (HCPF) continues to make
significant progress towards implementation of the state’s American Rescue Plan Act
(ARPA) Medicaid Home and Community-Based Services (HCBS) spending plan.
The Department remains focused on the goals laid out in our initial plan:
● To supercharge existing initiatives
● Support the COVID-19 response and recovery
● Foster innovation and long-term transformative change
● Increase quality and fiscal stewardship
The 61 projects HCPF is supporting through these funds are focused on improving
access to community-based services and supports, strengthening the provider
network, and investing in the critical workforce providing the services. The initiatives
will also improve access by expanding availability of services, streamlining processes
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and enhancing quality for members and their families. These initiatives fall into the
following eight categories:
1. Strengthen the Workforce & Enhance Rural Sustainability
2. Improve Crisis & Acute Services
3. Improve Access to HCBS For Underserved Populations
4. Support Post-COVID Recovery & HCBS Innovation
5. Strengthen Case Management Redesign
6. Invest in Tools & Technology
7. Expand Emergency Preparedness
8. Enhance Quality Outcomes
Since our last report, submitted on February 1, 2024, the active projects continue to
make progress towards their goals. The ARPA project support team has been focused
on ensuring projects remain on track with their spending, as well as meet critical
deadlines. The team also continues to develop resources and tools to support the
project teams leading the work. Over this last quarter, the team has been working to
move forward the new monitoring program for our ARPA HCBS grantees. To date, four
grant programs have completed or are actively being monitored. An additional two
will begin monitoring in the next quarter. Additionally, the team has been closely
tracking the execution of project contracts for next fiscal year and the overall
spending by project. As we move closer towards the end of the ARPA time period,
teams are required to report to the ARPA leadership team when actual spending does
not match forecasted spending. The ARPA project support team continues to use the
project management software and uses dashboards to ensure consistent tracking of
progress and monitoring for risks or issues.
Between January and March 2024, HCPF hosted one stakeholder meeting attended by
providers, advocates, members, and families to continue to keep them informed on
the overall progress across our ARPA HCBS initiatives and to garner feedback and
recommendations. In addition to this large stakeholder webinar, project-specific
engagement has continued. HCPF also leverages the ARPA HCBS webpage as a method
of communication and transparency and has released two new ARPA Project Pulse
Newsletters, a monthly update for stakeholders on the status of ARPA initiatives and
upcoming engagement opportunities.
Per the June 3, 2022 State Medicaid Director’s Letter, the Centers for Medicare and
Medicaid Services is allowing for a one-year extension for states to spend the 10%
enhanced FMAP funds allowed under ARPA Section 9817. Spending now must conclude
on or before March 31, 2025, instead of the previous end date of March 31, 2024. To
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ensure enough time for a thorough closeout, HCPF is leveraging this additional time
and will conclude all spending by March 31, 2025.
The ARPA Leadership Team has continued to review individual project requests to
extend beyond their original end date of March 31, 2024. Project teams that feel that
they need additional time to complete their initiative successfully must present to the
Leadership Team justification for the extension and a new timeline for completion.
Project teams continue to be encouraged to maintain their initial timeline and
project schedule unless there are substantial risks of underspending or not
successfully completing the project by the original deadline of March 31, 2024. Since
our last quarterly report, eleven additional projects have requested and received
approval to change their project completion date. For the majority of these projects,
the scope and budgets are not changing, but instead they are extending their end
date to ensure successful completion of project goals. Four of the projects do have a
corresponding budget or scope change. Table 1 includes all project end dates. The
projects with adjusted end dates over the last quarter, are shown in blue.
We anticipate that a small number of additional projects may still come forward to
request an extension of their timeline. These additional extension requests would be
made based on unexpected barriers that emerge that threaten the ability of the team
to complete on the original timeline, or as shown above, to accommodate small scope
changes to expand the project’s capacity.
Table 1. Initiative Timelines
Project # Project Name End Date
1.01 Increase Payments to Providers and Workers March 31, 2025
1.02 Direct Care Workforce Data Infrastructure December 31, 2024
1.03 Standardized Core Curriculum & Specialization June 30, 2024
1.04 Resource & Job Hub December 31, 2024
1.05 HCBS Workforce Training Fund December 31, 2024
1.06 Career Pathways October 31, 2024
1.07 Public Awareness Campaign May 31, 2024
1.08 Home Health Delegation Complete
1.09 Workforce Compensation Research May 31, 2024
1.10 Rural Sustainability & Investment July 31, 2024
2.01 Behavioral Health Transition Support Grants December 31, 2024
2.02 Expand Behavioral Health Crisis Teams December 31, 2024
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2.03 IMD Exclusion, Risk Mitigation Policy December 31, 2024
3.01 Equity Study December 31, 2024
3.02 Buy-In Analysis September 30, 2024
3.03 Community Transitions Support August 30, 2024
3.04 HCBS Training for Members & Families December 31, 2024
3.05 Translation of Case Management Material December 31, 2024
3.06 Expand the Behavioral Health Safety Net December 31, 2024
3.07
Wrap-Around Services, including Peer Supports for Members
with Complex Needs December 31, 2024
3.08 AI/AN Culturally Responsive Services Capacity Grants December 31, 2024
4.01 Residential Innovation August 30, 2024
4.02 Promote Single Occupancy December 31, 2024
4.03
Child/Youth Step-down Options Program and Provider
Recruitment December 31, 2024
4.04 Tiered Residential Rates & Benefits June 30, 2024
4.05 Pilot CAPABLE December 31, 2024
4.06 Supported Employment Pilot Extension December 31, 2024
4.07 New Systems of Care December 31, 2024
4.08 Respite Grant Program May 31, 2024
4.09 Respite Rate Enhancement May 15, 2024
4.10 Home Mod Budget Enhancements December 31, 2024
4.11 Hospital Community Investment Requirements September 30, 2024
4.12 Community First Choice December 31, 2024
5.01 Case Management Capacity Building December 31, 2024
5.02 Improve & Expedite Long-Term Care Eligibility Processes December 31, 2024
5.03 Case Management Rates Complete
5.04 Case/Care Management Best Practices December 31, 2024
5.05 Case Management Agency Training Program December 31, 2024
6.01 Home Health/PDN Acuity Tool December 31, 2024
6.02 Specialty Search in Provider Specialty Tool Complete
6.03 Member-Facing Provider Finder Tool Improvement December 31, 2024
6.05 Member Tech Literacy May 31, 2024
6.06 HCBS Provider Digital Transformation December 31, 2024
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6.07 Innovative Tech Integration Cancelled
6.08 Care & Case Management System Investments December 31, 2024
6.09 Updates to Salesforce Database September 30,2024
6.11 Centers for Excellence in Pain Management December 31, 2024
6.12 Systems Infrastructure for Social Determinants of Health December 31, 2024
6.13 Connect CMAs to ADT Data May 31, 2024
6.14 Data Sharing with the SUA July 31, 2024
6.15 Improvements - System Communication [Interface with
Trails]
September 30, 2024
7.01 Emergency Response Plans September 30, 2024
7.02 Member Emergency Preparedness December 31, 2024
8.02 Provider Oversight December 31, 2024
8.04 P4P for PACE December 31, 2024
8.05 P4P for HH & Residential HCBS Complete
8.06 PACE Licensure December 31, 2024
8.07 eConsult to Improve Quality October 31, 2024
8.08 HCBS Provider Quality Dashboard October 31, 2024
8.09 Waiver Quality Expansion Complete
8.10 Criminal Justice Partnership December 31, 2024
8.11 EPSDT Benefits Training June 28, 2024
Also included in the June 3, 2022 State Medicaid Directors letter, was a change to the
ARPA HCBS reporting requirements. Both a budget and narrative report were required
to be submitted 75 days before the start of the October 1, 2022 federal fiscal quarter
(submitted to CMS on July 18, 2022). Following that submission, states were only
required to submit a budget update to CMS on a quarterly basis and a narrative every
other quarter. If changes are requested to project scopes, or if new projects are
proposed, then a narrative report should also be submitted in the off quarters. Given
this change in reporting cadence, HCPF is submitting an abbreviated report this
quarter, including a budget report and shortened narrative with descriptions for those
projects that have had a change in budget or scope. All 61 ARPA HCBS project
descriptions are listed in Appendix 1, with detailed information provided only for
those projects that have had changes over the past quarter. All new content added to
the Appendix since our previous report, is in blue text for ease of identification.
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Table 3. Revised Planned Spending by Year
Total FY 2021-22 FY 2022-23 FY 2023-24 FY 2024-25
$551.7 million $86.8 million $175.1 million $253.7 million $36.0 million
Budget Changes and New Funds Requested
The budget changes reflected in table 4 below are those that have been proposed
since our last quarterly report. Through our continued efforts to better forecast the
planned spending for each project through the end of the ARPA HCBS spending
timeframe, several projects identified excess funds in their project budgets that were
no longer needed to support the project’s goals. Additionally, eleven projects have
identified a need for an increase in their budget to support new components of their
project or costs that are higher than anticipated. The projects that have a change in
their budget because of a scope change are denoted with an asterisk (*) in the table
below.
As a reminder, a ‘reallocation fund’ was established, to hold funds that were not yet
obligated to a particular project but could be reallocated when requests came in.
These funds will continue to be leveraged as new requests come in from projects,
such as if they have a need to expand their scope or if estimated costs are higher than
anticipated. Additionally, the ARPA Leadership team has a tentative plan for using any
unused funds once project budgets are closed out in late fall/winter 2024. All
outlined budget changes are subject to approval by the Colorado Joint Budget
Committee (JBC) and Centers for Medicare and Medicaid Services (CMS). As a
reminder, all ARPA HCBS funds must be used to expand, enhance, and strengthen
HCBS services within the state and cannot be reallocated for other uses. More
detailed information about these changes can be found in Appendix 1 under the
associated project.
Table 4. Project Budget Adjustments (January-March 2024)
Project
Number
Project Name Budget Change Description
1.02 Direct Care
Workforce Data
Infrastructure
+$75,423 Budget increase of $75,423 (GPS)
to support a third round of the
direct care workforce survey.
1.05 HCBS Workforce
Training Fund
-$1,386,566 Budget decrease to align with
anticipated grant needs.
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6.07 Innovative Tech
Integration
-$150,000 Project cancelled. No funds
were spent and will be returned
to the reallocation fund.
6.09* Updates to
SalesForce Database
+$150,000 Budget increase to evaluate the
existing duplicate data and using
a tool that is already in place for
data duplication management
(Cloudingo), determine what
new deduplication rules need to
be put into place to ensure all
duplicate data is captured
during ongoing, weekly data
clearing processes.
7.02 Member Emergency
Preparedness
+$1,000,000 Budget increase to support the
distribution of additional
generators for HCBS members.
8.05 P4P for Home
Health & P4P for
HCBS
-$35 Decrease due to project closeout
and final budget reconciliation.
8.06 Pace Licensure +$99,912 Funds increased to extend
contract with vendor to
complete VBP work.
8.09 Waiver Quality
Expansion
-$37,903 Decrease to correct an invoicing
error.
8.10* Criminal Justice
Partnership
+$50,000 Additional funds will support a
contractor to provide guidance
on person-centered
stakeholdering for criminal
justice projects.
* Indicate those projects that have a budget increase as a result of a change in their scope.
Project Overview
HCPF continues to make significant progress towards executing the 60 active
initiatives to enhance, expand, and strengthen Colorado’s HCBS system. To date, five
projects have closed:
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still underway. This decision will help increase staff capacity on other projects as we
move into the final year of implementation and close-out.
Stakeholder Engagement
The Department continues to keep stakeholders at the center of this work. To provide
timely information and updates to stakeholders, the Department has developed a
series of opportunities for ongoing interaction. Since our last report, the following
activities related to stakeholder engagement have been undertaken:
● Continued maintenance of the ARPA HCBS webpages, including the very popular
“Grant Opportunities” page, which provides easy access to information about
grant opportunities and direct links to open Requests for Applications.
○ Analytics from December 26, 2023 – March 24, 2024:
■ 9,859 Total Pageviews (Cumulative to date: 98,001)
■ Top 5 Subpages (in order of most views):
● ARPA Grant Opportunities
● ARPA Stakeholder Engagement
● Workforce & Rural Sustainability Projects
● Project Directory
● Improve Access to HCBS for Underserved Populations
● Released three editions of our Project Pulse monthly ARPA HCBS newsletter to
share updates, highlight successes, and provide information about upcoming
engagement opportunities
○ January 2024 Newsletter
○ February 2024 Newsletter
○ March 2024 Newsletter
● Through March 2024, 1,382 individuals are signed up to receive the Project
Pulse ARPA HCBS newsletter (flat since last quarter)
● Hosted a quarterly ARPA HCBS webinar and continued project-specific
stakeholder engagement for select projects
○ 46 stakeholders participated in the ARPA HCBS webinar
● Project-specific engagement: 39 meetings with 543 total participants
● For stakeholder engagement related to ARPA HCBS to date, the Department has
conducted 258 meetings with a total of 10,445 attendees
Administrative Status & Hiring
The project teams leading the ARPA HCBS initiatives continue to meet at a regular
cadence to ensure projects move forward as planned. Key priorities for these teams
over the last quarter were monitoring project activities and milestones, tracking
expenditures and budget activity, and completing project and/or grantee monitoring.
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Figure 2. Dashboard: Project Reporting, page 4
3
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in place since October 2022 and since that time has been working with project teams
to support the development of grant agreements and to begin the execution of grant
programs. PCG is currently contracted to manage 17 grant programs with 10 project
teams; six of the project teams have more than one grant program as a part of their
project scope. As of the writing of this report, all seventeen grant programs working
with PCG have developed grant agreement template(s). There are a total of 16 active
grant programs with 524 executed grant agreements. The final program will have
active grant agreements in the upcoming quarter. PCG has been a huge support in
these efforts, providing invoicing webinars, office hours, and technical assistance
support for all grantees.
HCPF has also contracted with KPMG to assist with oversight, compliance, and
monitoring of the Department’s projects. KPMG completed their initial guidance
review in the Fall of 2022 and provided the Department with recommendations for
improvements. The Department has an action plan in place that we are executing to
make adjustments where changes are needed. In the first quarter of calendar year
2023, KPMG finalized the first phase of the project-specific risk assessment and
determined project risk scores. These scores were used to inform the monitoring
plan. Risk was assessed quantitatively, through a survey of project teams to collect
information on aspects of the project that may put them at greater risk of non- compliance, as well as qualitatively to gather contextual information about the
project. Examples of factors that would put a project at increased risk include: a
budget over $10M, whether they are working with an external vendor/contractor,
grant projects, and those that are generally more complex.
Sixteen projects were determined to fall in the high priority, or potentially high-risk
category, with another nine falling in the medium priority or mid-risk category. These
mid and high-risk projects began monitoring in the last quarter of the state fiscal year
2022-2023. KPMG met with each project team to better understand their particular
initiative and talk through any potential known risks and mitigation strategies. KPMG
then requested a sample of project payments, as well as supporting documentation,
policy or programmatic project guidance, and/or communication material from the
project teams. KPMG reviewed these to ensure that work completed was within ARPA
Section 9817 and other guidelines, including subrecipient guidance at 42 CFR Part
200.332. Following this review, KPMG produced project specific monitoring reports, to
provide feedback and suggestions on transactions and/or supporting documentation,
and on the materials developed by the project teams, such as policy or guidance
documents, to ensure compliance is addressed consistently across the project
timeframe. Each project team then met with KPMG again to review the findings
report. Teams that participated in this first round of monitoring continue working to
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implement recommendations from their individual reports. There were several
recommendations that applied to or cut across several projects. In these cases, the
project support team has developed a standardized approach to resolving the
identified risk.
Over the last quarter, KPMG executed the second phase of the project-based risk
assessment and monitoring. Utilizing information provided from PWA and the Power BI
dashboards, KPMG assigned risk scores once again to each initiative. With the goal of
conducting monitoring with all 61 projects before the end of the ARPA timeframe,
KPMG selected 30 initiatives for the second phase of monitoring. These projects were
not part of the initial 25 that participated in phase 1 monitoring. These 30 teams
participated in a survey to provide additional information to the KPMG team and
provided programmatic and financial documentation and communication from their
project activities. KPMG is analyzing these and project reports are anticipated to be
ready for each team with recommendations for improving their activities to ensure
compliance with all state and federal rules in the next quarter.
As mentioned above, KPMG is also supporting HCPF in the monitoring of ARPA HCBS
grantees. Gathering information from the project teams and PCG first and then
requesting additional background information from grantees, HCPF and KPMG are
evaluating the grantees in several categories, including risk for supplanting,
duplication of benefit, record retention, and alignment with project scope. Grantees
are being provided with a report of the outcomes of the monitoring and, when
required, an outline of required changes.
Projects by Phase, Category, and Identification
Legend: Project Category Color
Workforce & Rural Sustainability Access for Underserved
Crisis & Acute Services Recovery & Innovation
Case Management Emergency Preparedness
Tools & Technology Quality
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4.01 Residential Innovation Support Post-COVID Recovery & HCBS Innovation
4.02 Promote Single Occupancy Support Post-COVID Recovery & HCBS Innovation
4.03 Child/Youth Step-down Options Program and Provider Recruitment Support Post-COVID Recovery & HCBS Innovation
4.04 Tiered Residential Rates & Benefits Support Post-COVID Recovery & HCBS Innovation
4.05 Pilot CAPABLE Support Post-COVID Recovery & HCBS Innovation
4.06 Supported Employment Pilot Extension Support Post-COVID Recovery & HCBS Innovation
4.07 New Systems of Care Support Post-COVID Recovery & HCBS Innovation
4.08 Respite Grant Program Support Post-COVID Recovery & HCBS Innovation
4.09 Respite Rate Enhancement Support Post-COVID Recovery & HCBS Innovation
4.10 Home Modification Budget Enhancements Support Post-COVID Recovery & HCBS Innovation
4.11 Hospital Community Investment Requirements Support Post-COVID Recovery & HCBS Innovation
4.12 Community First Choice Support Post-COVID Recovery & HCBS Innovation
5.01 Case Management Capacity Building Strengthen Case Management Redesign
5.02 Improve & Expedite Long-Term Care Eligibility Processes Strengthen Case Management Redesign
5.03 Case Management Rates Strengthen Case Management Redesign
5.04 Case/Care Management Best Practices Strengthen Case Management Redesign
5.05 Case Management Agency Training Program Strengthen Case Management Redesign
6.01 Home Health/PDN Acuity Tool Invest in Tools & Technology
6.02 Specialty Search in Provider Specialty Tool Invest in Tools & Technology
6.03 Member-Facing Provider Finder Tool Improvement Invest in Tools & Technology
6.05 Member Tech Literacy Invest in Tools & Technology
6.06 Provider Digital Transformation & EHR Upgrades Invest in Tools & Technology
6.07 Innovative Tech Integration X Invest in Tools & Technology
6.08 Care & Case Management System Investments Invest in Tools & Technology
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Education Access &
Quality Social & Community Context
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increase. Approval for the $15 per hour base wage through a rate increase for HCBS
direct care workers was approved through Colorado’s Appendix K amendment on
November 5, 2021. Colorado subsequently submitted, and received approval on March
31, 2022, to extend the rate increases for both the 2.11% and $15 per hour base wage.
The 2.11% provider rate increase remained effective until July 1, 2022. The
Department received approval to adopt the $15 per hour base wage permanently for
all waiver programs on January 1, 2023. The Department has submitted an Appendix K
Amendment for the Targeted Rate Increases for Non-Medical Transportation and
Group Residential Support Services, along with the 3% Across the Board rate increases,
to CMS on May 25, 2023. As Colorado’s Appendix K amendment is effective until
November 11, 2023, the Department will be submitting a 1915(c) amendment to all
ten (10) waiver programs in July 2023 to increase these rates. These amendments
have an effective date of November 1, 2023, to ensure there isn’t a decrease in rates.
Sustainability Plan
Understanding that the ARPA funds have an end date, we are committed to
identifying funds to ensure long-term sustainability of this effort. Approved in the
Fiscal Year 2023-24 budget was funding to sustain the $15.75 per hour base wage
increase for all direct care workers employed by HCBS providers, as well as the other
ARPA HCBS funded rate increases. Included within the Fiscal Year 2024-25 budget
requests is funding to continue the new $16.55 per hour base wage increase for direct
care workers.
Capital Expenditure Plan
No capital expenditures for this project.
Project Changes
This project was extended to March 31, 2025. ARPA dollars will be used to fund a
Direct Care Worker wage increase through the end of calendar year 2024 and any
remaining ARPA funds from other ARPA projects are being considered for a one-time
provider stabilization payment as described above. Funding for that payment will be
allocated to this project if approved in the SFY24/25 Supplemental Budget Request.
Initiative 1.02. Direct Care Workforce Data Infrastructure
Under this project, HCPF will expand the data infrastructure to better
understand the current supply and demand for direct care workers and to track the
impact of each investment strategy on recruitment, retention, and turnover. The
Department will develop two surveys for the direct care workforce. The first survey
will be a staff stability survey for providers of long-term services and supports (LTSS)
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access free training, and view job boards to quickly be placed in positions. The newly
developed personal care/homemaker/universal worker training will be
accessible through this site, and individuals who completed the training would
be entered into a database for easy tracking of certification.
State Plan Amendment and Waiver Information
There are no state plan amendments or waivers required for this project.
Sustainability Plan
HCPF is enthusiastic about launching this new resource to expand and embolden
opportunities for the direct care workforce. Increasing the ease of navigation to
employment paired with standardized skills validation (Initiative 1.03) is seen as a
critical component to maintaining a sufficient and successful workforce.
Capital Expenditure Plan
A capital expenditure request was submitted for the following: website development
and Learning Management System.
Project Changes
No changes for this project over the previous quarter.
Initiative 1.05. HCBS Workforce Training Fund
Note: As of December 2021, this project has incorporated project 3.03 Disability
Cultural Competency Training for Behavioral Health Providers under the scope of its
efforts.
Note: As of March 2023, this project has been renamed “HCBS Workforce Training
Fund” instead of its previous name, “Establish a Training Fund”.
Providing more training opportunities and incentives for workers to gain higher level
skills would promote greater retention within the workforce. HCPF will establish a
training fund targeted to high-demand jobs and to support specialization and
advancement opportunities for the HCBS workforce, including the behavioral health
workforce. Funds may be distributed directly to the prospective or current worker, to
the employer to provide the training to their employees, or to a training provider.
Additionally, funds may be used to expand standard training provider resources or
trainer availability where gaps exist.
This project will also develop a disability-specific, culturally competent curriculum
that includes the different types of disabilities and incorporates people’s lived
experiences to help providers understand diverse populations’ perspectives. The
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Care Gaps, Developing Geographic Modifiers, and Creating Shared Systems in Rural
Communities.
The first of these strategies is to expand the provider network in rural communities by
identifying gaps and potential opportunities for expansion. A care desert, also known
as a medical desert, exists mostly in rural places and inner cities and leads to
inequalities in health care. The federal government now designates nearly 80 percent
of rural America as ‘medically underserved’. About 20% of the U.S. population live in
rural areas, but only 10% of doctors and other health care professionals operate in
those regions, and that ratio is worsening each year. Additionally, a higher proportion
of rural populations are made up of those over the age of 65.
HCPF first needs more data and analysis on where there are care deserts and
potential solutions in those areas. Through this project, HCPF will complete an
environmental scan of Colorado’s current HCBS provider network via a GIS heatmap;
create a tool for HCPF to update and track ongoing progress on a statewide level;
identify gaps by waiver, service, and provider type; find out which populations are
the most impacted; and give recommendations for provider or service expansion and
solutions in a final report.
One way to help prevent a care desert is to pay providers differently by region to
account for differences in cost structure, which would encourage more people to
work in direct care professions in areas that are currently underpaid. HCPF will design
rates by geographic region to account for the cost differential associated with
different locations. Geographic modifiers are intended to improve the
appropriateness of Medicaid rates to providers by accounting for the differences in
prices for certain expenses, such as clinical and administrative staff salaries and
benefits, rent, malpractice insurance, and other defined costs. HCPF is dedicated to
identifying ways for implementing these proposed geographic rates if found
advantageous in the Sustainability Plan.
The workforce shortage is particularly concerning in rural areas. HCPF will research
ways to partner with hospitals and rural health clinics to identify opportunities to
share resources and/or more efficiently and creatively offer services in rural areas.
The goal of this initiative is to increase access to services by setting up partnerships
across hospitals, clinics, and HCBS providers to share certain resources between them.
This may include using a coordinated pool of workers, training, personal protective
equipment, or other resources. HCPF will identify areas that would benefit from this
approach and recommendations on how to pursue and implement it.
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required staff training, increasing their capacity for 24/7 response, equipment,
vehicle or telehealth purchases and potential technology needs. Funds would also be
available to create more culturally responsive mobile crisis services in Colorado.
State Plan Amendment and Waiver Information
HCPF has a CMS-approved State Plan Amendment authorizing a universal mobile crisis
benefit for Medicaid members via an external workstream for CMS Grant
2I2CMS331818-01-00.
Sustainability Plan
This project initiative will afford the opportunity to develop and refine alternative
approaches to addressing emergency behavioral health needs. Recognizing both the
importance and impact these initiatives will have, HCPF is developing a benefit
program to authorize universal mobile crisis benefits for Medicaid members.
Capital Expenditure Plan
A capital expenditure request was submitted for the following: grantees may utilize
funding to start a program or to come into compliance by using funds for required
staff training, increasing their capacity for 24/7 response, equipment, vehicle or
telehealth purchases and potential technology needs. Funds would also be available
to create more culturally responsive mobile crisis services in Colorado.
Project Changes
No changes for this project over the previous quarter.
Initiative 2.03. Institute for Mental Disease (IMD) Exclusion, Risk Mitigation Policy
As a complement to the crisis service grant programs, the Department will explore
the detailed policy and licensing requirements of different provider types that are
federally prescribed when serving persons experiencing behavioral health crises.
Colorado currently has a network of different facilities that can be used to assist a
person in crises including Acute Treatment Units (ATU), Crisis Stabilization Units
(CSU), emergency rooms, and when needed, traditional hospitalization. Both
emergency rooms and hospitals come at higher costs, may lack behavioral health
expertise, and may experience capacity issues to serve persons with medical needs
when supporting persons in crises.
By contrast, ATUs and CSUs are especially adapted to behavioral health crises.
However, there needs to be compliance work completed with ATUs and CSUs to align
with the State’s Behavioral Health Administration (BHA) new rules. Additionally, ATUs
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The study will address the following:
● Internal data analysis: Identify disparities in HCBS by analyzing enrollment and
utilization data by race, ethnicity, language, and geography; develop a
snapshot report that identifies disparities across the system to be presented to
stakeholders in the community.
● External stakeholder feedback and recommendations: Based on disparities
identified, contract with a vendor to gather feedback from stakeholders and
write up recommendations.
● Implementation planning: Once recommendations are gathered, an internal
team will put together an implementation plan to begin creating more equity
in HCBS.
State Plan Amendment and Waiver Information
There are no state plan amendments or waivers required for this project.
Sustainability Plan
Upon completion of the Equity Study, HCPF will consider the options to operationalize
inclusion efforts.
Capital Expenditure Plan
No capital expenditures for this project.
Project Changes
No change for this project over the previous quarter.
Initiative 3.02. Buy-In Analysis
Many people with disabilities are interested in working. Health insurance
coverage can have an important relationship to employment for people with
disabilities. For example, persons with disabilities on Medicaid may be
concerned that they will lose their Medicaid coverage if they enter or return to
the workforce. Commercial or employer-based health insurance might not
provide coverage for services and supports that enable people with disabilities to
work and live independently such as personal assistance services. The purpose of the
Medicaid buy-in program is to allow persons with disabilities to purchase Medicaid
coverage that helps enable them to work. Through this initiative, HCPF is developing
member-facing premiums information and educational materials for the Buy-In
program. This will provide members with the critical information they need about the
program and the upcoming reinstatement of premiums.
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Initiative 3.04. HCBS Training for Members & Families
In addition to providing training for providers, HCPF will develop and make
available culturally competent training and resources for members and their
families to assist with navigating the HCBS system. This will include providing
education and support to family caregivers. The training project will provide
information to members to help educate them on all waivers, navigate through the
different waivers, and explain members’ right to choose between service providers.
The training will be member-focused, person-centered and in plain language for ease
of use.
State Plan Amendment and Waiver Information
There are no state plan amendments or waivers required for this project.
Sustainability Plan
The suite of developed training materials will be incorporated into HCPF’s currently
available training resources for ongoing management and oversight.
Capital Expenditure Plan
No capital expenditures for this project.
Project Changes
No change for this project over the previous quarter.
Initiative 3.05. Translation of Case Management Material
HCPF does not currently have all member-facing materials translated into all
necessary languages. HCPF will translate public-facing case management and
other member-facing materials, such as forms, waiver charts, waiver flow
charts, specialized behavioral health programs and benefits, and other basic
information about waivers and other long-term services and support programs, into
multiple languages for members and caregivers to understand in their own language.
This work will also take into consideration plain language and other accessibility
needs such as hearing and vision impairments.
State Plan Amendment and Waiver Information
There are no state plan amendments or waivers required for this project.
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Sustainability Plan
Recognizing the importance of inclusion for all programs, HCPF is committed to
ensuring developed materials are maintained and accessible beyond the ARPA funding
period.
Capital Expenditure Plan
No capital expenditures for this project.
Project Changes
No changes for this project over the previous quarter.
Initiative 3.06. Expand the Behavioral Health Safety Net
HCPF has an opportunity with these funds to strengthen and expand the
behavioral health safety net through provider training, workforce
development, enhanced standards, high-intensity outpatient services, and
value-based pay for performance models supporting whole-person care.
Over the past two years, HCPF and the Regional Accountable Entities (RAEs), have
aligned on a definition for high intensity outpatient services through a collaborative
stakeholder engagement process. The safety net expansion effort will build upon and
implement this definition through the following activities:
● Conduct a gap analysis for high intensity outpatient services: HCPF will assess
the extent to which its current delivery system provides adequate high
intensity outpatient services and identify any needed improvements.
○ Perform a Behavioral Health Network Gap analysis for existing behavioral
health services under the ACC behavioral health managed care program.
This project will analyze three years of historical utilization patterns,
discern member population needs and identify existing network gaps by
service type and geographic locations. It also includes an in-depth
analysis of telehealth services to discern whether these services
replaced, enhanced and expanded access to care. This project will also
include analysis of active behavioral health practitioners and facilities
that have provided services to members within SFY 2021-2022; identify
non-active practitioners and facilities; perform network analysis based
on service type and geographic locations to discern member experience
of accessing care and the actualized network capacity. The findings from
this four-phase analysis will provide improved insight into the network
performance as well as provide future methodology recommendations
for expanded network monitoring and management.
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● Develop training and technical assistance to build capacity with providers and
health plans: Providers will need technical assistance and other support to
improve their capacity to deliver high intensity outpatient services.
● Develop value-based payment framework for high intensity services and whole
person care: Providers will also need alternative financing models that better
support whole person care and reward improved outcomes. The Department
will create a new value-based reimbursement model to support the
implementation of high intensity outpatient services and to improve the
capacity of the service networks.
Assess and review regulatory foundations for high intensity outpatient services: To
build adequate networks for high intensity outpatient services and to financially
support these networks, the Department, working with the Office of Behavioral
Health, needs to review and align their credentialing and contracting policies with the
safety net framework. This includes the development of a prospective payment rate
model for essential and safety net behavioral health providers. The Department will
assess and revise critical regulations concerning high intensity outpatient services.
● Develop a strategic plan to better serve youth with behavioral health needs
that require high intensity outpatient services.
● Expand services through grants to each RAE to strengthen and expand
behavioral health safety net resources.
● Following approval in March 2022 by the Joint Budget Committee (JBC), the
project scope was expanded to include helping Community Mental Health
Centers (CMHCs) to improve their financial reporting to include more
information to support analysis of cost and efficiency.
● The scope of this project was further expanded in September 2023 to enable
the team to update the Child & Adolescent Needs and Strengths (CANS)
assessment. The current version does not capture information in the necessary
way for Medicaid Reimbursement. With support from a contractor, the team
will update the assessment to support a multi-pronged approach to children
and youth with complex needs in Colorado.
● In October 2023, the scope was expanded to support a new contract that will
help author the update and stakeholder engagement portions of submitting a
new 1115 waiver.
● In March 2024, the project scope and budget were increased to support more
training modules for safety net providers covering more topics than originally
planned. Additional new work was incorporated to add a provider satisfaction
survey to measure the impact of the Independent Provider Network and
recommended solutions to support small group outpatient Behavioral Health
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providers. A supplemental scope change was also made to develop cost report
templates for state-run mental health homes within the existing budget.
State Plan Amendment and Waiver Information
HCBS will submit Waiver Demonstration Project No. 11-W-00336/8 (effective through
December 31, 2025,) by April 2024.
Sustainability Plan
The final stage of this project, regulatory and legislative review, speaks to the
interest in longevity of the initiative. HCPF is committed to implementing advanced
strategies for transformation in delivery of high intensity outpatient services. Each
service included in the definition of high intensity outpatient services is already
covered individually, though the services may be combined into a larger level of care
definition in the future. Shifting from a pay for service to a performance
compensation model is intended to change the focus of care to a person-centric
model. As such, HCPF will continue the initiative through programmatic changes and
continue to monitor the progress of change implemented under the ARPA funding.
Capital Expenditure Plan
A capital expenditure request was submitted for the following: grant funding provided
through Regional Accountable Entities (RAEs) to expand high intensity outpatient
services in communities across the state. Funds may be used for capital expenditures
including infrastructure and equipment.
Project Changes
The scope and budget have changed to support more training modules for safety net
providers covering more topics than originally planned. Additional new work was
incorporated to add a provider satisfaction survey to measure the impact of the
Independent Provider Network and recommended solutions to support small group
outpatient Behavioral Health providers. A supplemental scope change to develop cost
report templates for state-run mental health homes within the existing budget was
incorporated.
Initiative 3.07. Wrap-Around Services, including Peer Supports, for Members
with Complex Needs
HCPF is developing a sustainability strategy for wrap-around services, including
housing support services and community-based peer support, for recipients of
complex social service benefits such as housing vouchers and supportive housing
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services. This is focused on individuals with serious mental illness and a history of
homelessness and repeat hospitalizations and does not include any funding for room
and board.
Specifically, HCPF is implementing a pilot program to provide supportive services,
including peer support, behavioral health services, and pre-tenancy / tenancy
sustaining services, for at least 500 Medicaid members. Participating members will
receive housing vouchers from the Colorado Department of Local Affairs (DOLA). This
initiative is modeled on the evidence-based social impact bond project in Denver and
targets individuals who have serious mental illness and have a history of homelessness
and emergency care. HCPF has also been awarded a technical assistance program by
the National Academy for State Health Policy about how to best integrate services
across state agencies to expand housing options to their shared clients who are
unhoused.
With the support of the NASHP technical assistance program, HCPF is conducting an
analysis of funding mechanisms and payment models and develop recommendations
on how to improve support models of care for individuals with extensive history of
complex social and behavioral health needs.
For providers, this is creating options for them to expand their business models,
increasing their solvency and the populations they are able to serve. It is building
provider capacity, including housing service providers, and sustainability in rural areas
where traditional care models are becoming more difficult to provide due to changing
economic and population needs. It also aligns with Colorado’s broader behavioral
health safety net initiative in that it expands the network and financing of behavioral
health specialty providers.
State Plan Amendment and Waiver Information
HCPF may modify an existing 1115 Demonstration waiver to add a Health-Related
Social Need (HRSN) Amendment to build out the benefit package identified through
the pilot program and subsequent evaluation in 2025. The team does not believe that
these activities will occur during the ARPA HCBS time period.
Sustainability Plan
With the SWSHE pilot concluding in September 2024, HCPF has requested funds
through the Governor’s Budget (see R-7 Behavioral Health Continuum) to continue
supportive services for members who qualify for Permanent Supportive Housing (PSH).
These funds ensure that Medicaid will reimburse for the same supportive services
described above for members in PSH in addition to clinical services. This combination
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of supportive services and clinical services wrap around members with behavioral
health needs to increase housing stability.
Capital Expenditure Plan
A capital expenditure request was submitted for the following: as part of the Peer
Support grants, applicants could request capital funding to support project
implementation and project coordination expenses including infrastructure, supplies,
and software. They could also request funds to build administrative capacity for
Medicaid billing including supplies and equipment.
Project Changes
No changes for this project over the previous quarter.
Initiative 3.08. AI/AN Culturally Responsive Services Capacity Grants
Note: As of June 2022, this project has been renamed AI/AN Culturally Responsive
Services Capacity Grants (previously titled Behavioral Health Capacity Grants), to
better reflect the scope and goals of the project.
To finalize the suite of projects to expand the behavioral health safety net in
Colorado, HCPF is executing a project focused on community identified service gaps
that members of the American Indian and Alaska Native populations experience when
seeking behavioral health services. HCPF is working alongside two tribes, the Ute
Mountain Ute and Southern Ute, in Colorado to co-design a menu of services and
supports to meet the needs of the populations and expand access to behavioral health
and HCBS services. This work will include an extensive stakeholder engagement
process and formal tribal consultation engagement and is happening in conjunction
with the tribal liaisons at HCPF and is focused on ensuring the needs as identified by
the tribal partners remain at the forefront of the work. Funding will be provided in
the form of prospective grant payments to give tribes flexibility in implementing
programs that will best meet the needs of their members and will likely include
capital expenditures. A fiscal rule waiver to allow for a prospective payment was
approved by the Office of the State Controller in Q1 of SFY 2023-24.
In addition to the direct support provided to the tribal nations, HCPF recognizes the
large portion of Members who are a part of the Urban Indian population. To ensure
expansion of services to meet the needs of this population, HCPF is partnering with a
local Urban Indian Health Program to fund the expansion of behavioral health and
HCBS services. Funds will be used for evidence-based practices and capital
expenditures mitigating care deserts to better serve the Colorado American
Indian/Alaskan Native (AI/AN) population. This funding will prioritize programs that
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are improving their ability to serve individuals with disabilities on a HCBS waiver, who
also have co-occurring behavioral health (SUD and MH) needs with a focus on lower
acuity services and smaller community-based providers compared to the previously
mentioned initiatives. This includes Behavioral Health Services provided through
Colorado’s 1915(b)3 waiver.
State Plan Amendment and Waiver Information
There are no state plan amendments or waivers required for this project.
Sustainability Plan
ARPA funding provides a one-time capacity building opportunity to local communities,
allowing HCPF to maintain a high level of service delivery across all member
populations. HCPF will also continue to build upon relationships with both tribes and
their leadership, helping to foster continually improving outcomes for American Indian
and Alaska Native Coloradans into the future.
Capital Expenditure Plan
The capital expenditures for this project are utilizing state only funds.
Project Changes
No change for this project over the past quarter.
4. Support Post-COVID Recovery & HCBS Innovation
Initiative 4.01. Residential Innovation
Under this project, HCPF will develop and pilot continuum models of care that
incent the creation of financially viable small residential programs that are:
● Person-centered
● oriented to positive health outcomes
● and that focus on maintaining autonomy and independence for those aging
in place and for those with intellectual and developmental disabilities (IDD).
This will be accomplished by completing an analysis and pilot program.
● Models of Care Analysis: HCPF will conduct an analysis of funding
mechanisms and feasibility on how to improve transitions of care for people
transitioning from nursing facilities and other institutional settings to
potential new models of care for investment and innovation.
● Pilot Program: HCPF will award two grants to develop pilots where grantees
will, design and/or implement a re-envisioned holistic community that
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combines natural/community supports, residential homes, and existing
services across systems to support older adults and people with disabilities
to live as they would like to in a safe, supportive community environment.
Learnings from the pilot program will be used to scale the model to other
communities and to provide best practice recommendations for further
development of new, innovative models and approaches to aiding
Colorado’s aging adults and individuals with IDD. HCPF will hold at the
forefront the HCBS Settings Final Rule, including CMS guidance and
requirements for integration of persons residing in community placements,
when researching, planning, and implementing this pilot program. It is the
intent of this project to determine whether a fully integrated, planned
community can be one method for providing services to individuals with
disabilities and aging adults.
State Plan Amendment and Waiver Information
There are no State Plan Amendment or Waiver submissions planned during ARPA
timeline for this project.
Sustainability Plan
HCPF will closely examine the success and viability of supported communities and
based on the outcomes, formally develop any necessary administrative documentation
and other avenues for the ongoing support of such efforts.
Capital Expenditure Plan
A capital expenditure request was submitted for the following: One of the program
grantees intends to use funds to purchase large monitors for use during training and to
provide information to clients.
Project Changes
The project team reduced the overall project budget to align with actual executed
contract amounts.
Initiative 4.02. Promote Single Occupancy
This project will focus on supporting home and community-based services
waiver approved residential facilities in creating more single occupancy rooms,
which would help prevent the spread of diseases and promote greater
independence among residents. HCPF will research current practice and what it would
take for these providers to offer more single occupancy rooms. HCPF will offer
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incentive payments with state-only funding for providers to convert more space to
single occupancy rooms.
State Plan Amendment and Waiver Information
There are no State Plan Amendment or Waiver submissions planned during the ARPA
timeline for this project.
Sustainability Plan
The pandemic has brought to light shortcomings in the current occupancy rates and
impacts on disease transmission. HCPF is exploring options for both improving quality
of life and managing transmissibility in assisted living and other congregate care
settings. Sustainability funding for these efforts is being reviewed for long-term
viability.
Capital Expenditure Plan
No capital expenditures for this project.
Project Changes
No changes for this project over the previous quarter.
Initiative 4.03. Child/Youth Step-down Options Program and Provider
Recruitment
HCPF will focus on those areas in which there are currently gaps in services and
treatment programs for children and youth. These include members with
autism spectrum disorder, intellectual and developmental disabilities, severe
emotional disturbance, as well as those with dual behavioral health and physical or
developmental diagnosis.
HCPF will work with several providers to develop a viable step-down treatment
program, to create models of care that are financially viable and person-centered,
with a focus on those children and youth who are currently being sent out of state for
services. This project will also look at the creation or expansion of a step-down
service between hospitals and a short-term residential placement. Funding in the
form of grants will be available to support the infrastructure and equipment costs
associated with this expanded level of care. The grant programs will focus on
providers delivering Qualified Residential Treatment Programs (QRTP) and Children’s
Habilitation Residential Program (CHRP) services. Grantees delivering QRTP and CHRP
services are not providing those services in an Institute for Mental Disease (IMD).
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The scope of this project was expanded in September 2023 to enable the team to
secure a vendor to perform analysis on what it would mean to move our CHP+
program from a standalone program to a program folded into the larger Medicaid
benefit. This is particularly relevant during PHE unwind as children on CHP are not
eligible for critical services like Applied Behavioral Analysis therapy and Early and
Periodic Screening, Diagnostic, and Treatment benefits. Additionally, this project will
secure a vendor to help create the infrastructure for the step-down program.
State Plan Amendment and Waiver Information
HCPF does not anticipate the need to submit a State Plan Amendment for program
and service changes that are identified during the implementation of this project.
Sustainability Plan
HCPF is committed to improving programs for children and youth, including the
capacity of the State to provide services to this population. Additionally, HCPF must
remain cognizant to managing program cost. HCPF will explore outcomes from this
effort to better provide services in this area.
Capital Expenditure Plan
A capital expenditure request was submitted for the following: as part of the grants,
applicants may request capital funding to support project implementation and project
coordination expenses including infrastructure, supplies, and software to expand
capacity.
Project Changes
No change for this project over the previous quarter.
Initiative 4.04. Tiered Residential Rates & Benefits
Note: As of March 2022, this project has been renamed Tiered Residential Rates &
Benefits (previously titled Alternative Care Facility Tiered Rates & Benefit), to
reflect the expansion in scope.
HCPF currently pays one per diem rate for all members served in an Alternative Care
Facility (ACF), regardless of the level of setting. Through this project, HCPF will
develop a tiered rate methodology for setting levels, with an emphasis on secured
settings, for the ACF benefit. This initiative will provide insight on how HCPF could
create multiple level settings for the ACF program that would limit placement into a
skilled nursing facility. As of March 2022, the project scope was expanded to include
an additional setting type, Qualified Residential Treatment Programs (QRTPs).
Additional funds were added to the project and approved by the JBC for this purpose.
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HCPF will also analyze other states that utilize a tiered rate for HCBS residential
services, and their member assessment processes for assignment to the appropriate
tier. HCPF will provide recommendations related to services incorporated at each
level to limit nursing facility placement and analyze whether Colorado’s assessment
tools would be sufficient to determine an appropriate tier. A new assessment tool will
be developed, if appropriate.
As of March 2022, the project scope was expanded to include an additional setting
type, Qualified Residential Treatment Programs (QRTPs). Additional funds were added
to the project and approved by the JBC for this purpose. In a previous report, HCPF
inadvertently used historical state licensing language, stating that Residential Child
Care Facilities (RCCF) would be included in this project. The RCCF provider type has
sunsetted as an allowable provider to bill Medicaid and therefore will not be included
in this project. The intent of this initiative is to explore tiered rates that vary based
on the individual in need of services, to ensure non-institutional and least restrictive
settings are fully equipped to meet the needs of children and youth with complex
needs. The expanded scope of this project will focus on residential settings that serve
youth and children with complex needs, which must have 16 beds or less and submit
an attestation that they meet criteria, which requires that these providers do their
due diligence to ensure that they are not IMDs. This currently only includes QRTPs in
compliance with the Family First Prevention Services Act (FFPSA). These settings
provide services covered in Appendix B of the State Medicaid Director’s Letter dated
May 13, 2021, specifically Colorado’s 1915 (b)(3) waiver and state plan behavioral
health clinical and rehabilitative services.
The scope of this project was expanded following the approval of additional funds in
August 2023. The team will extend the project and expand the scope of the vendors
work to have them develop tiered rates from the already completed rate
methodology.
State Plan Amendment and Waiver Information
Any changes in rate methodology would be supported by the appropriate rate setting
structure and the submission of a waiver amendment after the ARPA period.
Sustainability Plan
HCPF is committed to developing programmatic incentives to manage costs and
improve quality of care. Stakeholders will be engaged both during the rate structure
development process and for feedback on programmatic changes. Once program
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recommendations are created, HCPF will pursue all appropriate administrative efforts
to implement program and rate changes.
Capital Expenditure Plan
No capital expenditures for this project.
Project Changes
No change for this project over the previous quarter.
Initiative 4.05. Pilot CAPABLE
HCPF will pilot and evaluate the innovative Community Aging in Place -
Advancing Better Living for Elders (CAPABLE) program to support HCBS
members to remain at home. HCPF will pilot the CAPABLE program in three to
four locations across the State with the goal of enrolling 400 people. Though the
program has been rigorously evaluated, HCPF will implement a pilot with an
evaluation to ensure it results in the same outcomes, including cost savings, when
implemented with a diverse group of members, including individuals of younger ages
and those living in rural communities.
State Plan Amendment and Waiver Information
HCPF will utilize the ARPA HCBS funding and time period to pilot test the CAPABLE
model in Colorado. The project team will review the evaluation outcomes and
determine whether HCPF should consider adding CAPABLE as an additional benefit
available to our waiver participants based on program success. At that time, post
ARHA HCBS, a waiver amendment will be pursued if considered feasible.
Sustainability Plan
HCPF embraces opportunities for improving member experience and managing
program costs. The CAPABLE program is one such alternative care model that has
demonstrated inroads to achieving these goals. HCPF is committed to the continued
support of that vision and is reviewing options for continuing efforts in the longer
term.
Capital Expenditure Plan
No capital expenditures for this project.
Project Changes
No change for this project over the previous quarter.
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Initiative 4.06. Supported Employment Pilot Extension
In recent years, HCPF has received State funding to conduct a Supported
Employment pilot program to incentivize outcomes where people achieve and
maintain employment. Funding for this project expired on June 30, 2022. HCPF will
extend and expand the current pilot program to allow for increased participation,
additional data collection, and to determine if expanding incentive-based payments
for Supported Employment services within the waivers is cost effective and produces
positive outcomes.
State Plan Amendment and Waiver Information
There are no state plan amendments or waiver amendments presently planned for this
project. However, HCPF is exploring how it can permanently implement a value-based
payments model for Supported Employment Services into the Home and Community
Based Services (HCBS) Developmental Disabilities (DD) and HCBS Supported Living
Services (SLS) waivers that may require amendments to both waivers, which would
not occur until after the end of ARPA.
Sustainability Plan
HCPF is committed to creating environments of inclusion and employment
opportunities for people with disabilities. It is believed that this program will prove to
be self-supporting, and HCPF plans to explore partnerships with sister agencies and
other options to support its long-term implementation.
Capital Expenditure Plan
No capital expenditures for this project.
Project Changes
No change for this project over the previous quarter.
Initiative 4.07. New Systems of Care
HCPF has an opportunity to identify and pilot innovative systems of care that
recognize and leverage the needs and capabilities of various populations.
Under this project, HCPF will study successful initiatives implemented by
other states and nations while also developing and administering pilot
programs that:
● Provide tuition and/or childcare reimbursement for Colorado Medicaid HCBS
Direct Care Workers.
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● Fund the facilitation of home sharing arrangements where at least one
individual in the home sharing match is at least aged 55 or older.
● Provide college credit for prior learning (CPL) and work experience for
Colorado Medicaid HCBS Direct Care Workers.
To administer the pilot, HCPF will create a grant program with state-only funding to
support innovative models of care. The Department will conduct an environmental
scan of evidence-based practices that could be used and to create an innovative
model to address “total compensation” for direct support professionals.
The 4.07 initiative will use existing project funds to launch an additional grant with
that will focus on expanding, enhancing, and strengthening the capacity of existing
service providers to serve individuals receiving Home and Community Based (HCBS)
waiver services in a residential setting with disabilities and complex behavior support
needs.
Through this grant program, HCBS providers may apply for funds for projects that will
enable agencies to better serve individuals with complex behavioral and/or medical
support needs that require intensive supports and interventions to include materials,
home modifications, use of a consultant, and/or equipment that are not already
billable to Medicaid.
State Plan Amendment and Waiver Information
There are no state plan amendments or waivers required for this project.
Sustainability Plan
The lessons learned from the identification and piloting of innovative systems of care
and what has been successful in other states will inform future budget requests,
programs, and policies.
Capital Expenditure Plan
No capital expenditures for this project.
Project Changes
No changes for this project over the previous quarter.
Initiative 4.08. Respite Grant Program
Expanding respite services was one of the most frequently cited items by
Colorado stakeholders for consideration in the ARPA spending plan. Respite services
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future programs, policies, and budget requests. The respite benefit will continue as
this is a critical service for our members and their families but may be modified or
expanded based on information gleaned from this ARPA project.
Capital Expenditure Plan
No capital expenditures for this project.
Project Changes
The project budget was reduced to revert unspent grant funds as part of the spending
reconciliation in preparation for project closeout.
Initiative 4.09. Respite Rate Enhancement
HCPF has provided a temporary targeted rate increase to incentivize
additional respite providers to serve HCBS adult and child members, with a
focus on home-based services. The rate increase also applies to respite services
provided under the DHS' crisis services program. HCPF changed the scope of this
project to remove the component of the project that would bring on a contractor to
identify innovation in respite care. This work is already underway within the Respite
Grant program (project 4.08).
State Plan Amendment and Waiver Information
HCPF received approval through an Appendix K Amendment on November 5, 2021 to
implement a temporary 25% rate increase for HCBS Respite providers.
Sustainability Plan
The aspects of this program that will extend in the future include what HCPF learns
through its meetings with providers and respite program providers to better
understand the barriers for enrollment and service provision. The expectation is that
these learnings will inform future budget requests, programs, and policies.
Capital Expenditure Plan
No capital expenditures for this project.
Project Changes
No change for this project over the previous quarter.
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Initiative 4.10. Home Modification Budget Enhancements
HCPF identified enhancements to the Home Modification benefit as a need for
our members, based on stakeholder feedback over the growing need to ensure
members could continue to live and receive care in their homes, as opposed to
congregate care settings, in response to the COVID-19 PHE. One way to help members
continue to live in their homes is by funding specific modifications, adaptations, and
improvements to their existing home setting. HCPF will provide additional funding
above the current service limitations for home modifications in response to members
needing multiple adaptations to their homes for accessibility and the increasing costs
related to construction and materials. The home modification budget enhancements
will be available for all waivers in which this benefit already exists.
State Plan Amendment and Waiver Information
HCPF received approval through an Appendix K Amendment on January 4, 2022 to
temporarily increase the Home Modification and Home Accessibility Adaptation
benefit by $10,000 to help members continue to live in their home and community.
On March 10, 2022 HCPF submitted HCBS waiver amendments for the affected
waivers, to include language that specifies during the Public Health Emergency (PHE),
some individuals on the waiver may exceed the $10,000 or $14,000 cap to help them
continue to live in their homes and the community. HCPF is awaiting approval from
CMS for this change with an anticipated effective date of January 1, 2024. In addition,
HCPF submitted a waiver amendment in the fall of 2022 to allow the continuation of
this temporary benefit through March 31, 2024.
Sustainability Plan
HCPF recognizes that addressing the increasing costs associated with home
modifications requires a long-term plan and funding strategy. The enhancement
funding that ARPA is providing will provide meaningful insights into cost challenges
and will put HCPF on better footing to ensure future budgets for this program
consider increasing labor and materials costs.
Capital Expenditure Plan
No capital expenditures for this project.
Project Changes
No change for this project over the previous quarter.
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Initiative 4.11. Hospital Community Investment Requirements
Under this project, HCPF will research and develop recommendations for how to
leverage hospital community investment requirements to support transformative
efforts within their communities including transitions of care for members receiving
home and community-based services. HCPF will develop minimum guidelines for
community benefit spending and reporting values to hold hospitals accountable to
meet community needs as determined by the community itself and align with
statewide health priorities. These guidelines should allow for more consistent
reporting and determination of what is a community health need as well as better
evaluate the impact of community benefit programs.
State Plan Amendment and Waiver Information
There are no state plan amendments or waivers required for this project.
Sustainability Plan
HCPF recognizes that providing guidance to hospitals regarding community investment
requirements and best practices is important to ensuring that those contributions
result in relevant and sustainable community change and improvement in community
health needs and health care outcomes. Once the guidelines have been developed,
HCPF is committed to both maintaining the hospital community investment guidelines
and working with hospital systems to evaluate the impact of their community benefit
efforts.
Capital Expenditure Plan
No capital expenditures for this project.
Project Changes
No changes for this project this quarter.
Initiative 4.12. Community First Choice
Community First Choice (CFC) was established by the Affordable Care Act in
2010 and allows states to offer attendant care services, including consumer
directed options, on a state-wide basis to eligible members of all ages, instead of only
those who meet criteria for a 1915(c) waiver. HCPF will use funding to cover the
administrative costs associated with the development and implementation of CFC,
including system costs, stakeholder engagement, staff, and a new Wellness Education
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Benefit. The goal is to implement CFC by July 2025. Once implemented, the state
would qualify for a 6% ongoing federal enhanced match on certain HCBS services.
To develop and implement CFC, HCPF will need the following:
● System changes: System changes will be required to add the existing HCBS
benefits into the State Plan which necessitates changes to the provider
subsystem, financial subsystem, prior authorization subsystem, provider
subsystem, and care and case management product. This work will include
ongoing testing and maintenance to ensure the changes made were accurate
and operating correctly.
● Develop a Wellness Education Benefit: HCPF is utilizing a contractor to develop
and manage the Wellness and Education Benefit. The Wellness Benefit will send
HCBS members information on a monthly basis to support their overall
healthcare. This benefit is slated to roll out with the Children’s Home and
Community-Based Services (CHCBS) waiver in the summer of 2024, to support
the changes to case management, and the rest of the waivers with
implementation of CFC.
To mitigate potential access to care issues, we will utilize ARPA funding to support
the initial licensing fee for Program Approved Service Agency (PASA) as an incentive
for early licensing compliance to mitigate the impact of the new licensing
requirement under CFC.
State Plan Amendment and Waiver Information
HCPF will submit an amendment to the State Plan allowing for the implementation of
the Community First Choice 1915(k) federal authority. Waiver amendments will be
required for the HCPF’s 1915(c) waivers to remove services provided under the
1915(k). An amendment to add the Wellness Education Benefit to the CHCBS waiver
was approved by CMS. Additional amendments will also be required to gain approval
for the Wellness Education Benefit to be added to the other 1915(c) waivers as part of
CFC implementation. The team plans to submit the SPA to CMS in Summer 2024 and
additional waiver amendments in the Fall of 2024.
Sustainability Plan
The ability to leverage the ARPA funds to allow the State to pursue CFC is a high
priority for HCPF and stakeholders. The funding accelerates investments in key
information systems and with relevant stakeholders to ensure that the State’s design,
development, and implementation of CFC is informed by stakeholder feedback and
aligns with best practices. The cost of this benefit will be absorbed by HCPF once CFC
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cost savings are realized. Funding to support this service was approved in Senate Bill
23-289.
Capital Expenditure Plan
A capital expenditure request was submitted for the following: ARPA funding will be
utilized to cover the administrative costs associated with the development and
implementation of CFC including system costs. System changes are needed in the Care
and Case Management System (CCM) and Medicaid Management Information Systems
(MMIS).
Project Changes
No change for this project over previous quarter.
5. Strengthen Case Management Redesign
Initiative 5.01. Case Management Capacity Building
Case management redesign is an overhaul of the current and traditional
processes utilized by case management agencies to ensure conflict free case
management services are provided to members. While the long-term effects are
necessary and invaluable, there will be substantial changes in those processes. This
project provides resources to help limit disruptions to members during that process.
HCPF will support case management redesign efforts in the community by developing
a framework to support the change management requirements to ensure successful
transition from the current system to implementation of a redesign that mitigates the
negative impact on members. HCPF will work with Case Management Agencies (CMAs),
local area organizations, and stakeholders to plan and prepare for Case Management
Redesign (CMRD). It will provide support to CMAs to implement CMRD policy changes,
transition, legal and corporate structures, change management, strategic and
organizational planning, capacity and ensuring member access to a CMA, including
developing an infrastructure for a learning collaborative so that CMAs have access to
individual resources relevant to their change management needs.
CMA Start Up and Transition Costs
With the extended timeline to implement ARPA, HCPF plans to create a grant program
to support the start-up of new contracts as a result of Case Management Redesign
(CMRD). Start-up and transition costs are needed to get the new CMAs online and able
to serve members faster.
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CMA Longevity and Retention Bonuses
Effective December 1, 2022, HCPF implemented longevity and retention bonuses to
qualified case management workers for all ten HCBS waivers to promote, encourage,
and support case management for the HCBS waivers during the public health
emergency and Case Management Redesign. CMAs may use funds for direct bonus
payments to case management staff or for retention incentives to help retain staff
through significant CMA systems changes and reward staff for their extraordinary work
and dedication during such uncertain times. The funds are distributed to each CMA
through a competitive grant award process. For the final grant distribution to the
CMAs in Fall 2023, the project team was approved by the Colorado Office of the State
Controller for a fiscal rule waiver to provide prospective payments that will be
distributed to case management staff as retention and hiring bonuses during the next
year of transition.
CMA Care and Case Management Stabilization Support
This funding will provide support to CMAs for unexpected costs outside of previous
funding opportunities or existing reimbursement structure during transitions to
implement CMRD, to support with staff retention, assist with data clean-up in the
CCM, digitization and/or storage of documents, and unexpected demands related to
the Public Health Emergency Unwind.
State Plan Amendment and Waiver Information
A state plan amendment and Appendix K amendment were submitted to CMS and
approved for the case manager retention payment component of this project with
approval effective January 1, 2023. With the Public Health Emergency’s end on May
11, 2023, the Department’s authority through the Appendix K amendment ended on
November 11, 2023. These retention payments tied to Public Health Emergency
response ended at that time. After that, the Department made available retention
payments for Case Management Agencies tied to the State’s Case Management
Redesign effort. These payments have been distributed through a competitive grant
program through fiscal year 2024.
Sustainability Plan
The Department recognizes that expanding the capacity of the case managers who
serve the HCBS population by designing an end-to-end case management paradigm is
essential to ensuring that all members have access to care and have a positive
experience with the healthcare system. Once CMRD has been implemented, the
Department is committed to continuing that vision both in the near- and long-term.
Capital Expenditure Plan