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COVID-19’s Impact on Medicaid

The COVID-19 pandemic brought on countless changes to our daily lives. For some, this meant changes to where, when, and how their Medicaid services were delivered. Appendix K was an important addition to Health First Colorado program during the pandemic by allowing temporary modifications to Medicaid services. Due to the end of the public health emergency in May 2023, there have been numerous changes regarding Appendix K modifications.

What is Appendix K?

Appendix K was created to quickly create temporary modifications to HCBS waiver rules for necessary flexibilities during the Public Health Emergency (PHE). These adjustments were made to allow more Colorado families to access services during the unprecedented times that came with the COVID-19 pandemic.

While Appendix K changes were originally intended to remain temporary throughout the Public Health Emergency, there have been multiple provisions that were later approved to become permanently available. Please review the list below for all changes that were made permanent, in addition to those that will no longer be available as of November 11th, 2023.

Approved Changes

These changes have already been approved for permanent adoption and are currently available.

Service Added to the Waiver

Remote Support Technology assists individuals by facilitating service delivery when in-person options may not be available or are not needed or wanted. This service provides real-time support with tasks that do not require hands-on assistance and that would otherwise require an in-home visit by a provider

  • Applicable Waivers: SLS, EBD, CMHS, CIH, and BI waivers

Modification of Provider Qualifications

The minimum age for an attendant has been amended from 18 to 16 in Consumer-Directed Attendant Support Services (CDASS) and In-Home Support Services (IHSS)

  • Applicable Waivers: EBD, CMHS, BI, CIH, and SLS waivers

Modification of Incident Reporting Requirements

In the circumstance that an individual must evacuate their current setting, there are additional flexibilities in location and timeliness of reporting

  • Applicable Waivers: All

Expand Settings where services may be provided to include a telehealth option

Applies to the following programs:

  • Life Skills Training (EBD, CMHS, CIH, and SLS)
  • Adult Day (CIH, EBD, CMHS, EBD) or Independent Life Skills Training (BI)
  • Supported Employment (DD and SLS)
  • Mentorship (SLS)
  • Movement Therapy (CES and CHRP)
  • Community Connector (CES)
  • Bereavement Counseling (CLLI)
  • Expressive Therapy (CLLI)
  • Palliative Support Services (CLLI)
  • Behavioral Services (CHRP, DD, SLS)
  • Mental Health Counseling (BI)
  • Substance Abuse Counseling (BI)
  • Transition Support Services (CHRP)
  • Peer Mentorship (SLS, EBD, DD, CMHS, CIH, and BI)
  • Behavioral Management and Education (BI)

Modification of Licensure Requirements

HCPF has removed the requirements that Adult Day Centers provide lunch and have showers located on the premises for those centers that offer this service virtually

  • Applicable Waivers: EBD, CMHS, CIH

Modification for Level of Care Evaluations or Re-Evaluation

Case managers may use phone or telehealth to engage in the development and monitoring of Person-Centered Service Plan when there is a documented safety risk to the case manager or member
• Applicable Waivers: All

Modification to Day Service Structure

Modified Adult Day Service (ADS) to include 15-minute unit increments instead of the half-day unit. The 15-minute unit approach allows ADS providers to render services for up to 3 hours a day, at $10.18/hour, for members who may be vulnerable and do not want to be in a group setting or a facility site

  • Applicable Waivers: EBD, CMHS, CIH, BI

Increase in Payment Rates

HCPF implemented a base wage requirement of $15/an hour through a rate increase for HCBS direct care workers

  • Applicable Waivers: All

Addition of Virtual Case Management

Allow HCBS waiver participants to request virtual case management activities, except for level of care assessments and one monitoring contact, which will be done in person unless there is a documented health and safety risk (i.e., pandemic, natural disaster) that necessitates virtual case management contact

  • Applicable Waivers: All

Modifications to Rate Structure

Modified Specialized Habilitation and Supported Community Connector to include a tiered rate for flexible billing

  • Applicable Waivers: DD, SLS

Pending Changes

These updates will be effective as of July 1, 2023.

Service Added to the Waiver

Expanded Settings where services may be provided to include a telehealth option

  • Applicable Waivers: DD, SLS

Virtual Monitoring for Case Management

The case manager shall perform quarterly monitoring contacts with the member, as defined by the member’s certification period start and end dates. An in-person monitoring contact is required at least one time during the Person-Centered Support Plan certification period. The case manager shall perform three additional monitoring contacts each certification period either in-person, on the phone, or through other technology based on the client’s preference

  • Applicable Waivers: All

Appendix K Changes No Longer Available

These Appendix K modifications will no longer be available due to the end of the Public Health Emergency. This will be effective November 11, 2023.

Expand Settings where services may be provided to include a telehealth option

Applies to the following programs:

  • Day Treatment (BI)
  • Prevocational Services (SLS and DD)
  • Behavioral Services – Line Staff (DD and SLS)

Allow Payment for services Rendered by Family Caregivers or Legally Responsible Adults

Applies to the following programs:

  • Community Connector (CES and CHRP)
  • Homemaker (CES)

Verbal Authorization of Signatures

Verbal authorization of a member’s signature will be revoked. Digital signatures will continue to be allowed

  • Applicable Waivers: All

Virtual Case Management

Reinstate the requirement for the Level of Care Screen and one monitoring contact to be performed in person

  • Applicable Waivers: All
Source: Colorado Dept. of Health Care & Financing. (2023). Unwinding Appendix K Flexibilities. Retrieved from:

We understand that navigating these changes in Medicaid rules can be a daunting task. Our knowledgeable team is here to help! If you have questions about Medicaid renewals or other changes as a result the end of the Public Health Emergency, please view our guide below.

Learn More About the Medicaid Renewal Process

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