Somewhere around the third or fourth session with a new family, after we’ve talked through the ABA therapy plan and the goals and what to expect over the coming months, I usually ask: are you connected with your Case Management Agency?
About half the time, the answer is no — or they don’t know what that means.
That’s the moment I realize we need to step back from ABA entirely and talk about the bigger picture. Because ABA therapy is one piece of what a child with intensive support needs requires. The respite care that keeps a caregiver functional. The home modifications that make the environment actually safe. The caregiver training that means behavioral strategies work at home, not just in sessions. These aren’t extras — they’re the scaffolding that determines how well everything else works.
In Colorado, that scaffolding is largely funded through the Children’s Extensive Support (CES) Medicaid waiver. And in 2026, the waiver is going through its most significant structural changes in years.
This guide covers everything I walk families through when we have that conversation — clearly, completely, and with the 2026 changes explained in a way that actually makes sense.
How Colorado’s Medicaid System Works for Children With Autism
Before diving into the CES waiver itself, it’s worth building a clear foundation about how Colorado’s Medicaid landscape is structured for children with autism and developmental disabilities.
Families often arrive at their first case management meeting confused because multiple programs exist, each with different rules, different eligibility criteria, and different application processes—and no one has drawn the map for them.
Health First Colorado: What Every Family Needs to Know First
Colorado’s Medicaid program is called Health First Colorado. It’s the starting point—the foundation beneath everything else. The most important benefit within Health First Colorado for children with autism is the Early and Periodic Screening, Diagnostic, and Treatment (EPSDT) program.
EPSDT is a federal mandate, not a discretionary state benefit. It requires every state Medicaid program to cover any service that is medically necessary for a child under 21—even if that service isn’t normally included in the state’s standard Medicaid plan. In practical terms, this is the mechanism through which ABA therapy is covered for children with autism in Colorado.
If your child is under 21, has an autism spectrum disorder diagnosis, and your household meets Medicaid financial eligibility, ABA therapy is almost certainly covered through EPSDT. The coverage isn’t capped arbitrarily by hours. If a Board Certified Behavior Analyst (BCBA) documents that a child requires a specific intensity of services, EPSDT is what legally requires Health First Colorado to fund it.
As of July 2025, Colorado HCPF also clarified in Policy Memo PM 25-005 that only Registered Behavior Technicians (RBTs) may deliver direct ABA therapy billed under CPT Code 97153 for Medicaid clients. This reflects Colorado’s ongoing commitment to quality standards in ABA delivery—and it’s something families should confirm when selecting an ABA provider.
What EPSDT Does Not Cover—and Why Waivers Exist
Standard Medicaid, even with EPSDT, has meaningful gaps. It doesn’t fund in-home respite care for caregivers who need relief. It doesn’t pay for accessibility modifications that make a home safe for a child who elopes. It doesn’t fund the kind of community inclusion support that helps an autistic child practice real-world skills outside the clinical setting. It doesn’t cover specialized recreational equipment or caregiver training programs beyond the clinical treatment plan.
That’s the gap waivers are designed to fill. A Medicaid waiver is a federal waiver of standard Medicaid rules—approved by the Centers for Medicare & Medicaid Services (CMS)—that allows states to offer additional services to specific populations, funded jointly by state and federal Medicaid dollars. Waivers are supplementary, not replacements. A child on the CES waiver is also eligible for all Health First Colorado covered services, including EPSDT-funded ABA therapy.
Colorado’s Waiver Programs: Understanding Which Applies to Your Child
Colorado operates multiple Home and Community-Based Services (HCBS) waivers, and the acronyms can be genuinely confusing. The ones most relevant to families of autistic children are:
CES (Children’s Extensive Support): For children birth through 17 with developmental disabilities who live in the family home and have intensive, around-the-clock support needs. This is the primary focus of this guide.
CHRP (Children’s Habilitation Residential Program): For children with developmental disabilities who live in a residential setting outside the family home.
CHCBS (Children’s Home and Community-Based Services): Serves children with complex medical needs alongside their developmental disabilities.
CwCHN (Children with Complex Health Needs): For children with medically complex conditions requiring nursing-level supports.
DD (Developmental Disabilities) Waiver: The primary adult waiver for individuals 18 and older with developmental disabilities. This is the program CES waiver children transition to at age 18—a transition that requires its own application process and has its own waitlist.
For most families of autistic children who live at home and need supports beyond ABA therapy, the CES waiver is the relevant program. Your Case Management Agency (CMA) will determine which waiver, if any, fits your child’s specific situation.
Who Qualifies for the Colorado CES Waiver
This is where families get confused, frustrated, or give up prematurely. The eligibility criteria sound clinical and abstract when written in policy language. Let me translate each one into what it actually means and what documenting it looks like in practice.
The ICF/IID Level of Care Standard
The CES waiver requires what’s called an Intermediate Care Facility for Individuals with Intellectual Disabilities (ICF/IID) level of care. The name sounds institutional, but the standard it describes is not. It means: your child’s support needs are significant enough that, if they weren’t living at home with family, they would require a structured residential care setting to be safe.
This determination is made through a Functional Needs Assessment conducted by your Case Management Agency. The assessment evaluates daily living skills across multiple domains—self-care, communication, mobility, behavior, safety awareness—and documents the frequency and intensity of caregiver support required throughout each 24-hour period.
I want to be direct with families about how to approach this assessment: be thorough and honest about the difficult parts. Parents who have adapted to their child’s needs often unconsciously minimize them during assessments. If your family has reorganized your entire home for safety, if you’re up multiple times a night managing behaviors or medical needs, if community outings require intensive preparation and active physical support—that adaptation is invisible to an assessor unless you explicitly name it.
Bring written notes. Describe a typical weekday morning in detail, a difficult afternoon, a hard night. The assessment needs to capture your child’s genuine support needs, not the smoothed-over version that emerges when parents are trying to present competence.
Age and Living Situation Requirements
The CES waiver covers children from birth through age 17. Children must reside in the family home—defined as the home of a parent or legal guardian. This includes biological parents, adoptive parents, and legal guardians.
The upper age limit is one of the most consequential pieces of information in this entire guide. When a child turns 18, CES waiver eligibility ends. The adult services transition—primarily to the DD waiver—requires a separate application, its own eligibility determination, and enrollment in a program with its own waitlist. Families who haven’t started planning for this transition by the time a child is 14 or 15 are almost certainly going to face a gap. I’ll address transition planning fully in a later section.
The Behavioral and Medical Intervention Criteria
Per HCPF’s official CES waiver program page, a child must demonstrate a behavior or medical condition requiring direct human intervention—intervention that is more active than a verbal reminder, redirection, or brief observation—at least once every two hours during the day, and at least once every three hours on a weekly average at night.
What does this look like in practice? A child who engages in self-injurious behavior, property destruction, or physical aggression at a frequency and intensity requiring physical management. A child with a seizure disorder, severe food refusal, or complex medical condition requiring active caregiver management throughout the day and night. A child with elopement behavior so persistent that active home monitoring is required to prevent crisis.
These aren’t edge cases. These are the daily realities for many families of autistic children with significant support needs. The criterion exists precisely to describe those families. If you’re managing a child at that level of intensity, the assessment needs to capture that reality in documentation.
Financial Eligibility: Not What Most Families Assume
Children must meet Health First Colorado’s financial eligibility criteria for long-term services and supports (LTSS). Critically, this determination is based on the child’s income and resources—not the household’s. Many families with middle-class incomes assume they won’t qualify for Medicaid-funded waiver services and never apply. Because eligibility is assessed based on the child’s own financial profile, many of those families would in fact qualify.
The financial eligibility determination is made through the CMA and HCPF’s processes. Don’t self-screen out of this benefit—let the system make the determination.
The SSA Disability Definition
Children must also meet the federal Social Security Administration’s definition of disability. For many children with autism who qualify for the CES waiver, this determination is already in place or can be established alongside the waiver application.
If your child hasn’t yet had an SSA disability determination, initiating that process simultaneously supports access to multiple benefits—including Supplemental Security Income (SSI) if financially eligible—and establishes a formal disability record that matters for future adult services.
Every CES Waiver Benefit Explained in Plain Language
This is the section I want to spend the most time on, because every service on this list represents a real impact on a real family’s life—and most families I meet don’t fully understand the scope of what they’re entitled to request.
Respite Care: The Service That Keeps Families Intact
Respite is temporary caregiver relief—funded to allow the primary caregiver to take a break while a qualified provider supports the child. That sentence sounds simple. What it represents for families is anything but simple.
I’ve seen what happens to families without access to respite. Caregiver mental health deteriorates. Behavioral strategies collapse at home because the parent is running on empty. The child’s environment becomes reactive and crisis-driven because the adults around them have nothing left to give. Marriages fracture. Siblings are neglected. Caregiver burnout is a clinical phenomenon with real, documented consequences for the child being cared for—and respite is a direct clinical intervention to prevent it.
Under the CES waiver, respite can be delivered in multiple ways. As documented in HCPF Operational Memo 24-014, the CES waiver includes a range of service delivery options for respite: Unskilled Individual respite, Unskilled Individual Day, Skilled CNA respite (under and over 4 hours), Skilled RN/LPN respite (under and over 4 hours), Skilled Therapeutic respite (under and over 4 hours), Day Group, and Dollar Camp options for group and overnight settings.
The addition of skilled therapeutic respite—allowing providers with clinical therapeutic training to deliver respite for children with complex medical or behavioral needs—was a direct response to stakeholder feedback from families whose children’s complexity exceeded what standard respite providers could safely manage.
Per HCPF respite guidelines, the total annual respite amount may not exceed an amount equal to 30 day units and 1,880 15-minute units in a support plan year. Families should work with their case manager to understand their authorized amounts and plan their use throughout the year.
Community Connector: Building Real Community Inclusion, One Skill at a Time
The Community Connector service funds a trained support person to accompany a child into community settings—libraries, recreation centers, parks, social programs, community events—and provide the support needed for genuine participation rather than simple presence.
For autistic children, community participation is not an optional quality-of-life add-on. It is a core therapeutic goal, and it directly supports the generalization of skills being built in ABA therapy. A child who can navigate a grocery store with support is building a skill. A child who can participate in a community class, maintain appropriate behavior at a local event, or engage with peers in a structured community setting with support is building the real-world competencies that will matter throughout their life.
This service saw significant changes in 2026, which I cover in detail in the changes section. Families who rely on Community Connector should be actively monitoring the status of their authorizations and discussing any proposed limitations with their case manager.
Assistive Technology: Communication Tools That Change the Behavioral Picture
Assistive technology under the CES waiver covers devices, systems, and equipment that allow a child to perform tasks they couldn’t otherwise perform—or perform them with greater independence. This includes augmentative and alternative communication (AAC) devices, specialized switches and access technology, adaptive learning tools, and daily living equipment.
I want to emphasize AAC specifically because it is one of the most transformative interventions available for autistic children with limited verbal communication—and it is one of the most consistently underfunded by insurance. A robust AAC system, properly implemented and consistently used, can change the behavioral picture dramatically for a minimally verbal child.
Many of the most challenging behaviors families encounter—aggression, self-injury, property destruction, severe tantrums—are, at least in part, communication behaviors.
When a child has no reliable means to express needs, frustration, or discomfort, behaviors become their most effective communication tool. And when a child gains access to functional communication through AAC, the purpose those challenging behaviors serve often shifts, and the behaviors frequently decrease.
CES waiver Assistive Technology funding can bridge the gap between what insurance covers and what a child actually needs. Requests require documentation from a qualified professional (typically a speech-language pathologist), prior authorization through the case manager, and confirmation that insurance was pursued first.
Home Accessibility Modifications and Adaptations: Safety as a Foundation
This benefit funds structural modifications to the family home that make it safer or more accessible for a child with a disability. Examples include: reinforced fencing and secured doors for children with elopement behaviors, door alarms, wheelchair ramps, widened doorways, grab bars and specialized bathroom equipment, sensory room construction, safety padding or protective wall modifications for children with self-injurious behavior, and safe outdoor spaces.
Elopement—when a child wanders away from safe supervision—is one of the most dangerous behavioral patterns in the autism population. Research consistently identifies it as a leading cause of accidental death and injury among autistic children. A securely fenced yard or reinforced exterior door hardware is not a cosmetic home improvement. It is safety infrastructure that can be the difference between a manageable daily environment and a family in perpetual crisis.
Home modification requests are submitted through the case manager, require documentation of medical necessity, and are authorized based on assessed safety need. Families should not wait for an incident to request this benefit—document the risk and request it proactively.
Vehicle Adaptations: Maintaining Access to Everything Else
Vehicle adaptations fund modifications to a family vehicle to accommodate a child’s disability—wheelchair lifts, specialized seating systems, safety harnesses, and related equipment. For families of children who use mobility equipment, safe transportation affects access to every other service in the child’s life. This benefit exists to ensure transportation isn’t the barrier that limits everything else.
Adaptive Therapeutic Recreational Equipment and Fees
This benefit covers equipment and program fees for therapeutic recreational activities that support a child’s development and community inclusion.
Think adaptive sports equipment, program fees for therapeutic swim programs, therapeutic horseback riding, specialized recreational programs—activities that are genuinely therapeutic in their effects and genuinely fun for children, but that have costs or equipment requirements that would otherwise exclude a child with a disability.
Recreational participation is a real clinical goal, not a luxury. Social engagement, physical activity, sensory experiences, and participation in age-appropriate community activities all contribute to development in ways that aren’t fully replicable in a clinical setting. This benefit recognizes that inclusion doesn’t happen only in therapy rooms.
Specialized Medical Equipment and Supplies
Beyond what standard Health First Colorado covers, the CES waiver funds specialized medical equipment and supplies directly related to the child’s disability and community living needs. This is distinct from assistive technology—it covers medically oriented equipment that bridges the gap between standard Medicaid coverage and what a child actually needs for health management in a home setting.
Primary Caregiver Education: The Most Clinically Important Benefit Most Families Don’t Use
This is the benefit I advocate for most consistently—because it has some of the strongest evidence in the entire autism intervention literature, and because most families I work with don’t know it exists or how to access it.
Primary Caregiver Education funds structured training for parents and primary caregivers in behavioral support strategies, communication approaches, crisis de-escalation techniques, and other skills directly related to the child’s disability. Families can use this benefit to fund formal training programs, workshops, or individualized coaching from qualified professionals.
From a behavior analytic standpoint, the clinical case for this service is clear and well-supported. Research on caregiver-implemented intervention consistently shows that when parents are trained in the same strategies used in ABA therapy, children generalize skills faster, maintain progress more effectively, and show greater functional gains. The research isn’t subtle—the effect sizes are meaningful.
What this looks like in practice: a parent who understands how to use differential reinforcement can support communication throughout the day, not just during therapy hours. A parent who understands functional behavior assessment can identify what a challenging behavior is communicating rather than reacting to it. A caregiver who knows how to structure a transition can prevent the anxiety spike that leads to meltdowns, rather than managing the meltdown after it happens.
If your child is on the CES waiver and you’re not actively using the Primary Caregiver Education benefit, ask your case manager at your next meeting. Ask how to access it, what qualified providers are available in your area, and how to get it added to your Individual Service Plan.
Massage Therapy and Movement Therapy
The CES waiver covers massage therapy and movement therapy, which includes music therapy. These services support sensory regulation, physical wellness, and quality of life for children with complex support needs.
An important note for 2026: HCPF proposed rate reductions for movement therapy and music therapy during the FY 2026–27 budget process—and then explicitly withdrew that proposal, stating that it does not believe a rate reduction is justified given the professional standards and service needs associated with these therapies. These services remain in the CES benefit set at their existing rates.
Extraordinary Cleaning: A Practical Reality Many Families Need
Some families feel uncomfortable discussing this benefit. But it addresses a genuine daily reality for many of the families I work with, and there’s no reason for embarrassment—it’s a legitimate medical support.
Extraordinary Cleaning funds cleaning services that exceed normal household maintenance when a child’s disability creates cleaning demands that are genuinely extraordinary—regular cleanup related to severe toileting accidents, destruction-related cleaning, biohazard-level cleaning tied directly to the child’s disability condition.
A family that is spending two to three hours every day on cleaning directly caused by their child’s disability is a family with significantly reduced capacity for implementing behavioral strategies, attending appointments, maintaining their own health, and being present for their other children. This benefit exists to restore that capacity. If this is your family’s reality, please ask your case manager about it.
Wellness Education Benefit
The Wellness Education Benefit supports health and wellness education relevant to the child’s disability—including nutrition, physical activity, and health management strategies specific to the child’s condition and family context. It’s a quieter benefit, but it supports the foundation of wellbeing that underlies everything else.
Youth Day Services: Specifically for Older Children and Working Caregivers
Youth Day provides structured daytime activities, supervised skill-building, and support in community or center-based settings. Per HCPF Operational Memo 20-013, this service is specifically designed for children over age 12, and it is available when caregivers are working, pursuing education, or volunteering.
This distinction from respite matters practically: Youth Day is tied to caregiver employment or education; respite is for caregiver relief more broadly. Families can use both—they serve different purposes. Youth Day is limited to 10 hours per calendar day and may not be used to cover camp costs.
For families navigating the combination of work schedules, school breaks, and long summer months with older autistic children, the combination of Youth Day, respite, and summer ABA therapy can create a genuinely sustainable summer plan that maintains structure, continues progress, and supports caregivers.
Community First Choice (CFC): How It Works Alongside the CES Waiver in 2026
One of the most significant—and most confusing—structural changes currently underway in Colorado is the relationship between the CES waiver and the Community First Choice (CFC) program. This transition is generating more confusion and anxiety than almost anything else, and it deserves careful explanation.
What CFC Is and Why It’s Not a Waiver
Community First Choice is not a waiver. It is a Health First Colorado benefit program—a separate Medicaid funding stream created under a different federal authority that operates alongside waivers for members who qualify for long-term care.
CFC was created to expand home and community-based services using a federal funding mechanism that provides states with a higher federal match rate than traditional waivers. The net effect: more services for more people using federal dollars more efficiently. CFC covers a specific set of services: Personal Care, Homemaker Services, Health Maintenance Activities, Home-Delivered Meals, Medication Reminder, Personal Emergency Response Systems (PERS), Remote Supports, and Transition Set-Up.
The Services Moving From CES Waiver to CFC—and the Hard Deadline
Per HCPF’s official CES waiver page and the HCBS-IDD Billing Manual, specific services that were previously funded through the CES waiver are transitioning to CFC. According to HCPF’s documentation, these services will be unavailable through the waiver from July 1, 2026 forward.
The transition is occurring at each member’s Continued Stay Review between July 1, 2025 and June 30, 2026. Services continue through the waiver until that review date.
The essential message: these services are not being eliminated—they are moving to CFC. The access continues. But the transition requires active participation. If your family’s Continued Stay Review hasn’t happened yet and your child uses personal care, homemaker services, or any of the other transitioning services, this is your most urgent action item.
What You Need to Do During the CFC Transition
If your child is currently on the CES waiver and receives any of the services listed for CFC transition, reach out to your Case Management Agency now to confirm when your Continued Stay Review is scheduled. Ask your case manager explicitly which of your child’s current services are transitioning to CFC and what the authorization process looks like on the CFC side.
The worst outcome here is a service gap—an authorization under the waiver ending before the CFC authorization is in place. This is preventable with proactive communication. Don’t assume the transition is happening automatically without your engagement.
What Changes for Families After the CFC Transition
For most families, the day-to-day delivery of services shouldn’t change significantly—the same types of support will be available through CFC as were available through the waiver. The difference is administrative: the funding authority, billing codes, and authorization structure are different.
What families should watch for: confirm that authorized service hours are comparable under CFC to what was authorized under the waiver. If there are discrepancies, work with your case manager to understand why and whether the level of need documentation supports the same authorization.
The 2026 CES Waiver Changes: A Complete Breakdown
The restructuring happening in 2026 is real, multifaceted, and still evolving. Here is the clearest picture I can provide of what has changed, what is proposed, and what remains stable.
The Fiscal Context Behind the Changes
Colorado’s LTSS system has seen substantial enrollment growth, rising program costs, and increasing average service hours per enrolled member over recent years. The state invested over $600 million to expand access and strengthen the direct care workforce. But fiscal constraints in 2026 are acute.
Governor Polis signed Executive Order D25-014 to address budget gaps for FY 2025–26. New federal legislation—H.R.1, the One Big Beautiful Bill Act—significantly alters Medicaid financing, administrative requirements, and eligibility processes in ways that increase state-level financial pressure. HCPF is implementing changes through the Governor’s Executive Order, FY 2026–27 Budget Requests (R-06, R-08, R-15, and R-17), and waiver amendments submitted to CMS.
HCPF’s Medicaid Sustainability page (accessed June 2026) states that the Office of Community Living remains committed to transparency and partnership throughout this process. Understanding the fiscal drivers helps families engage with the system constructively rather than reactively.
Community Connector Rate Reduction: What Happened and What It Means
Per HCPF Operational Memo 26-005, Community Connector rates were reduced effective January 1, 2026. HCPF aligned the rate based on service scope, training requirements, and comparability to similar services.
For families: the rate reduction doesn’t change eligibility to receive Community Connector services. What it may affect is provider availability. When reimbursement rates decrease, some providers reduce capacity in that service category or stop offering it entirely. Families who rely on Community Connector should speak directly with their current provider about whether they’re continuing the service and at what level, and identify backup options.
Proposed Age Limitations for Community Connector
As part of HCPF’s FY 2026–27 budget requests under the R-19 “Office of Community Living Reductions” proposal, HCPF has proposed implementing age limitations for Community Connector. This proposal is active as of this writing—June 2026—and implementation details and timelines can still change as budget processes finalize.
Families with older children who rely significantly on Community Connector should raise this specifically with their case manager now. Understanding the proposed limitation and its projected timeline allows for proactive planning rather than a scramble when a change takes effect.
The July 2026 Waiver Amendments Submitted to CMS
Per HCPF Informational Memo 26-002 (issued February 11, 2026), HCPF submitted amendments to ten of Colorado’s HCBS waivers—including the CES waiver—to CMS on March 20, 2026, requesting an effective date of July 1, 2026.
The full draft waivers and amendment fact sheets are publicly available at hcpf.colorado.gov/hcbs-public-comment. Families can request paper or electronic copies by calling 303-866-3684.
Provider Rate Reductions and What They Mean for Families
HCPF implemented broader provider rate reductions across HCBS waiver services as part of FY 2026–27 budget measures. A Medicaid Provider Rate Reductions Fact Sheet and Q&A were published in May 2026 and are available on HCPF’s sustainability page.
Provider rate reductions don’t change eligibility or service authorization amounts. Their practical effect is on the provider market. When reimbursement decreases, some providers reduce capacity or exit specific service categories. Families should monitor whether their child’s current providers are remaining active in the waiver system and identify alternatives in service categories where provider attrition is a risk.
The Proposed Weekly Caregiver Hour Limit
HCPF is also seeking feedback on a proposed rule establishing a weekly limit of 56 hours per caregiver for a single member across Personal Care, Homemaker, Health Maintenance Activities, Long-Term Home Health Home Health Aide, and Long-Term Home Health Nursing Services. For families whose children receive the most intensive personal care supports, this proposed limit—if implemented—could affect service authorization levels.
This is a proposed rule change as of June 2026. Families who have concerns should monitor HCPF’s rule revision process and participate in available public comment opportunities. The HCPF governance site publishes public comment periods and stakeholder engagement opportunities.
What Is Definitively Not Changing
Given the volume of changes, families need clarity about what remains stable. The CES waiver itself is not being eliminated. Core eligibility criteria remain the same. ABA therapy through EPSDT is a separate federal benefit unaffected by waiver restructuring. Respite care—in all delivery options, including skilled therapeutic respite—remains in the CES benefit set. Home modifications, assistive technology, vehicle adaptations, Primary Caregiver Education, movement and music therapy, and wellness benefits all remain available. The CFC transition is a structural funding shift that preserves access, not a service reduction.
How ABA Therapy and the CES Waiver Work Together
Families sometimes come to me thinking these are competing programs or that one affects eligibility for the other. They’re not competing—they’re complementary. And the outcomes for children whose families engage fully with both programs are meaningfully better than for those who use only one.
ABA Therapy Coverage Through EPSDT: The Specific Services Covered
ABA therapy in Colorado is funded through Health First Colorado’s EPSDT benefit for children under 21 with an autism diagnosis when services are medically necessary. The services covered under EPSDT-funded ABA include: comprehensive behavioral assessments by BCBAs, individualized treatment plan development and regular data-driven updates, direct ABA therapy sessions (individual or in small groups) delivered by Registered Behavior Technicians under BCBA supervision, functional behavior assessments, parent and caregiver training as a component of the treatment plan, and BCBA supervision of the overall program.
There are no arbitrary hour caps under EPSDT when medical necessity is properly documented and justified by the treating BCBA. The authorization is based on clinical determination of need—which is why thorough, accurate documentation of medical necessity is so important.
Why the CES Waiver Makes ABA Therapy Work Better
This is the clinical argument I make to every family who treats waiver services as optional extras: ABA therapy doesn’t exist in a vacuum. It takes place within a family system, in a home environment, and in a community context—and the quality of that context directly affects outcomes.
A child whose caregiver is depleted from managing intensive needs around the clock without relief is a child whose home environment cannot consistently reinforce the skills being built in therapy. A child who lacks a functional AAC system is a child whose communication goals are being worked on in sessions but not practiced between them. A child in a home with unaddressed elopement risks is a child whose safety limits what naturalistic learning can occur.
The CES waiver funds exactly the contextual supports that make ABA therapy more effective: respite restores caregiver capacity for consistent strategy implementation; Primary Caregiver Education bridges the clinic and home environments; assistive technology supports communication across all settings; home modifications create the safety infrastructure that allows naturalistic teaching to happen safely.
Families who engage fully with both their ABA therapy and their waiver services—consistently—show better skill generalization, better maintenance of progress, and better family functioning over time. This reflects what ecological validity research in autism intervention consistently shows: outcomes improve when the whole environment is engaged, not just the therapy hour.
Getting the ABA Authorization Process Right
One practical challenge families face is ensuring ABA therapy authorizations remain current as a child’s needs evolve. Colorado Medicaid authorizes ABA services through a managed behavioral health process. Medical necessity documentation—current treatment plans, progress data, functional behavior assessments, and clear BCBA justification for recommended service hours—needs to be thorough and up to date at every authorization period.
At Achieve ABA Therapy Group, we’re experienced with Colorado Medicaid’s authorization process. Our clinical team prioritizes thorough medical necessity documentation, treatment plans that clearly link recommended service hours to the child’s functional needs, and proactive communication with families about what’s needed at each authorization renewal.
How to Apply for the Colorado CES Waiver: A Step-by-Step Guide
The application process involves multiple agencies, several assessments, and distinct eligibility determinations. Understanding each step before you begin reduces friction and helps families move through efficiently.
Step One: Find and Contact Your Local Case Management Agency
The CES waiver application begins with your local Case Management Agency (CMA). CMAs are private, nonprofit organizations contracted by HCPF to handle intake, eligibility screening, enrollment, and ongoing service coordination for waiver members. Colorado has 20 CMAs covering different geographic areas.
Find the CMA serving your area through the Case Management Agency directory on HCPF’s website, or call HCPF’s Member Contact Center at 1-800-221-3943 (State Relay: 711). When you call, explain that you’re inquiring about your child’s eligibility for the CES waiver and want to begin the intake process.
Step Two: Complete the Initial Intake and Screening
The CMA will conduct an initial intake—gathering information about your child’s diagnosis, functional needs, living situation, and current services. This is not the full eligibility determination; it’s the first conversation that determines whether a comprehensive assessment is warranted.
Come prepared: have your child’s diagnosis documentation, any prior evaluations, school records, and a summary of current services. Being organized at intake signals that you’re a prepared advocate and helps the process move more efficiently from the start.
Step Three: The Functional Needs Assessment—How to Prepare
The CMA schedules a Functional Needs Assessment to determine whether your child meets the ICF/IID level of care standard. Everything in the eligibility section about being thorough and honest applies here.
Before the assessment, write out a realistic description of your child’s support needs across a typical 24-hour period. What does a morning look like in detail? What does a difficult afternoon look like? What happens during the night? What specific support is required during personal care tasks, mealtimes, transitions, and community outings?
Bring all documentation you have: diagnosis reports, psychological evaluations, medical records, IEP records, and any existing behavior intervention plans. The more complete the picture, the more accurately the assessment will reflect your child’s genuine level of need—and the more precisely your family’s actual experience will be represented in the determination.
Step Four: Financial Eligibility Determination
The CMA works with you through the financial eligibility determination for LTSS. Remember: this is based on the child’s income and resources, not the household’s. Most families will qualify. The determination needs to be formally made—don’t assume the outcome before the process runs.
Step Five: Enrollment or Waitlist Placement
If your child meets all eligibility criteria, they’ll be enrolled in the CES waiver—or placed on a waitlist if slots are not available. Two essential points about the waitlist: the only way to eventually access waiver services is to get on the waitlist now; waiting for a more urgent moment doesn’t change your position in line, it only delays it. And while waiting, your child can access ABA therapy through EPSDT without waiver enrollment—don’t wait for the waiver to start ABA.
Step Six: Individual Service Plan Development
Once enrolled, you and your case manager develop an Individual Service Plan (ISP) identifying which CES waiver services your child needs, in what amounts, and through which providers. The ISP drives every authorization. Take the process seriously: review it carefully, ask about any service you don’t fully understand, and advocate clearly for the full scope of what your child needs—with supporting documentation for any service you’re requesting. If you believe a service belongs in the plan but isn’t included, make the case with documentation and request reconsideration.
Planning for the Transition to Adult Services at Age 18
This is the area of most consistent underplanning in the families I work with. And the consequences of being underprepared—a gap in services, a loss of behavioral support momentum, a young adult suddenly without the structure they depend on—are significant and lasting.
Why the CES-to-DD Transition Doesn’t Happen Automatically
The CES waiver ends when a child turns 18. The primary adult services pathway for individuals with developmental disabilities in Colorado is the DD (Developmental Disabilities) Waiver, which serves individuals 18 and older meeting the ICF/IID level of care. It covers residential habilitation, day habilitation, supported employment, personal care, behavioral services, community inclusion, and more.
The DD waiver is not a seamless continuation of the CES waiver. It is a different program requiring a separate application, its own eligibility determination, and enrollment in a program with its own waitlist. Families who assume the transition will happen automatically at 18 are consistently caught off-guard.
Starting the DD waiver application process at age 14 or 15 gives families the best chance of a continuous service trajectory. Case managers are required to support transition planning, and families should be explicitly asking about the DD waiver application timeline starting no later than age 14.
What Skills ABA Therapy Should Prioritize Before Age 18
This is where clinical work and policy planning intersect. As a child approaches adolescence, ABA programming should be explicitly focused on the functional independence skills that will matter most in adulthood: self-care skills across all domains, communication and self-advocacy, community safety (traffic safety, stranger awareness, emergency protocols), navigation of routine community environments, and vocational readiness skills.
The most meaningful contribution an ABA treatment team can make to a young person approaching adulthood is a clear, data-informed picture of their functional abilities alongside a trajectory toward the highest possible level of independence. That transition planning should be happening actively, not starting at age 17.
ABA Therapy in Adulthood: What Families Should Know
The EPSDT mandate ends at age 21. ABA-informed behavioral support in adulthood in Colorado is accessible through several pathways: behavioral support services within the DD waiver, Community Mental Health Supports, and private insurance. The availability and intensity of services in adulthood is more variable and more dependent on individual waiver allocation than it is for children.
Planning for this change while a child is still within the CES waiver and receiving robust ABA services—and making intentional decisions about skill priorities during those years—is how families protect the continuity of support into adulthood.
How to Work Effectively With Your Case Manager
Your CMA and the specific case manager assigned to your child are the central navigating force in your child’s waiver services. The quality of this relationship has a direct practical effect on your family’s access to services, the completeness of the service plan, and how smoothly transitions are managed.
What Your Case Manager Is Responsible For
Case managers are responsible for conducting intake and eligibility screening, completing or coordinating the Functional Needs Assessment, developing and updating the ISP, authorizing services within approved levels, coordinating among providers, completing Continued Stay Reviews, and supporting transition planning. They are also required to inform families of their rights, including the right to appeal service denials.
Case managers carry significant caseloads and may not proactively surface every benefit your child could be accessing. Coming to meetings prepared—with specific questions, updated documentation, and a clear sense of what you’re requesting—consistently produces better outcomes than waiting for the system to present options.
Advocating Effectively Between Reviews and at Them
Document your child’s current needs between ISP reviews, not only at them. If your child’s support needs have changed—new behavioral patterns, medical changes, skill regressions, or emerging safety concerns—document those changes and bring them to your case manager before the next scheduled review. Don’t wait for a crisis to surface an urgent need.
If an authorization is insufficient or a service request is denied, ask for the specific basis of that decision in writing. If the basis is clinical, address it with additional documentation from your child’s treatment team. If the basis is administrative, your case manager can often address it directly once the specific issue is named. Your child has the right to appeal eligibility determinations, level of care decisions, service denials, and authorization amounts.
When and How to Escalate
If you have unresolved concerns about your case manager’s responsiveness, the accuracy of an assessment, or a service denial inconsistent with your child’s documented needs, Colorado provides formal escalation pathways. Complaints can be filed through the Health First Colorado and CHP Plus Grievance Form, which covers case management agency complaints. HCPF’s Member Contact Center is available at 1-800-221-3943.
Advocacy organizations including the Arc of Colorado and the Colorado Cross-Disability Coalition can provide guidance for families navigating complex or contested situations. You do not have to figure out appeals processes alone.
Practical Action Steps for Colorado Families Right Now
Given the pace and scope of changes in 2026, here is a clear, situation-specific action guide.
If Your Child Is Already Enrolled in the CES Waiver
Confirm the date of your child’s upcoming Continued Stay Review and ask your case manager explicitly which services are transitioning to CFC and what the process looks like for your family. Ensure CFC authorizations are being set up before waiver authorizations expire—there should be no service gap if the transition is managed correctly.
Confirm the current status of your Community Connector authorizations in light of the January 2026 rate reduction and proposed age limitations. If your child relies heavily on this service, understand the risk and begin planning for alternatives if needed.
Confirm that your child’s ABA therapy authorization is current and that required BCBA documentation is up to date. If you’re not using the Primary Caregiver Education benefit, ask your case manager today how to access it—it may be the most valuable untapped benefit in your plan.
Bookmark hcpf.colorado.gov/medicaid-sustainability-and-ltss and check it regularly. HCPF publishes fact sheets, memos, and FAQs as changes finalize, and the landscape is continuing to evolve through 2026.
If You Haven’t Applied for the CES Waiver Yet
Apply now—even if you’re uncertain about eligibility, even if the process feels overwhelming, even if the waitlist seems discouraging. The only path to accessing waiver services eventually is to begin the process now. Contact your local CMA through the HCPF directory or call 1-800-221-3943.
While waiting for enrollment, ensure your child is accessing ABA therapy through EPSDT if eligible. ABA coverage doesn’t require waiver enrollment—that process can begin independently of where you are in the waiver application.
If Your Child Is Approaching Age 18
Begin the DD waiver application process today if you haven’t already. Ask your case manager explicitly about the DD waiver waitlist, application timeline, and what steps need to happen before your child’s 18th birthday. Work with your ABA provider to prioritize the functional independence skills that will matter most in adulthood: self-care, communication, safety awareness, vocational readiness.
Do not assume the transition is automatic. It requires active involvement, and starting early is the most protective thing you can do for your child’s continuity of support.
If your child’s authorization is approaching renewal or you have questions about coverage, reach out to our team directly.
Our ABA therapy services are available across Colorado—including Denver, Aurora, Colorado Springs, Fort Collins, Lakewood, and Pueblo.
Frequently Asked Questions About the Colorado CES Waiver
Does the CES waiver pay for ABA therapy?
No—not directly. ABA therapy in Colorado is funded through Health First Colorado’s EPSDT benefit, which is a separate program from the CES waiver. Children can—and many do—receive both ABA therapy through EPSDT and CES waiver services simultaneously. The two programs are designed to complement each other.
Is there a waitlist for the CES waiver, and how long is the wait?
Yes, the CES waiver has operated with a waitlist historically. Waitlist times vary based on enrollment, available slots, and individual need assessments. The most important step is applying as early as possible through your local Case Management Agency. Waiting for a more urgent situation doesn’t improve your position—it only delays it.
Can a child qualify for the CES waiver without an autism diagnosis?
A: Yes. The CES waiver covers children with developmental disabilities broadly, which includes autism spectrum disorder but isn’t limited to it. Children under age 5 can qualify with a developmental delay even without a confirmed diagnostic label. An autism diagnosis additionally opens access to EPSDT-funded ABA therapy, which is a separate and significant benefit.
Q: What is the Continued Stay Review, and what will happen at mine in 2025–2026?
A: The Continued Stay Review is a periodic reassessment—typically annual—where your case manager evaluates ongoing eligibility, level of care, and the service plan. In 2025–2026, it is also the transition point where certain personal care services move from the CES waiver to CFC. Come prepared with updated documentation of your child’s current support needs and any changes since the last review.
Q: My child has private insurance and Medicaid. Does having both affect waiver eligibility?
A: No. Having private insurance does not disqualify a child from CES waiver eligibility. Medicaid is the payer of last resort—private insurance is billed first where applicable. Having private insurance affects billing order, not access.
Q: What happens if my child no longer meets the ICF/IID level of care standard at a review?
A: If a level of care finding would result in disenrollment, you have the right to appeal. Request the specific basis for the finding in writing, and work with your child’s treatment team—ABA provider, physicians, therapists—to prepare additional documentation for the appeal. Don’t accept a determination without understanding the specific basis and your right to contest it.
Q: Can the CES waiver help fund my child’s AAC device?
A: Yes. Assistive Technology is a covered CES waiver benefit, and AAC devices and accessories are eligible. Insurance should be pursued first; the waiver can supplement what insurance doesn’t cover. A recommendation from a qualified professional—typically a speech-language pathologist—is required.
Q: What changed with Community Connector in 2026?
A: Community Connector rates were reduced effective January 1, 2026 per HCPF Operational Memo 26-005, based on a realignment with comparable services given training requirements. Additionally, age limitations for Community Connector have been proposed as part of HCPF’s FY 2026–27 budget requests. Families should confirm the current status of their authorizations with their case manager.
Q: What is the difference between the CES waiver and the DD waiver?
A: The CES waiver serves children birth through age 17 living in the family home. The DD waiver serves adults 18 and older with developmental disabilities and provides residential supports, day habilitation, supported employment, and community services. The transition requires a separate application, separate eligibility determination, and navigating a waitlist—families should begin the DD waiver application process by age 14 or 15.
Q: How do I find the most current information about CES waiver changes?
A: Refer directly to hcpf.colorado.gov/childrens-extensive-support-waiver-ces for current benefit set and eligibility criteria, and hcpf.colorado.gov/medicaid-sustainability-and-ltss for 2026 restructuring updates. This post reflects information available as of June 2026 and is sourced from official HCPF documents and memos.
Q: My child is on the waitlist and not receiving waiver services yet. What can we access now?
A: Several things. Ensure your child is accessing ABA therapy through EPSDT if eligible—this doesn’t require waiver enrollment and can begin immediately with a diagnosis, Medicaid enrollment, and a qualified ABA provider. Ask your CMA whether any non-waiver HCBS programs or bridge services are available while waiting. Keep your application current—notify your CMA of significant changes in your child’s needs.
Q: How does the CES waiver interact with my child’s school IEP?
A: They’re separate systems that operate independently. IEP services are educational supports provided by the school district under IDEA; CES waiver services are Medicaid-funded home and community supports. There’s no conflict between them. Many families benefit from coordinating their child’s ABA provider, school team, and case manager around shared goals—which tends to improve outcomes—but that coordination is a best practice, not a requirement.
If you have questions about your child’s ABA coverage, need help understanding how the CES waiver and EPSDT work together, or want to know whether your child might be accessing services they’re entitled to but not currently receiving—talk to our team. That conversation costs nothing and might open a door you didn’t know was there.
Sources:
- https://hcpf.colorado.gov/childrens-extensive-support-waiver-ces
- https://www.dpcolo.org/programs-services/long-term-care-case-management/children-extensive-supports-medicaid-waiver/
- https://www.douglasco.gov/human-services/assistance/medical-assistance/medicaid-children-special-needs/
- https://www.medicaid.gov/medicaid/section-1115-demo/demonstration-and-waiver-list/Waiver-Descript-Factsheet/CO
- https://pmc.ncbi.nlm.nih.gov/articles/PMC5819338/
All CES waiver eligibility criteria, benefit lists, CFC transition details, and 2026 change information referenced in this post are sourced from hcpf.colorado.gov and related HCPF informational memos, including: IM 26-002 (February 11, 2026), OM 26-005 (Community Connector rate reduction, 2026), IM 25-028 (November 2025 waiver amendments), OM 24-014 (respite service delivery expansion, 2024), OM 20-013 (Youth Day Services), and HCPF’s Medicaid Sustainability and LTSS page and HCBS-IDD Billing Manual. Always consult your Case Management Agency or HCPF directly at 1-800-221-3943 (State Relay: 711) for guidance specific to your child’s situation. This post was last reviewed June 2026.