Colorado: The 56-Hour Cap and the Staffing Paradox

Colorado’s new 56-hour caregiver cap creates staffing gaps and RCM risk, as billing hour 57 can trigger denials and post-payment reviews.


The Hardship: Artificial Limits on Natural Supports

Colorado’s Department of Health Care Policy and Financing (HCPF) has introduced a hard 56-hour-per-week cap on total hours a single caregiver can provide, effective April 1, 2026. For IDD providers who rely heavily on family caregivers or dedicated residential staff to cover high-acuity needs, this creates a vacuum that the current labor market cannot fill.

RCM Insight: The "Unit 57" Denial

From an RCM perspective, this is a compliance minefield. Billing for hour 57 will not just result in a single unit denial; it can trigger a "Post-Payment Review" for the entire week. Providers must now integrate "hard stops" in their Electronic Visit Verification (EVV) systems that prevent staff from checking in once they hit the 56-hour threshold across all HMA, Personal Care, and Nursing codes.

Source: Colorado HCPF, Funding Request for the FY 2026-27 Budget Cycle - LTSS Spending Reductions (Jan 2026).

Subscribe to our newsletter

Get insights into industry trends, company updates, and more.