Health First Colorado, the state’s Medicaid program, does cover assisted living in Colorado, but only the care services and only in facilities with a specific state certification. It does not pay for room and board. Residents still owe the housing and meal portion of the bill out of pocket, while Medicaid picks up personal care, supervision, and related services through the Elderly, Blind and Disabled (EBD) waiver.
That split is the single most important thing to understand before counting on Medicaid to make assisted living affordable.
What Medicaid Pays For, and What It Doesn’t
Medicaid will only cover care in an assisted living residence that holds Alternative Care Facility (ACF) certification from the state. ACFs are assisted living residences certified by Health First Colorado to deliver health-related services in a community setting. Not every assisted living community in Colorado is an ACF, so confirm the certification with any facility you are considering before assuming Medicaid can help.
Inside an ACF, Medicaid reimburses the facility for:
- 24-hour protective oversight
- Personal care, including bathing, dressing, toileting, mobility, and eating
- Help with daily living skills a resident can no longer manage alone
- Homemaker services such as housekeeping and laundry
Memory care units within assisted living residences are included.
As of January 2026, the state pays ACFs $103.72 per day outside Denver County and $109.32 per day inside Denver County for these services.
What Medicaid will not cover is the roof over the resident’s head or the food on the plate. Those are the resident’s responsibility.
The Room-and-Board Math
The median cost of assisted living in Colorado is approximately $5,877 per month, according to CareScout survey data. Private pay at that level is out of reach for most people. The Medicaid ACF structure is designed to keep the out-of-pocket piece affordable.
For a Medicaid recipient in an ACF, state rules cap what the facility can charge for room and board at $810 per month as of January 2026. The resident also keeps a personal needs allowance of $184 to $435.46 per month, depending on income. Those two figures are calculated against the federal Supplemental Security Income benefit of $994 per month.
For someone whose only income is SSI, the numbers line up. For someone with a larger Social Security check or a pension, nearly all of that income goes toward care, and only the room and board payment and the personal needs allowance stay with the resident.
One note on how this compares to nursing home coverage: nursing home care under Health First Colorado is an entitlement that covers room and board, with no waitlist. Assisted living through the EBD waiver is not an entitlement, though as of 2026 the EBD waiver has no enrollment cap and no current waitlist either. A semi-private nursing home room runs about $120,450 per year in Colorado, compared to roughly $70,521 for assisted living, which is part of why the state funds community-based care as the alternative.
Who Qualifies for the EBD Waiver
The EBD waiver is the main Medicaid pathway for assisted living in Colorado. Qualifying has two sides: financial and functional.
Financial Eligibility
For 2026:
- A single applicant must have monthly income below $2,982 and no more than $2,000 in countable assets.
- If one spouse of a married couple is applying, the applicant faces the same $2,982 and $2,000 limits. The non-applicant spouse may keep up to $162,660 in assets under the Community Spouse Resource Allowance.
- If both spouses are applying, combined income must be below $5,964 per month, with a $3,000 asset limit.
Several assets don’t count: a primary residence (with equity up to $1,130,000, provided the applicant intends to return home or a spouse lives there), one vehicle, household goods, personal belongings, and irrevocable burial trusts.
Functional Eligibility
The applicant must need what Colorado calls a Nursing Facility Level of Care. A case management agency representative conducts a face-to-face evaluation called the Uniform Long Term Care (ULTC) 100.2 assessment. It looks at the person’s ability to perform six activities of daily living (bathing, dressing, toileting, mobility, transferring, and eating) and their need for supervision due to behavioral issues or memory and cognition problems.
To qualify, the person must need at least moderate assistance with two or more of those activities, or require moderate supervision for behavior or cognitive reasons. A physician must also complete a Professional Medical Information Page documenting diagnoses, medications, and dietary needs.
When Income or Assets Are Too High
Being over the limits is not an automatic no. Colorado recognizes several planning tools.
Miller Trusts for Excess Income
If monthly income exceeds $2,982 but falls below the actual cost of care, the applicant can set up a Qualified Income Trust, usually called a Miller Trust. All income flows into the trust’s checking account, which then distributes funds under Medicaid rules: care costs, personal needs allowance, Medicare premiums, and any spousal income allowance. The trust effectively redirects the “excess” so it isn’t counted.
Spending Down Assets
Giving assets away to get under the $2,000 limit does not work. Colorado enforces a 60-month look-back period, and any transfer for less than fair market value during those five years triggers a penalty period in which Medicaid will not pay. The penalty length equals the value transferred divided by the average monthly cost of nursing home care in the area.
Legitimate spend-down options include paying off a mortgage or credit card debt, funding home repairs, buying a vehicle, setting up irrevocable prepaid funeral and burial plans, and in some cases buying Medicaid-compliant annuities. These convert countable assets into exempt ones without triggering a penalty. Many families work with an elder law attorney or a Medicaid planner because the rules are unforgiving.
Protecting the Spouse at Home
When one spouse applies and the other stays in the community, federal law protects the non-applicant from being impoverished. The community spouse may keep up to $162,660 in assets and is guaranteed a Minimum Monthly Maintenance Needs Allowance of $2,643.75 per month (effective July 1, 2025 through June 30, 2026). If the community spouse’s own income falls below that amount, income can be shifted from the applicant to make up the difference. If housing and utility costs exceed $793.13 per month, the spousal income allowance can go higher, up to $4,066.50.
How to Apply
Getting approved involves two separate steps: enrolling in Health First Colorado, then applying for the EBD waiver.
For Health First Colorado enrollment, you can apply:
- Online through the Colorado PEAK portal at co.gov/peak (usually the fastest route)
- By phone at 1-800-221-3943, Monday through Friday, 8 a.m. to 4 p.m.
- By mail using a printed application from the HCPF forms page
- In person at a local county Department of Human Services office
Once you’re enrolled in Health First Colorado, contact your local Case Management Agency (formerly called a Single Entry Point agency) to start the EBD waiver application. The Department of Health Care Policy and Financing publishes an interactive map and county directory on its website. You can also call 1-844-264-5431 to reach your regional agency.
The waiver application triggers the functional assessment described above and requires extensive financial documentation. Be ready to produce bank statements, investment and retirement account records, property deeds, records of any gifts or transfers, life insurance policies, vehicle titles, and trust documents covering the prior 60 months. Processing time for long-term care Medicaid applications typically runs 45 to 90 days, and complex cases can take longer.
Other Pathways to Coverage
Health First Colorado Buy-In for Working Adults with Disabilities
Working adults with disabilities who earn too much for standard Medicaid can still access EBD waiver services, including ACF placement, through the Buy-In Program. There is no asset limit, and income can be up to 450% of the federal poverty level. Participants pay a monthly premium between $0 and $200 on a sliding scale. The applicant must be currently employed and have Social Security Administration verification of a qualifying disability. Applications go through Colorado PEAK or local Medicaid offices, and the dedicated line is 1-800-711-6994.
PACE
The Program of All-Inclusive Care for the Elderly bundles Medicare and Medicaid services into a single coordinated plan. PACE serves adults 55 and older who meet nursing facility level of care and live inside a participating organization’s service area. When a participant can no longer be safely supported at home, the PACE organization is responsible for arranging and funding care in a long-term care facility. All care has to go through the PACE organization’s network.
Six PACE organizations currently operate in Colorado:
- Colorado PACE: Adams, Arapahoe, Denver, Douglas, and Jefferson counties
- HopeWest PACE: Mesa County
- InnovAge Colorado PACE: Adams, Arapahoe, Broomfield, Denver, Jefferson, Larimer, Pueblo, and Weld counties
- Rocky Mountain PACE: El Paso County
- Senior CommUnity Care PACE: Delta and Montrose counties
- TRU PACE: Adams, Boulder, Broomfield, Jefferson, and southwest Weld counties
People eligible for both Medicare and Health First Colorado pay no premium. Those eligible only for Medicare may be charged a premium, and a private-pay option exists for people not eligible for either program.
Estate Recovery After Death
Federal law requires Colorado to run a Medicaid estate recovery program, and it applies to people who received assisted living services through HCBS waivers. After the recipient dies, the state may seek reimbursement from the estate for benefits paid on the person’s behalf, particularly for services received at age 55 or older. Real estate, vehicles, bank accounts, investment and retirement accounts, and personal property can all be reached.
Recovery is prohibited if the deceased is survived by a spouse, a child under 21, or a blind or disabled dependent. Additional protections apply to siblings or adult children who lived in the home and provided care under specific circumstances. The state also considers hardship waivers when recovery would force heirs onto public assistance or cause the loss of a family business such as a working farm or ranch. The program is administered through Health Management Systems, with more information at comedicaidrecovery.com.