To apply for Colorado Medicaid long-term care, file through Health First Colorado online at Colorado PEAK, or on a paper application you mail in or drop off at your county office. If gross monthly income tops $2,982 but is still below the average private-pay nursing-facility rate for your region of Colorado, you must first set up an income trust that names Colorado Medicaid as a beneficiary. This guide covers the three application channels, the income trust requirement, required documents, processing timelines, and appeals.

In This Guide

Two Application Tracks: Nursing Facility vs. Home-Based Care

Long-term-care Medicaid in Colorado runs on two tracks, and knowing which one you are on changes what to expect. Both share the same financial rules (the $2,982 income cap, the income trust, and the $2,000 asset limit for a single applicant, $3,000 for a couple, though that couple figure isn't the test when one spouse needs care and the other stays home), but the care setting differs.

  • Nursing-facility Medicaid pays for care in a licensed nursing home.
  • Home and Community-Based Services (HCBS) waivers pay for supports that let a person stay in their home or another community setting instead of a nursing facility.

Long-term care also turns on a clinical finding, the nursing facility level of care: the determination that a person needs the kind of care a nursing facility provides. The criteria behind it are set in state rule, not by one national test. For the home-based track, Colorado's EBD waiver requires that the person meet an institutional (nursing-facility) level of care. Ask HCPF or your county office how the level-of-care assessment is arranged for the track you're on.

The practical difference: HCPF notes that waivers have extra program rules and sometimes have waitlists. If you're already enrolled in Health First Colorado, you start the EBD waiver application by contacting your local Case Management Agency; if you aren't, you apply for Health First Colorado first.

Before You Apply: The Income Trust

Colorado is an income-cap state. If an applicant's gross monthly income exceeds $2,982 (300% of the 2026 Supplemental Security Income (SSI) Federal Benefit Rate of $994), they cannot qualify for nursing-facility or HCBS-waiver coverage unless they first establish an income trust, which is Colorado's term for a Qualified Income Trust (also called a Miller Trust). The trust route is bounded on both ends: it is the fix for an applicant whose gross income is above the $2,982 level but still below the average private-pay nursing-facility rate for their region of Colorado.

Colorado's income trust carries a distinctive requirement: HCPF must be a beneficiary of the trust alongside the member, and when the trust terminates the trustee must pay HCPF whatever remains in it, up to the total medical assistance Colorado paid on the member's behalf. That cap matters: the state is repaid what it spent, not automatically everything left in the account. HCPF's trust instructions say the trust is required to establish and maintain income eligibility for long-term care, so get it signed and ready to receive each month's excess income before your application is decided.

Once the trust is set up, the applicant deposits the income above the cap into the trust account each month, so the income Colorado counts falls below the $2,982 limit. If the applicant is living in a nursing facility or an intermediate care facility, they keep a Personal Needs Allowance of $110.36 a month for 2026 if they are not a veteran or a veteran's widow(er). The allowance is lower, $90 a month, for a veteran with no spouse or dependent child who receives a non-service-connected VA disability pension, and for a veteran's widow(er) with no dependent children; a resident who works may keep an extra $65 a month plus half of the remaining gross earnings. These allowances are facility figures; if you'll be on a home-based waiver, ask your case manager how your own income will be treated.

An elder law attorney familiar with Colorado Medicaid can help you set up the trust, and HCPF tells applicants to check with their eligibility site whether one is needed at all. If your income is below $2,982/month, skip this step and proceed directly to the application.

How to Apply for Colorado Medicaid: Step by Step

The application itself is one process with three ways to file. Work through these steps in order, and if your income tops the cap, handle the income trust (Step 1) before you submit.

1
Step 1

Set up the income trust first, if your income is over the cap

If gross monthly income exceeds $2,982 but stays below the average private-pay nursing-facility rate for your region, the applicant cannot qualify until an income trust is in place to receive the excess each month. Get it done before you file. If income is below $2,982, skip to Step 2.

2
Step 2

Gather your documents

Pull together identity and residency proof, income statements, financial-account records (including the long-term-care look-back statements), property documents, and the medical records that support the level-of-care need. The document list below is a working checklist.

3
Step 3

Choose a channel and submit

File whichever way fits the applicant's situation:

  • Online through Colorado PEAK. HCPF's application page sends online applicants to www.colorado.gov/PEAK, the state's benefits portal.
  • On paper, by mail or in person. Print a paper application from HCPF and mail it in, or drop it off at your county of residence's local county office or at a local application assistance site. Find your county office through the state's county human services directory. Going in person can make sense when the situation is complex, such as a married couple with spousal-impoverishment questions.
  • By phone. Federal rules require every state Medicaid agency to accept applications by telephone, though HCPF's application page describes online and paper applications. Call HCPF's Member Contact Center at 1-800-221-3943 (State Relay 711) to ask how. Have the applicant's Social Security number, income documentation, and an asset summary ready before calling.
4
Step 4

Complete the level-of-care assessment

Long-term care also turns on the clinical finding that the applicant needs the kind of care a nursing facility provides, under criteria set in state rule. For home-based care, an applicant already enrolled in Health First Colorado starts the EBD waiver application with the local Case Management Agency. Tell your county office or HCPF whether you're applying for nursing-facility or home-based care so they route you correctly.

5
Step 5

Respond quickly to any document requests

Check PEAK and your mail regularly after you file, and answer each request by the date it gives.

What Documents You'll Need

Gather these before submitting. The eligibility site decides what it needs from you, so treat this as a starting list and expect requests for more.

Identity and residency:

  • Social Security card or letter
  • Colorado driver's license or state ID
  • U.S. birth certificate, passport, or Certificate of Naturalization
  • Proof of Colorado residency (utility bill, lease, or similar)

Income:

  • Social Security award letter or most recent SSA-1099
  • Pension and retirement income statements
  • Any other monthly income statements

Financial accounts:

  • Bank statements for all checking and savings accounts (far enough back to cover the 60-month look-back, which counts backward from the application)
  • Statements for CDs, retirement accounts, stocks, and bonds
  • If an income trust is required: the signed trust document and records of the monthly deposits of excess income into it

Property:

  • Property deed for the primary residence
  • Recent property tax statements
  • Vehicle title or registration
  • Life insurance policy information (face value and cash surrender value)
  • Burial plot or prepaid funeral contract documentation

Medical:

  • Recent physician's statement or hospital records supporting the level-of-care need
  • Medicare card and any supplemental insurance cards

What Happens After You Apply

After you submit, expect requests for any missing documents. If your income is over the cap, the income trust is what establishes income eligibility, so send the trust document as early as you can.

Federal rules cap how long the state may take. The determination may not exceed 45 days for most applicants, or 90 days for applicants who apply on the basis of disability, measured from the date of application. Those figures are outer limits the agency must work inside, not a guarantee your decision will arrive by then. The regulation excuses the limits only in unusual circumstances, and gives examples rather than a closed list: a delay caused by the applicant or by an examining physician, an administrative or other emergency beyond the agency's control, or the 30-day period an applicant gets to respond to a community-engagement notice of noncompliance.

The application date also anchors retroactive coverage. Federal law requires Medicaid to cover services furnished in or after the third month before the month of application, if the applicant would have been eligible then, which can cover care received in the months just before you applied. The three-month window is the federal default, but an approved Section 1115 demonstration can give a state a shorter one, so confirm Colorado's current retroactive window with HCPF. (For applications filed on or after January 1, 2027, federal law shortens this window to two months before the application month for most enrollees, and one month for the Medicaid expansion adult group.)

If HCPF or the county needs more information, answer by the date on the request. Keep every written notice you get: if the decision is a denial, the date on that Notice of Action starts your appeal clock.

Why Applications Get Denied

These are the problems to rule out before you file a long-term-care application.

Income over the cap without a trust. An applicant whose gross monthly income exceeds $2,982 is denied unless an income trust is in place. If you receive a denial for this reason, have an elder law attorney prepare the trust document and reapply.

Assets over the limit. HCPF requires countable resources under $2,000 for a single person or under $3,000 for a couple, but that couple figure isn't the test when one spouse needs care and the other stays home (see the spouse question in the FAQ). Colorado applies a 2026 home-equity maximum of $1,130,000. When one spouse stays at home, Colorado's rule puts no limit on the value of household goods, personal effects and one automobile, and the home isn't counted in the at-home spouse's resource allowance.

Asset transfers during the look-back period. Colorado looks back 60 months, counting backward from the application, for gifts or below-market transfers., Uncompensated transfers within that five-year window can trigger a penalty period, though federal law exempts some transfers, such as those to a spouse. A penalty isn't a denial of Medicaid itself: it's a stretch of months when Medicaid won't pay for nursing-facility or waiver care. An elder law attorney can evaluate whether any exceptions apply.

Missing or late documentation. Don't let a document request sit. Check PEAK and your mail regularly after applying, and answer each request by the date it gives.

How to Appeal a Colorado Medicaid Denial

If your Health First Colorado application is denied, you have the right to request a state fair hearing. Federal law caps that window rather than guaranteeing it. Under 42 CFR 431.221(d), a state must allow a reasonable time to request a hearing, and that time may not exceed 90 days from the date the notice of action is mailed. Ninety days is the most a state may allow, not a minimum you are entitled to. Colorado allows less: HCPF says you generally have 60 days from the date on your Notice of Action to ask for a state fair hearing, and tells you to follow the directions in your letter, because missing a deadline can cost you coverage or leave a gap in it. A shorter state window like this is enforceable. Plan against 60 days, not three months, and check the deadline printed on your own denial notice, which is the one that governs your case.

To request a hearing, follow the steps on the denial notice. Colorado's Office of Administrative Courts holds the hearing before an administrative law judge. You don't need a lawyer: a family member, advocate or anyone you trust can represent you, and a non-lawyer representative needs the OAC's Non-Attorney Authorization Form signed by both of you.

HCPF lists Colorado Legal Services, which gives free legal help to low-income Coloradans, among the places to get help with an appeal.

Where to Get Help

Health First Colorado Member Contact Center HCPF's member line for Health First Colorado questions (State Relay 711). 1-800-221-3943 www.colorado.gov/PEAK
Department of Health Care Policy and Financing (HCPF) Colorado's Medicaid agency; program information and contacts. hcpf.colorado.gov/contact-hcpf
Colorado Office of Administrative Courts Holds Medicaid state fair hearings before an administrative law judge. oac.colorado.gov
Colorado Legal Services Free legal help for low-income Coloradans; HCPF lists it for appeals help. www.coloradolegalservices.org

Frequently Asked Questions

What is Health First Colorado and who administers it?

Health First Colorado is Colorado's Medicaid program, administered by the Department of Health Care Policy and Financing (HCPF). It covers long-term care for aged, blind, and disabled residents who qualify.

Do I apply differently for home care than for a nursing home?

You apply for Health First Colorado the same way, but home-based care then runs through the EBD waiver, which requires an institutional (nursing-facility) level of care and, HCPF notes, sometimes has a waitlist. If you're already enrolled, you start the waiver application with your local Case Management Agency. Tell your county office or HCPF which setting you're applying for so they route you correctly.

Can a family member apply on behalf of an applicant?

Yes. Federal rules require the state Medicaid agency to let an applicant name an authorized representative, who can be authorized to sign the application, receive the agency's notices, and act for the applicant in other matters with the agency. The agency must also recognize authority under state law, such as a power of attorney or a guardianship order. Contact HCPF or your county human services office for the current form requirements.

How long does the Colorado Medicaid application process take?

Federal rules cap the determination at 45 days for most applicants, and at 90 days for applicants who apply on the basis of disability, measured from the application date; Colorado must operate within those limits, apart from the narrow unusual circumstances the regulation allows. Read them as ceilings on the agency rather than a promised turnaround. Sending a complete application with all documents helps avoid delays. For questions along the way, call HCPF's Member Contact Center at 1-800-221-3943.

Does a spouse's income affect the income trust requirement?

No. Colorado's income trust test turns on the applicant's own gross income. Resources are handled separately, and Colorado's spousal-impoverishment formula protects the couple's total resources up to a maximum, not half of them: under 10 CCR 2505-10 § 8.100.7.M.1 the Community Spouse Resource Allowance is the couple's total resources up to HCPF's 2026 maximum of $162,660, unless an increased allowance under the rule or a court-ordered amount is larger. There is no one-half spousal-share step and no minimum-resource-standard step in Colorado's calculation. The institutionalized spouse is resource eligible once the couple's total resources are at or below that CSRA plus the $2,000 individual allowance. On the income side, CMS sets two federal standards for 2026: a Minimum Monthly Maintenance Needs Allowance of $2,705.00 (effective July 1, 2026) and a Maximum Monthly Maintenance Needs Allowance of $4,066.50 (effective January 1, 2026). Colorado's rule builds the at-home spouse's income protection on them: the at-home spouse's minimum monthly needs are the MMMNA plus an excess shelter allowance when shelter costs exceed 30% of the MMMNA, that total can't exceed the $4,066.50 maximum, and the monthly income allowance from the institutionalized spouse's income covers the gap between those needs and the at-home spouse's own income. The $4,066.50 cap isn't an absolute ceiling on the allowance: an additional amount may be approved for certain medical and insurance costs, a higher amount can be set through a fair hearing when exceptional circumstances cause significant financial duress, and a court support order sets a floor under it. An elder law attorney can run the exact numbers for your situation.

Learn More

Find personalized help applying for Colorado Medicaid through Health First Colorado at brevy.com.


The information on Brevy.com is for educational purposes only and is not a substitute for professional legal, financial, or medical advice. Rules vary by state and program and change frequently. Always verify with the relevant agency or a qualified professional. Brevy is not a law firm, financial advisor, or healthcare provider.

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