Colorado Class B home care agency license: opening a non-medical personal care agency

One license, two classes

Colorado licenses every in-home care business under a single Home Care Agency (HCA) license. CDPHE issues it in two classes ⁠¹:

• Class A agencies provide any skilled healthcare service delivered by licensed nurses, certified nursing assistants, or licensed therapy and respiratory professionals. They may also provide personal care ⁠¹.
• Class B agencies provide only personal care services. A Class B agency “shall not provide any skilled healthcare service” ⁠¹⁠².

The licensing rules are 6 CCR 1011-1 Chapter 2, which covers general licensure for every health facility, and Chapter 26, which covers home care agencies ⁠¹. The Board of Health adopted the version of Chapter 26 in force on 2026-10-12 on April 16, 2025, effective July 1, 2025 ⁠². Every Class B agency must meet Part 5 of Chapter 26 (general requirements) and Part 7 (non-medical/personal care). Part 6, the skilled-care part, applies only to Class A ⁠².

You pick the class when you apply. To move from Class B to Class A later, you file a new initial application and pay the initial Class A fee. It is not treated as an amendment ⁠². If you expect to add nursing visits within your first few years, see the Colorado Class A home care agency guide before choosing.

Companion care counts: who needs a Class B license

Some states let companion-only or homemaker-only businesses register instead of getting a license. Colorado’s line falls in a different place. Chapter 26 defines personal care services as help with activities of daily living, “including but not limited to: bathing, dressing, eating, transferring, walking or mobility, toileting, continence care, housekeeping, personal laundry, medication reminders, and companionship services,” furnished in the client’s home ⁠². A business that sends staff out to provide companionship is therefore providing personal care.

The statutory definition of a home care agency leaves out a short list of providers. These include ⁠¹:

• organizations that provide only housekeeping services;
• an individual who is not employed by or affiliated with an agency and “acts alone, without employees or contractors”;
• consumer-directed attendant programs administered by the Department of Health Care Policy and Financing (HCPF);
• home care placement agencies;
• facilities otherwise licensed by CDPHE (subject to conditions), dialysis centers, outpatient rehabilitation agencies, early intervention providers and PACE programs (PACE home care services stay regulated).

Hiring even one worker moves a solo caregiver into the agency definition, because the solo exclusion applies only to someone working without employees or contractors ⁠¹.

A placement agency registration is not a shortcut. A placement agency “does not provide skilled home health services or personal care services, directly or by contract” ⁠². Running one without a registration is a misdemeanor carrying a $50 to $500 fine, and CDPHE can add a civil penalty of up to $10,000 per violation ⁠².

Residential settings get specific rules. A residential facility that delivers personal care it is not otherwise licensed to provide must either become a licensed HCA or use a licensed HCA. Each resident must be able to choose their own home care agency, and the facility “may not contract for nor provide” these services on a facility-wide basis under an HCA license ⁠². If you are planning a care home, read the Colorado assisted living residence guide first.

Medicaid made the license mandatory for personal care

Community First Choice (CFC) became active in Colorado Medicaid on July 1, 2025. Personal Care under CFC can be provided only by agencies with a Class A or Class B license ⁠⁹. HCPF’s February 2025 policy memo said that providers without one “will not be permitted to provide, or be reimbursed for, Personal Care services” on or after that date. Homemaker services, by contrast, do not require a license ⁠⁸. HCPF and CDPHE “strongly recommend applying for a Class B license” for personal care providers moving into CFC ⁠⁸.

Chapter 26 sets the same default. An HCA providing home care services regulated by HCPF is licensed Class B unless it also provides skilled care or services delivered by a licensed professional, in which case it must be Class A. Agencies in the In-Home Support Services (IHSS) program may hold either class ⁠².

Medicaid billing is a separate step after licensure:

1. Get the license

   CDPHE’s HCBS guidance says Personal Care/Homemaker Services (specialty 666) and IHSS (specialty 656) both require a Class A or Class B license ⁠⁷.

2. Add the service through CDPHE

   A licensed agency submits a letter of intent to add the service. CDPHE then surveys the agency. After a zero-deficiency survey, CDPHE uploads a Certification and Transmittal (C&T) to COHFI, its online licensing system ⁠⁷.

3. Enroll with HCPF

   You attach the C&T to your Medicaid provider enrollment application. HCPF requires a separate application for each physical location where waiver services are provided ⁠⁷. IHSS applicants must also be approved for specialty 666 ⁠⁷.

Homemaker-only Medicaid work (specialty 652) does not need an HCA license. It goes through a different CDPHE credential, the Program Approved Service Agency ⁠⁷. In its 2025 memo, HCPF estimated that the license application and provider enrollment process “takes approximately 8 months to complete” ⁠⁸.

Office, service area and insurance

A Colorado office. Every HCA serving Colorado clients must have “a physical business office capable of conducting day-to-day business as an HCA within Colorado.” That applies to out-of-state companies as well ⁠². The governing body or its designee must maintain “a fixed office location that provides for consumer confidentiality and a safe working environment” ⁠². CDPHE conducts the initial survey at the address on your application, so the lease must take effect before that survey ⁠⁶.

No plan review. Home care agencies (Class A and B) are exempt from the Facility Guidelines Institute plan review and the Division of Fire Prevention and Control Life Safety Code plan review that facility-based licenses require ⁠⁶. Chapter 2 also waives the fire Certificate of Compliance for home care agencies “because they do not provide services on their own premises” ⁠³.

Service area. You must submit a list of the contiguous counties you plan to serve. You must also show adequate staffing, supervision and services within that area ⁠². Changing the service area is a reportable change under Chapter 2 ⁠³.

Branches and workstations. You must notify CDPHE in advance before opening a branch. The branch’s area must sit inside the parent’s area, and it may not offer services the parent does not ⁠². A personal-care-only branch must have someone who meets the supervisor qualifications available during all operating hours ⁠². A workstation is a lighter option: a place where caregivers can work closer to clients. It may not hold client charts, take referrals, host marketing or training, or be open to the public ⁠².

Insurance. With your initial application and every renewal, you must show liability insurance, or a surety bond in its place, kept for the whole license term. The Class B minimum is $100,000 per occurrence and $300,000 aggregate. Class A requires $500,000 and $3,000,000 ⁠². Chapter 2 also requires proof of professional liability insurance in the applicant’s name with CDPHE listed as certificate holder ⁠³. CDPHE accepts a future effective date on the certificate, but not “TBD,” and the policy must be active before the license is issued ⁠⁶.

The HCA manager

A Class B agency may have a governing body. If it does not, it designates one individual to carry those duties. That person or body appoints an HCA manager ⁠². The manager must ⁠²:

• be at least 21 and hold a high school diploma or GED;
• have at least one year of documented supervisory experience providing personal care. Without it, the manager needs either a healthcare-services degree plus one year of healthcare work in the past ten years, or a degree in any field plus two years of healthcare work in the past ten years;
• complete an eight-hour agency manager training course, or show documented job experience or education equivalent to it, then 12 hours of related training in the first year and every year after;
• be able to communicate effectively with clients, families and other providers, using translator services when needed.

The course counts if an accredited college, university or vocational school runs it, or an organization with specific expertise. It must include at least eight actual hours. Required topics are: personal care versus health care, consumer rights, governing body duties, quality management, occurrence reporting, complaint investigation, staffing and supervision, the needs of fragile and disabled clients, and behavior management ⁠². Keep the completion certificate in the manager’s personnel file. Surveyors ask for proof of manager training at the initial survey ⁠²⁠⁶.

The manager or a written designee must be available for all hours that staff are providing services ⁠². The manager also answers for the accuracy of the agency’s marketing, which must represent only care the agency can actually provide ⁠².

Background checks for owners and staff

Owners and managers. Each owner and each manager or administrator submits fingerprints to the Colorado Bureau of Investigation (CBI) for a state and national check. They do this with the application, or within ten calendar days of becoming an owner or manager, and each pays the CBI fee ⁠². CDPHE will not issue or renew a license if an owner has a felony or misdemeanor conviction that it determines could put clients at risk. Owners must report later convictions themselves ⁠². No provisional license is granted before the background check is finished ⁠². Chapter 2 also requires a signed statement covering ten years of convictions, health-care license sanctions and refusals to license or to contract with Medicaid or Medicare, for everyone with a controlling interest ⁠³.

Caregivers. Before hiring, the agency must run a criminal history check that, at a minimum, searches Colorado records and is no more than 90 days old at the hire date. Either the agency or the applicant may pay ⁠². You must also show compliance with the Colorado Adult Protective Services (CAPS) check before employing anyone for direct care. Before employing anyone for direct care, you must also contact the Department of Regulatory Agencies (DORA) to verify whether a license, registration or certification exists and is in good standing, and put a copy of the inquiry in the personnel file ⁠².

Applying through COHFI

1. Letter of intent

   Every applicant starts with CDPHE’s letter of intent form. CDPHE then sends instructions for COHFI, its online licensing system ⁠³⁠⁶.

2. Application and fee

   Build the application in COHFI and pay the non-refundable fee. Submit at least 90 calendar days before your planned start-up ⁠³. The 90 days is a filing deadline, not a processing estimate ⁠⁶.

3. Contents

   Chapter 2 requires a distinctive name, controlling-interest disclosures (including stockholders holding 5% or more), organizing documents and bylaws, the service address, manager details, any management agreement and lease, and the ten-year history statement ⁠³. Chapter 26 adds the insurance proof, the county list and the fingerprints ⁠².

4. Defect notices

   You have 14 calendar days to respond to a written notice of any application defect ⁠³. CDPHE may treat an application as abandoned if it is not completed within 12 months ⁠³.

5. Fitness review

   After the application is complete, it goes to a fitness review. Any later change to the application triggers a new review ⁠⁶.

6. Initial survey

   A surveyor schedules the visit, which is usually on site. Have ready: proof of manager qualifications and training, staff background checks in personnel files, every required policy, the medical malpractice loss information form, and a Quality Management Plan ⁠⁶.

7. License

   CDPHE issues the license after a survey with zero deficiencies and posts it to COHFI as a PDF. Display it where clients at your address can see it ⁠⁶.

If you are not fully compliant but are making a “substantial good faith attempt,” CDPHE may issue a 90-day provisional license. A second one is possible, but never more than 180 days in total ⁠³. The provisional fee is 15% of the initial fee ⁠⁴.

On timing, CDPHE’s guidance (as read on 2026-10-12) says that initial licenses “may take anywhere from 3-12 months,” and that home care agencies “are currently taking additional time due to the number of applications coming in” ⁠⁶.

Fees on the 2026/2027 schedule

CDPHE publishes a new fee schedule by March 1 each year, effective July 1 ⁠¹. The 2026/2027 schedule applies to initial, change-of-ownership and change-of-information applications submitted on or after July 1, 2026, and to licenses expiring on or after that date ⁠⁵.

Source: CDPHE fee schedule ⁠⁴.

At renewal, Medicaid- or Medicare-certified agencies deduct $100 from the base fee. Agencies accredited by a CMS-recognized body get 10% off the base fee. Neither discount applies to branch, workstation or volume fees ⁠⁴. A revisit fee of 100% of the initial or renewal fee is charged for the second and each later on-site inspection of the same uncorrected deficiency ⁠²⁠⁴. Fees for the Colorado Bureau of Investigation fingerprint checks are paid separately ⁠².

Training and supervising caregivers

Chapter 26 does not set a minimum number of training hours for caregivers. It sets required topics, a competency check before anyone works alone, and annual minimums ⁠².

Homemakers must complete interactive initial training before working independently. It can be in person, online or hybrid, with a demonstration of what they learned. Topics include incident and mandatory reporting, the rules for non-medical care, consumer rights, home safety and infection control, and communication. They must also pass a competency evaluation that includes direct observation ⁠². Ongoing training covers at least four of those topics every 12 months ⁠².

Personal care workers complete the homemaker training plus: the difference between personal care, nurse aide care and health care; observing and documenting the client’s condition; hands-on help with daily activities; medication reminders; and any adaptive equipment the client uses. Before assignment, the manager or a supervisor runs a hands-on competency evaluation ⁠². Ongoing training covers at least six topics every 12 months ⁠². Workers with a current healthcare license or certification are exempt from the initial personal-care task training. They still need orientation and a competency check ⁠².

Supervisors must be at least 18, have experience or training in home care that meets agency policy, and have completed personal care training ⁠². A supervisor reviews each worker at least every three months, either in person or by live audio-video, checking client satisfaction and the worker’s competence. Once a year the review must be in person and include observation of the tasks the worker performs and the worker’s relationship with the client ⁠².

Where personal care stops

Part 7.4(F) of Chapter 26 lists task by task what a Class B worker may do. Anything beyond it needs a Class A agency ⁠². The limits that most often catch new agencies:

• Medications: reminders only, from medication minders already filled by the client, a family member, a nurse or a pharmacist. Workers may not set up medications, and must report irregularities immediately ⁠².
• Skin care: only on unbroken skin, preventive, with non-prescription lotions. Wound care and dressing changes are skilled ⁠².
• Transfers: only when the client can “reliably stand and pivot” and help with the transfer. Lift devices are allowed with training and demonstrated competency ⁠².
• Nail care: soaking and filing are allowed; nail trimming is not. Clients with circulation problems or loss of sensation need a skilled agency ⁠².
• Toileting: workers may empty catheter and ostomy bags but may not insert or remove catheters, do digital stimulation, insert suppositories or give enemas ⁠².
• Exercise and respiratory care: no passive range of motion and no suctioning. A worker may set oxygen flow by written instruction when changing tanks, if specifically trained ⁠².
• Feeding: only when the client can chew and swallow without difficulty and sit upright. No tube or syringe feeding ⁠².

Policies and paperwork CDPHE checks

Before the survey, your policies must cover at least the following, all required by Chapter 26 ⁠²:

• Client disclosures within one business day of starting services: a signed disclosure notice stating who employs, pays, insures, supervises and schedules the worker; a consumer rights notice; advance directive policies; payment expectations; and the state home health hotline number.
• Emergency preparedness: a documented risk assessment covering weather, outages, violence and outbreaks, and a written plan built from it. Review both every year. Train staff on the plan at hire and every year.
• Missed visits: a back-up plan for coverage. It may not rely on calling an ambulance unless emergency services would have been warranted anyway.
• Infection control: training at hire and every year, plus a policy on work restrictions for staff with communicable illnesses.
• Complaints: a log kept for at least two years, with a non-retaliation statement.
• Incidents: investigation findings available within five working days. Staff must report suspected abuse of an at-risk adult to law enforcement within 24 hours.
• Records: client records kept for five years after discharge, with a plan for records if the agency closes.
• Quality management: a quality management program, an annual evaluation of the whole operation, and a review of client records at least every quarter.

You must notify CDPHE before discharging a client who needs and wants continuing paid care when no transfer is arranged. Emergency discharges made to protect staff must be reported within 48 hours ⁠².

Renewal, inspections and enforcement

A regular license runs one year from issue ⁠³. File the renewal at least 60 days before expiration, or 90 days if the agency’s insurance has a self-insured retention ⁠³⁠⁴, reporting the previous year’s admissions ⁠². Late fees are 10% of the renewal fee at 6 to 29 days late, 50% at 30 to 59 days, and 75% at 60 to 89 days. On day 90 the license is invalid: you must stop operating and apply as a new agency ⁠⁴.

Routine unannounced inspections happen only between 7 a.m. and 7 p.m. ⁠³. During an inspection, administrative records must start reaching the surveyor within 30 minutes of a request. Records kept in a client’s home must be produced within two hours if the last visit was 14 or more days earlier ⁠². Surveyors may not inspect a client’s home without the client’s consent ⁠². An agency licensed for at least three years with a clean record may move to a survey cycle of up to three years or a tiered inspection ⁠³.

Sanctions short of revocation include hiring a consultant, monitoring, directed correction plans, and civil fines of up to $10,000 per calendar year ⁠². Moving your office requires 30 days’ notice. You keep the license only if the new address is inside your existing service area and the governing body and administrator stay the same ⁠². A change of ownership needs CDPHE’s prior approval. The current licensee’s letter of intent and the new owner’s application are due at least 60 days before the change ⁠³⁠⁴.

What changed in 2025 and 2026

• July 1, 2025: Community First Choice went live, making a Class A or B license a condition of billing Medicaid for personal care ⁠⁸⁠⁹. Chapter 26 amendments adopted April 16, 2025 took effect the same day, revising Parts 4.4 to 4.10 (fees, inspections and enforcement) ⁠².
• September 14, 2025: the version of Chapter 2 (general licensure rules) in force on 2026-10-12 took effect ⁠³.
• July 1, 2026: the 2026/2027 fee schedule took effect for new applications ⁠⁵. CDPHE posts the next schedule by March 1, 2027 for July 1, 2027 ⁠¹.

For other care licenses in the state, see the Colorado state page. The family child care home and child care center guides cover child care, which a different state department licenses.

Sources

1. 1
   Colorado Department of Public Health and Environment, Home Care Agencies Checked 12 Oct 2026 · Back to text ↑
2. 2
   Colorado Secretary of State, Code of Colorado Regulations, 6 CCR 1011-1 Chapter 26, Home Care Agencies (effective July 1, 2025) Checked 12 Oct 2026 · Back to text ↑
3. 3
   Colorado Secretary of State, Code of Colorado Regulations, 6 CCR 1011-1 Chapter 2, General Licensure Standards (effective September 14, 2025) Checked 12 Oct 2026 · Back to text ↑
4. 4
   Colorado Department of Public Health and Environment, Home Care Agencies (HCA/HHA) Fee Schedule 2026/2027 Checked 12 Oct 2026 · Back to text ↑
5. 5
   Colorado Department of Public Health and Environment, Facility Fees Checked 12 Oct 2026 · Back to text ↑
6. 6
   Colorado Department of Public Health and Environment, Initial Health Facility/Agency Licensing: Guidance and Instructions (All License Types) Checked 12 Oct 2026 · Back to text ↑
7. 7
   Colorado Department of Public Health and Environment, Medicaid Certification Guidance Document for HCBS Waiver Services Checked 12 Oct 2026 · Back to text ↑
8. 8
   Colorado Department of Health Care Policy and Financing, HCPF PM 25-001: Upcoming Licensure Requirement for Personal Care Service Providers Under Community First Choice Checked 12 Oct 2026 · Back to text ↑
9. 9
   Colorado Department of Health Care Policy and Financing, Community First Choice Option Checked 12 Oct 2026 · Back to text ↑

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