Colorado Medicaid commission picks adviser, sharpens scrutiny of CES growth and funding gaps

Colorado’s Commission on Medicaid moved from setup to substance June 17, choosing State Health Governance as its technical adviser and using the adviser interviews to surface what many lawmakers described as the panel’s central problem: they still do not believe they have clear answers about some of the program’s fastest-growing costs.

The sharpest example was Child Extensive Services, or CES, a Medicaid home- and community-based waiver for children and teens with high support needs. During the meeting, commissioners repeatedly challenged applicants to explain how they would investigate a recent rise in the program and broader questions about whether the state has provided complete budget information.

Official budget documents confirm that CES has grown quickly, though not by a clean 100% under the most directly comparable state measures. In its FY 2025-26 cost-and-caseload adjustment request, the Department of Health Care Policy and Financing reported CES average monthly enrollment of 2,842 in FY 2023-24 and a preliminary 3,520 in FY 2024-25, with 3,941 projected for FY 2025-26. A separate Joint Budget Committee staff briefing shows CES at 3,603 enrollees on a full-program-equivalent basis by the end of FY 2024-25.

Still, the June 17 discussion showed commissioners were less focused on the exact phrasing than on what caused the increase. Sen. Barbara Kirkmeyer told applicants the commission already has the underlying numbers in budget documents and wants help figuring out "what the heck happened between 23 and 25".

HCPF’s FY 2026-27 hearing materials point to at least part of the answer. The department said it proposed ending automatic enrollment into the developmental-disabilities waiver for youth aging out of the CES and Children’s Habilitation Residential Program waivers, a practice it said had been driving future enrollment and spending. Those materials describe the change as prospective, beginning July 1, 2026, suggesting lawmakers were probing not only ordinary caseload growth but also earlier policy choices and eligibility pathways that may have expanded the program.

Commissioners also used the interviews to air broader frustration with the information they say they have received from the department. Kirkmeyer said at one point that lawmakers still do not get "accurate data" or "complete data", framing that as one reason the adviser needs to do more than facilitate meetings.

That complaint extended to federal funding. During the meeting, commissioners raised concern that Colorado may not have claimed every federal Medicaid dollar available to it, with Kirkmeyer saying lawmakers still do not know about "all the federal draw downs that we aren't getting". The meeting record presents that as a legislative concern, not a verified finding.

There is, however, official evidence that HCPF recently identified at least one area where it believed more federal money could be claimed. In the same FY 2026-27 hearing response, the department said it recognized an opportunity to claim enhanced federal matching funds for certain non-citizen emergency-services members and, within the federal two-year filing window, pursued those claims for FY 2023-24 and FY 2024-25. The document says HCPF could have drawn an average of about $6.6 million a year for that population from FY 2013-14 through FY 2022-23. The material does not tie that issue specifically to CES, but it helps explain why commissioners are questioning whether other drawdown opportunities have been missed.

The commission’s new adviser will now be expected to help turn those grievances into a work plan. Applicants were pressed on how they would test state data, identify policy changes behind enrollment jumps and compare Colorado’s Medicaid financing and waiver decisions with other states. That puts SHG at the center of a commission created by Senate Bill 26-187 to recommend legislative and executive responses to looming federal Medicaid cuts and Colorado’s own budget strain.

That larger backdrop has not changed since the panel’s first meeting. As lawmakers were told earlier this month, federal HR1 changes are expected to reduce federal Medicaid spending by about $911 billion over 10 years, tighten eligibility and financing rules, and force states to rethink how they pay for coverage.

The commission still does not directly control Medicaid spending or rules. Under SB 26-187 and the adviser request for proposals, it can only make recommendations to lawmakers, the governor and state agencies. But the June 17 meeting made clearer what those recommendations may revolve around: whether recent Medicaid growth reflects deliberate policy choices, poor information, missed federal reimbursements, or some combination of the three.