Colorado is actively investing in its home care workforce via HB25-1328, which set a $17/hr base wage targeting $25/hr by 2028. The COMPS Order provides daily OT after 12 hours for agency-employed workers, but directly-employed companions remain exempt. SEIU Local 105 organizes on an employer-by-employer basis with no statewide bargaining framework. ∼60,000 direct care workers serve a rapidly aging state (25%+ will be 60+ by 2050). FAMLI Act provides paid family leave.
| # | Metric | Colorado | Status |
|---|---|---|---|
| 1.1 | BLS median hourly wage (SOC 31-1120) | ∼$17–$18/hr | Estimated |
| 1.2 | PHI median hourly wage (all DCW, ACS) | TBD | Gap |
| 1.3 | Median annual earnings (DCW) | TBD | Gap |
| 1.4 | MIT living wage (1 adult, 0 children) | ∼$24.83/hr | Proxy |
| 1.5 | Wage gap (living wage minus BLS median) | ∼$6.83–$7.83/hr below living wage | Estimated |
| 1.6 | State minimum wage (2026) | $15.16/hr (2026); Denver: $19.29 | Public |
| 1.7 | Local minimum wage (highest city) | Denver $19.29/hr; Edgewater $18.17; Boulder County $16.82 | Public |
| 1.8 | Low-income household rate (<200% FPL) | TBD | Gap |
| 1.9 | Public assistance reliance (state-specific) | ∼49% (national proxy) | Proxy |
| 1.10 | Housing cost-burdened rate | TBD | Gap |
| 1.11 | Uninsured rate (DCW) | Yes (Medicaid expansion state) | Public |
| 1.12 | PHI Overall State Index ranking | TBD | Gap |
| 1.13 | Wage competitiveness vs. similar jobs | TBD | Gap |
| 1.14 | Genworth median home health aide rate | TBD | Gap |
| 1.15 | Genworth median NF semi-private rate | TBD | Gap |
| 1.16 | Family Care capitation PMPM (NH LOC) | $17.00/hr (HCBS base wage; Denver: $19.29) | Public |
| 1.17 | Blended HCBS avg cost (all acuity) | TBD | Gap |
| 1.18 | NF private pay monthly avg | TBD | Gap |
| 1.19 | HCBS-to-NF cost ratio (state-specific) | TBD | Gap |
| 1.20 | Exemption aggregate savings (national est.) | $500-700M/yr (∼0.2% of HCBS) | Estimated |
| 1.21 | Per-worker OT loss (50hr/wk worker) | TBD | Gap |
| # | Metric | Colorado | Status |
|---|---|---|---|
| 2.1 | Headline caregiver vacancy rate | TBD | Gap |
| 2.2 | Open caregiver positions | TBD | Gap |
| 2.3 | Available job seekers (entire labor market) | TBD | Gap |
| 2.4 | Annual turnover rate | TBD | Gap |
| 2.5 | Individuals denied/delayed services | TBD | Gap |
| 2.6 | Agencies unable to staff all hours | TBD | Gap |
| 2.7 | Nursing homes closed since 2016 | TBD | Gap |
| 2.8 | NF beds empty due to staffing | TBD | Gap |
| 2.9 | Total direct care workers | ∼60,000 (SEIU Local 105 est.) | Estimated |
| 2.10 | New jobs projected (2022–2032) | TBD | Gap |
| 2.11 | Total openings incl. separations (2022–2032) | TBD | Gap |
| 2.12 | Population 75+ growth projection | TBD | Gap |
| 2.13 | Workforce demographics: % women | ∼85% (national proxy) | Proxy |
| 2.14 | Workforce demographics: % people of color | TBD | Gap |
| 2.15 | Workforce demographics: % immigrants | TBD | Gap |
| 2.16 | Health insurance offered by agencies | TBD | Gap |
| 2.17 | Family caregivers providing 80%+ of all care | TBD | Gap |
| 2.18 | Unpaid caregiver hours/economic value | TBD | Gap |
| # | Metric | Colorado | Status |
|---|---|---|---|
| 3.1 | State companionship/OT exemption status | Agency-employed: OT required (COMPS Order, incl. >12 hrs/day). Directly-employed companions: EXEMPT. | Public |
| 3.2 | State overtime threshold | 40 hrs/wk + 12 hrs/day (agency-employed; COMPS Order) | Public |
| 3.3 | Domestic Workers Bill of Rights | No comprehensive DWBOR; partial protections via HB22-1367 (anti-discrimination), HFWA (sick leave), FAMLI (paid leave) | Public |
| 3.4 | Paid sick leave law | Yes — Healthy Families and Workplaces Act (HFWA) | Public |
| 3.5 | Paid family/medical leave | Yes — FAMLI Act (0.88% premium, eff. 2026; additional NICU leave via SB25-144) | Public |
| 3.6 | Primary self-directed Medicaid program | HCBS-EBD, DD, SLS, CES, CHRP, BI, CMHS waivers + Community First Choice (CFC) state plan | Public |
| 3.7 | Self-directed program enrollment | TBD | Gap |
| 3.8 | Primary managed LTC program | Fee-for-service + RAEs (Regional Accountable Entities) for behavioral health/coordination | Public |
| 3.9 | Managed LTC enrollment | TBD | Gap |
| 3.10 | Combined HCBS enrollment | TBD | Gap |
| 3.11 | HCBS share of LTSS spending | 91% of LTSS users in HCBS (2023; top quartile nationally) | Public |
| 3.12 | HCBS waiting lists status | TBD | Gap |
| 3.13 | Spouses as paid Medicaid caregivers | Yes (CDASS — Consumer-Directed Attendant Support Services; family/spouses can be hired) | Public |
| 3.14 | Parents of minors as paid caregivers | Yes (CDASS + IHSS self-direction models within EBD/CFC) | Public |
| 3.15 | COVID family caregiver relaxations permanent? | HB25-1328 ($17/hr base, $25/hr target by 2028); HB25-1001 (anti-retaliation); SB25-005 vetoed (union); HB26-1005 pending | Public |
| 3.16 | SDPC maximum wage (self-directed) | TBD | Gap |
| 3.17 | OT rate cap in self-directed programs | TBD | Gap |
| 3.18 | IRIS/SDPC weekly hour cap | TBD | Gap |
| 3.19 | Minimum fee schedule for HCBS | TBD | Gap |
| 3.20 | Wage pass-through requirement | TBD | Gap |
| 3.21 | MCO contract wage floor provisions | TBD | Gap |
| 3.22 | Union representation (home care workers) | SEIU Local 105 (8,000+ members, healthcare/janitorial/security); no statewide home care bargaining framework | Public |
| # | Metric | Colorado | Status |
|---|---|---|---|
| 4.1 | Travel time/mileage reimbursement mandate | TBD | Gap |
| 4.2 | Caregiver-to-senior ratio by county | NOT COMPILED | FOIA |
| 4.3 | Counties with zero/limited home care agencies | NOT COMPILED | FOIA |
| 4.4 | Rural broadband coverage (for EVV compliance) | TBD | Gap |
| 4.5 | EVV system & vendor | TBD | Gap |
| 4.6 | EVV offline/low-connectivity accommodation | TBD | Gap |
| 4.7 | EVV hard launch date (personal care) | TBD | Gap |
| 4.8 | Rural vs. urban NF admission rates | NOT COMPILED | FOIA |
| 4.9 | Rural nursing home closures since 2016 | TBD | Gap |
| 4.10 | Rural HCBS alternatives (adult day, ALF) | TBD | Gap |
| 4.11 | Projected NF bed shortage (statewide) | TBD | Gap |
| # | Metric | Colorado | Status |
|---|---|---|---|
| 5.1 | Medicaid rate-setting authority model | Multiple HCBS waivers (EBD, DD, SLS, CES, CHRP, BI, CMHS) + CFC state plan (July 2025) | Public |
| 5.2 | Minimum fee schedule exists? | $17.00/hr base (HB25-1328); Denver: $19.29; target: $25/hr by 2028 | Public |
| 5.3 | Fee schedule codified in statute or budget? | TBD | Gap |
| 5.4 | Wage pass-through % requirement | TBD | Gap |
| 5.5 | State-level 80/20 compensation rule? | No (federal CMS rule faces rescission) | Public |
| 5.6 | MCO contract cycle & next renewal | Yes — dollar-amount wage pass-through (as of 2024; PHI indicator) | Public |
| 5.7 | MCO workforce adequacy reporting required? | TBD | Gap |
| 5.8 | IRIS IBA formula inputs reflect market wages? | TBD | Gap |
| 5.9 | Premium pay structure for extended hours? | $530M ARPA HCBS funding (expired 2025); Gov. Polis ordered $616M+ in HCPF cuts (Aug+Oct 2025) | Public |
| 5.10 | State domestic service OT exemption status | Agency-employed: state COMPS Order provides OT. Direct-hire companions: exempt. | Public |
| 5.11 | Legislative path to eliminate state OT exemption? | Partial protection — agency workers covered, direct-hire companions not; COMPS daily OT is stronger than federal | Analysis |
| 5.12 | Federal Medicaid loss projection (10yr) | TBD | Gap |
| 5.13 | Annual new cost to state taxpayers | TBD | Gap |
| 5.14 | State-directed payment limit impact (eff. 2028) | 110% Medicare cap; exact impact TBD | Pending |
| 5.15 | Provider tax moratorium status | TBD | Gap |
| 5.16 | NF staffing rule moratorium (10yr) | Applies (est. 13,000 add'l deaths/yr nationally) | Public |
| 5.17 | Work requirements effective date | Dec 31, 2026 (childless adults) | Public |
| # | Metric | Colorado | Status |
|---|---|---|---|
| 6.1 | 2013 DOL rule status (as of March 2026) | Technically in effect; enforcement suspended July 25, 2025 (FAB 2025-4) | Public |
| 6.2 | Proposed rescission rule published? | Yes — July 2, 2025 (90 FR 28976) | Public |
| 6.3 | Final rescission rule published? | No (as of March 2026) | Monitor |
| 6.4 | Chevron deference status | Eliminated — Loper Bright v. Raimondo (2024) | Public |
| 6.5 | Private litigation still viable? | Yes — 2013 rule provisions still invocable by private parties | Public |
| 6.6 | DOL estimated annual transfer (2013 RIA) | .8M (medium scenario, 7% discount) | Public |
| 6.7 | Adjusted current estimate | -700M annually | Estimated |
| 6.8 | GAO post-implementation finding | Hour caps, not cost absorption; pay did not increase; workforce declined 11.6% | Public |
| 6.9 | Familial caregiver % in self-directed programs | 50-78% nationally; CA IHSS >70% | Public |
| 6.10 | Disparate impact demographics | 85% female; 67% POC; 27% Black; 26% Hispanic | Public |
| 6.11 | CMS 80/20 Access Rule status | Finalized May 2024; faces likely rescission/non-enforcement | Public |