How to Stay Compliant Under Colorado’s Updated Assisted Living Rules (July 2025)

Colorado’s assisted living regulations (6 CCR 1011-1, Chapter 7) were updated effective July 1, 2025. While the structure of the rules remains familiar, the expectations for how homes operate, document, and train staff are sharper than before.

This guide walks you through exactly what to do as an owner to stay compliant—and avoid avoidable problems.

STEP 1: Treat Compliance as an Operating System (Not a Binder)

What changed:
The 2025 rules reduce ambiguity. Surveyors now have clearer language to enforce expectations that used to be “understood.”

What owners should do:

  • Review policies for realism—not perfection

  • Eliminate policies staff don’t actually follow

  • Align written procedures with daily practice

Owner rule of thumb:
If staff can’t explain the policy in plain English, it’s a liability.

STEP 2: Lock Down Your Staffing & Training Proof

What changed:
The rules emphasize staff capability, not just staffing levels—especially around:

  • Falls

  • Lift assistance

  • Emergency decision-making

What owners should do:

  • Confirm staff are trained to assess before calling 911

  • Document fall prevention and lift assistance training

  • Keep training logs survey-ready at all times

Owner checklist:

  • ✔ Training dates logged

  • ✔ Staff signatures on competency acknowledgments

  • ✔ Policies available to emergency responders

STEP 3: Build a Real Fall Management Program (Not Just a Policy)

What changed:
Fall management is now a defined operational responsibility—not an afterthought.

What owners should do:

  • Implement a written fall management program

  • Tie fall risk to individual care plans

  • Document corrective actions after each incident

Survey reality:
Repeated falls without documented intervention = pattern of non-compliance.

STEP 4: Make Care Plans Actually Drive Daily Care

What changed:
CDPHE expects alignment between:

  • Assessments

  • Care plans

  • Engagement activities

What owners should do:

  • Update care plans when conditions change

  • Connect engagement activities to resident abilities

  • Evaluate engagement programs quarterly

Owner insight:
Engagement is no longer “activities”—it’s regulated care.

STEP 5: Audit Emergency Preparedness & Safety Systems

What changed:
Rules reinforce expectations around:

  • Emergency lighting

  • Communication access

  • Equipment readiness

What owners should do:

  • Confirm battery or generator-powered emergency lighting

  • Ensure emergency phone access independent of household power

  • Keep AED training current if applicable

Quick test:
If power goes out tonight, can staff function immediately?

STEP 6: Re-Check Your Physical Plant—Especially for Acuity Creep

What changed:
Room sizes, bathrooms, accessibility, and safety features are mostly unchanged—but survey tolerance is lower when resident acuity increases.

What owners should do:

  • Review auxiliary aid accessibility

  • Confirm egress routes meet resident needs

  • Watch for triggers that eliminate grandfathering:

    • Renovation

    • Ownership change

    • Higher acuity residents

Owner warning:
Acuity creep creates building compliance issues fast.

STEP 7: Tighten Secure Environment Disclosures

What changed:
Secure environment requirements now emphasize transparency and informed consent.

What owners should do:

  • Ensure disclosures match actual restrictions

  • Document monitoring methods (including technology)

  • Align marketing, agreements, and operations

Common mistake:
Saying “memory care” without fully meeting secure environment standards.

STEP 8: Manage Your Survey History Like a Business Asset

What changed:
The 2025 rules make patterns of non-compliance easier for the Department to cite.

What owners should do:

  • Track recurring deficiencies

  • Show corrective action—not just correction

  • Maintain continuity in leadership and procedures

Transaction insight:
Buyers and lenders now scrutinize survey history more than ever.

STEP 9: Update Resident Agreements & Disclosures Annually

What changed:
Rules reinforce that resident agreements cannot waive compliance obligations.

What owners should do:

  • Review agreements annually

  • Align disclosures with current operations

  • Avoid over-promising services or care levels

Owner mantra:
If it’s in writing, you must deliver it.

STEP 10: Run a Self-Survey Before the State Does

What changed:
Surveyors now have better tools. Owners need them too.

What owners should do annually:

  • Walk the building like a surveyor

  • Review 5 random resident files

  • Test staff knowledge on:

    • Falls

    • Lift assistance

    • Emergency response

    • Resident rights

Bottom Line for Owners

The July 2025 Chapter 7 updates don’t change what assisted living is—but they absolutely change how it must be run.

Homes that:

  • Train intentionally

  • Document consistently

  • Align care plans with reality

…will do just fine.

Homes that rely on outdated habits, informal practices, or “we’ve always done it this way” are now exposed.

Assisted LivingBrian PinkowskiPinkowski Law & Policy Group LLCHealthcare attorneys, Health Law Attorneys, Assisted Living Lawyers, assisted living