Texas revises CFC fees impacting agency budgets

Significant changes are underway for Texas Community First Choice (CFC) payments, bringing important challenges for agencies serving individuals with intellectual and developmental disabilities (IDD). As of September 1, 2025, newly approved updates to the state’s Medicaid plan have altered attendant care reimbursement in ways agencies must address without delay. The Centers for Medicare & Medicaid Services (CMS) approved Texas’ state plan amendment TX-25-0004 on November 24, 2025, officially updating CFC fee schedules and eliminating the attendant compensation rate enhancement program (often called ACEP). This move ends extra rate add-ons that many providers previously relied upon, reverting payment rates to standard fees based on broader Medicaid cost reports and existing waiver programs.

What does this mean for IDD providers?

First, any budget or staffing plan that accounted for enhanced pay or add-on rates will likely face a shortfall. Although some prior notices increased base wage support for attendant services, the termination of ACEP means reimbursement will no longer include those supplemental payments. Agencies could now find their operational costs outpacing available funding if they don’t revise assumptions quickly. To navigate these shifts, agencies must thoroughly audit their CFC claims, authorizations, and budgets. Pay close attention to wage assumptions, attendant hours, payroll-related expenses, and administrative overhead, ensuring all are in line with the new fee schedules. Staffing strategies that depended on overtime or bonuses must be reevaluated. Adjusting shift allocations and compensation expectations early can prevent unsustainable losses and avoid risking underpayments to providers.

Additionally, agencies operating under multiple Medicaid programs—such as CFC, waiver services, or personal care services—should carefully track which services are impacted and reconcile reimbursement structures accordingly. Because these changes took effect months ago but were only approved by CMS recently, providers are facing immediate operational risks. Prompt action is critical. Scheduling a deep review of budget and staffing plans before year-end will help catch and correct any financial gaps before they become liabilities. Texas IDD agencies must act now to adapt to changing CFC reimbursement. Taking a proactive approach will be vital to maintaining quality care and financial stability in this evolving landscape.