Death of an Individual

Guidance for Colorado HCBS providers on required notifications, documentation, supporting families and staff, and fulfilling follow-up responsibilities with care and dignity.

The death of an individual receiving services is one of the most profound events a support team can experience. How an agency responds — with both compassion and procedural care — reflects its deepest values. The guidance below is intended to help providers meet their legal obligations while honoring the dignity of the person who has passed and supporting those who loved and cared for them.

Respecting Dignity and Wishes

• Treat the individual with the same respect in death as in life — this includes how you speak about them, how their space is managed, and who is present
• Follow any documented end-of-life wishes, advance directives, or do-not-resuscitate (DNR) orders that are on file
• Do not disturb the individual or their environment beyond what is necessary for emergency response, unless instructed by emergency personnel
• Be thoughtful about what is said in the presence of others — family members, housemates, and other individuals receiving services may be present and affected
• If the individual had religious, cultural, or personal wishes about death and burial, communicate these to family and relevant parties as soon as it is appropriate

Required Notifications

[Immediately] Emergency Services (911): Call 911 if the individual's death was unexpected, unattended, or the cause is unknown. Do not attempt to move the individual before emergency personnel arrive.

[Immediately] Your supervisor / agency leadership: Notify your supervisor the moment you become aware of the death, regardless of the time of day.

[As soon as possible] Authorized family members or guardian: Notification of family or legal guardian should occur as soon as possible after the event. Follow the support plan's instructions for who to contact and in what order.

[Within 24 hours] Case manager and Community Centered Board (CCB): The death of a Medicaid waiver recipient must be reported to the case manager and CCB within 24 hours.

[As required] Colorado HCPF and CDPHE: Depending on circumstances, the Colorado Department of Health Care Policy and Financing (HCPF) and CDPHE may require notification. Follow current reporting requirements and your agency's policy.

[As required] Law enforcement: If the death was unexpected, suspicious, or involved injury, law enforcement must be notified and the scene must not be disturbed.

Documentation Requirements

• Complete an incident report documenting the date, time, and circumstances of the death as you observed or were informed — factually and without speculation
• Record all notifications made — who was contacted, at what time, by whom, and what was communicated
• Document any emergency response — if 911 was called, when they arrived, and what instructions they gave
• Preserve all documentation, support plans, MARs, and service notes intact — do not alter or remove any records
• Follow agency policy regarding medication documentation and securing or disposing of medications after a death
• Document support provided to family members, housemates, or other individuals who were present or affected
• Record any follow-up actions required by the case manager, CCB, or regulatory body

Supporting Family and Staff

Supporting Family

• Communicate with warmth, clarity, and patience — family members are in grief
• Provide information about what happened in straightforward, respectful language
• Honor family preferences for privacy and timing
• Follow the individual's documented wishes in any communication about their passing
• Be available for follow-up questions within appropriate boundaries

Supporting Staff

• Debrief with staff as soon as it is appropriate — acknowledge that this is a significant event
• Connect staff with employee assistance resources if available
• Check in with staff over the days following the event
• Recognize that staff may grieve differently — some may need time, others may need to return to routine
• Document any staff support provided as part of the agency's post-incident response

Coordinating with Outside Agencies

• Cooperate fully with any investigation by law enforcement, CDPHE, HCPF, or Adult Protective Services
• Provide requested documentation promptly and completely
• Do not speculate or provide opinion — provide facts as documented
• Follow instructions from the coroner or medical examiner if applicable
• If the individual was on Medicaid, coordinate with the case manager to close the service authorization appropriately
• Submit required reports to regulatory bodies within required timelines

Follow-Up Responsibilities

Internal review: Conduct an internal review of the events surrounding the death to identify any practice or documentation concerns and implement improvements.

Quality assurance: Include the event in your agency's quality assurance review process. Identify any systemic issues and document corrective actions.

Regulatory follow-up: Respond to any requests or findings from HCPF, CDPHE, or other regulatory bodies in a timely manner.

Support plan closure: Work with the case manager to formally close the individual's service records and support plan in accordance with agency policy and state requirements.

Ongoing staff support: Check in with staff in the weeks following the event. The impact of losing someone in their care may be felt over time, not just immediately.

Need Help? Contact Extended Care Services Education

Extended Care Services Education offers consulting, staff training, mock audits, and compliance support tailored for Colorado HCBS providers.

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