Serving Colorado's Counties

Cybersecurity threats continue to evolve, and attackers are increasingly targeting counties through the vendors, software providers, and third-party systems they rely on every day. These incidents, often called supply chain attacks, occur when cybercriminals compromise a trusted outside partner to gain access to county systems or information.

For counties, third-party relationships are essential for daily operations. Outside vendors may support payroll, benefits administration, financial systems, public records, cloud storage, software platforms, and other critical services. While these partnerships create efficiencies, they can also introduce cybersecurity risks if proper safeguards are not in place.

UNDERSTANDING VENDOR RISKS

Third-party cybersecurity incidents can happen in several ways. A vendor may experience a data breach, a software provider may have a vulnerability exploited, or an attacker may use compromised vendor credentials to access connected systems.

Common risks include:

Because counties manage sensitive information, including PII, financial records, and employee data, understanding vendor security practices is important to reducing risk.

STRENGTHENING VENDOR OVERSIGHT

Cybersecurity should be considered throughout the vendor relationship, from selection and contracting to ongoing monitoring.

Counties should consider:

Vendor agreements should clearly define expectations for protecting information, reporting incidents, and managing access.

SHARED RESPONSIBILITY FOR CYBERSECURITY

Even when an outside provider manages information, counties still have a responsibility to understand how data is protected. Employees also play an important role by following cybersecurity best practices when interacting with vendor platforms. 

Employees should:

Cybercriminals often exploit trusted relationships, making awareness and communication essential.

WHAT THIS MEANS FOR COUNTIES

Third-party vendors are valuable partners, but cybersecurity risks do not stop at county systems. As cyber threats become more sophisticated, counties should regularly evaluate vendor relationships, access permissions, and data protection practices. Strengthening vendor oversight can help reduce data breaches, service interruptions, financial impacts, and potential claims affecting counties and CAPP. By treating cybersecurity as a shared responsibility between counties, employees, and trusted partners, counties can better protect information, control costs, and maintain essential services. For questions or additional cybersecurity resources, please contact CTSI at 303.861.0507.

The 2026 legislative session introduced several updates to Colorado’s workers’ compensation system focused on modernization, compliance, workplace protections, and administrative processes. While these changes vary in scope, counties should understand how new requirements may affect claims management, safety practices, and overall workers’ compensation operations. 

SB26-093 INSURANCE COVERAGE COMPLIANCE

SB26-093 focuses on ensuring compliance with workers’ compensation insurance coverage requirements. The legislation strengthens oversight of employer responsibilities and supports efforts to confirm appropriate coverage is maintained. Maintaining proper workers’ compensation coverage is essential to protect employees and reduce potential liability exposure. Counties should continue reviewing employee classifications, documentation, and contract requirements, including verifying workers’ compensation coverage limits of approximately $1 million as a best practice.

SB26-175 EXPERIENCE MODIFICATION FACTOR ADJUSTMENTS

SB26-175 addresses adjustments to an employer’s experience modification factor, which is used in determining workers’ compensation premium calculations. The bill updates how certain information may impact an employer’s experience modification factor. Counties should understand how claims experience and program changes may affect future workers’ compensation costs.

SB26-186 TECHNOLOGY UPDATES

SB26-186 updates the Workers’ Compensation Act of Colorado to reflect current technology needs and practices. These updates help modernize processes and improve efficiency within the workers’ compensation system.

Key areas include:

HB26-1272 CLIMATE CHANGE WORKER PROTECTIONS

HB26-1272 establishes worker protections related to changing climate conditions and workplace risks. As weather events and environmental conditions evolve, employers should evaluate potential impacts on employee safety, particularly for employees working outdoors or in changing environments.

Considerations may include:

HB26-1017 CRIMINAL RESTITUTION PROCESS CHANGES

HB26-1017 prohibits an insurer from receiving restitution through the criminal restitution process. While this change primarily affects insurance recovery processes, counties should understand that claim-related financial recovery options may be impacted when criminal proceedings are involved.

HB26-1405 CASH FUND TRANSFERS

HB26-1405 authorizes transfers from certain cash funds to the state General Fund. Although not specific to individual workers’ compensation claims, changes involving state funds may impact program administration and future funding structures.

WHAT THIS MEANS FOR COUNTIES

The 2026 legislative updates reinforce the importance of maintaining strong workers’ compensation practices, accurate documentation, and proactive safety programs. Counties should review internal policies, employee communications, and claims management procedures to ensure alignment with updated requirements. Continued focus on workplace safety, timely reporting, and compliance helps protect employees, manage claim costs, and reduce risk. CWCP will continue monitoring regulatory updates and, if a member of CWCP, know that CWCP will remain compliant with legislative changes. For questions or support related to workers’ compensation changes, please contact CTSI at 303.861.0507.

County vehicles are essential tools for delivering services and supporting community programs. In some cases, counties may consider allowing vehicles to transport participants, volunteers, or individuals involved in county-supported activities, including programs coordinated with outside organizations.

While these arrangements may support valuable community services, counties should carefully evaluate the potential risks before allowing county-owned vehicles to be used. Establishing clear expectations for vehicle use, authorized drivers, passengers, and travel limitations can help reduce liability exposure and protect county resources.

UNDERSTANDING COVERAGE CONSIDERATIONS

If a county chooses to allow a county vehicle to be used for community programs or activities, members of the Colorado Counties Casualty and Property Pool (CAPP) have coverage for this practice. However, counties should understand the potential impact of an accident.

When a county vehicle is involved in an accident, and the county driver is determined to be at fault, the loss may be charged against the county’s loss experience. Increased losses can impact a county’s loss ratio and may affect future CAPP contributions.

COLORADO GOVERNMENTAL IMMUNITY ACT

The Colorado Governmental Immunity Act (CGIA) provides certain protections and limitations for public entities. Effective January 1, 2026, CGIA claim limitations are:

However, counties should understand that these limitations may not fully address all financial impacts associated with a vehicle accident. For example, medical expenses, claim costs, and other impacts may create challenges when multiple individuals are involved.

Additionally, when a county vehicle is taken outside Colorado, CGIA protections and claim limitations may not apply. This could result in increased exposure for the county. Counties should carefully evaluate the use of out-of-state vehicles and establish guidelines to manage potential risks.

RECOMMENDED VEHICLE USE PRACTICES

To help reduce risk, counties should develop and consistently follow policies outlining appropriate county vehicle use.

Consider the following practices:

Counties should also consider requiring appropriate waivers or agreements when transporting non-employees. Any waiver or transfer-of-risk document should be reviewed by the county attorney before implementation.

WHAT THIS MEANS FOR COUNTIES

Allowing county vehicles to be used for community programs can provide important support and services, but counties should understand the associated responsibilities and potential risks. While CAPP provides coverage for approved county vehicle use, strong policies and consistent procedures are important tools for reducing claims and protecting county resources. Reviewing who is permitted to drive, where vehicles may travel, and how passengers are approved can help counties better manage risk. For questions regarding county vehicle use, coverage considerations, or risk management practices, please contact CTSI at 303.861.0507.

More than three decades after the passage of the Americans with Disabilities Act (ADA), accessibility remains an important responsibility for county governments. The ADA is a civil rights law designed to ensure individuals with disabilities have equal access to employment, public services, programs, activities, and facilities. For counties, compliance extends beyond physical accessibility and requires an ongoing commitment to removing barriers and providing reasonable accommodations.

The need for accessible government services remains significant. According to recent Colorado data, approximately 11% of Coloradans—more than 625,000 people—live with a disability, while roughly 335,000 working-age Coloradans report being unable to work because of a disability. Nationally, more than one in four adults has some form of disability.

UNDERSTANDING ADA RESPONSIBILITIES

Under Title II of the ADA, state and local governments must provide qualified individuals with disabilities equal access to public programs, services, and activities, including making reasonable modifications when necessary. Disabilities may be physical, mental, cognitive, sensory, or emotional, and while some are visible, others—such as anxiety, depression, diabetes, learning disabilities, or chronic illnesses—may not be immediately apparent.

KEY COMPLIANCE AREAS FOR COUNTIES

Counties should regularly review the following areas:

THE INTERACTIVE PROCESS

A key component of ADA compliance is engaging in an interactive process when an accommodation request is received. Requests may be made verbally or in writing and do not require specific legal language. Once a need is identified, counties should work with the individual to determine a reasonable accommodation. When necessary, additional documentation may be requested to evaluate options. The goal is to engage in good-faith discussions and identify an effective solution that does not create an undue hardship on county operations.

WHAT THIS MEANS FOR COUNTIES

ADA compliance is an ongoing process rather than a one-time project. Counties should regularly evaluate facilities, communications, websites, and service delivery methods to identify barriers and improve accessibility. Equally important is fostering a culture that recognizes disability rights as civil rights and seeks practical solutions through flexibility and collaboration. By proactively addressing accessibility concerns, maintaining required policies and procedures, and engaging in meaningful dialogue with employees, counties can reduce the risk of complaints and claims, improve service delivery, and ensure all community members have equal access to county programs and services. For more information, please contact CTSI at 303.861.0507.

As pets become increasingly common in public spaces, many counties are exploring whether to allow animals in the workplace. A pet-friendly office may improve morale and serve as a recruitment tool, but it can also create operational and safety concerns that counties should carefully evaluate. At the same time, counties must understand the legal distinction between pets and service animals, particularly under the Americans with Disabilities Act (ADA) and Colorado law.

UNDERSTANDING SERVICE ANIMALS

A service animal is not considered a pet. Under the ADA, service animals are limited to trained dogs or miniature horses that are individually trained to perform tasks for the benefit of a person with a disability. These animals are considered an extension of the individual and are protected under both federal and Colorado law. Colorado law requires employers to allow an employee with a disability to keep a service animal in the workplace unless doing so would create an undue hardship. This requirement applies even if a county otherwise prohibits pets in the workplace.

Service animals must remain under the handler’s control at all times and should be harnessed, leashed, or tethered unless the handler’s disability prevents the use of those devices. Employers may require the removal of a service animal if it becomes aggressive, disruptive, or unhousebroken.

PET POLICIES AND LIABILITY

While service animals are legally protected, employers generally have discretion regarding whether ordinary pets are permitted in the workplace. Colorado does not currently have a state law governing pets in the workplace. Counties that choose to allow pets should establish clear policies outlining acceptable behavior, supervision requirements, designated pet areas, and expectations for owners. Employers should also consider employee health and comfort, including allergies, asthma, or fears related to animals. In some situations, accommodations may be needed for both employees with disabilities who use service animals and employees with animal-related medical conditions under the ADA.

Liability is another major concern. Even well-behaved animals can behave unpredictably in unfamiliar or stressful situations. Bites, scratches, trips, and property damage can expose counties to claims and workplace disruptions. Before allowing pets into county facilities, employers may want to require employees to verify homeowner’s or renter’s insurance coverage for incidents involving their animals and establish agreements addressing responsibility for any property damage caused by pets.

WORKPLACE SAFETY CONSIDERATIONS

Safety risks increase significantly around equipment, vehicles, and maintenance operations. Animals can become distractions or create sudden obstructions in areas where heavy equipment is being operated. Pets should never be permitted in hazardous work zones or around machinery. Clearly defined pet-free areas and consistent enforcement of workplace safety policies are critical to reducing risk.

Additional practical considerations may include cleanliness, vaccination requirements, parasite prevention, noise, visitor interactions, and employee break requests to care for pets during the workday. Counties should evaluate whether allowing pets aligns with operational needs, public interactions, and workplace culture before implementing any pet-friendly policy.

WHAT THIS MEANS FOR COUNTIES

Colorado has no state laws specifically addressing pets in the workplace, giving counties discretion to establish their own policies. However, counties should understand the important distinction between discretionary pet policies and legally protected service animals, which are generally required to be accommodated under state and federal law. Because pets in the workplace can create safety, operational, and liability concerns, CTSI does not recommend allowing them without clear written policies and consistent enforcement. Poorly behaved pets can create distractions, cause property damage, or pose safety risks to employees and the public. For more information, please contact CTSI at 303.861.0507.

Slip, trip, and fall incidents remain one of the most common and costly exposures facing counties. These incidents occur in offices, parking lots, sidewalks, stairways, public facilities, and road and bridge operations. While many injuries may seem minor, they can still result in medical costs, lost work time, liability exposure, and operational disruption. Nationally, slip, trip, and fall incidents account for approximately 15 percent of all accidental deaths and remain a leading cause of workplace injuries. Recent 2025 claims data from the Colorado Counties Casualty and Property Pool (CAPP) and County Workers’ Compensation Pool (CWCP) reflect many of the same trends counties continue to face. 

CAPP CLAIM TRENDS

Within CAPP, slip, trip, and fall incidents accounted for 7% of all claims in policy year 2025. Many claims involved members of the public experiencing falls on county property or during county-related activities. Common incidents included slips on ice or snow, uneven sidewalks or pavement, wet floors, parking lot falls, stairway incidents, and accidents involving entry or exit from county transportation vehicles.

The claims data shows that many incidents occurred during routine movement through public-facing county spaces. Uneven walking surfaces, changing weather conditions, and transitions between surfaces continued to be recurring contributing factors. While some claims involved relatively minor injuries, the overall frequency of these incidents creates significant liability exposure and operational impact for counties.

CWCP CLAIM TRENDS

Employee slip, trip, and fall incidents remain a significant source of workers’ compensation claims for counties. These incidents accounted for 20% of all claims in policy year 2025, accounting for 27% of total incurred losses. Claims frequently involved employees slipping on wet or icy surfaces, falling while entering or exiting vehicles or equipment, navigating stairs, or tripping over workplace clutter, debris, or uneven ground surfaces. Equipment-related falls and winter weather conditions also appeared consistently throughout the claims data.

A common trend within the CWCP claims is that many injuries occurred during routine daily tasks rather than high-risk operations. Walking through facilities, exiting patrol vehicles or heavy equipment, climbing steps, and moving through parking lots all created opportunities for injury when footing, visibility, or environmental conditions were compromised.

PREVENTION STRATEGIES

Slip, trip, and fall prevention requires continuous attention to both workplace conditions and employee behavior. Counties should focus on identifying hazards early and correcting them before an incident occurs.

Preventive measures may include:

WHAT THIS MEANS FOR COUNTIES

Slip, trip, and fall incidents continue to affect both county employees and the public across a wide range of environments and job duties. Many claims stem from routine activities and everyday conditions, making prevention efforts especially important. Counties should continue focusing on housekeeping, winter weather response, walking surface maintenance, equipment access procedures, and supervisor-led incident investigations. Identifying root causes and contributing factors can help improve training and reduce repeat incidents. Consistent safety expectations, proactive hazard identification, and clear reporting practices can help reduce both the frequency and severity of these claims while improving workplace safety. For additional guidance, contact the CTSI Loss Control team at 303.861.0507. 

The Family and Medical Leave Act (FMLA), enacted in 1993, guarantees eligible employees up to 12 weeks of unpaid, job-protected leave in a 12-month period for specific family and medical reasons. This federal law applies to all public agencies, including counties, regardless of size.

Colorado’s Family and Medical Leave Insurance (FAMLI) program continues to evolve, with several important updates taking effect Jan. 1, 2026. Counties should review leave policies and administrative procedures to ensure alignment with both federal and state requirements.

To be eligible for FMLA, employees must:

Qualifying events include:

LEAVE MUST BE DESIGNATED APPROPRIATELY

The U.S. Department of Labor has made it clear that once an employer is aware that an absence qualifies for FMLA, it must be designated immediately. Neither the employer nor employee may delay designation or classify the absence under another type of leave first.

Paid leave may run concurrently with FMLA, but it does not extend the 12-week federal entitlement. Counties may choose to offer additional leave benefits beyond those required by FMLA.

COMMON COMPLIANCE PITFALLS

Counties should continue monitoring several common areas of risk, including:

FAMLI UPDATES FOR 2026

Colorado adopted Senate Bill 25-144 on May 30, 2025, expanding benefits available through the FAMLI program beginning Jan. 1, 2026. One of the most significant changes allows eligible employees caring for an infant receiving treatment in a neonatal intensive care unit (NICU) to take up to an additional 12 weeks of leave, for a total of 24 weeks of FAMLI leave.

Additional updates include:

The updated rules also clarify that employers may require employees to apply for or exhaust FAMLI benefits before accessing employer-provided benefits under county policy. However, employers cannot require employees to exhaust FAMLI before accessing leave protections otherwise guaranteed by law.

WHAT THIS MEANS FOR COUNTIES

Compliance with both FMLA and Colorado’s FAMLI program requires careful and consistent administration. Counties should review policies, procedures, and supervisor training to ensure qualifying leave is designated appropriately, cannot be reclassified, and is not considered in employment decisions. The 2026 FAMLI updates may also require adjustments to leave administration practices, particularly regarding NICU-related leave, benefit coordination, and policy language. Preventing retaliation, intentional or inadvertent, must remain a priority. Supervisors, County Managers/Administrators, and HR teams should work together to ensure consistency, fairness, and compliance in every case. For questions, please contact Siri Vensel via email or at 303.861.0507.

Law enforcement operations continue to represent a significant portion of claims activity across both the Colorado Counties Casualty and Property Pool (CAPP) and the County Workers’ Compensation Pool (CWCP). Recent data highlights a consistent pattern. A relatively small number of claim types drive both frequency and severity, creating concentrated areas of exposure for counties.

MOST COMMON CLAIM TYPES 

From a frequency standpoint, vehicle-related incidents remain the most common within CAPP. Vehicle strikes involving other vehicles, pedestrians, or objects account for 45 claims, followed by constitutional violations (24) and arrest-related incidents (22). Total law enforcement claim frequency for the 2025 policy year reached 204 claims. These categories reflect the routine, high-contact nature of law enforcement work. 

Within CWCP, inmate-related incidents remain the most common source of law enforcement claims, accounting for 77 claims. Slip, trip, and fall incidents follow with 34 claims, while training-related incidents account for 31 claims. Total law enforcement claim frequency for the 2025 policy year reached 333 claims. 

Common high-frequency exposures include:

TOP DRIVERS OF SEVERITY 

Severity trends within CAPP highlight where the greatest financial impact occurs. Arrest-related claims represent the highest total incurred cost at $1,965,247. Constitutional violations follow at $396,515, with vehicle strike incidents at $387,510. Total Law Enforcement Division claims for policy year 2025 were $4,284,977. 

Within CWCP, the highest-cost claims are tied to inmate-related incidents, totaling $424,540. Slip, trip, and fall claims follow at $383,617, while training-related claims account for $314,218. Total Law Enforcement Division claims for policy year 2025 were $2,239,680.  

Higher-severity claims are often tied to:

KEY TRENDS

The data shows a clear connection between daily law enforcement activities and claims outcomes. High-frequency exposures such as vehicle operations and arrests are also closely tied to the highest-cost claims. These claim types often involve more complex circumstances, higher legal exposure, and longer resolution timelines. This overlap creates an opportunity for targeted risk management efforts. Reducing the frequency and severity of these claims can help lower overall costs to both pools and strengthen opportunities with excess insurance carriers.

Focusing on these areas can help:

WHAT THIS MEANS FOR COUNTIES

Counties should continue to focus on areas where frequency and severity overlap, particularly vehicle operations and arrest-related activity. Reinforcing defensive driving practices, reviewing use-of-force policies, and maintaining clear documentation standards can help reduce both the number of incidents and their overall impact. Supervisor investigation reports that identify root causes and contributing factors are also critical to preventing repeat incidents and improving overall risk management efforts. Regular training and cross-departmental communication can lead to more consistent outcomes and reduce variability in how situations are handled. For additional guidance, contact the CTSI Loss Control team at 303.861.0507.