What’s changing with Medicaid in Colorado?

New federal rules are changing Medicaid eligibility, renewals, and coverage for some people in Colorado starting in late 2026 and 2027. Here are the basics:

• Colorado’s Medicaid program is called Health First Colorado.
• Many of the biggest changes will affect adults age 19 to 64 who are part of the Medicaid expansion group (adults with incomes up to 133% of the federal poverty level).
• Some Health First Colorado members will have to meet new Medicaid work requirements and renew their coverage more often.
• New immigration rules will also change who can qualify for full Medicaid coverage.

Health First Colorado says it will send letters to members who are affected by changes. Make sure your contact information is updated and keep an eye out for notices from the state.

Here's what to know about changes to Health First Colorado and what you can do to stay covered.

What are the new rules for Medicaid in Colorado?#what-are-the-new-rules-for-medicaid-in-colorado

1. Work or community engagement requirements#1-work-or-community-engagement-requirements

Starting January 2027, some adults ages 19 to 64 will need to meet new work requirements, called “community engagement requirements,” when applying for or renewing their Health First Colorado coverage (if you are subject to and complying with SNAP work requirements, you don’t need to show that you meet the Medicaid ones).

If the requirements apply to you, you can meet them by:

• Completing at least 80 hours every month of qualifying activities
• Earning at least $580 per month

Approved activities include paid work, self-employment, seasonal work, school or training, work programs, and volunteering. You can also combine activities to reach the 80-hour requirement, so if you work part time and go to school that can still count.

If you’re applying for Health First Colorado for the first time, you’ll need to show that you met the requirement during the calendar month before you apply. If you already have Health First Colorado, you’ll need to show that you met the requirement during at least one calendar month since your last renewal.

Health First Colorado says it will send letters to members who may need to meet the new requirements. If you are unsure if the requirements may apply, use Health First Colorado’s work requirements screener to find out if you may be affected.

2. More frequent renewals#2-more-frequent-renewals

Starting January 2027, some adults ages 19 to 64 with incomes at or below 133% of the federal poverty level will need to renew Health First Colorado every six months instead of once a year.

Most Health First Colorado members will continue to renew every 12 months. This includes:

• Children 18 and younger
• Adults age 65 and older
• Pregnant members and members who were pregnant in the last 12 months
• Parents or caretaker relatives whose income is 68% of the federal poverty level or less
• Members who receive home and community-based services (HCBS) waivers or other long-term services and supports (LTSS) programs
• Members in Medicaid buy-in programs
• Members who qualify based on blindness or disability
• Members who have Medicare
• Former foster care youth between ages 19 and 26
• Members who are American Indian or Alaska Native, including Indian, Urban Indian, and California Indian members

Your renewal date for Health First Colorado may be different from another person in your household. Some members may be subject to six month renewals even if they are exempt from other Medicaid changes like the new work requirements.

If you are subject to the new requirement and your coverage is renewed before January 2027, your existing renewal date generally won’t be shortened until after your first renewal in 2027.

That means that if you renew in October 2026, your next renewal will be 12 months later in October 2027, and the renewal following that one will be six months later, in April 2028. Health First Colorado will contact you if your renewal schedule changes.

3. Limited retroactive coverage#3-limited-retroactive-coverage

Retroactive Medicaid coverage can help pay qualifying medical bills from before you applied for Health First Colorado.

That means that if you have bills from the months before you apply (or apply again, if you had a gap in coverage), retroactive coverage can pay for them even though you weren’t a Health First Colorado member at the time you got the care.

Starting in January 2027, the amount of retroactive coverage available will be reduced for some applicants:

• Low-income adults ages 19 to 64 with incomes up to 133% of the federal poverty level will receive up to one month of retroactive coverage instead of three
• Children age 18 and younger, adults age 65 and older, and people enrolled in LTSS or Medicaid buy-in programs will receive up to two months of retroactive coverage

Because less coverage will be available for medical expenses from before you apply or renew after a gap, it may be especially important to apply for Health First Colorado as soon as you think you’re eligible or stay on top of your regular renewals.

If you apply for retroactive coverage, you do not have to show that you met Medicaid work requirements during the months for which you are requesting that coverage.

4. Restrictions on immigrant eligibility#4-restrictions-on-immigrant-eligibility

Starting October 1, 2026, some immigrants who used to qualify for full Health First Colorado and CHP+ coverage no longer qualify because of new federal eligibility rules.

People who may continue to qualify for full coverage if they meet the program’s other requirements include:

• U.S. citizens and U.S. nationals
• Lawful permanent residents, or green card holders, who meet or are exempt from the five-year waiting period
• Citizens of the Marshall Islands, Micronesia or Palau living in the U.S. under the Compacts of Free Association (COFA)
• Certain Cuban or Haitian entrants
• Qualifying children age 18 and younger
• Qualifying people who are pregnant or were pregnant within the past 12 months

Some refugees, asylees, humanitarian parolees, people granted withholding of removal, trafficking survivors, members of a U.S. federally recognized Indian tribe or American Indian born in Canada, refugees who have a “conditional entrant” status granted before 1980, and certain other immigrants will no longer qualify for full Health First Colorado based on those statuses unless they qualify through an exception, like the rules for children or pregnancy.

But losing full Health First Colorado does not necessarily mean losing access to every type of health coverage.

Depending on your situation, you may still qualify for programs or services like Emergency Medicaid Services, Reproductive Health Care Services, or Cover All Coloradans.

Health First Colorado will send affected members a letter before their coverage changes. To learn more about these services and whether you may be affected, visit Health First Colorado’s immigrant eligibility screener.

Who is affected by the new Medicaid rules and who is most likely to lose coverage?#who-is-affected-by-the-new-medicaid-rules-and-who-is-most-likely-to-lose-coverage

The changes won’t affect everyone with Health First Colorado in the same way.

Here’s who may be most affected:

• Some adults ages 19 to 64: These plan members may need to meet work or community engagement requirements when applying for or renewing coverage, unless they qualify for an exemption.
• Some adults ages 19 to 64 with incomes at or below 133% of the federal poverty level: These plan members will need to renew every six months and will have less retroactive coverage available.
• People with certain immigration statuses: Some immigrants lost eligibility starting in October 2026.

Children, adults aged 65 and older, pregnant and postpartum members, and people enrolled in LTSS or Medicaid buy-in programs are among the groups who are not affected by the major 2026 and 2027 changes.

Who doesn’t have to meet Medicaid work requirements?#who-doesnt-have-to-meet-medicaid-work-requirements

The new work requirements don’t apply to everyone enrolled in Health First Colorado. Some people are excluded from the requirements, while others may qualify for an exception based on their circumstances.

There are lots of reasons someone can be exempt—you may not have to meet the requirements if you are:

• Aged 18 or younger
• Aged 65 or older
• A parent, guardian, caretaker relative or family caregiver for a child age 13 or younger
• Caring for a person with a disability
• Pregnant or a current member who was pregnant within the past 12 months
• Currently living in a jail, prison or certain halfway houses, or lived in one within the past three months
• Currently living in a hospital, nursing home, or another long-term care facility, or lived in one within the past three months
• Receiving SSI or SSDI
• Eligible for or enrolled in Medicare
• Enrolled in a Medicaid buy-in program
• Receiving long-term care services
• In treatment for a drug or alcohol use disorder
• Meeting SNAP or Colorado TANF work requirements
• An eligible American Indian or Alaska Native
• A former foster youth age 19 to 26 who was in foster care when you turned 18
• A veteran with a VA-determined, 100% qualifying service-connected total disability rating or Total Disability based on Individual Unemployability (TDIU)

People who meet the criteria for “medical frailty” may also be excluded from the work requirements.

This can include people with certain disabilities, disabling mental health conditions, drug or alcohol substance-use disorders, blindness, a physical, intellectual or developmental disability that makes daily activities difficult, or serious or complex medical conditions requiring regular treatment.

Health First Colorado will review available information to determine whether a person qualifies for this exclusion and may request additional information if needed.

What do I need to do to meet Medicaid work requirements in Colorado?#what-do-i-need-to-do-to-meet-medicaid-work-requirements-in-colorado

If the work requirements apply to you, you can meet them by showing you earn at least $580 in taxable income in a month or completing at least 80 total hours of approved activities in a month.

Qualifying activities include:

• Working at a paid job
• Working for yourself
• Doing seasonal work
• Attending a qualifying school or education program
• Participating in a work program
• Volunteering
• Combining more than one approved activity

If you’re a seasonal worker, Health First Colorado says your earned income can be averaged over the previous twelve months. Your average must be at least $580 per month.

If you’re enrolled at least half-time in a qualifying education program, your enrollment can satisfy the work requirement.

If you’re enrolled less than half-time, your education hours may still count toward the required 80 hours per month when combined with other activities, such as work or volunteering.

A qualifying work program is a structured job or training program that helps people gain job skills or work experience. In order to count toward work requirements, it must be recognized by a federal, state, or local government.

Volunteer activities can also count toward work requirements if they are organized activities that benefit the community, usually through a public or nonprofit organization. Examples include volunteering at a food bank or helping with community programs that support education, health, the environment, or child care.

What you need to show depends on whether you’re applying for Health First Colorado for the first time or already have coverage:

• If you’re applying for the first time: You’ll need to show that you met the requirement during the calendar month before you submit your application or show that you qualify for an exclusion or exemption.
• If you already have Health First Colorado: When you renew, you’ll need to show that you met the requirement during at least one calendar month since your last renewal or that an exclusion or exception applies to you.

Health First Colorado will first use information they already have to determine whether you meet requirements or qualify for an exemption. If more information is needed, you’ll receive a letter explaining what to provide.

During 2027, you will be able to self-attest to certain information without obtaining documentation from an employer, school, or other third party. You should be able to submit documents through Colorado PEAK, the Health First Colorado app, mail, or in-person drop-off.

What if I lose Medicaid in Colorado because of the new rules?#what-if-i-lose-medicaid-in-colorado-because-of-the-new-rules

If you lose Health First Colorado because of the new rules, you may have other options for health coverage. What you should do next depends on why your coverage ended and whether you qualify for another program.

Depending on your situation, you may be able to:

• Provide missing information within 30 days of a missed deadline to re-open your existing Medicaid case and get coverage again
• Reapply for Health First Colorado if your situation changes and you now meet the work requirements or they no longer apply to you, like if you develop a serious health condition
• Appeal the decision if you believe your Health First Colorado coverage was ended incorrectly
• Get Emergency Medicaid Services or Reproductive Health Care Services if your immigration status prevents you from qualifying for full Medicaid and you meet the program requirements
• Get Cover All Coloradans coverage if you’re age 18 or younger or pregnant and meet the other eligibility requirements, regardless of immigration status
• Get care through a community health center, which may offer sliding-scale fees based on your income
• Use Colorado’s Hospital Discounted Care program if you qualify for reduced hospital and emergency room costs
• Get private health insurance through Connect for Health Colorado, Colorado’s Health Insurance Marketplace, and see if you qualify for financial help
• Use OmniSalud to explore private health insurance options if you’re undocumented and can’t use the regular Marketplace. OmniSalud is a program that provides Coloradans a safe way to compare affordable, private health insurance plans and enroll on a secure online platform.
• Enroll in Medicare if you qualify based on your age, disability or another eligibility reason

Be sure to read any letters you get in the mail or electronically from Health First Colorado. Your notice should explain why your coverage is changing, when the change takes effect and what steps you can take to keep or replace your health coverage