Date published: February 18, 2026
This page answers common questions about important changes to Health First Colorado (Colorado’s Medicaid program) mandated by the federal legislation H.R. 1., also known as “One Big Beautiful Bill Act.” These changes include work requirements, also known as community engagement requirements, and 6-month renewals for some low-income adults. Immigration status changes will also affect which immigrants can qualify for Health First Colorado.
Work requirements
The requirements are different, and we are working with SNAP/TANF to align where possible.
Please respond to any letter that asks for more information by the deadline in the letter.
No, parents or caregivers of children 13 or younger or caregivers of people with disabilities of any age do not need to meet the new work requirements.
No, the work requirements passed in H.R. 1 do not apply to people with the Medicaid Buy-In Program for Working Adults and Children with Disabilities.
Buy-In members must continue to complete the program’s other requirements for income and employment, which have not changed.
No, work requirements do not apply to people receiving SSI or Social Security Administration income such as SSDI.
No, people with severe mental illness or who are in treatment for substance use fall under the “medically frail” exemption. They do not need to complete the work requirements.
A medically frail person is someone who is blind or disabled; with a substance use disorder; with a disabling mental disorder; with a physical, intellectual or developmental disability that significantly impairs their ability to perform one or more activities of daily living; or with a serious or complex medical condition.
We expect final federal guidance that will more clearly define this exception in June 2026 and will update this glossary at that time.
New applicants who are not exempt from the work requirement will need to meet the work requirement the month prior to submitting their application, or show they are exempt.
Current Health First Colorado members who are not exempt and renewing their health coverage will need to meet the work requirement at least 1 of the months within their 6-month renewal period.
These rules are based on our understanding of the federal law. We will update these rules once the federal government gives more detailed information.
You should be able to use all the current channels (Colorado PEAK, Health First Colorado app, mail, in-person drop-off) to submit proof that you’ve met the new requirements.
We will update these FAQs as the information becomes available.
If you are a low-income adult age 19–64 and not enrolled in a long-term care services or buy-in program and you do not show that you qualify for an exemption, then you must meet work requirements.
Example: If you apply for health coverage in February 2027, you will need to show proof that you worked, participated in a work program, volunteered or went to school at least 80 hours per month (or a mix of these) in January 2027.
If work requirements apply to you and you are applying for Health First Colorado for the first time, you must meet the requirement unless you qualify for an exemption. This means that in the month before you apply, you need to show proof that you either earned at least $580 or completed at least 80 hours of work, job training, volunteering, school, or a combination of these.
We expect the federal government to provide final details on this topic by June 2026. We will update these FAQs when information becomes available.
Health First Colorado will send you a letter in August 2026 letting you know if, based on the information we have, you must meet work requirements.
The new work requirements begin Jan. 1, 2027. Not all Health First Colorado members who are subject to the new work requirements will need to show proof right away.
Current members who must comply with work requirements will need to show at renewal that they met the work requirement for at least 1 of the months within their 6-month renewal period.
They will also need to renew their health coverage every 6 months instead of once a year.
Example: If your renewal is due March 2027, you will need to show proof that you have earned $580 or worked, participated in a work program, volunteered or went to school (or a mix of these) at least 80 hours during one of the months within your 6-month renewal period. (September 2026 through February 2027). Your next renewal date would be six months later, September 2027, not March 2028.
For seasonal workers, all earned income must be totaled over the previous 6 months and divided by 6. The average income over those 6 months must be at or above $580. The $580 represents 80 hours at the federal minimum wage of $7.25. We expect the federal government to issue final guidance by June 2026. We will update these FAQs as more information becomes available.
If a current member subject to work requirements earns at least $580 per month (federal minimum wage x 80 hours) and we can verify that income, they should not have to complete additional documentation to show that they meet the work requirements. The $580 represents 80 hours at the federal minimum wage of $7.25. If you work but we cannot verify that income, we will send a letter asking for proof.
As of January 2027, some adults ages 19 to 64 who are not enrolled in certain programs (such as long-term services and supports [LTSS] or buy-in programs) must show they meet new work requirements, or that they are exempt.
Not all Health First Colorado members subject to the new work requirements will need to show proof right away.
- Current members will need to show at renewal that they met the requirement in at least one of the previous six months. Ways to meet the requirement include:
- Completing 80 hours of approved activities: working, participating in a work program, volunteering or going to school (or a mix of these)
- Earning at least $580 from paid work
- Showing documentation that they meet an exemption and do not need to meet the requirement
- New applicants will need to complete paperwork to show they met the work requirement in the month before they submit their application for Health First Colorado. Ways to meet the requirement include:
- Completing 80 hours of approved activities: working, participating in a work program, volunteering or going to school (or a mix of these)
- Earning at least $580 from paid work
- Showing documentation that they meet an exemption and do not need to meet the requirement
Example: If your renewal is due March 2027, you will need to show proof that you have earned $580 or worked, participated in a work program, volunteered or went to school (or a mix of these) at least 80 hours during one of the months within your 6-month renewal period. (September through February).
Health First Colorado will implement H.R. 1’s new work requirements by Jan. 1, 2027.
These requirements will apply to:
- Adults ages 19 to 64 who are not enrolled in certain programs (such as long-term services and supports [LTSS] or buy-in programs)
- Who do not show that they meet any exemptions
Existing members need to show at renewal that they met the work requirement by earning at least $580 or working, participating in a work program, volunteering or going to school (or a mix of these) at least 80 hours for at least 1 of the months within their 6-month renewal period.
New applicants will need to show that they met the work requirements by earning at least $580 or working, participating in a work program, volunteering or going to school at least 80 hours (or a mix of these) in the month before they submit their application.
Renewals for this group of adults will change to every 6 months, instead of once a year.
People who meet any of the following criteria should not have to meet the work requirement.
- Children 18 and younger
- Adults 65 and older
- Parents, guardians, caretaker relatives or family caregivers responsible for a child aged 13 or younger
- Parents, guardians, caretaker relatives or family caregivers responsible for caring for a person of any age, who has a disability
- Veterans with a service-connected disability that the U.S. Department of Veterans Affairs has determined to be total and permanent
- People who qualify or are enrolled in Medicare
- People enrolled in a long-term services and supports (LTSS) program
- People enrolled in Medicaid buy-in programs (Working Adults or Children’s)
- People who are receiving Supplemental Security Income (SSI) and/or Social Security Administration (SSA) income, such as Social Security Disability Insurance (SSDI) or Social Security Retirement (SSR)
- Former foster care youth age 19 to 26
- Current Health First Colorado members who are pregnant and some members who were pregnant within the last 12 months
- American Indians and Alaska Natives (AI/AN) who qualify for Indian Health Services (IHS)
- People who are medically frail. A medically frail person has significant health needs, such as a disabling mental health condition, substance use disorder, or other complex medical condition that limits daily functioning or requires ongoing medical care.
- People enrolled in treatment or rehab for a mental health or substance use disorder
- People living in a jail, prison or some halfway houses, now or in the past 3 months
- People who comply with Supplemental Nutrition Assistance Program (SNAP) or Colorado’s Temporary Assistance for Needy Families (TANF) work requirements.
- People with SNAP or TANF who fail to comply with their work requirement must comply with Health First Colorado’s work requirement to keep their health coverage.
If Health First Colorado needs more information to decide if you must meet work requirements, we will send you a letter. Open and respond to letters from Health First Colorado right away.
Use our screener tool to find out if you might be affected by Medicaid work requirements. (Please note: the screener tool is only an estimate. It is not an official application or eligibility decision.)
6-month renewals
As of January 2027, if you are an adult age 19 to 64 and earn up to 133% of the federal poverty level (calculator), you will have to complete the renewal process twice a year instead of once a year. Only American Indians and Alaska Natives (AI/AN) who qualify for Indian Health Services (IHS) are exempt from this provision.
Immigrants
On June 6, 2025, HCPF received a request from CMS for data and information related to eligibility, claims, and cost allocations for people with an “unsatisfactory immigration status.” CMS has renewed their request for data every three months since. The requests include people who accessed Emergency Medicaid Services during each requested quarter (currently three quarters—April through June 2025, July through September 2025, and October through December 2025). While the first request excluded certain populations like pregnant people and children, subsequent requests have included pregnant people. CMS stated that the reason for this particular request is to ensure HCPF has not received funds for federal reimbursement for any person with an unsatisfactory immigration status who participates in a state-only funded program.
Additionally, there is a new court ruling indicating that CMS may share limited Medicaid information with federal agencies under specific circumstances, such as for people who are not “lawfully residing” in the United States. CMS has not yet provided Colorado with details on whether or how it may share information, and we are monitoring developments closely. We will update our members as more information becomes available.
No. Information that may be shared for people not “lawfully residing” can include citizenship
or immigration status, address, phone number, date of birth, and Medicaid ID. CMS must exclude anyone who is lawfully residing in the United States. If it is not possible to separate this data from information about lawful residents or U.S. citizens, CMS cannot share it. These restrictions remain in place while legal challenges are ongoing.
HCPF only shares Medicaid information with CMS. HCPF does not share information with federal immigration officials, although as this communication outlines, we cannot directly control what CMS shares.
Not at this time. However, executive action, legislation or both could change the factors that determine what constitutes a public charge decision.
Currently, the federal government has the authority to decide what benefits can be considered for public charge decisions. Right now, Medicaid and CHP+ are not considered for public charge, but that could change in the future. The federal government has proposed a change to the public charge rule. HCPF is reviewing what this may mean for members and households in Cover All Coloradans, Emergency Medicaid Services, and Reproductive Health Care Services. As we learn more, we will share updates.
You can find information on the current public charge rules, and resources on the proposed changes.
Starting in October 2026, some immigrants who qualified for coverage will no longer be able to receive Health First Colorado benefits. This includes refugees, asylees, and other humanitarian groups.
These immigrants will still qualify for Health First Colorado and CHP+:
- Members who meet the definition of lawful permanent resident (“green card” holders)
- Certain Cuban and Haitian immigrants
- Citizens of the Freely Associated States (COFA migrants) lawfully residing in the U.S.
- Lawfully residing children and pregnant adults in states that cover them under the Immigrant Children’s Health Improvement Act (ICHIA) option.
Colorado law says state Medicaid and CHP+ workers and their business partners cannot reveal personal information to ICE for immigration investigation or enforcement. It is important to remember that state laws cannot override federal laws. Federal law preempts state law when the two disagree.
HCPF only shares Medicaid information with CMS. HCPF does not share information with federal immigration officials, although as this communication outlines, we cannot directly control what CMS shares.
Reports include basic demographic and eligibility details, such as name, address, date of birth, Social Security Number (if provided) or Medicaid ID, and immigration status for every Medicaid member, who has received services through the Medicaid program. Reports are filed on a regular basis, so disenrolling from Medicaid will not prevent data from being reported to CMS. The exception to this is for people who have only received services through HCPF programs that are exclusively funded by the state budget.
- Starting in January 2027, low-income adults ages 19–64 who earn up to 133% of the federal poverty level (up to $20,815 per year for a single individual or $42,760 per year for a family of four) who are applying for Health First Colorado will only receive one month of retroactive coverage instead of three. This means that if you qualify and enroll in Health First Colorado, we can cover your qualifying medical bills the month before you applied but no earlier.
- Children age 18 and younger, adults age 65 and older and people enrolled in long-term services and supports [LTSS] or buy-in programs will receive 2 months of coverage prior to their application.
Staying Informed
Health First Colorado will mail letters to members affected by the new work requirements ahead of time, starting in August 2026.
These letters will tell you:
- Instructions on how to share proof that you’ve met the requirements or that you are exempt.
- Information about what activities count towards the 80-hour work requirements.
Health First Colorado will share information about the work requirements with members by mail, text and email. We will also partner with providers and community-based organizations to make sure people understand the new requirements.
Members can stay up to date by subscribing to the Health First Colorado newsletter (a monthly email) and opting into digital notifications on the Health First Colorado app. They can also follow us on social media and check the Health First Colorado website for news updates.
Appeals
Yes, you have 60 days from the date on your Notice of Action to ask for an informal meeting with the eligibility site and a state fair hearing. The Notice of Action is the letter that has the decision you disagree with.
For more information about appeals, go to How to appeal a health coverage or benefits decision. Or follow the instructions on your Notice of Action on how to appeal the decision.