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, adults ages 65 or older do not need to meet the work requirements.
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 has significant health needs, such as a disability, serious mental health condition, substance use disorder, or other complex medical condition that limits daily functioning or requires ongoing medical care.
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 low-income adults ages 19–64 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:
- Low-income adults ages 19–64 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.
- 18 years old or younger
- 65 years or older
- Parent or caregiver of a child age 13 or younger
- Parent or caregiver of people with disabilities
- Veterans with a total disability rating
- Enrolled in Medicare Part A or Part B
- Enrolled in a Long-Term Services and Supports (LTSS) program. For example, in a nursing home or enrolled in one of the following programs:
- Brain Injury Waiver (BI)
- Community Mental Health Supports Waiver (CMHS)
- Complementary and Integrative Health Waiver (CIH)
- Developmental Disabilities Waiver (DD)
- Elderly, Blind and Disabled Waiver (EBD)
- Supported Living Services Waiver (SLS)
- Programs for All-Inclusive Care for the Elderly (PACE)
- Enrolled in Medicaid Buy-In Programs (Working Adults & Children’s)
- Have a confirmed disability demonstrated by:
- Receiving Supplemental Security Income (SSI) and/or Social Security Administration (SSA) income, such as Social Security Disability Insurance (SSDI) or Social Security Retirement (SSR)
- The State Disability Determination vendor
- Foster youth or former foster youth age 0 to 26
- Current qualified Health First Colorado or CHP+ members who are pregnant or were pregnant within the last 12 months
- American Indian or Alaskan Native
- Medically frail
- Enrolled in a treatment program for a mental health or substance use disorder
- People who are incarcerated or people who have been released from incarceration in last 90 days
- Already meeting work requirements for TANF or SNAP
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.
6-month renewals
As of January 2027, if you are an adult age 19–64 and 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), you will have to complete the renewal process twice a year instead of once a year. There are no exemptions for this provision.
Immigrant status 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.
- 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.