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.