Medicaid Changes (2026-2027): Frequently Asked Questions

(Updated April 20, 2026)

The requirements are different. However, people who comply with Supplemental Nutrition Assistance Program (SNAP) or Colorado’s Temporary Assistance for Needy Families (TANF) work requirements will also meet the work requirement for Health First Colorado (Colorado’s Medicaid program).

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.

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 Health First Colorado Buy-In Program for Working Adults 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 person is considered medically frail if they:

• Are blind or have a disability
• Have a substance use disorder
• Have a disabling mental health condition
• Have a physical, intellectual, or developmental disability that makes it hard to do daily activities
• Have a serious or complex medical condition

We’re using current federal guidance to set these rules. We’ll update this page if we get new information.

• First time applicants:
  • You must show that you complied with the work requirement in the month before you submit your application, or prove that you don’t have to comply.
• Current members who are renewing:
  • You must show that you complied with work requirements during at least 1 calendar month since your last renewal deadline, or prove that you don’t have to comply.

We’re using current federal guidance to set these rules. We’ll update this page if we get new 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.

You may need to comply with work requirements if

• You are an adult age 19 to 64
• Are not enrolled in LTSS or buy-in program, and
• Do not have an approved reason for not complying with work requirements

To comply with work requirements, first time applicants will need to show in the calendar month before they submit their application, that they

• earned at least $580, or
• spent at least 80 hours working, going to school, participating in a work program, volunteering, or a combination of these activities.

Use our work requirements screener tool to find out if you might be affected by Medicaid work requirements.

You may need to comply with work requirements if 

• You are an adult age 19 to 64
• Are not enrolled in LTSS or buy-in program, and
• Do not have an approved reason for not complying with work requirements

To comply with work requirements, first time applicants will need to show in the calendar month before they submit their application, that they

• earned at least $580, or
• spent at least 80 hours working, going to school, participating in a work program, volunteering, or a combination of these activities.

Health First Colorado will send you a letter in September 2026 letting you know if,  based on the information we have, you must comply with work requirements. 

The new work requirements begin January 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 will need to prove they complied with work requirements during at least 1 calendar month since their last renewal deadline

They will also need to renew their health coverage every 6 months instead of once a year.

For example, if your renewal is due in March 2027, you will need to show proof that in one calendar month since your last renewal deadline you either:

• earned at least $580, or
• worked, participated in a work program, volunteered, or attended school (or a combination of these) for at least 80 hours.

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.

Starting January 1, 2027, adults ages 19 to 64 not enrolled in a long-term services and supports (LTSS) or buy-in program must comply with the work requirement when applying for or renewing their coverage. If this rule applies to you, Health First Colorado will send you a letter.

You can comply with work requirements by either completing 80 hours of approved activities, or earning at least $580 from paid work or a combination of these.

• First time applicants: In the calendar month before they submit their application, they will need to show that they
  • earned at least $580, or
  • spent at least 80 hours working, going to school, participating in a work program, volunteering, or a combination of these activities
• Current members who are renewing: In at least 1 calendar month since their last renewal deadline, they will need to show they
  • earned at least $580 or
  • spent at least 80 hours, going to school, participating in a work program, volunteering, or a combination of these activities
    • They can contact their county or visit CO.gov/PEAK to find their last renewal deadline if they are not sure.

Health First Colorado (Colorado’s Medicaid program) will implement H.R. 1’s new work requirements starting January 1, 2027.

In January 2027, Health First Colorado will mail letters to members with a March 2027 renewal date. If a member is subject to work requirements, they will have to show that they comply or prove they do not have to comply to keep or receive their health coverage.

Work requirements do not apply to: 

• 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)
• Former foster care youth age 19 to 26
• Current Health First Colorado members who were pregnant within the last 12 months, or who are pregnant
• American Indians and Alaska Natives (AI/AN) who qualify for Indian Health Services (IHS) 
• People who are medically frail. A person is considered medically frail person if they
  • Are blind or have a disability
  • Have a substance use disorder
  • Have a disabling mental health condition
  • Have a physical, intellectual, or developmental disability that makes it hard to do daily activities
  • Have a serious or complex medical condition
• 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.

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 and asylees
• People granted humanitarian parole, such as certain Afghans who aided U.S. military operations in Afghanistan or people fleeing violence in Ukraine
• People granted withholding of removal
• Survivors of domestic violence with a pending or approved application under the Violence Against Women Act
  Survivors of trafficking with a pending or approved application for a victim of trafficking visa
• 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

These immigrants may qualify for Health First Colorado and CHP+:

• U.S. citizens or U.S. nationals
• Lawful Permanent Resident status holders (LPR/Green Card) who meet the 5-year requirement
• Citizens of the Marshall Islands, Micronesia, and Palau who are living in one of the U.S states or territories (referred to as Compact of Free Association or COFA migrants)
• Certain Cuban or Haitian entrants
• Children under age 19
• Pregnant women, or pregnant within the last 12 months

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.

Health First Colorado (Colorado’s Medicaid program) will mail letters to members affected by the new work requirements ahead of time, starting in September 2026.

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.