Community Engagement and Work Requirements Frequently Asked Questions

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Date published: October 24, 2025

As of Jan. 1, 2027 new federal rules under H.R. 1 (formerly called “The One Big Beautiful Bill Act”) will require some adults ages 19-64 without a disability to

Meet community engagement or work requirements to keep their Health First Colorado coverage when it’s time for them to renew, and
Renew their coverage every 6 months, instead of once a year.

We will update these FAQs as the federal government shares more information about the community engagement and work requirements.

Overview of new community engagement and work requirements

What are the new community engagement and work requirements for Health First Colorado (Colorado’s Medicaid program)?

As of January 2027, some adults ages 19-64 without a disability who are applying for or renewing their Health First Colorado coverage must meet new community engagement and work requirements to keep their Health First Colorado health coverage.

Not all Health First Colorado members subject to the new community engagement and work requirements will need to show proof right away.

When it’s time for impacted members to renew their health coverage, they will need to show that they meet the 80-hour work requirement at least 1 of the months within their 6-month renewal period.

They can meet these requirements by working, participating in a work program, volunteering or going to school at least 80 hours per month (or a mix of these).

Example: If your renewal is due March 2027, you will need to show proof that you have worked, participated in a work program, volunteered or went to school at least 80 hours per month (or a mix of these) during one of the months six months prior (September through February).

Who needs to meet the new community engagement and work requirements?

As of January 2027, if you are an adult age 19-64 without a disability and you do not qualify for an exemption, you may need to meet the new community engagement and work requirements when it’s time for you to renew your health coverage.

I am applying for Health First Colorado health coverage for the first time. Do I need to meet the new community engagement and work requirements?

If you are an adult age 19-64 without a disability and you do not qualify for an exemption, then you may need to meet the new community engagement and 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.

Who is exempt from the community engagement and work requirements?

Certain groups of people do not need to meet the new community engagement and work requirements:

Children ages 18 or younger
People with disabilities
Adults ages 65 or older
People who are pregnant or postpartum (12 months after a pregnancy ends)
Former foster care children ages 25 or younger
Parent or caregiver of a child age 13 or younger
Parent or caregiver of people with disabilities
Veterans who have disabilities
American Indian/Alaska Natives
People who are medically frail
People in treatment for a substance use disorder
People who are incarcerated or people who have been released from incarceration in last 90 days
People who qualify for Medicare Part A or B

Do parents or caregivers of people with disabilities have to meet the community engagement and 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 community engagement and work requirements.

Do older adults ages 65 or older have to meet the community engagement and work requirements?

No, older adults ages 65 or older do not need to meet the community engagement and work requirements.

Do people on the Working Adults with Disabilities Medicaid Buy-In Program have to meet the new community engagement and work requirements?

No, the community engagement and work requirements passed in H.R. 1 do not apply to people with disabilities. People on the Medicaid Buy-In Program for Working Adults and Children with Disabilities do not need to meet the new requirements.

How are you defining “medically frail?”

The federal law, H.R. 1, defines “medically frail” as:

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 1 or more activities of daily living; or
with a serious or complex medical condition.

We will update our information about how we define “medically frail” after the federal government shares more details.

Do people with severe mental illness or who are in treatment for substance use disorder have to meet the new community engagement and work requirements?

No, these Health First Colorado members fall under the “medically frail” exemption. They do not need to meet the community engagement and work requirements.

Do people receiving Supplemental Security Income (SSI) or Social Security Disability Insurance (SSDI) have to meet the community engagement and work requirements?

No, the community engagement and work requirements do not apply to people with disabilities, including those receiving SSI or SSDI.

When do the community engagement and work requirements start?

Health First Colorado will implement H.R. 1’s new community engagement and work requirements by Jan. 1, 2027.

These requirements will apply to some adults ages 19-64 without a disability whose application or renewal we receive on or after Jan. 1, 2027.

Members subject to the new requirement will need to show proof that they’ve met 80 hours of community engagement and work requirements at the same time as their renewal. Renewals for this group of adults will change to every 6 months, instead of once a year.

I’m a current Health First Colorado member. When do I need to prove that I have met the new community engagement and work requirements?

Not all Health First Colorado members subject to the new community engagement and work requirements will need to show proof right away.

When it’s time for current members subject to the new requirements to renew their health coverage, they will need to meet the 80-hour work requirement at least 1 of the months within their 6-month renewal period.

Example: If your renewal is due March 2027, you will need to show proof that you have worked, participated in a work program, volunteered or went to school at least 80 hours per month (or a mix of these) during one of the months six months prior (September through February).

I’m a current Health First Colorado member. How often do I need to show proof that I meet the community engagement and work requirements?

If you need to meet the new requirements, you will need to show that you worked, participated in a work program, volunteered or went to school (or a mix of these) for 80-hours in one month during your 6-month renewal period.

Your Health First Colorado renewal will now happen every 6 months instead of once a year.

I’m applying to Health First Colorado for the first time. How and when do I show that I’m either exempt from or meet the community engagement or work requirements?

Only some adults ages 19-64 without a disability must meet community engagement and work requirements.

If you are applying for Health First Colorado health coverage for the first time, you will need to show proof on your application that

You qualify for an exemption or
In the month before applying, you’ve met the new requirements by working, volunteering, or going to school at least 80 hours per month (or a mix of these).
- 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.

These rules are based on our current understanding of the federal law. We will update this information as the federal government gives us more details.

Are the community engagement and work requirements the same for SNAP and Health First Colorado?

While the requirements are different, if you meet the SNAP/TANF community engagement and work requirements, then you meet the Health First Colorado’s requirements, according to H.R. 1.

If you do not meet SNAP/TANF work requirements, you may need to show that you meet Health First Colorado’s community engagement and work requirements to enroll or to keep your health coverage when it’s your time to renew. We are working with SNAP/TANF to align where possible.

Verifying employment and engagement hours

How often do I have to show I meet the requirement?

New applicants who are not exempt from the requirement will need to meet the 80-hour work requirement the month prior to applying.

Current Health First Colorado members who are not exempt and renewing their health coverage will need to meet the 80-hour 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.

I’m a gig worker, self employed or have seasonal income. How do I prove that I meet the community engagement and work requirements?

We expect the federal government to give the final details on this topic by June 2026. We will update these FAQs when information becomes available.

I just lost my job and with it my employer sponsored insurance. How do I show I have met the new community engagement and work requirements?

If you are applying for Health First Colorado health coverage for the first time, you will need to show proof on your application that

You qualify for an exemption or
In the month before applying, you’ve met the new requirements by working, participated in a work program, volunteering, or going to school at least 80 hours per month (or a mix 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.

How will I submit documents to show I have met the new community engagement and work requirements?

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.

Staying informed (Notices and communication)

How and when will Health First Colorado let me know if I need to meet the new requirement to keep my health coverage?

Not all Health First Colorado members subject to the new community engagement and work requirements will need to show proof right away.

The first group of adults 19-64 without disabilities impacted by the requirements will be

People submitting their applications for the first time on or after Jan. 1, 2027, or
People whose renewals are started after Jan. 1, 2027.

Members subject to the new requirement will need to show proof that they’ve met 80 hours of community engagement and work requirements when they submit their renewal. Renewals for this group of adults will change to every 6 months, instead of once a year.

Health First Colorado will mail letters to members affected by the new community engagement and work requirements ahead of time.

While we are still working out timing and details, you should expect

A letter telling you if you are subject to the new community engagement and work requirements.
Information about what activities count towards the 80-hour community engagement and work requirements.
Instructions on how to share proof that you’ve met the requirements

How can members stay up to date on all the changes?

Health First Colorado will share information about the community engagement and 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

If I disagree with a decision about whether I qualify for Health First Colorado, can I appeal?

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.

Where to go for help

Can Health First Colorado connect people to work, volunteer opportunities or education to help them meet the community engagement and work requirements?

H.R. 1 tells states they must have a community engagement or work requirement in place, however, the law does not require or provide funding for Health First Colorado to help people meet the requirement.

If the federal government provides more information on this topic, we will update our FAQs.