Work requirements
(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, 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 calendar month before you submit your application, or prove that you do not 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.