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.
How will I submit documents to show I have met the new 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.
I just lost my job and my employer- sponsored insurance. How do I show I have met the new work requirements when I apply for Health First Colorado?
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.
I’m a gig worker, self employed or have seasonal income. How do I prove that I meet the work requirements?
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 I’m a current member and already working, do I still have to show that I meet the work requirement?
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.
How often do I have to show I’ve completed the work requirement?
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.
Are work requirements the same for SNAP and Health First Colorado?
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.
I’m a current Health First Colorado member. When do I need to prove that I have met the new work requirements?
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.
Do people receiving Supplemental Security Income (SSI) or Social Security Disability Insurance (SSDI) have to complete the work requirements?
No, work requirements do not apply to people receiving SSI or Social Security Administration income such as SSDI.
Do people with severe mental illness or who are in treatment for substance use disorder have to complete the new work requirements?
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.

