Archives: FAQs

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.

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.

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.

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.

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 medically frail person is 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 one or more activities of daily living; or with a serious or complex medical condition.

We expect final federal guidance that will more clearly define this exception in June 2026 and will update this glossary at that time.

No, the work requirements passed in H.R. 1 do not apply to people with the Medicaid Buy-In Program for Working Adults and Children with Disabilities.

Buy-In members must continue to complete the program’s other requirements for income and employment, which have not changed.

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