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.

• 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

(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.

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.

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.

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, adults ages 65 or older do not need to meet the work requirements.