Colorado officials prepare for Medicaid eligibility changes set for 2027

Colorado’s Medicaid program is preparing to implement new work requirements and shorter renewal periods for the program beginning next year.

Beginning Jan. 1, some Coloradans on Medicaid, known as Health First Colorado, will need to self-attest that they are meeting new requirements or are exempted. Otherwise, they will lose their health coverage.

“In many cases, we do expect that the changes will result in, or already have resulted in, coverage loss, additional administrative burden, like more paperwork or processing times, and impacts on statewide uncompensated care,” said Adela Flores-Brennan, the Medicaid director and director of the Health Policy Office at the state’s Department of Health Care Policy and Financing.

When Arkansas implemented work requirements for its Medicaid program in 2018, about 18,000 adults lost coverage in one year, primarily because people did not report their work data to the state. The move didn’t meaningfully increase employment numbers.

The change is one of many due to new federal rules under the “One Big Beautiful Bill Act” passed by Republicans and signed by President Donald Trump in 2025. About 5,900 people in Colorado have already lost Medicaid coverage because of a change related to which immigrants can receive Medicaid. Most of those people who lost coverage are refugees and people seeking asylum, Flores-Brennan said. She expects that around 3,800 more people will be removed from the program as her department manually works through people who get Supplemental Security Income and will remain qualified.

The work requirements will affect about 175,000 of the 1.2 million Coloradans on Medicaid, Flores-Brennan said. Those are people who qualify for Medicaid because of their lower income under the Affordable Care Act expansion. The department sent out notification letters to recipients in September, and it will send a second round at the end of October.

Verification comes in 2028

Colorado is one of many states that will rely on self-attestation for the first year of the new requirements, as well as data it already has. People will be able to fill out a form about their qualifying activities — a combination of 80 hours per month of work, volunteering or education. People also fulfill the work requirement if they earn $580 in a month.

Some people are excluded from the work requirements. That includes people who are incarcerated, pregnant people, young adults who were in foster care, people receiving treatment for a substance disorder, disabled veterans, caregivers and people deemed “medically frail.” Medical frailty would prevent a person from working or volunteering 80 hours per month, such as blindness, a disability, drug or alcohol disorder, serious health condition that requires regular treatment and disabling mental health disorder.

The department will use existing data when possible to identify Medicaid recipients who have medical frailty, but the state might need more information, and recipients will be able to self-attest.

Beginning in 2028, the department will have to verify everything that is self-attested. That will create a lot of administrative workload.

“Throughout the the next year, we are going to be working with our stakeholders to think about what the processes are and how we operationalize that verification process in a way that is minimally burdensome for both our eligibility workers, our members and also providers in the case of medical frailty,” Flores-Brennan said.

The department launched an online self-screener tool for Coloradans on Medicaid to determine if they are subject to the new requirements. It also offers a page that answers many frequently asked questions about the changes.

The Medicaid renewal timeline will shrink to six months starting next year. State officials said they are working to see if an auto-renewal system is feasible. If not, they will send renewal packets to individuals. The department urges recipients to make sure their mailing address, phone number and email are up to date in Colorado PEAK, the state benefit manager.