Changes Are Coming to Health First Colorado

The ACA expansion population, also known as Modified Adjusted Gross Income (MAGI) adults in Colorado’s eligibility system, refers to a group of people who became eligible for Medicaid coverage after passage of the Affordable Care Act (ACA). 

These are adults ages 19 to 64 who 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). They represent 377,000* of the 1.2 million Coloradans enrolled in Medicaid.*

‘ACA expansion population’ and ‘MAGI Adult’ refer to the same group. MAGI Adult is the only Medicaid eligibility category subject to the new work requirements and 6-month renewals. 

Coloradans enrolled in Medicaid are unlikely to recognize either term, as both refer to a category that HCPF uses for administrative purposes. Partners may see either one in HCPF materials, in county correspondence or on eligibility system screens.

Low-income adults ages 19–64 who are not enrolled in certain programs such as long-term services and supports (LTSS) or buy-in programs must meet the work requirement when applying for or renewing their coverage.

• Current members will need to show at renewal that they met the requirement in at least one calendar month since their last renewal deadline. Ways to meet the requirement include:
  • Completing 80 hours of approved activities: working, participating in a work program, volunteering or going to school (or a mix of these)
  • Earning at least $580 from paid work
  • Showing documentation that they meet an exemption and do not need to meet the requirement
     
• New applicants will need to complete paperwork to show they met the work requirement in the calendar month before they submit their application for Health First Colorado. Ways to meet the requirement include:
  • Completing 80 hours of approved activities: working, participating in a work program, volunteering or going to school (or a mix of these)
  • Earning at least $580 from paid work
  • Showing documentation that they meet an exemption and do not need to meet the requirement

These criteria are based on our current understanding of guidance from conversations with CMS and may change as future guidance becomes available.

Qualifying activities include work, community service, a work program, or educational enrollment (each requiring at least 80 hours per month, or any combination totaling 80 hours), or monthly income of at least $580.

More details about what counts for these qualifying activities will be available in the coming months. 

Work requirements do not apply to: 

Age

• Children age 18 or younger
• Adults age 65 or older

Caregivers

• Parents, guardians or caretaker relatives or family caregivers for a child 13 or younger
• Parents, guardians or caretaker relatives or family caregivers responsible for caring for a person of any age who has a disability

Living situation

• People living in a jail, prison or some halfway houses, now or in the past 3 months
• People living in a hospital, nursing home or other long-term care facility now or in the past three months

Pregnancy

• Current Health First Colorado members who were pregnant within the last 12 months, or are currently pregnant

Health conditions 

• People living with a drug or alcohol use disorder that prevents them from completing 80 hours per month of work, school, and/or volunteer activities
• People in recovery from a drug or alcohol use disorder for 5 years or less that prevents them from completing 80 hours per month of work, school, and/or volunteer activities
• People living with a physical, intellectual, or developmental disability that makes it hard to do daily activities and that prevents them from completing 80 hours per month of work, school, and/or volunteer activities
• People living with a disabling mental health disorder that prevents them from completing 80 hours per month of work, school, and/or volunteer activities
• People living with a serious health condition that requires regular treatment that prevents them from completing 80 hours per month of work, school, and/or volunteer activities
• People who are blind and their condition prevents them from completing 80 hours per month of work, school, and/or volunteer activities

Health coverage and benefits 

• People enrolled in a Medicaid Buy-in Programs (Working Adults or Children)
• People receiving long-term care services (for example, in a nursing home or through home-based care)
• People receiving Supplemental Security Income (SSI) and/or Social Security Disability Insurance (SSDI)
• People who qualify or are enrolled in Medicare
• People in a treatment program for drug or alcohol use disorder
• People who comply with Supplemental Nutrition Assistance Program (SNAP) or Colorado’s Temporary Assistance for Needy Families (TANF) work requirements

Population

• American Indians and Alaska Natives (AI/AN) who are eligible for Indian Health Services (IHS), a Tribal Health program, or an Urban Indian Health program; or who have received services from Indian Health Services (IHS), a Tribal Health program, or an Urban Indian Health program, now or in the past
• People who were in foster care when they turned 18 and who are now between ages 19 and 26
• Veterans with a service-connected disability that the U.S. Department of Veterans Affairs (VA) has determined to have either a 100% disability rating (temporary or permanent); or a Total Disability based on Individual Unemployability (TDIU), even if their combined disability rating is below 100%

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.

Health First Colorado (Colorado’s Medicaid program) and Child Health Plan Plus (CHP+) review information annually to make sure a member still qualifies for health coverage. This is known as the renewal process or redetermination (RRR). Some members are automatically renewed based on information on file. Other members must complete their renewal and supply required documentation by their renewal deadline or risk losing coverage.

Most adults who need to meet work requirements will also need to renew their Health First Colorado coverage every 6 months instead of every 12 months.

According to federal guidance released in June 2026, the following people are considered medically frail:

• People with any of the following conditions that prevent them from completing 80 hours each month of work, school, volunteering, or other approved activities:
  • People living with a drug or alcohol use disorder
  • People in recovery from a drug or alcohol use disorder for 5 years or less 
  • People living with a physical, intellectual, or developmental disability
  • People living with a disabling mental health disorder 
  • People living with a serious health condition that requires regular treatment
  • People who are blind 
• People who are living in a hospital, nursing home or other long-term care facility now or in the past three months
• People who are receiving long-term care services (for example, in a nursing home or through home-based care)
• People who are receiving Supplemental Security Income (SSI) and/or Social Security Disability Insurance (SSDI)

Self-attestation means an applicant or member can certify certain information themselves without having to obtain verification or a signature from a third party, such as a doctor or school official.

Federal guidance released in June 2026 allows states to temporarily accept self-attestation for certain work-requirement and exemption information during calendar year 2027. Colorado has decided to use this option during the first year of implementation to simplify processes for applicants and members and reduce administrative burden for eligibility workers.

During 2027, self-attestation may be used for certain information related to:

• medical frailty,
• student status,
• volunteer work, and
• work program participation.

HCPF may still need to request information from an applicant or member. However, when self-attestation is permitted, the applicant or member will not need to obtain an “official” third-party verification or signature for that information.

Note that applicants or members who are veterans with a total disability rating will need to provide a benefit letter from the U.S. Department of Veterans Affairs that confirms their rating. A total disability rating is either a 100% rating (temporary or permanent) or a total rating based on individual unemployability.

HCPF will continue developing verification processes for 2028 and later in accordance with federal requirements.

Ex parte is a process that uses data and information already available to the state to determine whether a member remains eligible for Medicaid. If there is enough information to confirm eligibility, the member’s coverage can be renewed automatically without requiring additional information.