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Continuous Coverage Unwind


In January 2020, the U.S. Department of Health and Human Services (HHS) responded to the COVID-19 pandemic by declaring a public health emergency (PHE). Congress passed legislation to ensure that anyone enrolled in Medicaid (Health First Colorado (Colorado’s Medicaid program) in Colorado), as well as children and pregnant people who were enrolled in the Children’s Health Insurance Program (Child Health Plan Plus (CHP+) in Colorado), was guaranteed to keep their health coverage during the PHE. This is the continuous coverage requirement. Congress recently passed a bill that ended the continuous coverage requirement in the spring of 2023.

Planning for the End of Continuous Coverage

For Members

Health First Colorado and CHP+ members have returned to normal eligibility renewal processes. Eligibility processes for Health First Colorado and CHP+ members will return to normal. Members due in May 2023 will be notified in March 2023. The Colorado Department of Health Care Policy & Financing (HCPF) will take 14 months, including noticing, to go through and complete renewals for each of the approximately 1.7 million people enrolled.

What do you need to know about the renewal process?

Understanding the renewal process will help you to best support your Health First Colorado eligible patients through this transition. Click here to learn more about what they must do for their renewal, including determining eligibility and how to re-enroll. 

What are we doing to support our providers?

  • We are informing our members about the end of continuous coverage. Our care management team is contacting them on behalf of primary care medical providers (PCMPs), and they are prioritizing high-risk members.
  • We created FREE informational postcards, posters, and other materials for you to give your patients. You can order through this form.
  • We created educational videos for you to share with your staff and members.
  • We added members renewal dates to the monthly attribution report (PEPR) so that you can filter your report for engaged and non-engaged members, high risk members, and members with upcoming renewal dates. Ask your practice facilitator for instructions.
  • We created step-by-step instructions for how you can check member eligibility on the State Web Portal.
    • If you have questions about checking eligibility please contact your provider network manager for additional support.
    • To find out who your provider network manager is please email
  • We created FAQs for you to review questions that have come up from your peers. Please scroll to the bottom of this page to view the FAQs.

Scam Alert

Scammers may be targeting Health First Colorado (Colorado’s Medicaid program) and Child Health Plan Plus (CHP+) members through text messages and phone calls.

  • They threaten members and applicants with loss of health coverage
  • They demand money
  • They ask for sensitive personal information and may even threaten legal action

HCPF does not ask members or applicants for money or sensitive personal information like social security numbers over phone or text; HCPF does not threaten legal action over phone or text.

HCPF and county departments of human services may contact members by phone to ask for current contact information including phone number, email address, and mailing address. You can update this information in PEAK at any time.

Members, applicants and partners should visit the State’s website for more information and report potential scam messages to the Attorney General Consumer Protection Unit.

How can providers help?

  • You can help us alert members of potential scams by sharing the messaging (text, social, newsletter) found on HCPF’s website:
  • You can report a scam and learn more at

How can you take action?

  • Make sure that your staff is familiar with Health First Colorado eligibility and re-enrollment processes so they can answer any questions your patients may have.
  • To ensure that you get properly reimbursed, you must check the Health First Colorado eligibility of each of your patients:
    • At the time their appointment is scheduled
    • When the patient arrives for their appointment
  • Ask your practice facilitator any questions you may have.
  • View our monthly attribution lists. These lists will help you understand which patients are due for renewal and when. These lists will show:
    • Your patients’ respective renewal dates
    • Your patients who are engaged and unengaged
    • Any of your patients who are qualified as high risk
  • Enhanced clinical partners (ECPs) are taking the responsibility to outreach engaged members.

How can you help your Health First Colorado eligible patients?

We need your support to:

  • Ensure your eligible patients can keep their health coverage. Use and share the materials in the toolkits from HCPF to:
    • Inform your patients they must take action to keep their health coverage, and how they can do so.
    • Educate yourself on the renewal process so you can effectively help your patients.
  • Direct any of your patients who no longer qualify for Health First Colorado to affordable health care coverage resources.

We value your partnership and encourage you to share feedback on best practices, new tools, and meaningful metrics with us at

Keep Coloradans Covered


HCPF estimates that more than 325,000 current members will no longer be eligible for Health First Colorado after their annual eligibility review. These reviews will be done in the anniversary month of when the member enrolled, meaning that if a member enrolled in July 2022, their eligibility review will be done in July 2023.

If a current member’s circumstances have changed since they enrolled in Health First Colorado, such as starting a new job that might put them over the income limit, they should find other health insurance coverage options to avoid the potentially devastating consequences of becoming uninsured.

As of April 2023, income eligibility limits have been increased to account for inflation. While a household may be over the income limit for Health First Colorado, it’s possible that children in that household could qualify for CHP+. CHP+ also covers pregnant people through their pregnancy and delivery, and for 12 months postpartum. Click here to see the updated eligibility limits.

Connect for Health Colorado

Those who are no longer eligible for Health First Colorado coverage can find alternative health care coverage options on Connect for Health Colorado, the state of Colorado’s official health insurance marketplace.

How Will I know When My Renewal is Due?

Spring 2023

How Do I Complete the Renewal Process?

Spring 2023

Quick Tips for Completing Your Renewal

Spring 2023

How Can I Get Help With My Renewal?

Spring 2023

Frequently Asked Questions

What is going to happen to telehealth coverage?

  • Phone and video visits will continue to be covered for all Health First Colorado and CHP+ members. This excludes Well Child Visits.
    • Telemedicine will still be a benefit, we are removing the Well Child Check codes from telemedicine effective May 12, 2023.Affected procedure codes include 99382, 99383, 99384, 99392, 99393 and 99394. Learn more here. If you have any questions, please email Morgan Anderson at and Naomi Mendoza at
  • Health First Colorado and CHP+ members can use phone and video visits for routine medical care, therapy and other visits. Not all providers offer telehealth services though, so members should check that their provider offers telehealth. This was a change in policy made in response to Covid-19 tha Health First Colorado has made permanent.

What will happen with providers that have closed their doors and are fully operational doing telehealth?
Providers can still operate and bill in the same manner after the PHE. A provider specialty, ehealth entity, for clinics and non-physician provider groups that deliver services exclusively via telemedicine will be available soon. When it is available these providers will update their current enrollment to indicate that they are providing services only via telemedicine.

Will there be a rate change for behavioral health telehealth?
For fee-for-service behavioral health telemedicine visits, there is no anticipated rate change due to the PHE. Payment parity between in-person and telemedicine visits is still in place. There will be no change to how the RAEs pay for behavioral health telemedicine benefits.

Will providers be able to see the renewal due dates in the Provider portal?
The provider portal does not provide the eligibility renewal due dates. The portal will show coverage start and end dates. We encourage members to log into their PEAK accounts to see their renewal due dates.

Is there a specific data field that indicates the status of a renewal?
The weekly data files from HCPF do not contain a specific field to indicate the status of a member’s renewal. It is not possible to determine if a renewal has been submitted by the member or is in the process of being reviewed by an eligibility worker. However, using the renewal date field users can determine if a renewal is not yet approved.

Is there a data field that indicates members who will be auto renewed?
Currently, the HCPF files do not include a field that indicates auto renewals. However, once ex-parte processes take place monthly, members renewal dates will be updated to the next year.

Frequently Asked Questions

Why are we seeing redetermination dates such as 2018, 2011 for some members?
We have not been able to get clarity from HCPF concerning why we are seeing these dates. However, any renewal date from the last three years of the PHE that is before 5/31/23 would fall under continuous coverage. Members who receive a renewal packet with a renewal date of May 2023 or later need to complete that packet in order to retain benefits.

If a member does not have an email address or phone number, how can they create an account on the PEAK website?
The PEAK account set up does not offer another option other than a phone number or email address. The only way around this currently is to help the member set up an email address in order to create the account.

Will children who are in foster care or those who were formerly in foster care be automatically renewed?
Children in foster care will receive a renewal packet to update demographic information. However, if the member does not take action then they will still be auto-renewed. Children who are currently in foster care and under the age of 18 will be auto-renewed and will not receive a packet. Those who were formerly in foster care will continue to be automatically renewed until they are 26 years old.

Will counties have sufficient staffing support to keep up with the volume of Medicaid member renewals?
HCPF is currently investigating how they can support eligibility workers to address workload backlogs. HCPF will also invest $15 million in additional appeals resources.

What will the process be if a renewal is submitted within the appropriate timeframe, but the county does not process it before the end of a member’s enrollment date?
When a member renewal is submitted through PEAK, the renewal is considered submitted on that date. There will be a grace period between the 5th and 15th of each month for that month’s member renewals. As long as PEAK “acknowledges” a member’s renewal by the 15th of the month in question, it will be considered complete for renewal purposes.

How can providers help with the renewal process?
Providers can bring awareness about the renewal process by posting our flyers in their public areas. Flyers, social media, website content, and other outreach tools can be found on our PHE Planning webpage. The materials in the toolkits raise awareness on key actions for members to take: updating contact information, taking action when a renewal is due, and seeking help with renewals at community or county resources when they need it.

Providers can also educate themselves and their staff on the basics of the renewal process to assist patients who may have questions. See our Renewal Education toolkit.

Additional frequently asked questions about the end of the continuous coverage requirement can be found here.