Medicaid Work Requirements in Colorado
Starting January 1, 2027, some Health First Colorado adults ages 19 to 64 must meet the work requirement. Colorado has an online screener and accepts proof through PEAK, the Health First Colorado app, mail, or in person.
Check your situation in Colorado
When it starts in Colorado
- Fall 2026: letters to affected members (state pages give September and November 2026).
- January 1, 2027: the requirement starts.
- January 2027: letters go to members with March 2027 renewals.
Who has to meet it
The rule applies to people ages 19 to 64 in the Medicaid adult expansion group, unless they are pregnant, have Medicare, or are exempt. You meet it in a month with 80 hours of work, community service, a work program, or school (in any mix), by going to school at least half-time, or with at least $580 in monthly income.
You are exempt if, for example, you care for a child 13 or younger or a person with a disability, are pregnant or postpartum, are American Indian or Alaska Native, are medically frail, are a veteran with a total (100%) VA disability rating or TDIU, were in foster care at 18 and are under 26, are in drug or alcohol treatment, meet SNAP or TANF work rules, or left jail or prison in the last 3 months. See the full exemption list.
Court ruling, October 29, 2026. In Massachusetts v. Oz, a federal court struck down the CMS rule's extra "significantly impairs" test for the medically frail exemption. If you are in any of the five medically frail groups in the law, you qualify. Colorado was one of the parties that sued, so the court also gave Colorado six months of relief from federal enforcement of its medically frail decisions while it updates its systems. The January 1, 2027 start date did not change, and CMS may appeal. What the ruling means.
How Colorado checks and how to report
Months checked: New applicants must show they met the rule in the calendar month before they apply. At renewal, you need at least one month since your last renewal.
Send proof through Colorado PEAK, the Health First Colorado app, by mail, or by dropping it off in person. Your county human services office can help by phone or in person. If the state can confirm your income from work, you should not need to send more papers.
Other things to know in Colorado
- Meeting SNAP or Colorado Works (TANF) work rules counts.
- Colorado lists caregivers of a child 13 or younger, pregnancy, American Indian and Alaska Native people, former foster youth ages 19 to 26, and veterans with qualifying VA disability ratings among the exemptions.
Official tools and contacts
- Check if it applies: Work Requirements Screener
- Report and upload: Colorado PEAK
- Health First Colorado Member Contact Center (State Relay 711): 1-800-221-3943
- Health First Colorado: work requirements
- Work requirements FAQ
- Screener in Spanish (evaluador)
- Agency: Colorado Department of Health Care Policy & Financing (HCPF)
Federal protections that apply in Colorado
- The state must check its own records before asking you for proof.
- If it can't confirm you meet the rule, you get a notice and at least 30 days to respond, and your coverage continues meanwhile.
- You get written notice and the right to a fair hearing before coverage ends, and you can reapply at any time.
- If you lose Medicaid for not meeting the rule, you cannot get marketplace premium tax credits for those months. Learn more.
Frequently asked questions
When do Medicaid work requirements start in Colorado?
January 1, 2027. Current members are usually checked at their first renewal on or after that date.
How many months does Colorado check?
New applicants must show they met the rule in the calendar month before they apply. At renewal, you need at least one month since your last renewal.
How do I report my hours or an exemption in Colorado?
Send proof through Colorado PEAK, the Health First Colorado app, by mail, or by dropping it off in person. Your county human services office can help by phone or in person. If the state can confirm your income from work, you should not need to send more papers.
Who do I call about Health First Colorado work requirements?
Health First Colorado Member Contact Center (State Relay 711): 1-800-221-3943
Can I lose Health First Colorado right away if I don't meet the requirement?
No. Federal law requires a notice, at least 30 days to show you comply or are exempt, continued coverage during that time, and fair hearing rights before coverage ends.
Sources
- Health First Colorado: work requirements
- Health First Colorado: when do the work requirements start?
- Health First Colorado: work requirements FAQ
- Public Law 119-21 (H.R. 1), sec. 71119: community engagement requirement (GovInfo)
- CMS interim final rule, Medicaid community engagement requirement, 91 FR 33348 (June 3, 2026)
- Massachusetts v. Oz, No. 1:26-cv-12962-RGS (D. Mass.), memorandum and order (Oct. 29, 2026)