Colorado Medicaid builds systems for HR1 changes as commission reviews access and spending
Colorado is developing systems for a Jan. 1, 2027, Medicaid work requirement while a separate eligibility change could end coverage for about 7,000 lawfully present immigrants on Oct. 1. A state commission is also reviewing access concerns, spending outliers and vendor arrangements.
Colorado Medicaid officials are building systems for a new federal work requirement and other eligibility changes, including a separate change that could end coverage for about 7,000 lawfully present immigrants on Oct. 1. The work requirement generally must be operating by Jan. 1, 2027, officials told the Commission on Medicaid in July.
The changes are part of the federal budget law known as HR1. The Centers for Medicare & Medicaid Services says states generally must implement the community-engagement requirement by Jan. 1, 2027. Covered adults generally must complete 80 hours a month of work, community service, an approved work program, education or a combination of those activities.
Colorado’s Department of Health Care Policy & Financing estimates the requirement will apply to about 375,000 members before exemptions. Children 18 and younger, adults 65 and older, American Indian and Alaska Native members, people in long-term services and supports or buy-in programs, and others who meet federal exemptions will not be subject to it. HCPF staff told commissioners that about 47,000 people in the affected population are expected to qualify for exemptions.
The state plans to use self-attestation during the first year while it develops audit trails and verification systems. HCPF is adding data connections to automate exemptions where possible; staff said the joint eligibility system already contains some SNAP and TANF information. The state also must identify people who are medically frail. Staff said federal rules require both a medically frail finding and a significant impairment that prevents a person from completing 80 hours of activity. Colorado is considering existing disability information and diagnoses to identify those exemptions.
County eligibility workers will need new training and procedures. HCPF said the materials were still being developed and that county funding was increased by $17 million over two years through an HR1 supplemental.
Immigrant coverage changes come first
A separate HR1 eligibility change is scheduled to take effect Oct. 1, according to HCPF. The department estimates about 7,000 lawfully present immigrants will lose Medicaid coverage, including people with refugee or asylum status, humanitarian parole and withholding of removal. HCPF said it had begun sending notices and planned additional formal notices and community outreach.
A community health center representative told commissioners that at least one-quarter and possibly one-half of the affected immigrants are already community health center patients or could seek care there if uninsured. The estimate was not accompanied by a public breakdown by clinic, county or hospital.