Continuous Coverage Unwind Data Reporting

Federally required eligibility redeterminations for each of the 1.8 million people covered by Health First Colorado (Colorado’s Medicaid program) and the Child Health Plan Plus program were reviewed during the Public Health Emergency (PHE) Unwind between May 2023 and April 2024. The 90-day reconsideration period provided additional time for all members to submit the appropriate information for review. Throughout the unwind of the PHE continuous coverage requirement, HCPF’s priority has been to Keep Coloradans Covered.

This page covers enrollment data, renewal trends and learnings from the PHE Unwind and post-unwind periods. It also provides links to ways that stakeholders can collaborate with the state to identify additional opportunities to improve the state’s eligibility ecosystem as well as connect Coloradans to coverage.

Our member focused renewal resources are available on the Health First Colorado website.

Colorado Medicaid & CHP+ Enrollment Trends - Current Snapshot

As of October 2024, total enrollment in Colorado’s Medicaid and CHP+ programs is about 1.3M people, higher than pre-pandemic enrollment figures.

The state continues to advance efforts to make it easier to enroll and stay enrolled in our programs, with progress across all metrics over the last year. About 60% of our Medicaid & CHP+ renewals are processed without human intervention at the member or county processing level, meaning that more Coloradans are being renewed automatically. This is further improving our monthly renewal approval rates.

From May to October 2024, members were approved for renewal in Medicaid and CHP+ an average of 79% of the time, after applying the results of the 90 day reconsideration period (when members can turn in information late and counties may be processing renewals late). Not including the impact of the 90 day reconsideration period, the average is over 76%. These post-PHE Unwind approval rates are far better than the 55% PHE Unwind May 2023 - April 2024 period and the 57% pre-pandemic renewal approval rate (based on calendar years 2018 and 2019). The overall procedural denial rates post the PHE Unwind are below pre-pandemic rates and about half of the PHE Unwind rate, showing further system improvements. 

Coverage Options for Coloradans

Coloradans who no longer qualify for Health First Colorado or CHP+ have other coverage options.

CHP+: HCPF is auto-enrolling eligible children as part of the Medicaid redeterminations process. CHP+ enrollment has gone from a low of about 45,000 in May 2023 to 90,450 in October 2024, above prepandemic enrollment of about 79,000.

Employer Sponsored Insurance: Traditionally, about 50% of Coloradans tend to get their coverage through employer sponsored plans, more than any other type of coverage. Employers have annual open enrollment periods as well as opportunities for employees to enroll after a qualifying event, such as losing Medicaid coverage.

Family Member Employer Sponsored Coverage: Spouses, dependents, and children up to age 26 can be on their family’s employer plan.

Connect for Health Colorado: This is the state’s ACA marketplace. Premium and cost sharing subsidies are available below certain income thresholds.

OmniSalud: This is the coverage option for people who are undocumented or have DACA status.  Immigration status is not asked as part of application. Less than 150% Federal Poverty Level (FPL) may qualify for subsidies. This program has an enrollment cap, which has been met for this calendar year.

Medicare is coverage primarily for older adults - people over age 65. Coloradans can qualify for Medicare and Medicaid (duals), where Medicare is the main payor and Medicaid is the payor of last resort and primary payor for long-term services and supports.

To apply for health coverage or programs, visit: colorado.gov/health

GET INVOLVED: We appreciate your partnership in helping to get Coloradans connected to coverage. Learn about stakeholder opportunities to help us improve our eligibility and enrollment processes.

Overview

Public Health Emergency (PHE) Medicaid Continuous Coverage 2019 - 2023

• The COVID-induced economic downturn caused hundreds of thousands of Coloradans to lose their jobs and with them, their employer sponsored health benefits. As a result, Health First Colorado (Colorado’s Medicaid program) rosters grew by 45%, one of the top states for membership growth during the PHE. We should all be proud of this result, which is a reflection of a massive, collaborative, unified effort to connect Coloradans to our safety net coverages when they needed them. More than 550,000 Coloradans were added to our safety net rosters during this time, meaning HCPF programs were covering 30% of Coloradans at our PHE enrollment high.
• While Colorado processed Health First Colorado and Child Health Plan Plus (CHP+) member renewals throughout the pandemic, members did not lose coverage if they were determined ineligible due to the federal continuous coverage requirement in place during the PHE. 

Unwind of the PHE Medicaid Continuous Coverage May 2023 - April 2024 (renewals processes through 90 day reconsideration period ending in August 2024)

• When the federal government called an end to the public health emergency more than 3 years later, Colorado was required to act on renewal determinations, including disenrolling those who did not requalify for Medicaid or CHP+ (PHE Unwind). Every state is a little different; in Colorado, Medicaid is a state-supervised, county administered system. That means county departments of human/social services and specific Medical Assistance sites process Medicaid renewals.
• HCPF and its contracted partners outreached more than 2.4 million times via text, email, mailings and phone calls to about 726,000 Colorado households as of October 2024 to educate on what they needed to do to maintain their coverage. This outreach was in addition to a collaborative campaign with our partners who shared our toolkit messaging and a statewide Public Service Announcement (PSA) campaign (87,990 PSAs) in English and Spanish to raise awareness of the need for Health First Colorado and CHP+ households to renew their coverage through the PHE Unwind and to update their contact information to ensure their receipt of renewal information. Members were  outreached at least four times, plus, an additional, final outreach to more than 350,000 households was completed in September educating those disenrolled from Medicaid on how to reconnect to Medicaid or connect to other coverage options, based on their unique circumstances.
• Colorado’s PHE Unwind leveraged the time CMS provided — 12 months, or 14 months including noticing. Notices began in March 2023 for members with renewals due in May 2023, while the last group of renewals in the PHE Unwind were due in April 2024. We aligned with existing member renewal dates to maintain member action consistency, return to normal renewal processes in an equitable manner, mitigate impacts to county and eligibility staff workloads, and align with tapering federal funding available to finance coverage for individuals during the 12-month PHE Unwind.
• Not all populations grew at the same rate during the COVID continuous coverage period, the income sensitive populations (MAGI) including working aged adults without disabilities, parents and their children grew more during the pandemic and subsequently those populations also experienced higher disenrollments during the unwind.

Post Unwind

• During the PHE, Medicaid and CHP+ membership grew by about 550,000. In alignment with HCPF’s February 2024 budget forecast, membership returned to pre-pandemic levels. Since the PHE Unwind, we have seen a slight, consistent increase in total enrollment.
• This historic unwind has been challenging for many members, families and health care providers. Throughout, we have collaborated with providers, patient advocates, counties, RAEs, other contracted partners, and more to achieve the shared goal of Keeping Coloradans Covered. The good news is that all post PHE Unwind metrics are reflecting systemic advances made over the last few years, to the betterment of the member experience and county eligibility processing workloads going forward. While all metrics are improving, we still have work to do to address the reality that some have experienced coverage loss, confusion, and difficulty maintaining coverage through the PHE Unwind.
• Termination of Medicaid coverage for members with Long Term Services and Supports (LTSS) continue to be paused as Colorado received federal permission to conduct these more complicated renewals on a different timeframe, with extra time for these members to complete the renewal process; those LTSS members’ eligibility will be reviewed in 2025.
• We are focused on connecting any eligible kids to coverage. HCPF recently received federal approval for a new policy that will allow continuous coverage for kids ages 0-3. That new policy as authorized by the General Assembly will be effective in January 2026.

Improving Performance Across Numerous Metrics

As noted in the chart below, all metrics are headed in the right direction. Performance is getting better, but we still have a lot of work to do.

* July 2024 marked the implementation of additional automation for renewing members with incomes at and below the federal poverty level.  This additional automation is due to a temporary flexibility (known as an e14 waiver) allowed by the federal government through June 2025. HCPF has urged the federal government to make this waiver permanent as it improves the member experience by reducing paperwork needed for renewals and reduces associated county workloads.

**MAGI is Modified Adjusted Gross Income or income based populations. In October 2024, MAGI accounted for 76% of total enrollment.

***Given the renewal volume, the processing backlogs that evolved through the PHE Unwind, our state supervised-county administered structure, and the investments needed in our eligibility systems and staffing to improve capacity and processing time, this 90-day reconsideration period is an important metric for Colorado.

Challenges Remain

While Colorado has worked hard to Keep Coloradans Covered, people and providers have struggled to navigate this massive transition. Despite our improvements, we have a lot more work in progress to ease eligibility processes for Coloradans. Our top priority remains to Keep Coloradans Covered, focused on making it easier for those who are eligible for Medicaid to renew or re-enroll. Key initiatives are to reduce the county eligibility processing backlog, increase the rate of automated and digital renewals, and improve communications. Further details on what we are doing are below.

Immediate Actions to Reconnect People to Medicaid

Colorado Medicaid is a state supervised, county administered eligibility and enrollment system. That means counties and eligibility sites process Medicaid applications and renewals. Below are the state actions to reconnect those who may still qualify to Medicaid:

• We outreached to more than 350,000 households who were previously enrolled with information on Coverage Options, including Medicaid.
• We are collaborating with county partners to work through any remaining renewal backlogs and work tasks to get members covered back to their renewal date, as appropriate.
• We continue to encourage providers to help get patients re-enrolled in Medicaid, where appropriate, when they show up for care without health coverage.  For those who are found to be eligible, coverage can start on the application date and providers can be paid for those services for individuals found eligible.
• We are continuing to pause LTSS, Buy-In, and PACE disenrollments for all reasons (except for death and relocation out of state).
• We put in place a state centralized Return Mail Center to manage member contact updates and update addresses.

We are collaborating with key partners like Connect for Health and employer chambers to leverage the January 1 enrollment period going on now to further connect disenrolling Medicaid members to other coverage options.

We have ongoing work to improve operations in the following areas:

• Our renewal and new application automation (ex parte rates);
• PEAK performance, our member digital tool; and
• Eligibility correspondence clarity within 55 common member eligibility communications, with all letters updated by December 31.
   

Work in Progress to Further Improve Eligibility Determination Performance

Though Colorado’s renewal performance metrics have improved significantly, there is still more work to do to the betterment of our members and county partners, and we are committed to completing that work. Major initiatives designed to improve the eligibility process reflect our state-county partnership:

• Senate Bill 22-235 County Administration of Public Assistance Programs: A Long Term Plan that provides recommendations to improve county administration of eligibility and enrollment and related activities, including properly resourcing our state-county infrastructure, addressing county staff wage rate gaps, advancing the eligibility tools employed by county workers, and more. This report was released to the legislature on November 1.
• A funding request in FY 2025-26 HCPF/R-07 and CDHS/R-01 of nearly $44.5 million in new federal, State and local funding, which aligns with the above SB22-235 Report and aims to improve access to eligibility determinations for applicants and members and support counties administering HCPF and CDHS programs, including an increase in the number of county eligibility workers and their wages. This request demonstrates the State’s commitment to improving eligibility and enrollment processes while simultaneously supporting counties, who are on the front lines connecting Coloradans to public and medical assistance programs and supporting them through the enrollment process. 
• Through the Joint Agency InterOperability (JAI) project, we will advance county consistency through the use of shared, universal tools that support counties in eligibility task management, including new applications, renewals, case changes and other tasks; dashboarding; document capture; and related critical work. Target implementation date: Anticipated 2026 - 2027.
• The Colorado Benefits Management System (CBMS) Vision & Strategy project is driving alignment and clarity around CBMS operational advances, infrastructure, and priorities. Target completion date: June 2025.

The above project solutions achieve shared goals prioritized between HCPF, CDHS, and our County partners. All of the above strategies will continue to improve the member experience and drive down Colorado’s procedural denials, which are administrative denials for issues other than income and other eligibility requirements as well as individuals voluntarily opting out of Medicaid coverage because they no longer need safety net coverage.

Where Are We Now? Returning to Prepandemic Enrollment Levels

For each of the 3 years prior to the pandemic, Health First Colorado and CHP+ membership had been declining in aggregate by about 3% annually, reflecting Colorado’s strong economy. During the PHE, Medicaid and CHP+ membership grew by about 550,000. Through the PHE Unwind, we tracked with the February 2024 estimate of a net enrollment reduction of 519,000 members. Post the PHE Unwind, we have a slight, consistent increase in overall enrollment (includes all medical assistance programs).

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Through the PHE Unwind, members with higher medical needs have remained covered or returned to coverage, while those disenrolling had lower medical needs. This is causing a significant increase in the average per member per month (per capita) cost of Medicaid membership, post the PHE Unwind. This increase is above expectations and reflects a net 1.2% over-expenditure against our FY 2023-24 services budget projection. Many states are facing similar anticipated increases in Medicaid spending despite lower enrollment post unwind (KFF Brief & News 10/23).