COVID-19 Public Health Emergency FAQs

Public Health Emergency Planning

Frequently Asked Questions

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GeneralRenewalsEligibilityUnhousedMedicare/MedicaidBuy-In ProgramsLong Term Services & Supports (LTSS)Former Foster CareMaternity and Family PlanningProviderTransitions in CoverageAppeals


How does the public health emergency continuous coverage requirement impact members??

At the beginning of the COVID-19 pandemic, the federal government declared a public health emergency (PHE). During the PHE, state agencies were required to provide health care coverage for all medical assistance programs, even if a member’s eligibility changed. This is known as the continuous coverage requirement.

In December 2022, Congress passed a bill that ends the continuous coverage requirement in spring 2023. This required states to return to normal eligibility renewal processes. 

What happens when continuous coverage ends?

Health First Colorado (Colorado’s Medicaid program) and Child Health Plan Plus (CHP+) will return to regular eligibility renewal processes with renewals notices going out in March 2023 for people with May renewal dates. The Department of Health Care Policy & Financing (HCPF) will take 12 months (14 months including noticing) to complete renewals for each of the approximately 1.7 million people currently enrolled. Not all members will be renewed at the same time. Each member’s renewal month will align with their already established annual renewal month. Some members will be automatically renewed based on the most recent information already on file with the state. Other members will need to go through the renewal process and take action. The Department will send renewal packets to those members in advance of their renewal dates with key information and their individual timelines to take action.
What can members do now to prepare for the end of the continuous coverage requirement?

  • Update their contact info and communication preferences in PEAK
  • Watch for and respond timely to official notices from the state
  • Check the member renewal resources page.

How will HCPF work with its partners?

  • We will work closely with our county and eligibility partners to redetermine members' eligibility leveraging the member’s annual renewal date and our modernized, member-centric processes and only disenroll those who are no longer eligible.
  • We will properly notice all members whose eligibility changes about their benefits or enrollment status, including appeal information
  • We will work closely with our partners at Connect for Health Colorado to ensure those eligible for marketplace health plans are made aware of their coverage options as well as the availability of financial subsidies that make coverage more affordable.

How can I get more information?

The Department will continue to provide messaging to members through the Health First Colorado newsletter, PEAK, the Health First Colorado mobile app, emails, text messages and social media.

We will also provide policy and operational information to our partners through stakeholder meetings, at and through our COVID-19 Public Health Emergency Updates.


What is the renewal process?

The renewal process (sometimes called redetermination or RRR) for Health First Colorado (Colorado’s Medicaid program) and Child Health Plan Plus (CHP+) members occurs annually. Some members will be automatically renewed based on information we have for them from other data sources. Members may need to reply to additional letters asking for more information after the renewal process.

If we are not able to verify a member’s eligibility based on most recent information already on file (reported information from members and/or information from other data sources) they will have to go through the renewal process to see if they still qualify for coverage. These members will receive a renewal packet several weeks in advance of their renewal month. The packet will ask them if anything about their situation has changed, a signature to acknowledge review of the information, and may request verification to determine whether they still qualify to receive Medical Assistance. This is a new ask! During the PHE, members have received renewals but haven’t needed to return them to keep their coverage. This packet can be completed electronically through PEAK, the Health First Colorado mobile app, or by mail.

For more information about renewals visit the member renewal resources page.

How will members know when their renewal is due?

The Department will send a renewal packet either in the mail or to their email directing them to their PEAK inbox several weeks before their renewal due date. Members who use the Health First Colorado app, and have opted in to push notifications, will receive a push notification letting them know when it's time to take action.

Members can find out their renewal date on PEAK at any time.

What does the renewal packet look like?

Sample renewal packets are available to view and download on the Understanding the Renewal Process webpage.

What does the notice that members receive after their renewal packet has been processed look like?

Samples of written notices can be viewed on pages 17-20 in the Preparing for Renewals toolkit.

What is an Authorized Representative?

An authorized representative is an individual or organization who acts responsibly on the member or applicant’s behalf during the application and renewal process and other ongoing communications. An authorized representative needs to be added to the case when it is reported to the county within the Authorized Representative screen.

Why are there blank fields in the renewal packet?

The renewal forms sent in the mail ONLY include the minimal information needed to verify eligibility for the members in that household, not everything we have on file.The information in a person’s PEAK account includes ALL information we have on file for that member or household. If we printed all the information in the renewal packets, it would add a significant amount of pages to the mailing and unnecessary burden to the member. In addition, PEAK is a real time system that may dynamically ask for more information as questions are answered (something not achievable on paper renewal packets).

What does ex parte mean?

Some members are automatically renewed based on the most recent information already on file for them from other data sources. This process is known as ex-parte. These members will not receive a renewal packet, but will receive a “notice of action” letter that lets them know they are still eligible for coverage. Some members renewed through ex parte may still have to respond to letters asking for additional information about their income after the renewal process.

What percentage of members are renewed through the ex parte (automatic renewal) process?

HCPF estimates approximately one third of all members (includes both MAGI and non-MAGI enrollees) could be automatically renewed and not have to complete the renewal process. When looking at “active” members- defined as those who have been determined eligible and continue to be eligible (not part of the continuous coverage)- in the last year, the automatic renewal number is expected to be higher. For example, the average active non-MAGI ex parte rate over the last six months was approximately 50%, compared to 32% for the entire population. For those members that need to take action on renewals, the non-MAGI population is more likely than other populations to return their renewal packets. * Members who are renewed through ex parte may need to reply to additional letters asking for more information after the renewal process.

If a member is now over-income to qualify for Health First Colorado (Medicaid), can they be retroactively billed for coverage while they were locked in due to the continuous coverage requirement before their renewal date?

No, any benefits received while on Medicaid coverage, even during the continuous coverage period, can not be billed retroactively to the member.

If someone who currently has Health First Colorado coverage has a change of income before their renewal month, do they have to declare it? Could they lose their coverage if they do?

Members are required to report any changes online via PEAK, by phone, or by mail. For any changes reported for a member that was on Medicaid not due to the continuous coverage provision, after the public health emergency ends, the change can be acted upon and the member will receive advanced notice if their coverage changes as a result.

Why is a signature required for the renewal to be considered complete and how do I sign my renewal packet?

Due to a new federal requirement, members or an authorized representative must sign their renewal packet. There are several ways to do this:

  • Paper: Mail, fax, or bring the completed signature page and updated renewal form pages to the member’s local county office.
  • Online: Complete and sign the renewal through PEAK. If renewal was submitted to an eligibility site without the signature page, the member could upload the signed signature form via PEAK.
  • Telephone: Record the member’s renewal attestation and have their telephonic signature recorded through the member’s local county office. This will include the rights and responsibilities being read to the member.

Can an adult that lives in the home, but is not listed as the head of household sign the renewal?

Yes, an adult who is listed as part of the household on the case can sign the signature renewal form.

If the member does not know how to write, is an “X” acceptable as the signature?

Yes, a member is allowed to sign with the letter “X” if the signature is witnessed by someone and that witness prints their name after the phrase “witnessed by.”

How many days does the member have to provide the signed renewal packet?

The member must complete their renewal packet, including signature, by the date listed in their letter which is generally the 5th of their renewal month. Members will have approximately 45 calendar days to review and return the packet, with any updates and the signed signature page. This packet can be completed electronically through PEAK, the Health First Colorado mobile app or by mail If the member returns the renewal packet and the signature page is missing or unsigned, but all other information is complete, the eligibility system (CBMS) will send a form requesting the member’s signature.


What are the income limits for Health First Colorado (Colorado's Medicaid program)?

You can find the most recent income limits for Health First Colorado at These are set annually by the federal government.

How does someone qualify for Child Health Plan Plus (CHP+)?

Visit the CHP+ webpage for more information about CHP+ including eligibility and applications.

What is a verification checklist and what does a member do if they receive one?

A verification checklist is a document asking for additional information to see if someone qualifies for Medical Assistance (such as Health First Colorado or CHP+). If a member receives a verification checklist, they should read it carefully to see what information is needed and give this information to the eligibility site. If a member has questions about the verification being requested, they should contact their eligibility site listed on the letter.

What is an income discrepancy letter and what does a member do if they receive one?

An income discrepancy letter is a letter sent to a member when there’s a difference of more than 20% between the earned income our data source shows and what the member reported on their renewal paperwork. This difference is called “reasonable compatibility.” If a member receives an income discrepancy letter, they should review the income they reported and what our data shows. If the information they submitted is wrong, they need to submit new information showing correct earned income to their eligibility site. 

See the Additional FAQs specific to eligibility and COVID-19 PHE Unwinding.


Do unhoused members have to complete a renewal?

Unhoused members will go through the regular renewal process, including ex parte, to see if we have enough information for them to be automatically renewed. If they are not approved this way, they will be sent a renewal packet in the mail and through the PEAK portal if they are signed up for it. Health Care Policy & Financing (HCPF) is working with shelters to ensure they are aware of the renewal process and can help point members to support to complete renewals on time. Regional Accountable Entities are also working closely with community partners and organizations that help serve unhoused members. Members can receive in-person assistance completing their renewal at a Certified Application Assistance Site or at their county office.

How will an unhoused member be reached if their signature is missing from their renewal packet? 

We will make every attempt to contact members according to the methods they have opted into and the information we have on file. A signature is still required from unhoused members and can be completed in one of several ways- see the Signatures FAQ for more information.

How do unhoused members receive their renewal packets? 

HCPF uses information on file to send notices via mail or electronically through the PEAK portal for those who are signed up for it. Unhoused members sometimes list a local shelter as their address to receive mail - if this is the contact we have on file, that is where the renewal will be sent. HCPF has been working to ensure updated contact information is in place for all members, including emails and phone numbers to ensure we can reach them when their renewals are due. Members should visit the member renewal resources page to find out more.


If a member loses Health First Colorado (Colorado’s Medicaid program) coverage, will they also lose coverage for Medicare cost shares or full benefits (for people who are dually eligible) during the 60 day period following Medicaid coverage loss?

If someone no longer qualifies for Health First Colorado, they will no longer be eligible for related benefits such as Medicare premium cost shares or full Medicaid benefits if dually eligible for Medicare and Medicaid.

If a member is eligible for a Medicare Savings Program (MSP), but their income changes, will they be eligible for another MSP program if they continue to qualify for Medicaid?

When someone completes a renewal, they are assessed for eligibility to all programs administered by HCPF. For example, if an applicant is eligible for long-term services and supports and also meets criteria for a Medicare Savings Program, we will approve both programs.

Will MAGI Medicaid members who have aged have the opportunity to apply for and receive Medicare Savings Program benefits?

Yes, MAGI members who have aged or become eligible for Medicare can submit income and resource information to be determined eligible for a Medicare Savings Program category. County eligibility workers have been instructed on how to notify the state if a member does meet MSP eligibility so they can receive benefits.

Will the categories of Medicare Savings Program remain the same?

Yes. There has been no change to the eligibility for the Medicare Savings Programs.

What are the income limits for the Medicare Savings Program (MSP) and Low-Income Subsidy (LIS)?

The income limits for the MSP and LIS programs (QMB, SLMB, QI-1, QDWI and LIS) are based on federal poverty level (FPL) guidelines that are updated annually. For 2023, see OM 23-014, Medical Assistance - Medicare Savings Program and Low-Income Subsidy.

What are the resource/asset  limits for the Medicare Savings Program (MSP) and Low-Income Subsidy (LIS)?

For MSP/LIS resource/asset limits for 2023, see OM 23-001, Medical Assistance - Medicare Savings Program and Low-Income Subsidy

Buy-In Programs

Will Buy-In premiums for the Working Adults with Disabilities (WAwD) and Children’s Buy-In with Disabilities (CBwD) programs resume after the continuous coverage period ends?

No, premiums will continue to be waived at intake and renewal throughout the entire 14-month unwinding period. Health Care Policy & Financing (HCPF) will send out a formal communication before the premiums resume

When will Buy-In premiums for the WAwD, and CBwD programs start after the 14-month unwinding period ends?

HCPF is currently exploring and working with our federal partners to determine when these premiums will begin after our 14-month unwinding period ends. More information will be provided before the 14-month unwinding period ends.

Long Term Services & Supports (LTSS)

How does the state automatically renew LTSS (or Non-MAGI) members?

Ex Parte is the process by which the state reviews recent information already on file to determine eligibility- this information must be within the last six months. That information may come from a member’s renewal in another program, such as SNAP. If the information on file shows a member may not be eligible or if there is not enough information to determine if a member is eligible, a renewal packet will be sent out. Members are requested to review the information on file and make updates or provide new information. If a member needs additional documentation that cannot be automatically verified with existing data, a notice will be sent out identifying the items that require the documentation and types of acceptable documentation. *Depending on the program, a level of care assessment or other information may be needed to complete the renewal process.

How will this impact any LTSS programs a member is participating in?

During the continuous coverage requirement, members who have stopped meeting programmatic requirements for their selected LTSS program have continued to be held active in their selected LTSS program. Case Management Agencies (CMAs) will begin outreaching these members in April 2023 to inform them of the end of the continuous coverage requirement. Case managers will work with the member to identify if the member meets programmatic requirements, requires an assessment, a change of program, or service coordination. For those members who continue to no longer meet programmatic requirements, no adverse action will be taken by the CMA until after the members financial renewal date has passed. After the financial renewal date has passed, the CMA will outreach the member again to identify the programmatic requirements for their selected LTSS program. For members who continue to no longer meet requirements, a Notice of Adverse Action will be sent to the member which includes the members appeal right. For more information, please see OM 23-024: “Case Management Eligibility and Notice of Action Requirements for the Ending of the COVID-19 Public Health Emergency”

Do members in Long Term Care on waivers have to go through the renewal process?

All members will go through a renewal for Medicaid eligibility and if they do not meet requirements for the program then they could lose coverage. This includes members in Long Term Care on a waiver. If they still meet the requirements (income and resources, disability, and level of care) they should just renew for another year.

More information on helping LTSS members through the Continuous Coverage Unwind.

Former Foster Care

Do former foster care youth who are under 26 years old and currently have Health First Colorado (Colorado’s Medicaid program) coverage need to complete a renewal?

No, they will continue to receive coverage until they turn 26 unless they move to another state. If a person is within 3 months of turning 26, they will go through the regular renewal process and may receive a renewal packet if we need more information to see if they qualify for Health First Colorado. Their county Human Services office will contact them if they need any further information.

If someone was in foster care in another state, can they qualify for former foster care youth Health First Colorado?

If someone was in foster care in another state before Jan. 1, 2023, and they turned 18 on or after Jan. 1, 2023, they may qualify for Health First Colorado. They must be living in Colorado to qualify. They need to complete the Health First Colorado Out of State Former Foster Care Youth Form and return it to their county Human Services office.

Maternity and Family Planning

Does the renewal month change for pregnant people since they have 12 months of coverage following pregnancy?

Yes. The renewal month will be 12 months after the pregnancy ends. So if a member’s pre-pregnancy renewal is due in July 2023 but their pregnancy ends in September 2023, their new renewal date will become September 2024. Members must report their pregnancy in their PEAK account or to their county to qualify for the extended 12 months of coverage. Learn more by visiting the Health First Colorado webpage.

How does the renewal process and end of continuous coverage impact individuals currently enrolled for the Family Planning Limited Benefit coverage who do not have full Health First Colorado (Medicaid) coverage?

Members enrolled in Family Planning Limited Benefits have an annual renewal date and will go through the renewal process to see if they still qualify. Members who are currently receiving the family planning limited benefits must request (opt-in) through PEAK or their county when it is their time to renew to continue receiving these 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.

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.

Transitions in Coverage

What if a member loses their coverage?

We want all Coloradans to get covered and stay covered. If a member is no longer eligible for Health First Colorado or CHP+, they will receive:

  • Notice of when their enrollment ends
  • Information on how to appeal
  • Information about options for purchasing other health care coverage.

If a family is no longer eligible for Health First Colorado (Colorado’s Medicaid program), is it possible for the children to qualify for Child Health Plan Plus (CHP+)?

Yes. If a child is not eligible for Health First Colorado, they may qualify for the CHP+ program. These members will receive information about the new program they qualify for in their notice of action and we will connect them to the other coverage.

If someone is no longer eligible for Health First Colorado, how long do they have before their Medicaid coverage expires?

Members will receive a letter called a Notice of Action that tells them the date their coverage stops, the reason for coverage ending and information on how to appeal if they feel the decision is incorrect. The notice also gives information on who to contact with questions as well as information on how to contact the Connect for Health Colorado, the state insurance marketplace, to determine if they may be eligible for their program.

Renewals are sent 60-70 days prior to the coverage end dates. If a member responds completely to a renewal in a timely manner they will have more time to find other coverage after they find out they are no longer eligible for Health First Colorado or CHP+ coverage. Members are encouraged to fill out their renewal packets, sign and submit them right away.

If a member loses coverage at the end of the continuous coverage period, will that be considered a Qualifying Life Change Event to enroll in another type of health insurance?

Yes, when continuous coverage ends, the loss of Health First Colorado or CHP+ coverage will be considered a Qualifying Life Change event. This will open a Special Enrollment Period for the member to enroll in another type of health coverage.  Members should sign up for coverage by the end of the month their Medicaid coverage ends in order to avoid a gap in coverage.

For more information about coverage options visit

What is a Special Enrollment Period?

A Special Enrollment Period is a period of time triggered by a life event like the loss of Medicaid or CHP+ coverage in which a member can enroll in a health insurance plan outside the annual Open Enrollment Period. The COVID-19 Public Health Emergency (PHE) Unwind Special Enrollment Period lasts through July 31, 2024. For more information about coverage options visit

What is Connect for Health Colorado?

Connect for Health Colorado is the state’s official health insurance marketplace. It’s the only site that provides financial help to make health insurance plans more affordable.

How is information from people who no longer qualify for Health First Colorado shared with Connect for Health Colorado to determine eligibility for other health insurance programs?

Health Care Policy & Financing (HCPF) has worked closely with Connect for Health Colorado to establish a secure transmission that will send the individual’s information to Connect for Health Colorado. People will still need to complete an application with Connect for Health Colorado to find out what financial help programs they are eligible for.


Will individuals be able to appeal eligibility decisions once the continuous coverage period ends?

Individuals are always allowed to appeal any action taken on an eligibility decision. They can ask for a State Level Hearing (Formal), Dispute Resolution Conference (Informal), or both simultaneously. Information about the appeals process and how to appeal is part of the member letter known as a "notice of action".

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