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H.R. 1 Medicaid Community Engagement/Work Requirements Frequently Asked Questions

Date published: October 20, 2025

Starting in January 2027, new federal rules under H.R. 1 will require low-income adults ages 19-64 who do not have a disability (also known as the ACA expansion population) to meet community engagement/work requirements to keep their Health First Colorado coverage.

We are preparing for these changes and will share more information and details as the federal government releases final rules for the new community engagement/work requirements by June 2026.

These FAQs are based on information known as of the publish date; they are subject to change as federal guidance is available over the coming months.

Implementation Timeline and Key Dates

Overview of New Community Engagement/Work Requirements

Who is affected by the new community engagement/work requirements?

Who is exempt? Compliance and Verification

Member Notification and Communication

County and Eligibility Worker Operations

Stakeholder Engagement and Updates Broader Policy and Impact

Implementation Timeline and Key Dates

When do the community engagement/work requirements start?

H.R. 1 directs states to implement the new community engagement/work requirements by January 2027. These requirements will apply to low-income adults ages 19-64 who do not have a disability and whose application we receive on or after Jan. 1, 2027.

When will current Health First Colorado members need to prove they have met the new community engagement/work requirements?

Only low-income adults ages 19-64 who do not have a disability (known as the ACA expansion population) have to comply with the new eligibility requirements starting in January 2027. Current Medicaid members who are part of this group and who are renewing must meet the 80-hour community engagement/work requirement during at least 1 of the months within their 6-month renewal period.

Not everyone will need to show proof that they meet the community engagement/work requirements or an exemption right away: community engagement/work requirements will be aligned with a member’s renewal date. H.R. 1 also mandates that this same group of people will need to complete renewals twice a year instead of once a year.

These criteria are based on our current understanding of guidance from conversations with CMS and may change as future guidance becomes available.

When will first-time Medicaid applicants need to show they are either exempt from or meet the community engagement/work requirements?

Only low-income adults ages 19-64 without a disability who are applying for the first time must meet community/engagement/work requirements. They will need to show on their application that they qualify for an exemption or meet the requirements by working, volunteering, or going to school at least 80 hours per month (or a mix of these) in the month before applying.

These criteria are based on our current understanding of guidance from conversations with CMS and may change as future guidance becomes available.

Overview of New Community Engagement/Work Requirements

What are the new community engagement/work requirements for Medicaid?

Low-income adults ages 19-64 without a disability who are applying for or renewing their Medicaid coverage and do not qualify for an exemption, must meet the community engagement/work requirement by working, volunteering or going to school at least 80 hours per month (or a mix of these).

Who is affected by the new community engagement/work requirements?

Who is subject to the community engagement/work requirement?

Low-income adults ages 19-64 without a disability and who are applying for or renewing their Medicaid coverage must meet the community engagement/work requirement. This group, also known as the ACA expansion population, will need to show that they qualify for an exemption or meet the requirements by working, volunteering or going to school at least 80 hours per month (or a mix of these). 

Who is the ACA expansion population?

The ACA expansion population refers to a group of people who became eligible for Medicaid coverage after passage of the Affordable Care Act (ACA). These are low-income adults ages 19-64 who do not have a disability. They represent 369,368* of the 1.2 million Coloradans enrolled in Medicaid.

Coloradans enrolled in Medicaid probably aren’t familiar with the term “expansion population” because it’s a category that HCPF uses for administrative purposes.

* Data is based on annualized monthly caseload from FY 2024 to 2025 as of June 30, 2025.

We will update our letters so people impacted by the new community engagement/work requirements will 1) know in advance if they are subject to the requirements; and 2) tell them how to comply and keep their health coverage. We will also include in our updated letters information on who is exempt from the new community engagement/work requirements.

The first set of people impacted by the community engagement/requirements will be those who submit new applications on or after Jan. 1, 2027, or current members who have a renewal due date in or after January 2027.  

Health First Colorado will be doing additional outreach via text and email. We appreciate partner support in educating members affected by the new community engagement/work requirements about what they need to do to keep coverage and help encourage members to opt-in to digital communications through PEAK and the Health First Colorado app for timely and efficient notifications.

Who is exempt?

Who is exempt from the community engagement/work requirement?

  • Children ages 18 or younger
  • People with disabilities
  • Adults ages 65 or older
  • People who are pregnant or postpartum (12 months after a pregnancy ends)
  • Former foster care children ages 25 or younger
  • Parent or caregiver of a child age 13 or younger
  • Parent or caregiver of people with disabilities
  • Veterans with disabilities
  • American Indian/Alaska Natives
  • People who are medically frail
  • People enrolled in a substance use disorder treatment program
  • People who are incarcerated or people who have been released from incarceration in last 90 days
  • People who qualify for Medicare  

How are you defining “medically frail?”

H.R. 1 defines “medically frail” as: someone who is blind or disabled; with a substance use disorder; with a disabling mental disorder; with a physical, intellectual or developmental disability that significantly impairs their ability to perform 1 or more activities of daily living; or with a serious or complex medical condition. CMS is expected to allow states to further define medically frail and will provide more guidance on this criteria in the coming months.

Are those with severe mental illness or undergoing substance use disorder treatment exempt?

Yes, these members would fall under the medically frail exemption.

Are parents of people with disabilities age 14 or older exempted?

Yes, parents of people determined to have a disability are exempted. H.R. 1 indicates parents of people with disabilities of any age will be exempt; however, we are waiting for additional guidance from CMS.

Do people on the Working Adults with Disabilities Medicaid Buy-In Program have to meet the new community engagement/work requirement?

No, the community engagement/work requirements passed in H.R. 1 do not apply to people with disabilities.  People on the Medicaid Buy-In Program for Working Adults and Children with Disabilities still need to meet requirements for that program, which is different from H.R. 1.  

Are older adults subject to the community engagement/work requirements?

No, only low-income adults ages 19-64 who do not have a disability are subject to the community engagement/work requirement.  

Are people receiving Supplemental Security Income (SSI) or Social Security Disability Insurance (SSDI) subject to the community engagement/work requirement

No, the community engagement/work requirements passed in H.R. 1 do not apply to people with disabilities, those receiving SSI or SSDI.

Compliance and Verification

How often do adults subject to community engagement/work requirements have to show proof?

New applicants who are not exempt will need to meet the 80-hour community engagement/work requirement the month prior to applying.

  • Example: if someone applies for coverage in February 2027, they will need to prove they met the 80-hour community engagement/work requirement in January 2027.

Existing Medicaid members who are not exempt and renewing will need to meet the 80-hour community engagement/work requirement at least one of the months within their six-month renewal period.

  • Example: if a current member who is not exempt has a renewal that is due March 2027, they will need to prove they met the 80-hour community engagement/work requirement in one of the months six months prior (September through February).  

These criteria are based on our current understanding of guidance from conversations with CMS and may change as future guidance becomes available.

How does a gig worker or someone with seasonal income meet the community engagement/work requirements?

We expect CMS to issue guidance on this topic and will update these FAQs as the information becomes available. CMS is expected to issue final guidance to states by June 2026.

How do new applicants and current members submit verification to show they meet the new community engagement/work requirements?  Will this be through Colorado PEAK account or on the Health First Colorado app?

We are working on this process as we wait for final CMS guidance.  We will update these FAQs as the information becomes available. We intend to let people submit information using all the current methods: Colorado PEAK, Health First Colorado app, mail, drop-off, etc.

Are the community engagement/work requirements for Supplemental Nutrition Assistance Program (SNAP) and Health First Colorado (Colorado’s Medicaid program) the same? Do people need to complete the requirement for each program separately?

No, the community engagement/work requirements are not exactly the same across all programs. After H.R. 1 passed, the American Public Human Services Association published a comparison of the various public assistance programs with a community engagement/work requirement for reference.  

Some people are enrolled in both Health First Colorado and SNAP or TANF.  H.R. 1 states that if people are compliant with the SNAP/TANF work requirements, they can be considered compliant for Medicaid community engagement/work requirements.

However if someone does not meet  SNAP/TANF community engagement/work requirements, they may have to show they meet the Health First Colorado community engagement/work requirements to become enrolled or at renewal of their coverage. We are working with SNAP/TANF to align where possible.

How does someone who just lost their job and their employer-sponsored insurance show they have met the new community engagement/work requirement?

We expect CMS to issue guidance on this topic and will update these FAQs as the information becomes available.  CMS is expected to issue final guidance to states by June 2026.

Member Notification and Communication

How and when will Health First Colorado let current members know if they need to meet the new community engagement/work requirement to keep their health coverage?

We will update our letters so people impacted by the new community engagement/work requirements will 1) know in advance if they are subject to the community engagement/work requirements; and 2) tell them how to comply and keep their health coverage.

Before a member’s renewal date, we will send them a notice saying they’ve been renewed if we have data showing that they have met community engagement/work requirements by working, meeting an exemption or complying with work requirements for SNAP/TANF.

If we cannot prove that a member meets the community engagement/work requirements or exemptions using the available data, we will send the member a form asking them to provide information proving they meet the new community engagement/work requirement.

What will the notices look like for the new community engagement/work requirements?

We are starting work on the update to the notices and do not have a draft yet. We will update these FAQs as the information becomes available.  

How can members stay up-to-date on all the changes surrounding the community engagement/work requirements?

Members can stay up-to-date by creating and or signing in to their Colorado PEAK or Health First Colorado app and  opting into digital communications. They can also follow us on Facebook or Instagram and check the Health First Colorado website for news updates.

County and Eligibility Worker Operations

What will counties need to do differently to process eligibility with the new community engagement/work requirements?

Our goal is to automate as many exemptions and verifications as possible to reduce the workload for county workers and our members.  Once we receive federal guidance, we can develop more detailed plans for how verifications will work and who will do them if they cannot be automated.  

We expect CMS to issue guidance on this topic and will update these FAQs as the information becomes available. CMS is expected to issue final guidance to states by June 2026.

Will verifications for SNAP and Colorado Works work requirements meet the new Medicaid community engagement/work requirements too?  Will the renewal timelines be aligned to limit administrative burdens for members and workers?

If a member has met work requirements for TANF/SNAP, they also meet the community engagement/work requirement for Medicaid. Renewal timelines depend on an individual case, but we are working hard to partner with the Colorado Department of Human Services (CDHS) to align our approach as much as possible.

Will Colorado Benefits Management System (CBMS), the current eligibility system, be updated to determine if someone meets the new community engagement/work requirements?

We are still in the early stages of reviewing the H.R. 1 community engagement/work requirements to understand what changes will be needed to our systems. Our team is assessing how to use existing information in CBMS to support the new rules and identify any updates we need to make to the CBMS system in accordance with federal guidance.

How will the new community engagement/work requirements and exemptions be automated to limit administrative burden for county and eligibility workers?

We still need details from the federal government on the new community engagement/work requirements before we can accurately automate the new requirements and exemptions. The federal government has indicated it may be building tools that states could use to  help verify community engagement/work requirements..  

We will use existing meetings with county partners and other stakeholders to share information as we learn more.

To find and participate in specific engagement opportunities to work through operational details, go to Understanding the Impact of H.R.1 and Federal Changes to Medicaid.

When will training be available?

Training will begin after federal guidance is finalized, which is expected around June 2026. Once we have that guidance, we can work out  operational details and develop training on new processes or systems needed to meet federal community engagement/work requirements. Our goal is to ensure we’re prepared for a January 2027 implementation.  

Stakeholder Engagement and Updates

How do I find out more and stay updated with developments on the new community engagement/work requirement?

For ongoing updates on H.R.1 implementation, including community engagement/work requirements:

Is there a requirement for states to connect people to work so they can meet the community engagement/work requirements? If so, is there funding available for workforce centers to do this work?

Not at this time. While H.R. 1 requires states to have a community engagement/ work requirement in place, the law does not require or provide funding for the state Medicaid program to help people meet the requirement.

Medicaid funds have historically not been allowed to fund this activity.  Other state partners have infrastructure for workforce support. Medicaid members who do not meet the community engagement/work requirement may be referred to local workforce centers, similar to how members who do not qualify for coverage due to being over income are referred to Connect for Health Colorado to explore coverage options. CMS may provide states clarity in future guidance. We will update our FAQs as more information becomes available.

Broader Policy and Impact

Will Colorado apply for a waiver to allow for more time to implement the new community engagement/work requirements?

CMS has indicated it will not be giving many states waivers, so Colorado must work towards a January 2027 implementation timeframe to be in compliance with H.R. 1.

How many people will be subject to the new community engagement/work requirements?

HCPF is working on updating its estimates given the known exemptions and will post new analysis on Understanding the Impact of H.R.1 and Federal Changes to Medicaid when available. These will be estimates only based on who is enrolled currently. We do not know exactly who will be enrolled in January 2027 when the community engagement/work requirements will be in place.

How many are expected to lose coverage due to the new community engagement/work requirements?

Many national groups have different methodologies to estimate coverage loss, and we are referring to those numbers as we focus on implementing the community engagement/work requirements. Our information is based on actual enrollment, not projections for two years out, so we will report information through existing channels as the community engagement/work requirements take effect.