H.R. 1 Medicaid Work Requirements Frequently Asked Questions
Date published: February 17, 2026
This page answers common questions about important changes to Health First Colorado (Colorado’s Medicaid program) mandated by the federal legislation H.R. 1., also known as “One Big Beautiful Bill Act.” These changes include work requirements, also known as community engagement requirements, and 6-month renewals for low-income adults who are not enrolled in certain programs such as long-term services and supports [LTSS] or buy-in programs). Immigration status changes will also affect which immigrants can qualify for Health First Colorado.
Implementation Timeline and Key Dates
Overview of New Work Requirements
Who is affected by the new work requirements?
Who should not have to meet work requirements? 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 work requirements start?
H.R. 1 directs states to implement the new work requirements by January 2027. These requirements will apply to low-income adults ages 19–64 who are not enrolled in certain programs such as long-term services and supports (LTSS) or buy-in programs and whose application we receive on or after Jan. 1, 2027, or for members whose Medicaid renewal is set for January 2027.
When will current Health First Colorado members need to prove they have met the new work requirements?
Only low-income adults ages 19–64 who are not enrolled in certain programs such as long-term services and supports (LTSS) or buy-in programs 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 work requirement during at least one of the months within their 6-month renewal period.
Not everyone will need to show proof that they meet the work requirements or an exemption right away. Letters asking for proof that someone meets work requirements or is exempt will come at a member’s renewal date or when they experience a change in circumstance and we need more information to determine their eligibility. 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 work requirements?
New applicants will need to complete paperwork to show they met the work requirement in the month before they submit their application for Health First Colorado. Ways to meet the requirement include:
- Completing 80 hours of approved activities: working, participating in a work program, volunteering or going to school (or a mix of these)
- Earning at least $580 from paid work
- Showing documentation that they meet an exemption and do not need to meet the work requirement
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 Work Requirements
What are the new work requirements for Medicaid?
Low-income adults ages 19–64 who are not enrolled in certain programs such as long-term services and supports (LTSS) or buy-in programs must meet the work requirement when applying for or renewing their coverage.
- Current members will need to show at renewal that they met the requirement in at least one of the previous six months. Ways to meet the requirement include:
- Completing 80 hours of approved activities: working, participating in a work program, volunteering or going to school (or a mix of these)
- Earning at least $580 from paid work
- Showing documentation that they meet an exemption and do not need to meet the requirement
- New applicants will need to complete paperwork to show they met the work requirement in the month before they submit their application for Health First Colorado. Ways to meet the requirement include:
- Completing 80 hours of approved activities: working, participating in a work program, volunteering or going to school (or a mix of these)
- Earning at least $580 from paid work
- Showing documentation that they meet an exemption and do not need to meet the requirement
These criteria are based on our current understanding of guidance from conversations with CMS and may change as future guidance becomes available.
Will funding be available to support the increased workload?
We received approval of our Advanced Planning Document (APD) by CMS on November 28, 2025, giving federal approval to use $25,627,630 (of which 90%, or about $22.5 million, are federal dollars) to build the federally mandated Medicaid Work Requirements program. This funding supports Colorado’s efforts to maintain eligibility accuracy, automate verification processes, and ensure timely compliance with H.R. 1 work requirements. We also have a supplemental budget request for H.R. 1 implementation before the State General Assembly for consideration. Given the difficult state budget situation, we are exploring ways to be as efficient as possible with limited resources and will leverage automation (which has a higher federal matching rate) wherever possible.
How much will it cost to administer the new requirements?
Since final federal guidance is not available, costs to implement are estimates and could change over time as federal guidance is issued over the coming months. The total estimated cost for initial implementation of the H.R. 1 provisions related to Medicaid member eligibility are $5.4 million total funds (TF) in FY 2025-26 and $45.8 million total funds in FY 2026-27 (FY25-26: $5.4M TF and $0.3M GF / FY26-27: $45.8M TF and $5.6M GF). Our Advanced Planning Document (APD) and supplemental budget request outline some of these projected costs. There are many factors that impact the total “cost” such as system changes to drive automation which can reduce member and eligibility worker administrative burdens, number of individuals exempted from the work requirements and federal flexibilities that could reduce administrative costs for states or allow for a phased implementation over time.
Who is affected by the new work requirements?
Who is subject to the work requirements?
Low-income adults ages 19–64 who are not enrolled in certain programs such as long-term services and supports [LTSS] or buy-in programs) must meet the work requirement when applying for or renewing their coverage.
- Current members will need to show at renewal that they met the requirement in at least one of the previous six months. Ways to meet the requirement include:
- Completing 80 hours of approved activities: working, participating in a work program, volunteering or going to school (or a mix of these)
- Earning at least $580 from paid work
- Showing documentation that they meet an exemption and do not need to meet the requirement
- New applicants will need to complete paperwork to show they met the work requirement in the month before they submit their application for Health First Colorado. Ways to meet the requirement include:
- Completing 80 hours of approved activities: working, participating in a work program, volunteering or going to school (or a mix of these)
- Earning at least $580 from paid work
- Showing documentation that they meet an exemption and do not need to meet the requirement
Example: If your renewal is due March 2027, you will need to show proof that you have earned $580 or worked, participated in a work program, volunteered or went to school (or a mix of these) at least 80 hours during one of the months within your 6-month renewal period (September through February).
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 adults ages 19–64 who earn up to 133% of the federal poverty level (up to $20,815 per year for a single individual or $42,760 per year for a family of four). 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 work requirements will know in advance 1) if they are subject to the requirements and 2) how to comply and keep their health coverage. We will also include in our updated letters information on who should be exempt from the new work requirements. Members who must comply with work requirements will begin receiving letters in August 2026.
The first set of people impacted by the work 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 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 should not have to meet work requirements?
Who should not have to meet the work requirement?
People who meet any of the following criteria should not have to meet the work requirement.
- 18 years old or younger
- 65 years or older
- Parent or caregiver of a child age 13 or younger
- Parent or caregiver of people with disabilities
- Veterans with a total disability rating
Enrolled in Medicare Part A or Part B
Enrolled in a Long-Term Services and Supports (LTSS) program. For example, residing in a nursing home or enrolled in one of the following programs:- Brain Injury Waiver (BI)
- Community Mental Health Supports Waiver (CMHS)
- Complementary and Integrative Health Waiver (CIH)
- Developmental Disabilities Waiver (DD)
- Elderly, Blind and Disabled Waiver (EBD)
- Supported Living Services Waiver (SLS)
- Programs for All-Inclusive Care for the Elderly (PACE)
- Enrolled in Medicaid Buy-In Programs (Working Adults or Children's)
- Have a confirmed disability demonstrated by:
- Receiving Supplemental Security Income (SSI) and/or Social Security Administration (SSA) income, such as Social Security Disability Insurance (SSDI) or Social Security Retirement (SSR)
- The State Disability Determination vendor
- Foster youth or former foster youth age 0 to 26
- Current qualified Health First Colorado or CHP+ members who are pregnant or were pregnant within the last 12 months
- American Indian or Alaskan Native
- Medically frail
- Enrolled in a treatment program for a mental health or substance use disorder
- People who are incarcerated or people who have been released from incarceration in last 90 days
- Already meeting work requirements for TANF or SNAP
If enough information is not available to show that a member is exempt, a letter will be sent. Members must respond to letters asking for information so that we know they don’t have to complete a work requirement based on the criteria above.
le who have been released from incarceration in last 90 days.
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 one or more activities of daily living; or with a serious or complex medical condition. We expect final CMS guidance that will more clearly define this exception in June 2026.
Are those with severe mental illness or undergoing substance use disorder treatment exempt?
Yes, these members should fall under the medically frail exemption. Members may have to show documentation that they meet this exemption if we do not have data on file.
Are parents of people with disabilities age 14 or older exempted?
Yes, parents or caregivers 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 in the Buy-In Program for Working Adults with Disabilities Medicaid Buy-In Program have to meet the new work requirements?
No, people in the Buy-In Program for Working Adults with Disabilities do not need to meet the new H.R. 1 work requirements. Buy-In members must continue to meet the program's other requirements for income and employment, which have not changed.
Are older adults subject to the community engagement/work requirements?
No, only low-income adults ages 19–64 who are not enrolled in certain programs such as long-term services and supports (LTSS) or buy-in programs and do not show that they qualify for an exemption are subject to the work requirement.
Are people receiving Supplemental Security Income (SSI) or Social Security Disability Insurance (SSDI) subject to the work requirement
No, the work requirements passed in H.R. 1 do not apply to those receiving SSI or SSDI.
Compliance and Verification
How often do adults subject to the work requirement have to show proof?
New applicants who are not exempt will need to meet the 80-hour 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 work requirement in January 2027.
Existing Medicaid members who are not exempt and renewing will need to meet the 80-hour 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 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.
If a member is currently earning at least $580 per month (federal minimum wage x 80 hours) and reporting that income to Health First Colorado, they should not have to complete additional documentation to show that they meet the work requirements. The $580 represents 80 hours at the federal minimum wage of $7.25.
If a current member is already working, do they still have to show that they meet the work requirement?
If a current member subject to work requirements earns at least $580 per month (federal minimum wage x 80 hours) and we can verify that income, they should not have to complete additional documentation to show that they meet the work requirements. The $580 represents 80 hours at the federal minimum wage of $7.25. If they work but we cannot verify that income, we will send a letter asking for proof.
How does a gig worker or someone with seasonal income meet the work requirements?
For seasonal workers, all earned income must be totaled over the previous 6 months and divided by 6. The average income over those 6 months must be at or above $580. The $580 represents 80 hours at the federal minimum wage of $7.25. We expect CMS to issue final guidance by June 2026 and will update these FAQs as more information becomes available.
How do new applicants and current members submit verification to show they meet the new 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 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 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 work requirement for reference.
Some people are enrolled in both Health First Colorado and SNAP or TANF. If a person shows that they are compliant with the TANF work requirements, then they meet the new Medicaid work requirements and do not have to show further proof.
However, if a person is SUBJECT to SNAP work requirements and are compliant with SNAP work requirements, then they do not need to meet Medicaid work requirements. However if someone does not meet SNAP/TANF work requirements, they may have to show they meet the Health First Colorado 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 work requirement?
For new applicants, they must demonstrate that they’ve met the work requirement criteria in the month prior. Both new applicants and ongoing members should report any changes to their eligibility site or via PEAK in order for a correct determination to be made. Should verification be needed, an applicant or member will receive a letter giving them more information on what is needed and a date we need the information returned.
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.
Can I appeal the eligibility decision related to meeting the work requirement? If so, what is that process?
Yes, applicants and members can appeal eligibility decisions related to work requirements. Individuals who wish to appeal should follow the appeal instructions in the Notice of Adverse Action that they receive. Get additional information about appeals.
Member Notification and Communication
How and when will Health First Colorado let current members know if they need to meet the new work requirement to keep their health coverage?
We will update our letters so people impacted by the new work requirements will know in advance 1) if they are subject to the work requirements and 2) how to comply and keep their health coverage. Members who must comply with work requirements will begin receiving letters in August.
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 work requirements by working, meeting an exemption or complying with work requirements for SNAP/TANF.
If we cannot prove that a member meets the 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 work requirement.
What will the notices look like for the new work requirements?
We are starting work on the update to the notices and are inviting stakeholders to offer feedback. We will share draft notices as they’re available so members and partners can become familiar with them. We will update these FAQs as the information becomes available.
How can members stay up-to-date on all the changes surrounding the 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 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 what to do if they cannot be automated.
CMS is expected to issue final guidance to states by June 2026. We will update these FAQs as the information becomes available.
Will verifications for SNAP and Colorado Works work requirements meet the new Medicaid work requirements too? Will the renewal timelines be aligned to limit administrative burdens for members and workers?
If a member is compliant with work requirements for TANF/SNAP, they also meet the work requirement for Medicaid. Renewal timelines depend on an individual case and we are collaborating 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 work requirements?
We are still in the early stages of reviewing the H.R. 1 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 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 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 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 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 work requirement?
For ongoing updates on H.R.1 implementation, including community engagement/work requirements:
- Go to Understanding the Impact of H.R.1 and Federal Changes to Medicaid.
- Email your questions to hcpf_HR1@state.co.us.
- Sign up for HCPF’s At A Glance Monthly Newsletter.
Is there a requirement for states to connect people to work so they can meet the 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 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 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 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 work requirements?
HCPF estimates that about 378,500 members will be subject to work requirements before exemptions are applied. These are estimates only based on who is enrolled currently. We do not know exactly who will be enrolled in January 2027 when the work requirements will be in place.
How many are expected to lose coverage due to the new 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 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 work requirements take effect.