About 378,500 Health First Colorado adults face Medicaid work rules starting in January 2027, before exemptions are counted. Colorado’s Department of Health Care Policy and Financing, known as HCPF, estimates that number. For members the state cannot confirm as working or exempt, a compliance form comes with the renewal packet about 60 days before the renewal is due.
Health First Colorado is the state’s Medicaid program. The new rules come from the federal law known as H.R. 1, which directs states to start work requirements by January 2027. HCPF began sending letters to members who must comply in August 2026.
Which Health First Colorado members the work rules cover
HCPF’s partner FAQ, updated Sept. 21, says the rules apply to low-income adults ages 19 to 64 who are not enrolled in long-term services and supports or a Medicaid buy-in program. They are the adults added under the Affordable Care Act expansion, with income up to 133% of the federal poverty level. HCPF counts 377,000 of the 1.2 million Coloradans in Medicaid in that group as of August 2026.
The state’s own number is an estimate based on current enrollment, and it is a ceiling. HCPF says it counts members before exemptions are applied. The Denver7 report on the rules says the state expects about 175,000 of the affected members will need to take action to keep their coverage.
Natalie Coulter, HCPF’s director of communications, told Denver7 that the first step is to “find out if it applies to you.” The department is sending texts, emails and letters, and it offers a Work Requirements Screener that checks whether the rules apply to a given member.
That answers the question many members are asking: do the rules apply to me, and when do I have to report? They apply to adults 19 to 64 in the expansion group, starting with new applications on or after Jan. 1, 2027, and with current members whose renewal date falls in or after January 2027. Current members must show compliance in at least one calendar month since their last renewal deadline. New applicants must show it for the month before they apply.
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Eighty hours or $580: how members show they comply
The Health First Colorado work requirements page says adults can meet the rule with 80 hours in a month of work, school or training, or volunteering, or by earning at least $580 from paid work. Activities can be combined. Paid, self-employed and seasonal work count, as do a work program, college or GED classes at least half time, and volunteering.
Seasonal and gig workers add up their earned income over the previous six months and divide by six. The average has to be at least $580. Federal rules let states pick a look-back of one, two or three months, and HCPF chose one month for current members. Members who renew every six months need one qualifying month within the current six-month period.
During 2027, members can self-attest for medical frailty, student status, volunteer work and work program participation, HCPF says. Veterans still have to provide a VA benefit letter that confirms their rating.
When the compliance form arrives and how to send it back
HCPF says the work requirements form goes to current members when its automatic data-matching cannot confirm compliance or an exemption. In most cases it is mailed with the renewal packet about 60 days before the renewal is due, though it may be sent later depending on what a member reports. Members whose data shows they meet the requirement before renewal receive a notice of renewal instead.
Members can respond through Colorado PEAK, the Health First Colorado app, by mail or by drop-off. The state says it intends to accept all current methods. The Member Contact Center is at 1-800-221-3943, with State Relay at 711, and questions can go to hcpf_HR1@state.co.us.
Starting Jan. 1, 2027, adults in the expansion group must renew every six months instead of once a year. Most other members keep the 12-month cycle. That includes children, adults 65 and older, pregnant members, people in long-term services programs, people with blindness or a disability, Medicare members, and former foster youth through age 26.
Who is exempt from the Colorado Medicaid work rules
The exemptions cover several groups of adults: parents, guardians and family caregivers of a child 13 or younger or of a person with a disability, and people who are pregnant or were pregnant in the past 12 months. They also cover people with a substance use disorder, including recovery of five years or less, or a physical, intellectual, developmental or disabling mental health condition. A serious health condition that needs regular treatment counts, as does blindness, if the condition keeps the person from doing 80 hours a month of activity.
Other exempt groups include people who receive SSI or SSDI, people with Medicare Part A or B, American Indians and Alaska Natives, and people who were in foster care at 18 and are now 19 to 26. Veterans with a service-connected disability rated 100%, or with Total Disability based on Individual Unemployability, are exempt. So are people who meet SNAP or TANF work requirements.
People in or recently in a jail, prison, hospital, nursing home or other long-term care facility within the past three months are also exempt. HCPF says members must answer letters that ask for information so the state can confirm an exemption.
What happens to coverage if a member does not respond
Health First Colorado says plainly that people who do not comply with the work requirements or renew on time will lose their health coverage. HCPF’s FAQ notes that a member who does not meet the requirement may be referred to local workforce centers. A decision can be appealed by following the instructions in the Notice of Adverse Action.
The open question for a member in the expansion group is the date: when does the form arrive, and what must it show? HCPF says about 60 days before the renewal is due, in most cases, so the clock runs from each person’s own renewal date and not from a single statewide deadline. A member who has not heard yet can call the Member Contact Center now and ask which date applies.
Does the Colorado Medicaid work form land before your renewal?
A Health First Colorado member who misses the form or sends it late can lose coverage, and the 60-day window leaves little room if the packet sits unopened. Six-month renewals mean the dates come around twice as often.
The SNAP & Medicaid Renewal Organizer covers the new Medicaid work requirement and who is exempt, and it adds a renewal and reporting calendar and a renewal document checklist. Together they keep the exemptions and the renewal dates in one place.
Put the Medicaid work-rule dates on a renewal calendar in the organizer →
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This article was produced with the assistance of AI and reviewed by the editorial team.
David M. Keller is a finance writer based in Columbus, Ohio, covering personal finance and consumer-focused economic topics. He earned his degree in journalism from Ohio University and began his career reporting on local business and economic trends for a regional media outlet. Since then, he has contributed to a variety of online publications, focusing on clear, practical coverage of topics such as cost of living, debt, and everyday financial decision-making.
