State tracker

Colorado — Medicaid Coverage Retention

Applies Last updated 2026-06-03 · confidence: high

Colorado is subject to federal Medicaid community-engagement/work-requirement implementation beginning January 1, 2027, unless modified by future federal or state guidance.

Procurement / RFP activity

None identified

No public RFP for work-requirement communications/outreach identified as of 2026-06-03. Colorado's HCPF is implementing H.R.1 community-engagement (work) requirements through EXISTING contractors and in-house systems rather than a new competitive solicitation. The Community Engagement IAPD states the Department is "leveraging its existing contractors to implement the work requirements by January 2027" and will field a Minimum Viable Product within current eligibility infrastructure. Named incumbents performing the system/eligibility work: Deloitte (operates the Colorado Benefits Management System / CBMS and is building the work-requirement enhancements), EY, and 22nd Century Technologies (Product Management to define/design/implement H.R.1 system requirements). Member communications/outreach (letters, text, email, the H.R.1 Communications Toolkit) is being run in-house via Department-owned systems (Salesforce, PEAK) in partnership with stakeholders, health plans, and providers — not via an outsourced advertising/outreach RFP. HCPF is also "exploring new innovative public-private partnerships" for repeatable work-requirement tech, which could surface future solicitations, but none is publicly posted yet.

Procurement portal: BIDS Colorado (bidscolorado.com) is the state eProcurement portal; HCPF/CMES procurements are also posted at hcpf.colorado.gov/cmes-procurement and hcpf.colorado.gov/cmes-contracts. Colorado OSC/SPCO solicitations at osc.colorado.gov/spco/solicitations; some CDPHE/agency bids via BidNet Direct. · Implementation funding: IAPD-funded with federal financial participation (typically enhanced FFP for eligibility-system DDI). Estimated initial implementation cost for H.R.1 Medicaid member-eligibility provisions: $5.4M total funds in FY2025-26 and $45.8M total funds in FY2026-27. Funded via the Community Engagement IAPD (FFY26) and the S-08/BA-08 H.R.1 supplemental budget request to the legislature.

Latest detail

Federal H.R.1 mandates Medicaid community-engagement (work) requirements for ages 19-64 (with broad exemptions) for new applications on/after Jan 1, 2027 and renewals due Jan 2027+. HCPF expects final CMS guidance ~June 2026 and is building the system via existing contractors (Deloitte/CBMS, EY, 22nd Century Technologies) using an MVP approach (manual entry, self-attestation, existing interfaces). Member outreach begins with letters in August/September 2026 (and Sept/Nov 2026 notices), delivered in-house via PEAK/Salesforce plus an H.R.1 Communications Toolkit, with text/email opt-in — no outsourced communications RFP has been posted. The Department flagged interest in future public-private partnerships for repeatable work-requirement technology, a potential source of later procurement.

Medicaid expansion status	Expanded
Implementation status	Actively planning/implementing for Jan 1, 2027; leveraging existing contractors. State Board of Medical Services to adopt rules; data publication begins March 1, 2027.
Who may be affected	Yes — expansion adults
Reporting frequency	Pending state guidance
Reporting method	Pending state guidance
Renewal cadence	Every 6 months for expansion adults (H.R.1)
Notice timing	Pending state guidance
Self-attestation allowed?	Pending state guidance
State system / vendor	Pending state guidance
Major Medicaid MCOs	Pending state guidance
Languages likely needed	Pending state guidance

Key exemption categories to monitor

80 hours/month of work, job training, education, or community service — or qualifying monthly income.
Targets many ACA Medicaid expansion adults (19–64); non-expansion states largely have no such group.
Federal enforcement: January 1, 2027 (states implement; some earlier).
New: expansion adults redetermine every 6 months (not annually).
Commonly-defined exemptions: pregnancy/postpartum; medically frail; primary caregiver; disability; SUD treatment; certain students; tribe (AIAN); short-term hardship. Exact definitions set by CMS rule and each state.

Short-term hardship exemptions to track

Short-term hardship exemptions — adoption pending state guidance.

Member communication risk

Risk detail pending.

What MCOs & state partners should do now

Segment affected members
Identify likely exemptions
Send plain-language multilingual notices
Deploy SMS/email/IVR reminders
Track retention outcomes

Operating in Colorado?

The member-notice window is open now and closes August 31, 2026. Complete a Coverage Retention Readiness Audit while there is still time to act — we build CMS-compliant, plain-language, multilingual outreach to keep eligible Colorado members enrolled.

Request a Coverage Retention Audit

Frequently asked

Who is subject to Medicaid work requirements in Colorado?

Many ACA Medicaid expansion adults ages 19–64 who do not qualify for an exemption. Final scope is set by CMS rule and state implementation.

When do Colorado Medicaid work requirements start?

Federal enforcement begins January 1, 2027 (some states may implement earlier). Member notices are expected in the federally-required window of June 30–August 31, 2026.

What exemptions are available?

Federal baseline categories include parent/caretaker of a child under 14, pregnant/postpartum, disabled/medically frail, American Indian/Alaska Native, and those already meeting SNAP/TANF work rules. Short-term hardship exemptions and exact definitions are set by CMS rule and state implementation.

Sources

This page tracks publicly available implementation information and is updated as Colorado publishes guidance. State-specific rules are evolving. Not legal or eligibility advice.