Will immigrants who no longer qualify for Health First Colorado (Colorado’s Medicaid program) be auto-enrolled in Emergency Medicaid Services?

It depends. If an immigrant has previously selected Emergency Medicaid Services and Reproductive Health Care Services (EMS/RHCS) on their application, they may be automatically enrolled in EMS/RHCS after October 1, 2026.
If an immigrant did not select EMS/RHCS on their application before October 1, 2026, they will not be automatically enrolled.
Immigrants who will lose Health First Colorado (Colorado’s Medicaid program) coverage because of federal changes should apply for EMS/RHCS before October 1, 2026. 

For immigrants who are pregnant, do they need to provide status documents such as work permits to get approved for Health First Colorado (Colorado’s Medicaid program)?

Pregnant immigrants need to provide identification (a full name, date of birth) so that their status can be verified. They may also provide documentation such as an I-551 or I-94.
A person who is undocumented or not lawfully present status would not need to provide documentation as it is assumed that they do not have documentation.
However, for applications they will still need to provide name, date of birth, address and a signature, etc.

Will immigrant members who lose Health First Colorado (Colorado’s Medicaid program) automatically qualify for Cover All Coloradans (CAC) or other programs, or will they need to re-apply for CAC?

If, as a result of these federal changes, an immigrant no longer qualifies for Health First Colorado, we will check to see if they qualify for Emergency Medicaid Services/Reproductive Health Care Services.
Cover All Coloradans (CAC) may be considered if that person does not fall into another category. CAC only covers pregnant/postpartum women and children 18 and younger who do not have a legal immigration status.

Will immigrants in the affected groups who are pregnant and those under 18 lose coverage as of October 1, 2026, or will they be automatically covered under Cover All Coloradans?

Whether a pregnant person or child 18 or younger qualifies for Health First Colorado or Cover All Coloradans depends on legal immigration status.

If a pregnant person or child 18 or younger no longer meets qualified immigrant status AND they are lawfully present, they will continue with their current health coverage.

Example: As of October 1, 2026, refugees no longer qualify for Medicaid. However, if the refugee currently receives Medicaid, is pregnant and is lawfully present, then they may continue to qualify for Medicaid.

If a pregnant person or child 18 or younger no longer meets qualified immigrant status AND they are NOT lawfully present, they may qualify for Cover All Coloradans.

Example: As of October 1, 2026, refugees no longer qualify for Health First Colorado. However, if the refugee is pregnant but is not lawfully present due to expired documents, then they may qualify for Cover All Coloradans.

Are there updates to data privacy that qualified people should consider when applying?

On June 6, 2025, HCPF received a request from CMS for data and information related to eligibility, claims, and cost allocations for people with an “unsatisfactory immigration status.” CMS has renewed their request for data every three months since. The requests include people who accessed Emergency Medicaid Services during each requested quarter (currently three quarters—April through June 2025, July through September 2025, and October through December 2025). While the first request excluded certain populations like pregnant people and children, subsequent requests have included pregnant people. CMS stated that the reason for this particular request is to ensure HCPF has not received funds for federal reimbursement for any person with an unsatisfactory immigration status who participates in a state-only funded program.

Additionally, there is a new court ruling indicating that CMS may share limited Medicaid information with federal agencies under specific circumstances, such as for people who are not “lawfully residing” in the United States. CMS has not yet provided Colorado with details on whether or how it may share information, and we are monitoring developments closely. We will update our members as more information becomes available.

Can I be certain that federal immigration officers will not see the personal information I provide on my application for Medicaid or CHP+?

No. Information that may be shared for people not “lawfully residing” can include citizenship
or immigration status, address, phone number, date of birth, and Medicaid ID. CMS must exclude anyone who is lawfully residing in the United States. If it is not possible to separate this data from information about lawful residents or U.S. citizens, CMS cannot share it. These restrictions remain in place while legal challenges are ongoing.

HCPF only shares Medicaid information with CMS. HCPF does not share information with federal immigration officials, although as this communication outlines, we cannot directly control what CMS shares.