FAQ Category: Work requirements

No, the work requirements passed in H.R. 1 do not apply to people with the Health First Colorado Buy-In Program for Working Adults with Disabilities.

Buy-In members must continue to complete the program’s other requirements for income and employment, which have not changed.

No, adults ages 65 or older do not need to meet the work requirements.

No, parents or caregivers of children 13 or younger or caregivers of people with disabilities of any age do not need to meet the new work requirements.

(updated August 4, 2026)

Work requirements do not apply to: 

Age

• Children age 18 or younger
• Adults age 65 or older

Caregivers

• Parents, guardians or caretaker relatives or family caregivers for a child 13 or younger
• Parents, guardians or caretaker relatives or family caregivers responsible for caring for a person of any age who has a disability

Living situation

• People living in a jail, prison or some halfway houses, now or in the past 3 months
• People living in a hospital, nursing home or other long-term care facility now or in the past three months

Pregnancy

• Current Health First Colorado members who were pregnant within the last 12 months, or are currently pregnant

Health conditions 

• People living with a drug or alcohol use disorder that prevents them from completing 80 hours per month of work, school, and/or volunteer activities
• People in recovery from a drug or alcohol use disorder for 5 years or less that prevents them from completing 80 hours per month of work, school, and/or volunteer activities
• People living with a physical, intellectual, or developmental disability that makes it hard to do daily activities and that prevents them from completing 80 hours per month of work, school, and/or volunteer activities
• People living with a disabling mental health disorder that prevents them from completing 80 hours per month of work, school, and/or volunteer activities
• People living with a serious health condition that requires regular treatment that prevents them from completing 80 hours per month of work, school, and/or volunteer activities
• People who are blind and their condition prevents them from completing 80 hours per month of work, school, and/or volunteer activities

Health coverage and benefits 

• People enrolled in a Medicaid Buy-in Programs (Working Adults or Children)
• People receiving long-term care services (for example, in a nursing home or through home-based care)
• People receiving Supplemental Security Income (SSI) and/or Social Security Disability Insurance (SSDI)
• People who qualify or are enrolled in Medicare
• People in a treatment program for drug or alcohol use disorder
• People who comply with Supplemental Nutrition Assistance Program (SNAP) or Colorado’s Temporary Assistance for Needy Families (TANF) work requirements

Population

• American Indians and Alaska Natives (AI/AN) who are eligible for Indian Health Services (IHS), a Tribal Health program, or an Urban Indian Health program; or who have received services from Indian Health Services (IHS), a Tribal Health program, or an Urban Indian Health program, now or in the past
• People who were in foster care when they turned 18 and who are now between ages 19 and 26
• Veterans with a service-connected disability that the U.S. Department of Veterans Affairs (VA) has determined to have either a 100% disability rating (temporary or permanent); or a Total Disability based on Individual Unemployability (TDIU), even if their combined disability rating is below 100%

If Health First Colorado needs more information to decide if you must meet work requirements, we will send you a letter. Open and respond to letters from Health First Colorado right away. Use our screener tool to find out if you might be affected by Medicaid work requirements.

You may need to comply with work requirements if

• You are an adult age 19 to 64
• Are not enrolled in LTSS or buy-in program, and
• Do not have an approved reason for not complying with work requirements

To comply with work requirements, first time applicants will need to show in the calendar month before they submit their application, that they

• earned at least $580, or
• spent at least 80 hours working, going to school, participating in a work program, volunteering, or a combination of these activities.

Use our work requirements screener tool to find out if you might be affected by Medicaid work requirements.

Health First Colorado (Colorado’s Medicaid program) will implement H.R. 1’s new work requirements starting January 1, 2027.

In January 2027, Health First Colorado will mail letters to members with a March 2027 renewal date. If a member is subject to work requirements, they will have to show that they comply or prove they do not have to comply to keep or receive their health coverage.

Starting January 1, 2027, adults ages 19 to 64 not enrolled in a long-term services and supports (LTSS) or buy-in program must comply with the work requirement when applying for or renewing their coverage. If this rule applies to you, Health First Colorado will send you a letter.

You can comply with work requirements by either completing 80 hours of approved activities, or earning at least $580 from paid work or a combination of these.

• First time applicants: In the calendar month before they submit their application, they will need to show that they
  • earned at least $580, or
  • spent at least 80 hours working, going to school, participating in a work program, volunteering, or a combination of these activities
• Current members who are renewing: In at least 1 calendar month since their last renewal date, they will need to show they
  • earned at least $580 or
  • spent at least 80 hours, going to school, participating in a work program, volunteering, or a combination of these activities
    • They can contact their county or visit CO.gov/PEAK to find their last renewal date if they are not sure.