Gizmo Warehouseby Joe Eichenbaum | 17A

Medicaid work requirements · Colorado

Medicaid work requirements in Colorado: who is subject and who loses coverage (2027)

Data snapshot 2026-06-03 · part of These 5 Million People Are About to Lose Their Medicaid — But They Don't Have To

Colorado expanded Medicaid, so the federal work requirement that takes effect January 1, 2027 applies to its expansion adults. About 357,249 of them (9.8% of an expansion pool of 381,904) will have to prove 80 hours a month of work, school, or service, or an exemption, to keep coverage.

This model's bottom-up estimate is that 86,786 people in Colorado lose coverage by 2034: 76,069 of them still eligible but lost to paperwork and reporting failures, and 10,717 not meeting the requirement. Nationally the same model gives 5,461,400, against CBO's 5,200,000.

Whether those eligible people keep coverage depends on the state's ability to renew them automatically (ex parte) from data it already holds. Colorado scores 66 of 100 on this model's ex parte capability index, a mid band; its eligibility system is CBMS.

Key figures

Model v2-2026-06-03. "Strict" counts adults whose ACS record shows them subject with no observable exemption; "permissive" allows the broader exemption reading.
MeasureColorado
Expansion stateYes
Subject to the requirement via waiverNo
Expansion pool (adults 19 to 64)381,904
Adults subject, strict definition357,249
Adults subject, permissive definition350,104
Share of expansion pool subject9.8%
Projected coverage loss by 203486,786
Hardship exception statusAdopting
Early implementerNo
Ex parte capability score (0 to 100)66 (mid)

Who is subject in Colorado

Of the 357,248 subject adults, 41% already work 80 or more hours a month and 49% are not working. 29% have a child under 14 at home. Among those not working, 47% report a disability and 15% are caregivers.

ACS PUMS 5-year 2020 to 2024, subject adults only.
CharacteristicShare of subject adults
Age 19-2416%
Age 25-3423%
Age 35-4419%
Age 45-5417%
Age 55-6425%
Not working49%
1 to 19 hours a month1%
20 to 79 hours a month9%
80 or more hours a month (meets the bar)41%
Not working: Disabled47%
Not working: Caregiver15%
Not working: Postpartum0%
Not working: Student4%
Not working: Other34%

Why eligible people lose coverage

Of the 86,786 projected to lose coverage in Colorado, 76,069 meet the requirement or qualify for an exemption but fail to document it. 35,584 of those are working people who cannot prove their hours through data the state can see, and 40,485 qualify for an exemption the state does not detect automatically.

Bottom-up model v8.0-2026-05-30; documentation-failure buckets compound over the 14 six-month renewal cycles through 2034.
GroupProjected to lose coverage
Multiple part-time jobs (aggregation failure)10,974
Self-employed (other)7,586
Variable shifts / on-call work6,696
Full-time students not auto-verified2,811
Cash-paid construction & trades2,256
Seasonal: agriculture, hospitality, food service2,219
Gig / courier (DoorDash, Uber, Lyft, Instacart)1,724
Volunteering / job training1,318
Medically frail without auto-match15,546
Caregivers of a disabled adult8,832
American Indian / Alaska Native (tribal exemption)4,383
SUD treatment not flagged in claims data3,617
Parent caregivers of children ≤13 without auto-match3,288
Kinship caregivers (non-parent) of children ≤132,156
Recent incarceration (data-match gap)1,582
Other categorical exemptions (foster, AYA cancer, SNAP/TANF)922
Pregnancy / postpartum data lag159

Can the state renew people automatically?

The ex parte capability index blends the state's observed automatic-renewal rate (63% in CMS eligibility-processing data), the wage, disability, and other data sources it can query, and its history of churn. Colorado's composite score is 66 (mid band). A low score means more eligible people will be dropped for paperwork unless the state changes its process before January 1, 2027.

ComponentScore
Composite66
Observed ex parte63
Core capability100
Data sources76
Historical churn50

How subjects overlap across exemption categories

Each subject adult sits in exactly one cell. Categories: Working ≥ qualifying hours / income; Parent caregiver of child ≤13; Medically frail; Full-time student.
CombinationAdultsShare
None of the four123,95534.7%
Working ≥ qualifying hours / income80,21722.4%
Medically frail47,54513.3%
Working ≥ qualifying hours / income + Parent caregiver of child ≤1340,59211.4%
Parent caregiver of child ≤1317,8805.0%
Full-time student17,4114.9%
Working ≥ qualifying hours / income + Full-time student14,4534.0%
Working ≥ qualifying hours / income + Medically frail5,8501.6%

Counties in Colorado

Subject adults concentrate: El Paso County (42,185), Arapahoe County (38,460), and Denver County (36,084) account for 33% of the state's subject population.

All 64 counties in Colorado with subject adults, sorted by count. County figures are model allocations of the state estimate by ACS tract characteristics.
CountyAdults subjectSubject rateProjected lossPoverty rateWorking-age population
El Paso County42,1859.2%10,2489.0%456,926
Arapahoe County38,4609.4%9,3438.0%408,376
Denver County36,0847.3%8,76612.0%492,635
Jefferson County35,4739.8%8,6177.0%362,456
Adams County30,5599.2%7,42410.0%331,726
Larimer County26,15411.4%6,35411.0%228,964
Boulder County23,90911.5%5,80811.0%208,746
Douglas County23,0419.9%5,5973.0%231,920
Weld County20,9749.9%5,09510.0%210,964
Mesa County10,89912.0%2,64811.0%90,526
Pueblo County10,62310.9%2,58117.0%97,132
Broomfield County4,5219.4%1,0985.0%48,004
La Plata County4,03511.9%98011.0%33,842
Garfield County3,96910.7%9648.0%37,110
Eagle County3,1719.0%7708.0%35,218
Montrose County3,13813.5%76212.0%23,198
Fremont County2,99810.0%72815.0%29,962
Delta County2,35114.4%57115.0%16,293
Summit County1,9499.3%4737.0%20,908
Morgan County1,92711.3%46813.0%17,120
Elbert County1,92311.7%4674.0%16,430
Montezuma County1,87613.3%45613.0%14,092
Teller County1,82712.5%4447.0%14,572
Routt County1,74911.0%4258.0%15,888
Gunnison County1,44412.3%35111.0%11,711
Park County1,31211.8%3197.0%11,085
Logan County1,2719.9%30912.0%12,804
Otero County1,26212.7%30724.0%9,928
Chaffee County1,25110.4%30412.0%12,057
Pitkin County1,20011.3%2927.0%10,606
Grand County1,18011.8%2879.0%9,996
Alamosa County1,11511.6%27116.0%9,642
Archuleta County1,09114.6%2658.0%7,468
Las Animas County1,03813.2%25219.0%7,879
Moffat County85011.1%20715.0%7,682
Prowers County81812.8%19918.0%6,372
Rio Grande County78112.2%19010.0%6,384
Clear Creek County60810.6%1487.0%5,718
San Miguel County60211.9%1468.0%5,054
Yuma County59511.3%14414.0%5,274
Huerfano County56817.2%13821.0%3,310
Custer County50718.8%1238.0%2,704
Lake County50110.5%1227.0%4,760
Conejos County49212.3%11916.0%4,007
Kit Carson County48112.8%1179.0%3,740
Saguache County47813.2%11617.0%3,634
Rio Blanco County45312.1%11013.0%3,754
Gilpin County41211.4%1009.0%3,608
Ouray County40315.3%985.0%2,624
Washington County32712.3%7910.0%2,653
Bent County3148.8%7627.0%3,582
Lincoln County2828.0%6912.0%3,532
Costilla County26013.9%6323.0%1,878
Crowley County2596.6%6324.0%3,908
Phillips County25110.4%6114.0%2,401
Baca County21612.2%5223.0%1,768
Dolores County17813.7%4317.0%1,297
Sedgwick County16313.5%4016.0%1,202
Cheyenne County12212.1%3011.0%1,006
Jackson County10014.6%2421.0%685
Kiowa County9912.9%2416.0%766
Hinsdale County6613.2%167.0%504
Mineral County5313.0%1311.0%404
San Juan County5010.0%1219.0%497

State brief and methodology

Estimates, not counts. The model rakes to CBO's national subject total and allocates by ACS microdata; state agencies hold the administrative data that would replace these figures.

Sources

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