By Bridget Dandaraw-Seritt, Community Impact Manager
A major change to Medicaid is coming in January 2027, and many people are unsure what it means or who it affects. Here’s a simple overview.
Medicaid expansion allowed states like Colorado to cover more low-income adults by making it easier to qualify for health insurance. More than 40 states chose to expand their Medicaid programs.
In July 2025, Congress passed a new law (HR 1) that adds work and community engagement requirements for some adults enrolled through Medicaid expansion. Beginning in January 2027, many adults ages 19 to 64 who qualify through Medicaid expansion (MAGI Medicaid) and are able to work will need to meet these requirements to keep their health coverage.
However, not everyone will be affected. The law includes a number of exemptions for people in certain situations, and recent federal guidance has provided additional details about who is exempt and who may qualify for exceptions.
What is Community Engagement?
Starting January 1, 2027, every person on Medicaid between the ages of 19-64 will have
to engage in some combination of work and community engagement that equals 80 hours a month. The
Centers for Medicaid and Medicare Services (CMS) have listed several activities that qualify,
including being enrolled in school at least half time, employment making at least $580 a month,
or volunteering 80 hours a month. You can choose one activity or have a combination of
multiple activities, but it has to equal 80 hours of engagement every month.
This requirement doesn’t apply to everyone though. There are exclusions and exemptions that
may apply to you.
Who is Excluded or Exempt?
There are several groups of people either excluded or exempt from the community engagement
requirements. You are excluded from the requirements if you are:
● Pregnant or receiving postpartum care
● Caregiver to a child under the age of 14
● A caregiver to a disabled child of any age
● A foster care youth under the age of 26
● Currently incarcerated
● On Federal disability benefits
● A member of an indigenous tribe
● A veteran classified with total permanent disability1
Here is where things get more complicated. Another exemption exists that isn’t as clearly
defined, but could apply to anyone with a chronic illness like lupus. If you meet the definition of
medically frail and can show where it impacts your ability to meet the community engagement
requirements, then you could be exempt.
There are 5 categories in the medically frail exemption. These are:
● Blindness
● Substance Use Disorder, not in stable recovery
● Disabling mental, emotional, or behavioral disorder
● Physical, intellectual, or developmental disability
● A serious or complex medical condition
A new stipulation was added to the definition of medically frail, and to be exempt, your issues
need to significantly impact your ability to meet the engagement requirements. In the
past, the public has been able to self attest, meaning they’ll take your word that your disability
impairs your activities daily living (ADLs). After a one year grace period, this will no longer be
allowed. There will need to be auditable and verifiable documentation on file after January 1,
2028, and the state could choose to require that sooner.
Unfortunately, until the Department of Healthcare, Policy, and Financing (HCPF) finalizes the
process, we won’t know exactly what is needed to qualify for an exemption or make sure you
are excluded. They are supposed to start sending out notices this August, so hopefully they will
have the details ironed out by then.
In the meantime there are some things you can do to keep yourself informed.
Keep up with the Department of Healthcare, Policy, and Financing’s HR 1 implementation
website. HCPF is the agency managing Colorado’s Medicaid program. This webpage has
recorded webinars, updates, and opportunities to give feedback.
Get into the habit of checking your Colorado PEAK account monthly. Make sure you don’t
miss any notices so your care isn’t delayed or cut off completely. Be sure to log in here every
month to check your status and get ahead of any renewals.
Check to see if you could be impacted using the Work Requirement Screener. While this
tool isn’t 100%, it can give you an idea if you could be subject to the community engagement
stipulations. You still want to be sure that any documentation needed is on file, and always
make sure you check your account just to be sure. Access the screener here.
Over the next several months, Lupus Colorado will work to keep you informed of any changes
or updates, so be watching!