A renewal you never return can end your Health First Colorado (Colorado Medicaid) coverage even if you still qualify. Federal law requires the state to try to renew you automatically from data it already holds, but when a packet does reach you, it has to come back on time. This guide covers how the 2026 renewal cycle works, what to do when your packet arrives, and the 90-day window to recover if you miss the deadline.
Renew online at Colorado PEAK or call the Member Contact Center at 1-800-221-3943.
In This Guide
- The Colorado Medicaid recertification and renewal cycle
- Ex parte Colorado Medicaid renewal
- How to renew Health First Colorado
- The 90-day reconsideration window
- Children and pregnant women
- Long-term care and HCBS-EBD waiver renewals
- Returned mail
- Fair hearing rights
- What changes after 2026
- Common mistakes
- Frequently Asked Questions
- Learn More
Recertification is where a case closes even though the person still qualifies. Colorado Medicaid renewal (the annual redetermination) confirms you still meet the rules set at your application.U.S. Government Publishing Office. (2026). 42 CFR 435.916 — Periodic renewal of Medicaid eligibility (eCFR versioner API, title 42 issue date 2026-08-13). ecfr.gov. Retrieved Sep 21, 2026, from https://www.ecfr.gov/current/title-42/section-435.916 For the broader picture, start at the Colorado Medicaid hub or Medicaid renewals by state.
The Colorado Medicaid recertification and renewal cycle
Under 42 CFR 435.916 the state must redetermine eligibility at least every 12 months, a minimum rather than a ceiling: for coverage based on age, blindness, disability, or long-term care it may redetermine more often.U.S. Government Publishing Office. (2026). 42 CFR 435.916 — Periodic renewal of Medicaid eligibility (eCFR versioner API, title 42 issue date 2026-08-13). ecfr.gov. Retrieved Sep 21, 2026, from https://www.ecfr.gov/current/title-42/section-435.916 Your renewal month is set at approval and holds each year. County human services offices do the casework under HCPF, and each renewal takes one of two paths.
- MAGI populations (children, pregnant women, parents and caretaker relatives, expansion adults) are renewed on Modified Adjusted Gross Income methodology, which has no asset test. In Colorado they qualify against percentages of the Federal Poverty Level: children through 18 at 142%, pregnant women at 195%, parents and caretaker relatives at 68%, expansion adults at an effective 138%.Centers for Medicare & Medicaid Services. (n.d.). Medicaid.gov — Medicaid, Children's Health Insurance Program, & Basic Health Program Eligibility Levels. medicaid.gov. Retrieved Jul 15, 2026, from https://www.medicaid.gov/medicaid/national-medicaid-chip-program-information/medicaid-childrens-health-insurance-program-basic-health-program-eligibility-levels
- Non-MAGI populations (aged, blind, and disabled members, long-term-care and waiver participants, and Medicare Savings Program enrollees) are renewed under rules that include an asset test. Federal law requires the state to verify assets at every renewal through an Asset Verification System (Section 1940 of the Social Security Act), so these renewals usually need bank statements and a signed financial-records authorization. Refusing to give that authorization, or revoking it, is itself a ground on which the state may find you ineligible.Office of the Law Revision Counsel, U.S. House of Representatives. (n.d.). 42 U.S.C. 1396w (SSA §1940) — Asset verification through access to information held by financial institutions: the mandate, the aged/blind/disabled population, where it applies, the authorization's duration, the revocation right and its consequence (uscode.house.gov, prelim/rolling current edition). uscode.house.gov. Retrieved Sep 4, 2026, from https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title42-section1396w&num=0&edition=prelim
Ex parte Colorado Medicaid renewal: the federal mandate
The ex parte default in 42 CFR 435.916 comes first. Before asking you for anything, the state must try to redetermine eligibility from reliable information already in your account or reachable through electronic data sources, and only then may it request information from you. For non-MAGI cases that duty runs where sufficient information is available.U.S. Government Publishing Office. (2026). 42 CFR 435.916(a)(2) and (a)(3) — Periodic renewal of Medicaid eligibility, as revised by CMS-2454-IFC eff. 2026-07-31 (eCFR versioner API, title 42 issue date 2026-08-13). ecfr.gov. Retrieved Sep 21, 2026, from https://www.ecfr.gov/current/title-42/section-435.916
Those sources, named at 42 CFR 435.948, 435.949, and 435.956, include Social Security Administration earnings and benefit records, tax and wage data, and other state programs' records. If they confirm you remain within your category's income limit and nothing else changed, the renewal processes automatically and you get a notice saying coverage continues for another 12 months and no action is required. You do not have to sign and return that notice if everything on it is accurate.
When ex parte fails, the state must send a renewal form with the information it already has and give you at least 30 days from the date on that form to respond, add anything missing, and sign it. Under 42 CFR 435.916(a)(3) that is a federal requirement for MAGI eligibility. For the non-MAGI groups (age 65 or older, blindness or disability, long-term care, a Medicare Savings Program, or medically needy), Colorado may follow the same procedure but is not required to, so go by the deadline on your notice.U.S. Government Publishing Office. (2026). 42 CFR 435.916(a)(3) and (b) — renewal form, 30-day response window, and the permissive adoption of (a)(3) for non-MAGI beneficiaries (eCFR versioner API, title 42 issue date 2026-08-13). ecfr.gov. Retrieved Sep 21, 2026, from https://www.ecfr.gov/current/title-42/section-435.916 Ex parte tends to fail when income never appears in wage databases, when an asset check must be run by hand, or when the household changes.
How to renew Health First Colorado: Colorado Medicaid renewal channels
For a MAGI renewal, 42 CFR 435.916 lets you submit through any way the agency accepts applications and bars an in-person interview.U.S. Government Publishing Office. (2026). 42 CFR 435.916(a)(3) and (b) — renewal form, 30-day response window, and the permissive adoption of (a)(3) for non-MAGI beneficiaries (eCFR versioner API, title 42 issue date 2026-08-13). ecfr.gov. Retrieved Sep 21, 2026, from https://www.ecfr.gov/current/title-42/section-435.916 In Colorado the fastest channel is Colorado PEAK.Centers for Medicare & Medicaid Services. (2026). CMS CMCS Informational Bulletin — Updated 2026 SSI and Spousal Impoverishment Standards (April 27, 2026). medicaid.gov. Retrieved Jul 30, 2026, from https://www.medicaid.gov/federal-policy-guidance/downloads/cib04272026.pdf
| Channel | How | Notes |
|---|---|---|
| Online | Colorado PEAK (peak.my.site.com) or the Health First Colorado mobile app | Fastest, upload documents, check status, recommended |
| Phone | Member Contact Center, 1-800-221-3943 (State Relay 711) | Ask questions, request a packet, update your address |
| In person or mail | Your county human services office | Renew, drop off documents, or get help completing the form |
PEAK (Program Eligibility and Application Kit) is the state's benefits portal.Centers for Medicare & Medicaid Services. (2026). CMS CMCS Informational Bulletin — Updated 2026 SSI and Spousal Impoverishment Standards (April 27, 2026). medicaid.gov. Retrieved Jul 30, 2026, from https://www.medicaid.gov/federal-policy-guidance/downloads/cib04272026.pdf Use the account you set up at application, or create one with your name, date of birth, and the case or member ID from a notice.
The 90-day Colorado Medicaid reconsideration window
If coverage closed because you missed the renewal paperwork, you may not have to start over. Under 42 CFR 435.916, if you lose coverage for failure to return the renewal form or requested information (a procedural termination, not an eligibility-based one), the agency must reconsider your eligibility and treat the late-returned form as the renewal if you submit it within 90 days of the termination, without requiring a new application. That duty covers eligibility based on modified adjusted gross income (MAGI); for non-MAGI groups Colorado may offer the same window but is not required to, so ask HCPF.U.S. Government Publishing Office. (2026). 42 CFR 435.916(a)(3)(iii) — 90-day reconsideration without a new application, and (b) making (a)(3) permissive for non-MAGI beneficiaries (eCFR versioner API, title 42 issue date 2026-08-13). ecfr.gov. Retrieved Sep 21, 2026, from https://www.ecfr.gov/current/title-42/section-435.916 If your case closed June 30, you have until roughly September 28. The rule guarantees reconsideration, not that restored coverage reaches back to the closure date; ask how HCPF treats that gap.
The 90-day clock starts on the termination date, not the notice date. Read the closure notice carefully.
To activate it, submit the form through PEAK, your county office, or by phone. If you no longer have it, call 1-800-221-3943 or use PEAK for a new one, and note the closure date.healthfirstcolorado.gov. (n.d.). Health First Colorado (Colorado's Medicaid Program) - official member site. Retrieved Jul 9, 2026, from https://www.healthfirstcolorado.gov/
Children and pregnant women: continuous coverage
Federal law protects two groups from mid-year income changes at renewal.
Children under 19. Section 5112 of the Consolidated Appropriations Act, 2023 gives children under 19 on Medicaid or CHIP (in Colorado, Child Health Plan Plus) 12 months of continuous eligibility from enrollment, effective January 1, 2024.Office of the Law Revision Counsel, U.S. House of Representatives. (n.d.). 42 U.S.C. 1396a(e)(12) - State plans for medical assistance (uscode.house.gov, prelim rolling edition). uscode.house.gov. Retrieved Aug 3, 2026, from https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title42-section1396a&num=0&edition=prelim Coverage is locked in for those 12 months regardless of a rise in family income: if a parent loses Medicaid mid-year, the children keep theirs until their next annual renewal (exceptions: aging out at 19, leaving Colorado, death, voluntary disenrollment, fraud). Report the income rise anyway; accurate reporting protects you from fraud allegations.
Pregnant and postpartum members. Federal law gives states a permanent option to extend Medicaid coverage for a full 12 months after a pregnancy ends, well beyond the older 60-day window.Office of the Law Revision Counsel, U.S. House of Representatives. (n.d.). 42 U.S.C. 1396a(e)(16) — extending certain coverage for pregnant and postpartum women (uscode.house.gov, Office of the Law Revision Counsel, rolling prelim edition). uscode.house.gov. Retrieved Sep 4, 2026, from https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title42-section1396a&num=0&edition=prelim Where that extended coverage applies, income changes do not end it before the 12 months run, and the annual renewal cycle resumes after the postpartum period closes.
Long-term care and HCBS-EBD waiver renewals
If you get Medicaid long-term care in Colorado, in a nursing facility or through the HCBS waiver for the Elderly, Blind, or Disabled (HCBS-EBD), your renewal has two independent parts, and both must stay current.
Financial redetermination. On the 12-month cycle, this includes the asset test federal law requires at renewal.Office of the Law Revision Counsel, U.S. House of Representatives. (n.d.). 42 U.S.C. 1396w (SSA §1940) — Asset verification through access to information held by financial institutions: the mandate, the aged/blind/disabled population, where it applies, the authorization's duration, the revocation right and its consequence (uscode.house.gov, prelim/rolling current edition). uscode.house.gov. Retrieved Sep 4, 2026, from https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title42-section1396w&num=0&edition=prelim Colorado is an income-cap state: the standard for nursing-facility and waiver coverage is 300% of the SSI federal benefit rate, $2,982 a month for an individual in 2026, with a $2,000 countable-asset limit for a single applicant. The $3,000 couple limit HCPF publishes applies where both spouses are applying, not where one enters a nursing facility or waiver and the other stays home.Centers for Medicare & Medicaid Services. (2026). CMS CMCS Informational Bulletin — Updated 2026 SSI and Spousal Impoverishment Standards (April 27, 2026). medicaid.gov. Retrieved Jul 30, 2026, from https://www.medicaid.gov/federal-policy-guidance/downloads/cib04272026.pdf Income above the cap routes through an income trust (Colorado's Qualified Income Trust) that names HCPF as remainder beneficiary. Neither limit is the end of the road: HCPF points members who miss them to the Health First Colorado Buy-In Program for Working Adults with Disabilities, and its waiver page never lists what counts as a resource, so ask your Case Management Agency before reading $2,000 as a verdict on all you own.Centers for Medicare & Medicaid Services. (n.d.). Medicaid.gov — CO Elderly, Blind, and Disabled (HCBS-EBD) Waiver (0006.R09.00). medicaid.gov. Retrieved Sep 4, 2026, from https://www.medicaid.gov/medicaid/section-1115-demo/demonstration-and-waiver-list/81121 The review also confirms your Personal Needs Allowance, which Colorado's rule splits in two: $110.36 a month in 2026 for a resident who is not a veteran or a veteran's widow(er), but $90 for a veteran in a long-term-care institution with no spouse or dependent child drawing a non-service-connected VA pension, and for a veteran's widow(er) with no dependent children. A resident engaged in income-producing activity keeps $65 a month more, plus half the remaining gross income.Centers for Medicare & Medicaid Services. (2026). CMS CMCS Informational Bulletin — Updated 2026 SSI and Spousal Impoverishment Standards (April 27, 2026). medicaid.gov. Retrieved Jul 30, 2026, from https://www.medicaid.gov/federal-policy-guidance/downloads/cib04272026.pdf If your spouse is still at home, it also confirms spousal-impoverishment protections: under 10 CCR 2505-10 § 8.100.7.M.1 the Community Spouse Resource Allowance is the couple's total countable resources up to a 2026 maximum of $162,660, with no step that halves them.Centers for Medicare & Medicaid Services. (2026). CMS CMCS Informational Bulletin — Updated 2026 SSI and Spousal Impoverishment Standards (April 27, 2026). medicaid.gov. Retrieved Jul 30, 2026, from https://www.medicaid.gov/federal-policy-guidance/downloads/cib04272026.pdf
Level-of-care reassessment. Your local Case Management Agency reassesses whether you still need an institutional (nursing-facility) level of care.Centers for Medicare & Medicaid Services. (n.d.). Medicaid.gov — CO Elderly, Blind, and Disabled (HCBS-EBD) Waiver (0006.R09.00). medicaid.gov. Retrieved Sep 4, 2026, from https://www.medicaid.gov/medicaid/section-1115-demo/demonstration-and-waiver-list/81121 The two reviews are independent: you can pass the financial one and fail this, or the reverse. If it is not approved, long-term-care Medicaid ends, though you may continue on regular aged, blind, and disabled Medicaid if you otherwise qualify.
Medicare Savings Program renewals
Qualified Medicare Beneficiary, Specified Low-Income Medicare Beneficiary, and Qualifying Individual eligibility is redetermined at least annually on the non-MAGI cycle, with the state trying ex parte first.U.S. Government Publishing Office. (2026). 42 CFR 435.916 — Periodic renewal of Medicaid eligibility (eCFR versioner API, title 42 issue date 2026-08-13). ecfr.gov. Retrieved Sep 21, 2026, from https://www.ecfr.gov/current/title-42/section-435.916 For 2026 HCPF applies an MSP resource limit of $11,450 for an individual and $17,910 for a couple, and updates income limits each April with the new Federal Poverty Level. That is not a more generous Colorado ceiling: it is the federal limit ($9,950 and $14,910) with the burial-fund exclusion ($1,500 per person) folded in, allowed only if you actually set the money aside. HCPF's public MSP page still shows 2025 figures ($11,160 and $17,470), a stale chart rather than a different rule.U.S. Social Security Administration. (2026). SSA - POMS: HI 00815.023 - Medicare Savings Programs Income and Resource Limits - 02/26/2026. secure.ssa.gov. Retrieved Jul 9, 2026, from https://secure.ssa.gov/poms.nsf/lnx/0600815023
For MSP questions, the state's Part D guide says to contact Colorado's SHIP (official page) or your County Department of Human Services.Administration for Community Living. (n.d.). Local Help Navigating Medicare (SHIP overview flyer) — Administration for Community Living. acl.gov. Retrieved Sep 27, 2026, from https://acl.gov/sites/default/files/programs/2022-06/SHIP_OverviewFlyer_Final.pdf SHIP's information is free and unbiased.Administration for Community Living. (n.d.). Local Help Navigating Medicare (SHIP overview flyer) — Administration for Community Living. acl.gov. Retrieved Sep 27, 2026, from https://acl.gov/sites/default/files/programs/2022-06/SHIP_OverviewFlyer_Final.pdf
Returned mail: what happens if your packet comes back
If your renewal packet is returned as undeliverable, that can lead to a termination. The federal rule requiring the state to search for a new address first, 42 CFR 435.919, was removed effective July 31, 2026. Federal law now says only that the state may act without advance notice when your whereabouts are unknown (42 CFR 431.213(d)), and that coverage must be reinstated if your whereabouts become known while you are still eligible (42 CFR 431.231(d)).U.S. Government Publishing Office. (2026). 42 CFR 435.919 — [Reserved] (eCFR versioner API, title 42 issue date 2026-08-13). ecfr.gov. Retrieved Sep 21, 2026, from https://www.ecfr.gov/current/title-42/section-435.919 Colorado may have its own procedures, so call HCPF or your county office if mail has come back.
Your health plan's records are a separate file from the state's.U.S. Government Publishing Office. (n.d.). 42 CFR 431.230 — Maintaining services (continuation of benefits pending a Medicaid fair hearing), eCFR current. ecfr.gov. Retrieved Sep 4, 2026, from https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-431/subpart-E/subject-group-ECFR8ec5a6d55a4bb59/section-431.230 Update both the moment you move:
- Update your contact information in Colorado PEAK
- Call 1-800-221-3943healthfirstcolorado.gov. (n.d.). Health First Colorado (Colorado's Medicaid Program) - official member site. Retrieved Jul 9, 2026, from https://www.healthfirstcolorado.gov/
- Tell your county human services office and your health plan
- File a change-of-address form with the post office
Fair hearing rights: appealing a termination
If your renewal is denied or your coverage is terminated, you have a federal right to a fair hearing under Section 1902(a)(3) of the Social Security Act and 42 CFR 431.220. It has one carve-out: no hearing is required where the sole issue is a law requiring an automatic change that hits a whole group of beneficiaries.Office of the Law Revision Counsel, U.S. House of Representatives. (n.d.). 42 USC 1396a(a)(3) — State plans for medical assistance (uscode.house.gov, prelim/rolling edition). uscode.house.gov. Retrieved Aug 1, 2026, from https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title42-section1396a&num=0&edition=prelim Federal law caps the request window at 90 days from the notice's mailing, a ceiling on what a state may allow rather than a floor, so go by the date on your own notice.U.S. Government Publishing Office. (n.d.). 42 CFR 431.221(d) — Request for a hearing (eCFR, current). ecfr.gov. Retrieved Aug 8, 2026, from https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-431/subpart-E/section-431.221 In Colorado, a member requests a "state fair hearing" before an administrative law judge at the Colorado Office of Administrative Courts (OAC), not HCPF. HCPF states that you generally have 60 days from the date on your Notice of Action, and tells members to follow the directions and deadlines in their own letter. You can file the OAC's Request for State Level Hearing form, write a letter, email oac-gs@state.co.us, fax 303-866-5909, or call the OAC at 303-866-5626. Ask for an expedited hearing if waiting might put your life or health at risk.U.S. Government Publishing Office. (n.d.). 42 CFR 431.230 — Maintaining services (continuation of benefits pending a Medicaid fair hearing), eCFR current. ecfr.gov. Retrieved Sep 4, 2026, from https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-431/subpart-E/subject-group-ECFR8ec5a6d55a4bb59/section-431.230
In managed care, a benefit or service decision by your health plan goes through the plan-level appeal first; only after an adverse plan decision may you ask the OAC for a state fair hearing. The two plans named in Health First Colorado's own appeals materials are Denver (Elevate) Health Medicaid Choice and Rocky Mountain Health Plan Prime.U.S. Government Publishing Office. (n.d.). 42 CFR 431.230 — Maintaining services (continuation of benefits pending a Medicaid fair hearing), eCFR current. ecfr.gov. Retrieved Sep 4, 2026, from https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-431/subpart-E/subject-group-ECFR8ec5a6d55a4bb59/section-431.230
The judge's decision is not the last word. The ALJ usually rules within 20 days, in a Notice of Initial Decision that HCPF defines as expressly not final. If you disagree, you have 18 days from receiving it to file written exceptions with HCPF's Office of Appeals, which then issues the Final Agency Decision. Treat the initial decision as final and you lose that window.U.S. Government Publishing Office. (n.d.). 42 CFR 431.230 — Maintaining services (continuation of benefits pending a Medicaid fair hearing), eCFR current. ecfr.gov. Retrieved Sep 4, 2026, from https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-431/subpart-E/subject-group-ECFR8ec5a6d55a4bb59/section-431.230
Keeping coverage during the appeal. Federal law continues benefits ("aid paid pending") when you request the hearing before the action takes effect.U.S. Government Publishing Office. (n.d.). 42 CFR 431.230 — Maintaining services (eCFR, current/rolling edition). ecfr.gov. Retrieved Aug 3, 2026, from https://www.ecfr.gov/current/title-42/section-431.230 In Colorado this covers a renewal termination and a previously authorized service being reduced or stopped, and in either case only if your request lands inside a 10-day window. For a state or county eligibility decision, the OAC must receive the request no later than 10 days after the date of action, which HCPF defines as the date the termination or reduction takes effect, not the date on the letter. For a health plan's decision, contact the plan within 10 days of the date on its letter; if you lose that appeal, the OAC must receive your hearing request within 10 days of the plan's final decision. A denied first-time applicant may appeal but gets no continuation, nor does someone denied a new benefit or service.U.S. Government Publishing Office. (n.d.). 42 CFR 431.230 — Maintaining services (continuation of benefits pending a Medicaid fair hearing), eCFR current. ecfr.gov. Retrieved Sep 4, 2026, from https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-431/subpart-E/subject-group-ECFR8ec5a6d55a4bb59/section-431.230 If you are a few days late, ask anyway: 42 CFR 431.231(a) lets the agency reinstate services when you request a hearing within 10 days of the date of action. And where the state acted without the advance notice it owed you, reinstatement is not discretionary: 42 CFR 431.231(c) says it must reinstate if you request a hearing within 10 days of receiving the notice (receipt counts as 5 days after the notice date) and the action did not come from applying federal or state law.U.S. Government Publishing Office. (n.d.). 42 CFR 431.230 — Maintaining services (eCFR, current/rolling edition). ecfr.gov. Retrieved Aug 3, 2026, from https://www.ecfr.gov/current/title-42/section-431.230 If the action is upheld, the state may recoup the cost of services furnished solely because benefits continued.U.S. Government Publishing Office. (n.d.). 42 CFR 431.230 — Maintaining services (eCFR, current/rolling edition). ecfr.gov. Retrieved Aug 3, 2026, from https://www.ecfr.gov/current/title-42/section-431.230 Colorado Medicaid appeals and fair hearings goes deeper.
Members who declare U.S. citizenship or a satisfactory immigration status the state cannot promptly verify get a reasonable opportunity period (generally 90 days, starting 5 days after the notice date) during which they keep coverage while producing documentation, if otherwise eligible. The state may not cap how many such periods you get.U.S. Government Publishing Office. (n.d.). 42 CFR 435.956(a)(5)(ii) — no delay, denial, reduction, or termination during the reasonable opportunity period (eCFR, current text). ecfr.gov. Retrieved Sep 4, 2026, from https://www.ecfr.gov/current/title-42/section-435.956
What goes wrong: a renewal scenario
An illustrative composite, not a real individual.
A missed packet, worked end to end
90-day reconsideration after a move?
A member moves in August; the packet goes to the old address and comes back. It is re-mailed, she loses track of it during a family emergency, and her case closes at the end of October. In mid-November a pharmacy tells her she has no coverage. She calls the Member Contact Center, learns about the 90-day window, and submits the form in December, inside 90 days of closure. She stayed eligible throughout, so reconsideration puts her back on without a new application. Had she missed the 90 days she would have had to reapply through PEAK, and the 2026 federal default would reach back only to the third month before that application.Office of the Law Revision Counsel, U.S. House of Representatives. (n.d.). 42 U.S.C. 1396a(a)(34) — Office of the Law Revision Counsel, U.S. Code. uscode.house.gov. Retrieved Jun 22, 2026, from https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title42-section1396a&num=0&edition=prelim
Procedural vs eligibility-based termination
This decides whether you get a 90-day reconsideration or must reapply.U.S. Government Publishing Office. (2026). 42 CFR 435.916(a)(3)(iii) — 90-day reconsideration without a new application, and (b) making (a)(3) permissive for non-MAGI beneficiaries (eCFR versioner API, title 42 issue date 2026-08-13). ecfr.gov. Retrieved Sep 21, 2026, from https://www.ecfr.gov/current/title-42/section-435.916
| Termination type | What it means | Reconsideration? |
|---|---|---|
| Procedural | You did not return the renewal form, missed a signature, or did not respond to a request for information | Yes for MAGI-based eligibility, 90 days from the termination date; a state option for non-MAGI groups |
| Eligibility-based | HCPF determined you no longer meet income, assets, residency, citizenship, or a categorical rule | No, file a new application or appeal |
Read your notice: "failure to provide requested information" points to the 90-day window; an income or asset calculation, or a categorical change, points to a new application, an appeal, or both.
What changes after 2026: six-month renewals
The pandemic-era unwinding is over; a new federal change is what matters now. Section 71107 of the 2025 budget-reconciliation law (H.R.1, Public Law 119-21) requires states to redetermine once every 6 months instead of every 12 for the ACA expansion-adult population, for renewals scheduled on or after January 1, 2027. Its only exemption covers an Indian or Urban Indian as defined in the Indian Health Care Improvement Act, a California Indian, and anyone otherwise determined eligible as an Indian for the Indian Health Service.Office of the Law Revision Counsel, U.S. House of Representatives. (n.d.). 42 U.S.C. 1396a(e)(14)(L) — codified prelim text, Office of the Law Revision Counsel, U.S. House. uscode.house.gov. Retrieved Aug 7, 2026, from https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title42-section1396a&num=0&edition=prelim Colorado adopted expansion, so its expansion-adult group (ages 19-65, at an effective 138% FPL) renews every six months from 2027.Centers for Medicare & Medicaid Services. (n.d.). Medicaid.gov — Medicaid, Children's Health Insurance Program, & Basic Health Program Eligibility Levels. medicaid.gov. Retrieved Jul 15, 2026, from https://www.medicaid.gov/medicaid/national-medicaid-chip-program-information/medicaid-childrens-health-insurance-program-basic-health-program-eligibility-levels HCPF has said who is not moving, and it covers most readers of this page: children 18 and under, adults 65 and older, pregnant and postpartum members, parents and caretaker relatives at or below 68% FPL, members on HCBS waivers or other long-term services and supports, buy-in members, members qualifying on blindness or disability, members with Medicare, former foster youth through 26, and American Indian and Alaska Native members. Anyone already approved for a full 12 months before January 2027 keeps that renewal date.Office of the Law Revision Counsel, U.S. House of Representatives. (n.d.). 42 U.S.C. 1396a(e)(14)(L) — codified prelim text, Office of the Law Revision Counsel, U.S. House. uscode.house.gov. Retrieved Aug 7, 2026, from https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title42-section1396a&num=0&edition=prelim
The same law separately excuses a longer list of people from its new community-engagement (work) requirement, including anyone medically frail or the parent or caretaker relative of a dependent child 13 and under. A work-requirement exemption is not a renewal exemption: as HCPF puts it, a member can be exempt from work requirements and still renew every 6 months.Office of the Law Revision Counsel, U.S. House of Representatives. (n.d.). 42 U.S.C. 1396a(e)(14)(L) — codified prelim text, Office of the Law Revision Counsel, U.S. House. uscode.house.gov. Retrieved Aug 7, 2026, from https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title42-section1396a&num=0&edition=prelim
The same law also shortens retroactive eligibility for applications filed on or after January 1, 2027, to two months before the application month for most enrollees and one month for the expansion group, down from the three-month default. A state's own window can be shorter than the federal default under a Section 1115 demonstration, so confirm Colorado's with HCPF.Office of the Law Revision Counsel, U.S. House of Representatives. (n.d.). 42 U.S.C. 1396a(a)(34) — Office of the Law Revision Counsel, U.S. Code. uscode.house.gov. Retrieved Jun 22, 2026, from https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title42-section1396a&num=0&edition=prelim The renewal packet remains the failsafe: one left unanswered still closes a case even when the person qualifies.
Common Colorado Medicaid recertification mistakes
- Ignoring the packet because it looks like junk mail. Open anything from Health First Colorado, HCPF, PEAK, or your county office.
- Assuming ex parte will handle everything. When it fails, the packet has to come back by the deadline printed on the form.U.S. Government Publishing Office. (2026). 42 CFR 435.916(a)(3) and (b) — renewal form, 30-day response window, and the permissive adoption of (a)(3) for non-MAGI beneficiaries (eCFR versioner API, title 42 issue date 2026-08-13). ecfr.gov. Retrieved Sep 21, 2026, from https://www.ecfr.gov/current/title-42/section-435.916
- Missing the asset-verification signature on an aged, blind, or disabled case. Without it the state cannot run the required asset check, and refusing or revoking the authorization is a ground for finding you ineligible.Office of the Law Revision Counsel, U.S. House of Representatives. (n.d.). 42 U.S.C. 1396w (SSA §1940) — Asset verification through access to information held by financial institutions: the mandate, the aged/blind/disabled population, where it applies, the authorization's duration, the revocation right and its consequence (uscode.house.gov, prelim/rolling current edition). uscode.house.gov. Retrieved Sep 4, 2026, from https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title42-section1396w&num=0&edition=prelim
- Assuming children lose coverage when a parent does. Children under 19 keep their full 12-month period regardless of family income.Office of the Law Revision Counsel, U.S. House of Representatives. (n.d.). 42 U.S.C. 1396a(e)(12) - State plans for medical assistance (uscode.house.gov, prelim rolling edition). uscode.house.gov. Retrieved Aug 3, 2026, from https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title42-section1396a&num=0&edition=prelim
- Missing the 10-day window to keep coverage during an appeal. Request the hearing before the action takes effect.U.S. Government Publishing Office. (n.d.). 42 CFR 431.230 — Maintaining services (eCFR, current/rolling edition). ecfr.gov. Retrieved Aug 3, 2026, from https://www.ecfr.gov/current/title-42/section-431.230
Frequently Asked Questions
How often do I have to renew Colorado Medicaid?
At least once every 12 months, in the same month each year, set by your approval date. For aged, blind, and disabled coverage 42 CFR 435.916 sets a minimum, so a review can come sooner.U.S. Government Publishing Office. (2026). 42 CFR 435.916 — Periodic renewal of Medicaid eligibility (eCFR versioner API, title 42 issue date 2026-08-13). ecfr.gov. Retrieved Sep 21, 2026, from https://www.ecfr.gov/current/title-42/section-435.916 The ACA expansion-adult group moves to a 6-month cycle for renewals scheduled on or after January 1, 2027.Office of the Law Revision Counsel, U.S. House of Representatives. (n.d.). 42 U.S.C. 1396a(e)(14)(L) — codified prelim text, Office of the Law Revision Counsel, U.S. House. uscode.house.gov. Retrieved Aug 7, 2026, from https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title42-section1396a&num=0&edition=prelim
What happens if I miss my Colorado Medicaid renewal deadline?
Coverage closes at the end of your renewal month. If the closure was procedural, returning the renewal within 90 days gets your eligibility reconsidered without a new application. That is federally required for MAGI-based eligibility and a state option for non-MAGI groups.U.S. Government Publishing Office. (2026). 42 CFR 435.916(a)(3)(iii) — 90-day reconsideration without a new application, and (b) making (a)(3) permissive for non-MAGI beneficiaries (eCFR versioner API, title 42 issue date 2026-08-13). ecfr.gov. Retrieved Sep 21, 2026, from https://www.ecfr.gov/current/title-42/section-435.916 Miss the 90 days and you must reapply through Colorado PEAK.
Where do I renew Health First Colorado?
Online at Colorado PEAK (peak.my.site.com) is fastest, and lets you upload documents and check status. You can also call the Member Contact Center at 1-800-221-3943, or renew in person or by mail at your county human services office.Centers for Medicare & Medicaid Services. (2026). CMS CMCS Informational Bulletin — Updated 2026 SSI and Spousal Impoverishment Standards (April 27, 2026). medicaid.gov. Retrieved Jul 30, 2026, from https://www.medicaid.gov/federal-policy-guidance/downloads/cib04272026.pdf
My child is on Medicaid. If my income rises mid-year, does my child lose coverage?
No. Under federal rules effective January 1, 2024, children under 19 have 12 months of continuous eligibility from enrollment, so your child keeps coverage until the next annual renewal even if income rises.Office of the Law Revision Counsel, U.S. House of Representatives. (n.d.). 42 U.S.C. 1396a(e)(12) - State plans for medical assistance (uscode.house.gov, prelim rolling edition). uscode.house.gov. Retrieved Aug 3, 2026, from https://uscode.house.gov/view.xhtml?req=granuleid:USC-prelim-title42-section1396a&num=0&edition=prelim Exceptions: turning 19, leaving Colorado, death, voluntary disenrollment, or fraud.
Can I appeal if my renewal is denied?
Yes. Federal law caps the request window at 90 days from the notice's mailing, but HCPF states you generally have 60 days from the date on your Notice of Action to ask the Office of Administrative Courts for a state fair hearing.U.S. Government Publishing Office. (n.d.). 42 CFR 431.230 — Maintaining services (continuation of benefits pending a Medicaid fair hearing), eCFR current. ecfr.gov. Retrieved Sep 4, 2026, from https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-C/part-431/subpart-E/subject-group-ECFR8ec5a6d55a4bb59/section-431.230 Request it within 10 days of the date of action and your coverage continues pending the decision.U.S. Government Publishing Office. (n.d.). 42 CFR 431.230 — Maintaining services (eCFR, current/rolling edition). ecfr.gov. Retrieved Aug 3, 2026, from https://www.ecfr.gov/current/title-42/section-431.230
Colorado Medicaid renewal contacts
These offices help you renew, recover coverage lost in the last 90 days, or appeal.healthfirstcolorado.gov. (n.d.). Health First Colorado (Colorado's Medicaid Program) - official member site. Retrieved Jul 9, 2026, from https://www.healthfirstcolorado.gov/,cdhs.colorado.gov. (n.d.). Aging and Disability Resources for Colorado - Colorado Department of Human Services. Retrieved Jul 17, 2026, from https://cdhs.colorado.gov/our-services/older-adult-services/state-unit-on-aging/aging-and-disability-resources-for-colorado
To confirm your renewal was processed, check your case status in Colorado PEAK or call 1-800-221-3943.healthfirstcolorado.gov. (n.d.). Health First Colorado (Colorado's Medicaid Program) - official member site. Retrieved Jul 9, 2026, from https://www.healthfirstcolorado.gov/ Brevy's guides to how to apply, income limits, and long-term care cover the rules you confirm at renewal.
Learn More
Find personalized help renewing your Colorado Medicaid coverage at brevy.com.
The information on Brevy.com is for educational purposes only and is not a substitute for professional legal, financial, or medical advice. Rules vary by state and program and change frequently. Always verify with the relevant agency or a qualified professional. Brevy is not a law firm, financial advisor, or healthcare provider.
Still have questions?
Brevy answers from this guide and every other guide here, and can check what you qualify for.