Policy updateIn effect

Colorado sets the date for Medicaid immigrant changes: October 1, 2026

A Colorado memo says the immigrant eligibility changes started October 1, 2026. Adults who no longer qualify do not keep coverage until renewal.

· Colorado · This is already in effect.

Colorado has set the exact date for the federal change to which immigrants can get Health First Colorado (Colorado Medicaid). It took effect October 1, 2026. Adults who no longer qualify do not keep their coverage until their next renewal.

What's changing

The Colorado Department of Health Care Policy and Financing (HCPF) issued Operational Memo OM 26-063 on October 19, 2026. It puts in place the federal H.R. 1 change to who counts as a "qualified alien" for Health First Colorado. That is the legal term the memo uses.

The memo does three things:

  • It sets the effective date: October 1, 2026.
  • It tells eligibility sites that members who no longer qualify do not keep coverage until their next renewal.
  • It tells sites to check other programs first. Before ending anyone's coverage, a site must check if the person qualifies for Emergency Medicaid Services (EMS), Reproductive Health Care Services (RHCS), or Cover All Coloradans.

The memo says:

"existing eligibility will not continue through the member's next renewal period"

That is from HCPF Operational Memo OM 26-063.

Who it affects (and who it doesn't)

This affects adults in the groups that were removed, including:

  • Refugees and asylees
  • Parolees, including certain people granted humanitarian parole
  • Trafficking survivors
  • People who applied for a green card but are not yet lawful permanent residents (LPRs)

These groups keep full Health First Colorado:

  • Lawfully present children 18 and younger
  • Lawfully present pregnant members, and members in the 12 months after pregnancy
  • Lawful permanent residents who meet the five-year rule or an exemption
  • Compact of Free Association (COFA) migrants
  • Certain Cuban or Haitian entrants
  • U.S. citizens

These rules apply person by person. In one family, a parent could lose full coverage while the children keep theirs.

Key dates

  • October 1, 2026: The changes took effect.
  • October 19, 2026: HCPF issued the memo.

What you can do

  1. If an adult in your home is in one of the removed groups, apply for Emergency Medicaid Services (EMS) and Reproductive Health Care Services (RHCS). The memo encourages this. It also says a person can ask for EMS at any time, even after October 1, 2026.
  2. Open every letter from Health First Colorado or your county right away. Keep a copy.
  3. If a child 18 or younger, or a pregnant member, gets a notice ending full coverage because of immigration status, call and ask about it. The memo says they keep full coverage. Look on the notice for your appeal rights and deadline.
  4. If an adult in your home gets waiver services and is in one of the removed groups, talk to your case manager now.
  5. Immigration categories are technical. A county benefits worker or an immigration attorney can help check one person's situation.

You can read the memo here: HCPF Operational Memo OM 26-063.

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Sources

  1. HCPF OM 26-063, Amended Definition of Qualified Alien - CPPM 12288 (issued October 19, 2026)Read October 26, 2026

Written by the Red Ember team from the official documents above. This is general information, not legal advice.