Larimer County Medicaid Recipients Face Eligibility Overhaul: Twice-Yearly Reviews, Work Requirements

Nearly 28,000 Larimer County residents on Medicaid expansion will face eligibility reviews every six months instead of annually starting January 1, 2027, while also navigating new work requirements that county officials warn could cause widespread coverage loss due to administrative complexity.

The changes target Colorado's Medicaid expansion population—primarily working-age adults without dependent children—who gained coverage when the state expanded eligibility to 138 percent of the federal poverty level in 2014. Larimer County Human Services Director Heather O'Hare told county commissioners November 3 that the expansion group represents approximately 28,000 of roughly 70,000 county residents receiving Medicaid.

The federal HR1 legislation requires Medicaid expansion recipients ages 19 to 64 to complete 80 hours monthly of work, job training, volunteering or other community engagement activities to maintain health coverage. The law also mandates states conduct eligibility redeterminations every six months rather than annually for this population.

"We are going to go from 27,000 redeterminations a year for this population to 54,000 within the same staffing and resources," O'Hare said. "It is still a really significant increase in the administrative workload."

Work Requirements Mirror SNAP Rules

The 80-hour monthly threshold mirrors work requirements already in place for SNAP food assistance, though with critical differences in application. For Medicaid, recipients must meet the work requirement before accessing coverage, unlike SNAP which allows 90 days to comply after enrollment.

County officials are still awaiting detailed federal guidance on how Colorado's higher minimum wage affects the calculation. Federal regulations base the requirement on 80 hours at the $7.25 federal minimum wage—$580 monthly. Colorado's $15.13 minimum wage means 80 hours equals $1,210.40 monthly.

"There are unknowns as we wait for guidance to come in," said Vanessa Fuel, Division Manager with Larimer County's Benefits and Community Support Division. "We don't know how Medicaid work requirements would apply to two parent households and the age of the child."

Exemptions include pregnant women, parents with dependent children under age 14, people with disabilities, certain students and those deemed medically frail. County staff expressed concern about shifting residents from one exemption category to another as circumstances change.

Arkansas Experience Shows Coverage Loss

When Arkansas implemented similar Medicaid work requirements in 2018, over 18,000 individuals lost coverage in less than a year, primarily due to administrative complexity and reporting failures rather than actual failure to work. The state found no significant evidence of increased employment among those subject to requirements, according to Colorado Department of Health Care Policy and Financing analysis.

"The payment error rate, the payment error rate projects have multiple work streams," Fuel said, referencing concerns about documentation accuracy under increased administrative demands.

Commissioner Kristin Stevens asked about employer engagement to help recipients meet requirements, noting some businesses rely on federal benefits as de facto insurance for low-wage workers while providing insufficient hours.

"There's some community responsibility with solving this problem," Stevens said. "If people get sick or can't eat or can't get benefits, they're not going to show up to work."

County Convening Community Partners

O'Hare said the county will leverage technical assistance from the American Public Human Services Association using a collective impact model to bring together employers, workforce development, public health and other partners.

"We are prohibited from doing direct outreach for Medicaid," O'Hare said, explaining federal sanctions prevent county eligibility staff from educating the community about work requirements. "But there is another community partner likely that says, yes, I would love to do that and that fits within our mission."

The county organized community partners into two groups—those wanting regular updates and those prepared to help develop solutions—following initial outreach after an October work session. Officials scheduled an afternoon meeting November 3 to begin planning coordination efforts before the January 2027 implementation deadline.

"We're going slow initially, intentionally so that then we can ramp up as we're continuing to get more details from the state departments," O'Hare said.

Demographic Impact Across Age Groups

The Medicaid expansion population in Colorado totals 377,019 adults statewide as of 2025, representing roughly 30 percent of the state's 1.31 million Medicaid enrollees. Adults ages 19 to 64 comprise 55 percent of Colorado Medicaid recipients, according to state data.

For residents ages 54 to 64 who have left the workforce, re-entering employment to maintain health coverage presents particular challenges, O'Hare noted. The partnership between county Human Services, Economic and Workforce Development, and the Office on Aging will be crucial for developing strategies for this age group.

County officials presented four case scenarios illustrating how the changes intersect with other social services. One example showed a 61-year-old woman who would need to work or volunteer 80 hours monthly to qualify for Medicaid, with staff still awaiting federal definitions of exemptions for able-bodied adults in that age range.

Administrative Costs Unfunded

Colorado estimates administrative costs of approximately $152 per enrollee based on Arkansas data, totaling more than $57 million annually statewide to implement work requirements and semi-annual redeterminations. Counties receive federal matching funds covering 50 percent of general administrative expenses, though the rate increases to 75 to 90 percent for certain technology upgrades.

The state Department of Health Care Policy and Financing received limited guidance from the federal Centers for Medicare and Medicaid Services on Friday, November 1, according to O'Hare. Additional detailed direction is needed before counties can build the changes into eligibility systems.

Commissioner Jody Shadduck-McNally asked about state support for counties to manage the transition, noting the wide disparity in resources across Colorado's 64 counties.

"I can see one county having lots of resources to try to match this, whereas maybe a smaller county doesn't have a lot of capacity," Shadduck-McNally said.

O'Hare said counties have very different tools and data systems, even among large jurisdictions. Multiple state work groups are examining what counties already do that could reduce duplication with state quality assurance processes.

Larimer County commissioners scheduled a December 8 work session to review the governor's proposed budget, which was released November 1 and includes provisions addressing federal cost-shifting to the state.

Residents seeking information about Medicaid eligibility can contact Larimer County Human Services at 970-498-7750 or visit larimer.gov/humanservices.