Annie Martínez provided testimony in strong support of Senate Bill 26-176, which would have allowed Coloradans to hold federal actors accountable in constitutional rights violations.
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Skills2Compete CO testifies in support of older workers
Chaer Robert provided testimony on behalf of Skills2Compete Colorado on House Bill 26-1010, Older Adult Support & Representation in the Workforce, which would increase participation, representation, and support for older adults in the workforce, beginning at 55 years of age.
CCLP testifies on reducing administrative burden on the health care industry
Bethany Pray provided testimony on Senate Bill 26-138, Reducing Administrative Burdens on Health Care. CCLP is in an amend position because we prioritize reducing administrative and economic burdens for patients.
CCLP public comment on housing assistance for mixed status families
A public comment was submitted by Chris Nelson, MSW, on behalf of CCLP on April 20, 2026, to the U.S. Department of Housing and Urban Development, regarding housing assistance for mixed status families.
CCLP Public Comment on HHS Notice of Benefit and Payment Parameters

The following public comment was submitted by Bethany Pray, Esq. on behalf of CCLP on March 13, 2026, to the U.S. Department of Health and Human Services, regarding HHS Notice of Benefit and Payment Parameters. For more information see the proposed rule on the Federal Register.
Re: RIN 0938-AV62; CMS-9883-P
Patient Protection and Affordable Care Act, HHS Notice of Benefit and Payment Parameters for 2027; and Basic Health Program
The Colorado Center on Law and Policy (CCLP) is a state-based, anti-poverty organization that advocates for the rights of all Coloradans. Our mission includes improving access to affordable, quality health care for Coloradans and furthering the rights of Coloradans to access public programs for which they are eligible. CCLP appreciates the opportunity to submit comments regarding the proposed rule, entitled Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2027; and Basic Health Program (hereafter referred to as 2027 NBPP.[1] The text of this comment, as well as the text of all references identified in the body or footnotes of this document, should be considered part of the official record and considered prior to finalization of the proposed rule.
The Department of Health and Human Services (HHS) has proposed an expansive set of policies with a shortened comment period and has done so months later than is customary. The voluminousness of the proposed rule, the number of individual policy changes proposed, and the shorter-than-typical comment period are significant barriers to stakeholder engagement. At a minimum, we request that implementation be delayed until 2028. The better course would be for HHS to withdraw the rule, to allow time for a more reasoned and appropriately supported set of policies to be proposed.
Policies contained in the proposal are overall untested, unsupported and impossible to evaluate based on information provided. Where slightly more support is offered, it is clear that the rule would impose enormous administrative burdens on states, state exchanges, carriers and people seeking coverage, interfering with efficient administration of the exchange, de-stabilizing insurance markets, removing many thousands from affordable coverage they need to maintain their health, and throwing a bewildering range of changes at people seeking affordable coverage. The amount of change that would be imposed through this rule on states, exchanges and carriers would be disruptive, at best.
In many respects, the rule repeats errors in process that resulted in court action on the 2025 PPACA Marketplace Integrity and Affordability rule. As described below, in the 2027 NBPP, HHS has failed to consider important aspects of the problem, has offered explanations for its proposals that run counter to the evidence or that lack evidence. City of Columbus v. Kennedy.[2]
Because time to comment was inadequate, the following comment is necessarily limited. Had adequate time been permitted, there is more we would have liked to share about impacts on Colorado and nationally. As a result, we note our opposition to many other provisions, including those on Pre-Enrollment SEP Verification (§ 155.420(g)) (also barred by the court’s stay in City of Columbus v. Kennedy) and State Exchange Improper Payment Measurement (SEIPM) (§§ 155.1600-155.1650), but lack capacity and time to outline and document the basis of our opposition.
Read the full Public Comment here.
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[1] U.S. Dep’t. Health & Human Srvs., Patient Protection and Affordable Care Act, HHS Notice of Benefit and Payment Parameters for 2027; and Basic Health Program, 91 Fed. Reg. 6292 (proposed Feb. 11, 2026), https://www.govinfo.gov/content/pkg/FR-2026-02-11/pdf/2026-02769.pdf (hereinafter “2027 NBPP”).
[2] Memorandum Opinion, Aug. 22, 2025, pp. 10-11. Case 1:25-cv-02114-BAH.
