Jan 11, 2024

Bethany Pray currently serves as CCLP's Deputy Director. Her areas of expertise include regulatory analysis and advocacy for Medicaid and commercial coverage, access to behavioral health benefits, Medicaid eligibility and much more.Staff page ›

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The true cost of Colorado’s unaccountably high Medicaid disenrollment rates

by | Jan 11, 2024

Millions of people who relied on Medicaid during the Public Health Emergency (PHE) are now navigating renewal processes around the country. Amidst the PHE unwind, thousands of individuals and families on Medicaid and CHP+ have received notices informing them that their healthcare coverage is ending. Though the end of the PHE has resulted in increased rates of disenrollment for people across the country, Colorado’s terminations are disproportionately high, creating a crisis for those who depend on these programs for healthcare coverage.

In Colorado alone, six months into the PHE unwind, 412,102 beneficiaries have been terminated from these programs. An alarming two-thirds of these terminations are for what are termed “procedural reasons.” In other words, just one-third of the terminations have been the result of a determination that the person or family is no longer eligible for the program (for example, because the person’s income exceeds limits, or because they no longer qualify as disabled, or perhaps because they have moved out of state.)

Though Colorado is in the middle of the pack in terms of state population (ranked 21st nationally), it is near the bottom in terms of rate of procedural disenrollments — only 9 states have higher rates than Colorado, and our net loss of members ranks Colorado an astounding seventh in the nation.[1]

The administration has largely dismissed concerns about the high rate of procedural disenrollments, though these rates are anything but normal. Both before the PHE and during the unwind, Colorado has had extraordinarily high rates of procedural disenrollments. This is the result of the fallout from a glitchy IT system, chronically flawed communications, problems with contractor and county oversight, and our fragmented, county-administered system. Penny-wise and pound-foolish, the state has been slow to invest in wholesale changes and the most vulnerable Coloradans are paying the price.

When people who should have stayed on Medicaid are instead kicked off the program, they have three routes back to coverage. Typically, fewer than a thousand Coloradans have appeal hearings each year, where they can ask an administrative judge to reinstate coverage or services. Others provide missing information to the county or wait out county processing delays while uninsured and hope to be redetermined eligible.

But based on CCLP’s review of data provided to the Centers for Medicare and Medicaid Services, a great many simply reapply. Our conversations with eligibility enrollment sites and community advocates support that interpretation, that many who lose coverage and feel certain they are still eligible will fill out a new application, rather than trying to get through to their county or face an appeal without representation.

A quick comparison shows the dire state of our state. Consider Maryland and Minnesota, two states whose state and Medicaid populations are very similar to Colorado’s. Maryland and Minnesota’s application rates were fairly constant before, during and after the PHE, while Colorado’s were much higher before the continuous eligibility requirements were put into effect for the PHE, and soared again immediately after the unwind began. For some months, Colorado’s numbers totaled more than six times as many applications as Maryland’s and Minnesota’s.

Bar graph showing monthly Medicaid and CHIP applications in three states. Colorado has significantly higher applications per month. Maryland and Minnesota have lower and relatively close numbers of applications per month.

That Sisyphean loop of losing Medicaid and reenrolling is costly for counties and the state, and takes a real toll in terms of time, lost work, and stress for Medicaid members. Federal sources cite a 2015 estimate that states spend $400 to $600 dollars for each termination and re-enrollment. At that rate, 10,000 unnecessary applications per month would cost Colorado $4-6 million dollars a month, year in and year out.

The human cost is harder to calculate, but includes hours spent on the phone, waiting in county offices, gathering and uploading information, and the anxiety of not understanding where you’re going to get your next prescription or whether your scheduled surgery can take place as planned.

It doesn’t have to be this way.

In the short term, Colorado has the ability to put terminations for particular groups or larger populations on hold while the state digs into what is causing these outsized losses of coverage. That flexibility is available under special federal authority, along with other options to streamline renewals for people who utilize long-term services and supports. This would maintain coverage for vulnerable Coloradans and allow counties more time to keep up with the flood of renewals and new applications during the unwind. As we wait for longer term investments of resources in technology and enrollment assistance, it’s time to take that step to protect those that need it.


[1] Medicaid Enrollment and Unwinding Tracker, KFF, published Dec 13, 2023.

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To maintain health and well-being, people of all ages need access to quality health care that improves outcomes and reduces costs for the community. Health First Colorado, the state's Medicaid program, is public health insurance for low-income Coloradans who qualify. The program is funded jointly by a federal-state partnership and is administered by the Colorado Department of Health Care Policy & Financing.

Benefits of the program include behavioral health, dental services, emergency care, family planning services, hospitalization, laboratory services, maternity care, newborn care, outpatient care, prescription drugs, preventive and wellness services, primary care and rehabilitative services.

In tandem with the Affordable Care Act, Colorado expanded Medicaid eligibility in 2013 - providing hundreds of thousands of adults with incomes less than 133% FPL with health insurance for the first time increasing the health and economic well-being of these Coloradans. Most of the money for newly eligible Medicaid clients has been covered by the federal government, which will gradually decrease its contribution to 90% by 2020.

Other populations eligible for Medicaid include children, who qualify with income up to 142% FPL, pregnant women with household income under 195% FPL, and adults with dependent children with household income under 68% FPL.

Some analyses indicate that Colorado's investment in Medicaid will pay off in the long run by reducing spending on programs for the uninsured.


Hunger, though often invisible, affects everyone. It impacts people's physical, mental and emotional health and can be a culprit of obesity, depression, acute and chronic illnesses and other preventable medical conditions. Hunger also hinders education and productivity, not only stunting a child's overall well-being and academic achievement, but consuming an adult's ability to be a focused, industrious member of society. Even those who have never worried about having enough food experience the ripple effects of hunger, which seeps into our communities and erodes our state's economy.

Community resources like the Supplemental Nutrition Assistance Program (SNAP), formerly known as Food Stamps, exist to ensure that families and individuals can purchase groceries, with the average benefit being about $1.40 per meal, per person.

Funding for SNAP comes from the USDA, but the administrative costs are split between local, state, and federal governments. Yet, the lack of investment in a strong, effective SNAP program impedes Colorado's progress in becoming the healthiest state in the nation and providing a better, brighter future for all. Indeed, Colorado ranks 44th in the nation for access to SNAP and lost out on more than $261 million in grocery sales due to a large access gap in SNAP enrollment.

See the Food Assistance (SNAP) Benefit Calculator to get an estimate of your eligibility for food benefits.


Every child deserves the nutritional resources needed to get a healthy start on life both inside and outside the mother's womb. In particular, good nutrition and health care is critical for establishing a strong foundation that could affect a child's future physical and mental health, academic achievement and economic productivity. Likewise, the inability to access good nutrition and health care endangers the very integrity of that foundation.

The Special Supplemental Nutrition Program for Women, Infants and Children (WIC) provides federal grants to states for supplemental foods, health care referrals, and nutrition information for low-income pregnant, breastfeeding and non-breastfeeding postpartum women and to infants and children up to age five who are found to be at nutritional risk.

Research has shown that WIC has played an important role in improving birth outcomes and containing health care costs, resulting in longer pregnancies, fewer infant deaths, a greater likelihood of receiving prenatal care, improved infant-feeding practices, and immunization rates

Financial Security:
Colorado Works

In building a foundation for self-sufficiency, some Colorado families need some extra tools to ensure they can weather challenging financial circumstances and obtain basic resources to help them and their communities reach their potential.

Colorado Works is Colorado's Temporary Assistance for Needy Families (TANF) program and provides public assistance to families in need. The Colorado Works program is designed to assist participants in becoming self-sufficient by strengthening the economic and social stability of families. The program provides monthly cash assistance and support services to eligible Colorado families.

The program is primarily funded by a federal block grant to the state. Counties also contribute about 20% of the cost.


Child care is a must for working families. Along with ensuring that parents can work or obtain job skills training to improve their families' economic security, studies show that quality child care improves children's academic performance, career development and health outcomes.

Yet despite these proven benefits, low-income families often struggle with the cost of child care. Colorado ranks among the top 10 most expensive states in the country for center-based child care. For families with an infant, full-time enrollment at a child care center cost an average of $15,140 a year-or about three-quarters of the total income of a family of three living at the Federal Poverty Level (FPL).

The Colorado Child Care Assistance Program (CCCAP) provides child care assistance to parents who are working, searching for employment or participating in training, and parents who are enrolled in the Colorado Works Program and need child care services to support their efforts toward self-sufficiency. Most of the money for CCCAP comes from the federal Child Care and Development Fund. Each county can set their own income eligibility limit as long as it is at or above 165% of the federal poverty level and does not exceed 85% of area median income.

Unfortunately, while the need is growing, only an estimated one-quarter of all eligible children in the state are served by CCCAP. Low reimbursement rates have also resulted in fewer providers willing to accept CCCAP subsidies.