Jan 23, 2023

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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Unwinding Continuous Coverage

by | Jan 23, 2023

Since March 2020, Coloradans enrolled in Medicaid and Child Health Plus (CHP+) have been able to maintain their health coverage. This policy has meant fewer gaps in care, less paperwork, and more peace of mind. States kept people enrolled in exchange for the additional federal funding provided under the Families First Coronavirus Response Act, and in recognition of the benefit of health coverage in battling a public health crisis.  

Continuous coverage is nearing its end, however, with disenrollments due to resume on April 1, 2023. Every state, Colorado included, is reckoning with their ability to assess accurately and efficiently whether each enrollee meets eligibility requirements. And communities, clinics, and advocates are facing the prospect of thousands more without health coverage and the repercussions that will have on health and economic stability.  

The eligibility team at our state Medicaid agency, Health Care Policy and Financing (HCPF), deserves credit for meeting with the public about the coming renewal processes and sharing data, partnering with community organizations on a campaign to update addresses, and developing public-facing materials. 

However, major obstacles remain that could result in tens of thousands of Coloradans unnecessarily losing coverage. 


Counties will be unable to keep up with the volume of work. Our county-based eligibility system is unusual, with fewer than 10 states delegating enrollment and eligibility processing to counties.  And county-based systems are by nature less efficient and more costly, with Colorado estimated to spend about 30% more on administration of the SNAP program, for example, than states that use a centralized system, based on recent budget documents. The same is almost certainly true of Medicaid administration.  

On top of that, counties have struggled to retain and train county workers because eligibility is a tough job. It’s not easy to find staff who are able to work well with people from a range of cultures, who know the local resources, are computer savvy, and have a detailed knowledge of some ridiculously complicated programs. Reports are widespread about current county backlogs for the SNAP program, with Colorado Springs and Mesa County as two recent examples. Add Medicaid processing to that, and where will that leave counties, let alone the individuals and families that have relied on this coverage? 


Eligible Coloradans will lose coverage for the wrong reasons. People who have income sufficient for plans through Connect for Health or who have access to employer coverage can be appropriately disenrolled, but substantial numbers of people lose coverage every year because they don’t return paperwork – either because they didn’t receive it, didn’t understand it, or made errors. Other glitches may occur for people with disabilities, whose cases require extra time and coordination between counties and case management entities.  

Those who get dropped from Medicaid despite low incomes or disability may end up returning to coverage when they have a crisis. While uninsured, though, they are much less likely to get the care they need, whether that’s behavioral health services or blood pressure medication.  

The systems and processes Colorado uses to manage eligibility and enrollment create their own barriers to access. Colorado’s outdated IT system, the circa 2004 Colorado Benefits Management System, is one giant obstacle to better processing, and this coming year will likely show just how costly antiquated technology can be – both in a human and a fiscal sense. Another issue is a renewal packet that is not postage paid, as in other states. And, as CCLP has long advocated, there are major issues with Colorado’s returned mail policies and processing, which fail to incorporate some recommended practices for updating addresses, a particularly burdensome challenge for people who have unstable housing, as well as low-income renters who struggle to maintain an address. 

 There is no way to make the unwinding easy. Colorado’s leadership needs to be ready to pause processes if counties are unable to keep up with processing, if error rates are high, and if particular populations experience harm. It will be essential that HCPF continue to share information, ideally through an updated dashboard that includes geographical and demographic information, so that localities, providers, and advocates may identify the trouble spots. This is an all-hands-on-deck situation, and CCLP promises to update regularly as the process begins and we learn more.  


For more information, click here for our Continuous Coverage and the Public Health Emergency Fact Sheet. 

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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.