Will Medicaid work requirements affect your adult child on the DD waiver? In Colorado, most likely not.

What happened

A federal law passed in 2025, known as H.R. 1, says some adults on Medicaid must show what it calls “community engagement”: work, school or volunteering. States have to start by January 1, 2027 (federal court ruling, Oct. 29).

In Colorado, the rule applies to “adults ages 19 to 64 who are not enrolled in certain programs (such as long-term services and supports [LTSS] or buy-in programs)” and who don’t qualify for an exclusion (HCPF). To meet it, a person works, studies or volunteers at least 80 hours a month. Earning at least $580 a month also counts. People in that group will also renew their coverage every six months instead of once a year (HCPF webinar, Oct. 26). HCPF estimates about 378,500 Coloradans fall in the affected group before exclusions are counted (HCPF FAQ).

Letters start now. Health First Colorado, the state’s Medicaid program, says it will notify affected members in November “through letters, texts, emails and more” (HCPF timeline).

Then, on October 29, a federal judge ruled on a lawsuit brought by Colorado and other states. The federal Medicaid agency had added an extra test to the “medically frail” exclusion: a person’s condition also had to be one that “significantly impairs the individual’s ability to comply with the community engagement requirement.” The judge set that test aside and barred the agency from applying it to the states that sued. The January 1 start date did not move (Commonwealth of Massachusetts v. Oz).

Why it matters to you

If your adult child is on the DD or SLS waiver, Colorado’s rule leaves them out. HCPF counts home and community-based waivers among its long-term services and supports programs (webinar slide 37), and people enrolled in those programs are outside the requirement. If they also get SSI or SSDI, that’s a second exclusion on HCPF’s list. Their renewal stays once a year: members in long-term services and supports “will continue with a 12-month renewal cycle” (HCPF FAQ).

If they have Medicaid but no waiver yet,look at the “medically frail” exclusion. HCPF’s list includes “people living with a physical, intellectual, or developmental disability that makes it hard to do daily activities.” In 2027, people can attest to that themselves, and it holds for one year (webinar slide 15). One caution: HCPF’s page, published September 23, still carries the extra test the judge struck down. It says the condition must prevent someone “from completing 80 hours per month of work, school, and/or volunteer activities.” Expect that wording to change. Until it does, ask your case manager.

If you’re the parent or caregiver and on Medicaid yourself,HCPF leaves out “parents, guardians, caretaker relatives, or family caregivers who care for a person of any age with a disability” (HCPF). “Any age” matters. It covers parents of grown children.

One change does reach waiver members. Medicaid can pay bills from the months before someone applies. Starting in 2027, that window shrinks from three months to two. The change covers people on home and community-based waivers and people who qualify through a disability (webinar slide 37). If someone you support is about to apply, don’t wait.

Here’s how we read it at Grace Mountain. Work can be one of the proudest parts of an adult life, and the people we serve deserve every chance at it. But Colorado’s rules don’t ask adults on the DD waiver to prove a work schedule to keep their health coverage. The real risk is the mailbox. A letter set aside, or a renewal packet never sent back, can end coverage that was never in question.

If you’re weighing where your son or daughter could live as an adult, here’s how to choose a host home agency. (New to the waivers themselves? Start with HCBS-DD vs SLS vs CES.) Grace Mountain is also beginning the process of becoming benefits specialists, learning to help the people we serve use Social Security effectively. Bring us your questions; where we don’t know yet, we’ll find out with you.

What to actually do this week

1. Ask your case manager two questions.Is my son or daughter enrolled in a waiver or other long-term services? Do they get SSI or SSDI? A yes to either means Colorado’s rule leaves them out.
2. Open every Health First Colorado letter this month. Here’s HCPF’s sample notice, so you’ll know one on sight. Think a letter got it wrong? Call your case manager or the Member Contact Center at 1-800-221-3943.
3. If you’re a caregiver on Medicaid yourself, run the screener. Health First Colorado’s work requirements screener walks through the exclusions.

One thing to skip

Skip the headlines that say people with disabilities are about to lose Medicaid. The rule is real, and it touches a lot of Coloradans. But Colorado’s list leaves out people in long-term services, people on SSI or SSDI, people whose disability makes daily activities hard, and the family members who care for them. Read your own mail. It will tell you more than the national news.

Researched with AI assistance; edited by Ian Thomson.