Nov. 3, 2023

Public Health Emergency Planning header

Covid-19 Public Health Emergency (PHE) Unwind 

Colorado has resumed regular eligibility reviews for people with Health First Colorado (Colorado's Medicaid program) and Child Health Plan Plus (CHP+) after a 2+ year pause during the COVID-19 public health emergency (PHE). 

PHE Unwind Reporting

Health Care Policy & Financing (HCPF) released its fifth month of renewal information, for members whose coverage anniversary date was in September 2023. The unwinding data report for the September 2023 renewal period is live on the Continuous Coverage Unwind Data Reporting page

In September, Colorado implemented two projects to reduce procedural denials that impact September PHE Unwind Data. The first is a 60-calendar-day extension to complete the renewal process for vulnerable populations, including long-term care (LTC) members on waivered services, and buy-in recipients who have not returned their renewal packet on time during COVID unwind. The second is a change to how the ex parte process occurs and reinstatement of members who previously lost coverage, reflecting updated guidance from Centers for Medicare & Medicaid Services (CMS). Specifically, CMS has asked states to execute the automation of eligibility renewals (ex parte) based on each individual’s information instead of the household’s information, a change from how it’s been done in years past. HCPF paused terminations of members who did not return their renewal packets in September while implementing a system change to comply with the CMS-directed ex parte change. The system change went into effect in mid-October. These two projects resulted in an increase in pending renewals and a decrease in procedural terminations.

The information posted is point-in-time data about renewals as required by federal reporting requirements and does not include all the new members coming into the program or those who will take action during the 90-day reconsideration period. Members can resume coverage if they still qualify by returning their renewal packet and any missing information to their county for processing within 90 days of losing coverage. Based on pre-pandemic information, on average, about half of the members who had lost eligibility were deemed eligible for Medicaid again within two years.

Ex Parte Change & Reinstatements

Instead of renewing members through ex parte at the household level, we will now be performing ex parte at the individual level and reinstating coverage for members who were eligible but disenrolled between May and August because their household did not properly complete and submit the required renewal packet. Members eligible to have their coverage reinstated have been sent a letter.

A separate reinstatement memo will be issued for regional accountable entities (RAEs) and managed care organizations (MCOs). Guidance for providers will be issued via provider bulletin regarding ex parte reinstatements and guidance on resubmitting claims.

HCPF began doing ex parte at the individual level as of October 2023. This change applied to September and October renewals and every renewal month thereafter. Renewal packets will still be sent to households, but individuals within a household who are identified as eligible during ex parte will be approved instead of disenrolled even if the household fails to return their renewal packet by the deadline.

New Frequently Asked Questions (FAQs) Regarding Ex Parte

How many members will be reinstated due to the change in ex parte guidance?

We initially identified 10,044 individuals affected by this change. The number of members may change slightly once we finalize the reinstatement process.

Will HCPF be doing ex parte at the individual level by default as of October 2023?

Yes. Renewal packets will still be sent to households, but individuals within that household who are identified as eligible during ex parte will be approved instead of disenrolled if the household fails to return their renewal packet by the deadline.


When will members find out if they have coverage reinstated?

We will be sending letters to affected members the week of Oct. 30, 2023.

What does the letter to members telling them they have coverage again look like?

See a sample reinstatement letter in English and Spanish.

Why does a child/someone in a household now qualify for coverage again but another person still does not?

There are different eligibility rules for people in a household depending on their situation. For example, the income limit for children to qualify for coverage is higher than the income limit for adults. So it is possible for a child to be approved and a parent to not qualify for coverage.

Are members who were disenrolled as a result of the CMS mandated change to ex parte, but later approved and reinstated guaranteed coverage until their next renewal date? 

Reinstatement in coverage does not guarantee that adults will remain covered until their next annual renewal date. Changes in circumstances such as getting a new job may result in someone no longer qualifying for Health First Colorado or CHP+. However, this does not apply to children, pregnant or postpartum people as they are guaranteed coverage until their next renewal date regardless of changes in circumstances. If a person had coverage reinstated, but then reported changes that made them ineligible, they will receive one letter telling them that they qualify for a certain date but then no longer qualify for another date and the reasons for that. The letter will provide the dates they qualify and whether or not they currently qualify.

What should a reinstated member do if they have incurred medical expenses while they had a gap in coverage? 

If a member incurs medical bills during the time we said that members of the household were not covered, let us know so we can pay them. Members can call customer service and let them know about these bills:

  • Health First Colorado members, please call 800-221-3943 (State Relay: 711)
  • CHP+ members, please call 800-359-1991 (State Relay: 711)

Additional FAQs about the end of the continuous coverage requirement and return to regular renewal processes are in the PHE Resource Center.

PEAK Highlights and Updates

To keep you better informed of updates to PEAK, we are adding this new section to our COVID-19 PHE Unwind newsletter.

In order to make the renewal process easier to navigate on PEAK, the following new features and tools are currently available or will soon be available:

  • As of mid-October, member names were added to to-do cards. This will make it easier to understand who specifically on a case is assigned to each card, which will make it easier for PEAK users to see who has an upcoming renewal that is due.

A major goal for the PEAK team is to rebuild trust with users by using simplified, trauma-informed language and design. To that end, since October 2020, over 12,000 person hours have been dedicated to reviewing visual designs and almost all content on PEAK.

The PEAK team also continues to track analytics related to the PHE unwind, identifying pain points and on-boarding projects to address them. This includes finding ways to help county workers with renewals.

In September 2023, 67% of all the applications submitted on PEAK were renewals, and 13.1% of all Chatbot conversations were about renewals.

How can you help support members during the PHE unwind?

HCPF has developed extensive partner toolkits regarding the end of the continuous coverage requirement. Update Your Address, Understanding the Renewal Process and Take Action on Your Renewal toolkits all include resources to help members take action to keep their coverage. A new joint webpage includes partner resources and information for those who may need to transition to other health coverage.

The following toolkits have been transcreated into the top 11 languages spoken by members: Amharic, Arabic, Burmese, Chinese, Dari, Pashto, Russian, Somali, Swahili, Ukrainian, and Vietnamese


You can help us raise member awareness about the renewal process by sharing the messaging in our toolkits.


Materials in these toolkits identify key actions for members to take: updating contact information, taking action when a renewal is due, and seeking help with renewals at community or county resources when they need it. Flyers, social media messaging and graphics, website content, and other outreach tools are in the PHE Resource Center

Partners can educate themselves and their staff on the basics of the renewal process to assist members who may need help. See our Renewal Education toolkit. New Frequently Asked Questions (FAQs) about the end of the continuous coverage requirement and return to regular renewal processes have recently been added. 

Members with questions about the renewal process can learn more by visiting Health First Colorado’s renewal webpage available in English and Spanish.  

Thank you for your partnership and continued collaboration!

Scammer Alert

Scammers are targeting Health First Colorado (Colorado’s Medicaid program) and Child Health Plan Plus (CHP+) members through text messages and phone calls. They are telling members they must pay to keep or renew their health coverage. HCPF never asks members or applicants for money, bank account or credit card information, complete social security numbers, or any other financial information through text or over the phone. HCPF will contact members to ask them to update their address and contact information. Members can do this at any time online through PEAK and are not required to give this information over the phone. Please help us alert members of potential scams by sharing this important message. And report any suspected scam activity to the Attorney General Consumer Protection Unit.

PHE Unwind Partner Webinar

HCPF hosted an informational session about the end of the Continuous Coverage Requirement and the COVID-19 Public Health Emergency Unwind on Oct. 25, 2023. Thank you to those who were able to join. That presentation and recording are posted in the PHE Resource Center.

The next quarterly webinar will be held on Jan. 24, 2024, from 1 - 2 p.m. Mountain Time. Register in advance for this webinar. After registering, you will receive a confirmation email containing information about joining the webinar.

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