Your Voice Can Shape How This Works
Updated July 2026
Beginning January 2027, Medicaid expansion members must document 80 hours a month of qualifying activities to keep their coverage. Prime Health is collaborating with members and technology users to support the design of systems that works for real people.
Applications for the M-PAI Challenge have now closed
What Prime Health Is Doing
Prime Health is leading a statewide, multi-phase initiative to help shape Colorado’s technology system, centering the voices of the people most affected.
Our efforts include:
Ideation Workshops. Gathering direct input from Medicaid members, community organizations, and partners to surface real needs and inform system design
Comprehensive resources. Ensuring members and organizations have clear, accessible information about what's changing and what to do
Colorado Medicaid Participatory Action Incubator (MPAI) Challenge. A structured competition to identify, develop, and pilot the best technology solutions for tracking and verifying work requirement hours.
Ongoing engagement. Feedback loops and convenings throughout implementation to keep solutions grounded in community experience
What We’ve Done and What’s Next
September 2025: United ~100 innovators, policymakers, community partners, and Medicaid members in a full-day design sprint to yield recommendations for building a compliance system
October 2025: Hosted a follow-on session to align on priorities and set the agenda for the work ahead
February – May 2026: Conducting workshops to gather input from members, organizations, and partners to inform system and technology design
Spring/Summer 2026: Kick off MPAI Challenge for technology companies to develop tools that help members track and verify work requirement hours, built on community input from the ground up.
How To Get Involved
Updates coming soon!
Why Prime Health
Prime Health has a proven track record of bringing Colorado’s health innovation ecosystem together to solve hard problems. This initiative builds on that history, moving with urgency, centering equity, and keeping the people most affected at the table from start to finish.
We’ve been in the room since before the ink dried on H.R. 1, and we'll be there through implementation.
Ideation Workshop Reports
The purpose of the MPAI Discovery Phase Reports is to elevate the concerns, desires, and recommendations of those in each user group based on their life experience and expertise. The recommendations in these reports have not been edited for feasibility in terms of technology, accessibility, or state and/or federal compliance.
Potential solutions for tracking and verifying Medicaid Community Engagement (Work) Requirements will be evaluated for implementation feasibility as part of the MPAI Challenge and Vet and Validate Phase.
Job Training Organizations
RAEs
Providers and Clinics
Final Report
Discovery Phase Recommendations
Public Comment to Centers for Medicare & Medicaid Services
In response to the release of the Interim Final Rule: Medicaid Program; Community Engagement Requirements for Certain Individuals, using the information gathered through workshops and identified in reports, Prime Health created the following document as a public comment submitted to CMS: Comments on CMS-2454-IFC
Communicators
Medicaid Members
Counties
Volunteer Organizations
Theory of Change
IF
Medicaid members, data validators (employers, volunteer orgs, education, etc), data users and trusted supports are meaningfully engaged as co-designers of technology
+
THEN
Medicaid work requirement systems will better reflect community concerns, constraints, workflows and equity considerations
+
Technology solutions shared by life experience and operation realities are more usable, accessible and less likely to cause unintended harm
BECAUSE
RESULTING IN
Reduced administrative burden for Medicaid members, improved data accuracy and interoperability between state and local organizations, decrease inappropriate disenrollment because of WR data, more equitable access to care
State Medicaid policies and systems that are more humane, effective and aligned with community needs which in turn strengthens trust in public systems and improved health outcomes
LONG TERM IMPACTS:
What You Need to Know
Below is a summary of key requirements and exemptions as currently outlined by HCPF and CMS.
Qualifying Activities:
80 hours per month of work, community service, and/or “work program” participation
Enrolled in education at least half of time
Any combination of minimum wage multiplied by 80 hours
Seasonal workers with an average monthly income over 6 months of minimum wage multiplied by 80 hours
Exemptions:
Children under 19 or adults 65 and older
Individuals enrolled in a state disability program or determined to be medically frail
Native American or Alaskan American residents
Pregnant people
Parents or caregivers of children ages 13 and under or disabled individuals
Veterans with total disability ratings
Individuals participating in substance abuse treatment programs
Individuals already meeting work requirements for TANF or SNAP
Hardship exceptions will be available but this is outside of Prime Health’s scope or work and will be handled by the State. Check out our FAQs below to learn more.
Frequently Asked Questions
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Prime Health is a nonprofit health innovation organization that brings together Medicaid members, community partners, and technology builders to ensure the system built actually works for the people it’s meant to serve.
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Prime Health has spent years building the relationships, infrastructure, and trust needed to do exactly this kind of work. When a problem this complex shows up, we’re the organization Colorado turns to.
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Everything we hear goes directly into the design process for the PAI Challenge. Members and organizations will have ongoing opportunities to review and respond to solutions as they're developed, not just at the front end.
For information on the Medicaid work requirements, visit healthfirstcolorado.com and hcpf.colorado.gov/impact.
Questions?
Reach out to admin@primehealthco.com and check back for updates.
