Lessons from the Public Health Emergency Unwind in Colorado

Lessons from the Public Health Emergency Unwind in Colorado

by Karly Kaufman| Feb 17, 2026

Community Insight, Equity work, Health, Legal Advocacy, Public Utilities, Research and Policy Analysis, Resources

CCLP Legal Director Katherine Wallat, Esq., summarizes how CCLP addressed the disenrollment crisis. The case study covers how CCLP identified the problem, the role of community engagement finding systemic issues, the impact on thousands of Coloradans' access to care, and long-term positive outcomes.

In May 2023, the COVID-19 Public Health Emergency (PHE) officially ended, and Colorado was required to review the eligibility of the 1.8 million Coloradans who had enrolled in Medicaid during the pandemic.

Unfortunately, this was easier said than done. Some of the 64 counties responsible for determining eligibility were already behind in their processing of public benefits before this eligibility review began. Additionally, the technology systems they relied on had been plagued with errors for years.

We at CCLP recognized these unique challenges and sought to ensure we were gathering information from community advocates during this process. Through recurring meetings with Medicaid enrollment assisters and disability advocates around the state, CCLP helped identify systemic issues as they arose. Together with data gathered from Open Records Act requests and national sources, CCLP advocated directly with the state's Medicaid agency, the Colorado Department of Health Care Policy & Financing (HCPF), to institute changes aimed at keeping vulnerable populations enrolled.

As Colorado struggled under the strain of eligibility renewals, the number of people being disenrolled from their coverage reached a crisis point. CCLP expanded its advocacy to include a wider range of stakeholders, including county workers, providers, and eventually, legislators. Together with the National Health Law Program, CCLP filed a complaintwith the Office of Civil Rights in February 2024 about the discriminatory treatment of people with disabilities. This complaint resulted in media coverage, alerted state and federal agencies to the alarming issues Coloradans were facing, and helped change HCPF's approach to the crisis.

In December, CCLP published its report on the PHE unwind, including outlining the key lessons we learned in how best to approach statewide system changes through this work:

1. Diverse stakeholder engagement, directly with the communities affected by proposed changes, should take place as early and consistently as possible.
2. The state must engage in a thorough assessment of its limitations prior to launching any major effort, and should prepare contingency plans as part of preparing for implementation.
3. Robust data must be gathered, from multiple sources, and shared transparently in an ongoing way throughout a major change.
4. Stakeholders should consider all advocacy tools-direct appeals, media coverage, administrative advocacy, legal avenues, legislative work-and use them dynamically to make a broader impact.

With the passage of House Resolution 1 and its oncoming impacts on SNAP and Medicaid, together with Colorado's ongoing state budget structural deficit, we need to remember these lessons more than ever.

Read our Case Study: Lessons from the Public Health Emergency Unwind in Colorado to learn more.

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