Improving Automated Medicaid Renewals in Colorado

Impact

• We identified 21 actionable opportunities to improve Colorado’s ex parte process. 
• Colorado addressed a system bug we found in their implementation of a COVID-19 Public Health Emergency unwinding waiver, which will help about 4,600 clients each month. 
• As a result of Colorado implementing many of our top priority recommendations, an additional 138,880 clients are now ex parte approved each year, increasing their total ex parte pass rate by approximately 13% and delivering $850 million in Medicaid benefits annually.

The challenge

As pandemic-era Medicaid continuous coverage protections ended, states faced the urgent task of renewing coverage for millions of people—quickly, accurately, and without unnecessary loss of benefits. Federal policy requires states to first attempt  ex parte (automated) renewals, which allow states to confirm eligibility using existing data sources rather than asking enrollees to submit paperwork. When done well, ex parte renewals reduce administrative burden for both agencies and residents, prevent eligible people from losing coverage, and improve program efficiency.

In Colorado, like in many states, ex parte renewals were already part of the eligibility system, but they were not reaching their full potential. Complex rules, disconnects in state policies and technical implementation, and reporting gaps that made it difficult to maximize the number of renewals that could be completed automatically. 

States with high data maturity have a clear understanding of why and how many beneficiaries are falling out of the ex parte process. But in Colorado, while they could see an overview—like whether or not someone passed the ex parte process—they didn’t know the specific reasons why.

At a moment when accuracy and speed mattered more than ever, Colorado needed support to understand where its ex parte process was breaking down and how to improve it in a way that centered both staff and clients. We set out to help Colorado increase successful ex parte renewals while maintaining program integrity and minimizing burden—all while using data they already had.

Our approach

Since 2022, Code for America has been working with state health care agencies to improve outcomes for ex parte renewal. While we’ve found that some states are hesitant to make changes to their systems due to a lack of data maturity, our experience has shown that this doesn’t have to be a barrier to investigating and improving  systems. Regardless of a state’s technical maturity or capacity to access specific data, it is possible to successfully do this work and make meaningful improvements.

Code for America partnered closely with the Colorado Department of Health Care Policy & Financing (CO HCPF) as a collaborative, embedded partner—working alongside state policy, operations, and technical teams. From the outset, we grounded the work in a people-centered problem-solving mindset: understanding not just what the system was designed to do, but how it actually functioned for frontline staff and for residents moving through the renewal process.

We began by developing a shared understanding of Colorado’s current ex parte renewal process. Through early discovery and working sessions, we found high-impact opportunities for improvement. 

• One example was their use of “reasonable compatibility,” a Medicaid policy used to determine if a beneficiary’s self-reported income closely matches their electronically verified income.
  • Our findings revealed that Colorado was overly reliant on outdated case file data instead of more recent electronic data, unnecessarily preventing clients from being ex parte approved. 
  • We recommended that Colorado remove reasonable compatibility from their process and directly use electronically verified income. 
  • When the Centers for Medicare & Medicaid Services later clarified its stance that reasonable compatibility does not apply during an ex parte renewal, Colorado was ahead of the curve.
• In another example, while digging into system functionality with Colorado’s technical vendor, we learned that if an individual stopped receiving income from a reliable source, they were asked for verification and the system sent them a renewal packet instead of running eligibility without that income source.
  • We suggested that the system shouldn’t flag a verification for an income source that has been shown discontinued from a reliable data source (e.g. termination of unemployment benefits). 

Instead of aiming for a single large overhaul, we worked with Colorado to identify discrete, feasible, high impact opportunities to improve ex parte outcomes. Throughout the engagement, Code for America emphasized state capacity building in understanding and monitoring the health of their systems and processes. We shared tools, frameworks, and documentation practices that enabled state teams to continue diagnosing and improving their ex parte processes beyond the initial project. By co-creating artifacts and decisions with Colorado staff, we ensured that improvements were not only effective, but also sustainable and aligned with state priorities.

Outcomes

Through this partnership, Colorado gained a deeper, more actionable understanding of its ex parte renewal process and the opportunities to improve its effectiveness. State teams were better equipped to distinguish between policy constraints, system limitations, and process gaps—and to focus their efforts where change would have the greatest impact.

The work helped Colorado identify implementation-ready  improvements that would increase the number of renewals completed automatically, reducing unnecessary paperwork for eligible residents and easing pressure on eligibility staff. Just as importantly, the state strengthened its internal alignment across policy, operations, and technology teams, creating a shared language and framework for ongoing improvement. Together, we:

• identified 21 actionable opportunities to improve Colorado’s ex parte process
• addressed a bug which will help about 4,600 clients each month
• partnered with HCPF to help implement a set of recommendations that will help automatically renew an additional 138,880 clients each year, resulting in an ex parte pass rate increase of 13% and delivering $850 million in Medicaid benefits annually

Rather than delivering a one-time solution, the collaboration left Colorado with enhanced capacity to continuously refine its renewal processes in response to ongoing changes in  federal guidance and resident needs. The project demonstrated how a people-centered, agile approach—grounded in partnership and trust—can help states modernize critical public benefit systems while protecting access to care.

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