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Medicaid eligibility for child welfare

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Three photos of parents and children in home and medical settings

The Colorado Department of Human Services has released new guidance, clarification and resources to open, manage and close the Medicaid entitlement through Trails, Colorado's certified state-county SACWIS system. This website is designed to help counties and providers navigate questions about Medicaid eligibility for the more than 15,000 children and youth in Colorado receive their Medicaid eligibility through their involvement in the child welfare system, including:

  • Children and youth who are placed in foster care or certified kinship care, and children who are placed in Colorado through a reciprocal Interstate Compact on the Placement of Children (ICPC). 
  • Children or youth who receive adoption or relative guardianship assistance from the child welfare system or children and youth who move to Colorado from a reciprocal Interstate Compact on Adoption and Medical Assistance (ICAMA). 
  • Children or youth who have exited the child welfare system, including Continuous Eligibility Foster Care (CEFC), Former Foster Care, and Emancipation from Adoption. 

Training opportunity

CDHS and HCPF have created an interactive learning experience to give child welfare professionals the tools they need to help families understand how to access quality and consistent health care for children and youth.

  Take the training

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Resources and guidance

Expand the sections below for information about each type of involvement with the child welfare system.

Adoption

Rule 7.402, the Medical Resources section of 12 CCR 2509-5, outlines the responsibilities of Colorado counties to provide medical coverage through Colorado’s Medicaid program for those children and youth who are in state or county custody and how they should receive coverage after being in state or county custody. See below for rule citations.

Subject to certain income and resource limitations, medical assistance through the Colorado Medicaid program must be provided to certain children and youth receiving child welfare services:

  • Those for whom the Department of Human Services is assuming full or partial responsibility and who are receiving services under the state’s subsidized adoption program, including a clause in the subsidized adoption agreement to provide medical assistance for the child.

Additionally:

  • When a child/youth is adopted, they become categorically eligible for Medicaid until the age of twenty-one (21) (see Rule 8.100.4 H.1.f. of 10 CCR 2505-10).
  • Adoption Medicaid is allowed for children/youth who are Title IV-E eligible or non-Title IV-E eligible (see Rule 7.306.41 D. and 7.306.42 D. of 12 CCR 2509-4).

In 2022, CDHS released new guidance, clarification and resources to open, manage and close the Medicaid entitlement for children who receive adoption assistance through the child welfare system:

Child Welfare and Division of Youth Services Medicaid access

The Viewing Medicaid Eligibility Status from interChange in Trails Mod Job Aid provides information to counties and the Division of Youth Services for providing Medicaid to young people served in both systems.

Continuous eligibility for foster care

Rule 8.100, the Continuous Eligibility Medical Assistance section of 10 CCR 2505-10, outlines rules and regulations surrounding Continuous Eligibility Medical Assistance programs. See below for rule citations:

Continuous eligibility applies to children under age 19, who through an eligibility determination, reassessment, or redetermination, are found eligible for a medical assistance program. The continuous eligibility period may last for up to 12 months. Children, under the age of 19, no longer enrolled in Foster Care Medicaid will be eligible for the MAGI medical assistance program unless the youth is eligible for waivered services. The Continuous eligibility period will begin the month the child is no longer enrolled in Foster Care Medicaid as long as they meet one of the following conditions:

  • Living with other relatives
  • Reunification with parents
  • Guardianship

In 2022, CDHS released new guidance, clarification and resources to close out a Trails case to successfully trigger CBMS to open up a Continuous Eligibility Foster Care eligibility span:

Emancipation from adoption

Rule 7.402, the Medical Resources section of 12 CCR 2509-5, outlines the responsibilities of Colorado counties to provide medical coverage through Colorado’s Medicaid program for those children and youth who are in state or county custody and how they should receive coverage after being in state or county custody. See below for rule citations.

Subject to certain income and resource limitations, medical assistance through the Colorado Medicaid program must be provided to certain children and youth receiving child welfare services as follows:

  • Children and youth for whom the county department is assuming full or partial financial responsibility.
  • Former adoption assistance youth who emancipated from foster care or adoption assistance at age eighteen (18) or after and are under age twenty-one (21), and for whom the state made adoption assistance payments in the month the youth turned eighteen (18) years of age.

In 2022, CDHS released new guidance, clarification and resources to open, manage and close the Medicaid entitlement for youth who emancipated from foster care or adoption assistance at age eighteen (18) or after and are under age twenty-one (21) and for whom the state made adoption assistance payments in the month the youth turned eighteen (18) years of age:

Entering at removal

Rule 7.402, the Medical Resources section of 12 CCR 2509-5, outlines the responsibilities of Colorado counties to provide medical coverage through Colorado’s Medicaid program for those children and youth who are in state or county custody and how they should receive coverage after being in state or county custody. See below for rule citations.

In 2022, CDHS released new guidance, clarification and resources to open, manage and close the Medicaid entitlement for children and youth who have been removed from home:

Former foster care

Rule 7.402, the Medical Resources section of 12 CCR 2509-5, outlines the responsibilities of Colorado counties to provide medical coverage through Colorado’s Medicaid program for those children and youth who are in state or county custody and how they should receive coverage after being in state or county custody. See below for rule citations.

Subject to certain income and resource limitations, medical assistance through the Colorado Medicaid program must be provided to certain children and youth receiving child welfare services as follows:

  • Children and youth for whom the county department is assuming full or partial financial responsibility.
  • Former Colorado foster care youth, who were under the State’s or Tribe’s responsibility, when they emancipated from foster care at age eighteen (18) or after, and who were enrolled in Medicaid (Title IV-E or non-Title IV-E) under Colorado’s Medicaid State Plan at the time of their emancipation, and are under age twenty-six (26); are eligible for Colorado’s Former Foster Care Medicaid. Eligible placement types include the following:
    • Kinship family foster care
    • Non-certified kinship care
    • Foster home care
    • Group home and group center care
    • Children’s Habilitation Residential Program (CHRP)
    • Residential Child Care Facilities,
    • Independent living programs, or
    • Youth committed to the Division of Youth Services, living in one of the above, non-secure placements.

In 2022, CDHS released new guidance, clarification and resources to close out a Trails case to successfully trigger the Colorado Benefits Management System (CBMS) to open up a Former Foster Care (FFC) Medicaid eligibility span. 

In 2024, CDHS released Information Memo IM-CW-2024-0012 to inform county departments of human/social services about regulations 42 C.F.R. § 435.150, which include requirements to expand Health First Colorado Former Foster Care services to youth who were:

  • In foster care at the age of 18 on or after Jan. 1, 2023;
  • Were on Medicaid; and
  • Who have become residents of Colorado from another state.
Foster care

Rule 7.402, the Medical Resources section of 12 CCR 2509-5, outlines the responsibilities of Colorado counties to provide medical coverage through Colorado’s Medicaid program for those children and youth who are in state or county custody and how they should receive coverage after being in state or county custody. See below for rule citations.

Subject to certain income and resource limitations, medical assistance through the Colorado Medicaid program must be provided to certain children and youth receiving child welfare services as follows:

  • Children and youth for whom the county department is assuming full or partial financial responsibility.
  • Children and youth in foster care, including those who are in supervised independent living placement situations subsequent to being in foster care.

In 2022, CDHS released new guidance, clarification and resources to open, manage and close the Medicaid entitlement for Foster Care children and youth: 

Kinship care

Rule 7.402, the Medical Resources section of 12 CCR 2509-5, outlines the responsibilities of Colorado counties to provide medical coverage through Colorado’s Medicaid program for those children and youth who are in state or county custody and how they should receive coverage after being in state or county custody. See below for rule citations.

Subject to certain income and resource limitations, medical assistance through the Colorado Medicaid program must be provided to certain children and youth receiving child welfare services as follows:

  • Children and youth for whom the county department is assuming full or partial financial responsibility.
  • Children and youth in foster care, including those who are in independent living situations subsequent to being in foster care.

In 2022, CDHS released new guidance, clarification and resources to open, manage and close the Medicaid entitlement children or youth in a certified kinship placement:

Interstate Compact on Adoption and Medical Assistance

Rule 7.402, the Medical Resources section of 12 CCR 2509-5, outlines the responsibilities of Colorado counties to provide medical coverage through Colorado’s Medicaid program for those children and youth who are in state or county custody and how they should receive coverage after being in state or county custody. See below for rule citations.

The Interstate Compact on Adoption and Medical Assistance (ICAMA) is a legal agreement between member states to address the need to protect the interests of children/youth in interstate adoption as mandated by federal legislation: The Adoption Assistance and Child Welfare Act of 1980 (P.L. 96-272.). State law in all member states related to ICAMA supersedes any conflicting state laws to create unified policy and practice. ICAMA applies when there is an Adoption Assistance Agreement or a Title IV-E Relative Guardianship Assistance Agreement (RGAP) in effect and a child/youth with an agreement moves to another state. It works to ensure the uninterrupted receipt of Medicaid to children/youth. Children/youth with an effective Adoption Assistance Agreement or Title IV-E RGAP agreement are eligible for Medicaid in the state they reside. If the child/youth moves to another state, they maintain their Medicaid eligibility, however, if they are a non-Title IV-E child/youth and they move to a non-reciprocal state and the county department is responsible for providing a medical plan for the child/youth (CCR 7.402.4). The state to which the child/youth moves is considered the residence state and the state where the agreement was originally signed is known as the agreement state. All information is input via the national ICAMA database by county departments. 

Subject to certain income and resource limitations, medical assistance through the Colorado Medicaid program must be provided to certain children and youth receiving child welfare services as follows:

  • Children and youth who have an adoption assistance agreement (Title IV-E or non-Title IV-E) or Title IV-E relative guardianship assistance agreement that were finalized in Colorado and now reside in another state.
  • Children and youth who have an adoption assistance (Title IV-E or non-Title IV-E) or Title IV-E relative guardianship assistance agreement that were finalized in another state and now reside in Colorado.
  • It is the responsibility of the Colorado county department where the adoption agreement finalized to provide a medical plan for children and youth who have a non-Title IV-E agreement and reside in a non-reciprocal state.
  • The state in which the adoption is finalized, is known as the agreement state. The state in which the child/youth is moving is known as the receiving state. The agreement state is responsible for making requests and changes in the national ICAMA database (formerly known as Blue Iron).

In 2022, CDHS released new guidance, clarification and resources to open, manage and close the Medicaid entitlement for children who moved to Colorado and receive adoption assistance in another reciprocal ICAMA state:

Interstate Compact on the Placement of Children

The Interstate Compact on the Placement of Children (ICPC) is a law that has been enacted by all 50 states, the District of Columbia and the U.S. Virgin Islands. This law establishes orderly procedures for the interstate placement of children and fixes responsibilities for those involved in placing the child.

Rule 7.402, the Medical Resources section of 12 CCR 2509-5, outlines the responsibilities of Colorado counties to provide medical coverage through Colorado’s Medicaid program for those children and youth who are in state or county custody and how they should receive coverage after being in state or county custody. See below for rule citations.

Subject to certain income and resource limitations, medical assistance through the Colorado Medicaid program must be provided to certain children and youth receiving child welfare.

In 2022, CDHS released new guidance, clarification and resources to open, manage and close the Medicaid entitlement for children placed in Colorado through ICPC:

Medicaid resources

General resources

Tip sheets

Relative guardianship assistance

Rule 7.402, the Medical Resources section of 12 CCR 2509-5, outlines the responsibilities of Colorado counties to provide medical coverage through Colorado’s Medicaid program for those children and youth who are in state or county custody and how they should receive coverage after being in state or county custody. See below for rule citations.

Subject to certain income and resource limitations, medical assistance through the Colorado Medicaid program must be provided to certain children and youth receiving child welfare services as follows:

  • Children and youth for whom the county department is assuming full or partial financial responsibility.
  • Children and youth who are eligible for the Relative Guardianship Assistance Program, including relative guardianship assistance placements out of state who are Title IV-E eligible, until the receiving state can provide Medicaid.

In 2022, CDHS released new guidance, clarification and resources to open, manage and close the Medicaid entitlement for children or youth with an active relative guardianship assistance agreement:

Tribal children and youth

Rule 7.402, the Medical Resources section of 12 CCR 2509-5, outlines the responsibilities of Colorado counties to provide medical coverage through Colorado’s Medicaid program for those children and youth who are in state or county custody and how they should receive coverage after being in state or county custody. See below for rule citations.

Subject to certain income and resource limitations, medical assistance through the Colorado Medicaid program must be provided to certain children and youth receiving child welfare services as follows:

  • Children and youth for whom the county department is assuming full or partial financial responsibility.
  • Children and youth who are in the custody of the Ute Mountain Ute Tribe or the Southern Ute Indian Tribe.

In 2022, CDHS released new guidance, clarification and resources to open, manage and close the Medicaid entitlement for children and youth who are in the custody for the  Ute Mountain Ute Tribe or the Southern Ute Indian Tribe:

Other resources

Below are additional resources that can support counties in successfully triaging and escalating issues with child welfare Medicaid programs.