During Joe Biden’s presidential administration, Colorado took bold steps to expand health coverage to immigrants living in the state, regardless of their legal status.

Tens of thousands of people took advantage of those programs to gain coverage for themselves or their children. The hope of supporters is that this will lower the uninsured rate in Colorado since immigration status can be a major barrier to obtaining health coverage. Providing access to coverage for primary and preventive care could also reduce the amount the state spends paying for emergency care for uninsured noncitizens who have a health crisis.

But now, the long-term fate of those programs is unclear — and not just because of potential threats from Donald Trump’s administration. While an executive order issued Wednesday could affect one of the programs, state budget woes could also have an impact.

So what might come next for these programs? Here are some answers.

What are these programs?

The coverage expansions largely come through two programs.

One is called OmniSalud, and it connects people with private health insurance. Many immigrants are not eligible for federal insurance subsidies offered to people who buy coverage on their own. OmniSalud addresses that by offering state-funded subsidies to people not eligible for federal subsidies.

The program works in conjunction with the state’s insurance exchange, Connect for Health Colorado, but it does not use the exchange’s platform. Instead, Colorado created an entirely new exchange called Colorado Connect to handle the sign-ups.

For 2025, more than 13,000 people signed up for coverage through Colorado Connect, including 12,000 who signed up to receive subsidized coverage through OmniSalud. (Because of funding limitations, OmniSalud enrollment is capped, but people can still buy unsubsidized coverage.)

The second program is called Cover All Coloradans, and it rolled out only at the start of the year. The program allows children and pregnant women to receive Medicaid coverage regardless of their immigration status.

That program has now enrolled more than 11,000 people.

Colorado is among a handful of mostly Democratic-controlled states that offer coverage to children regardless of immigration status. But many states, including several run by Republicans, have extended federal programs to cover pregnant women.

Do these programs share immigration information with the federal government?

The answer here is complicated — mostly no but sometimes yes.

Colorado law generally prohibits state agencies from asking about immigration status or from sharing identifying information for the purposes of immigration enforcement.

For OmniSalud, the use of a separate enrollment platform means the data is stored separately from the state’s main insurance exchange and is not shared with the federal government. The OmniSalud application does not ask about immigration status, said Kevin Patterson, the CEO of Connect for Health Colorado.

For Cover All Coloradans, the application is the same as what is used for anyone else applying for Medicaid. That application does ask about immigration status.

But Colorado doesn’t always pass that information on to the federal government. The portion of the program for kids is entirely state-funded, so there is no federal match of funds for those enrollees.

“If there is not a match for an individual, their information will not be shared,” Marc Williams, a spokesperson for the state Department of Health Care Policy and Financing, wrote in an email. The department administers Medicaid in the state as well as the Cover All Coloradans program.

But the state does for now receive matching funds from the federal government to help pay for the care for pregnant people regardless of immigration status as well as for another program that covers emergency services. In that case, personal information, including immigration status, would be shared with the federal Center for Medicare and Medicaid Services, which is also known as CMS.

“Historically, CMS has used the information only for the purpose of determining eligibility,” Williams wrote.

Does the latest Trump executive order end Cover All Coloradans?

On Wednesday, Trump issued an executive order attempting to end federal benefits for people living in the country without documentation, as well as to crack down on so-called sanctuary policies at the local level.

“My Administration will uphold the rule of law, defend against the waste of hard-earned taxpayer resources, and protect benefits for American citizens in need, including individuals with disabilities and veterans,” Trump stated in the order.

How this will impact Medicaid programs nationally and in Colorado, though, is unclear.

The federal money that helps pay for coverage for pregnant people on Cover All Coloradans comes through a Medicaid companion program called the Children’s Health Insurance Program, or CHIP. States can choose to participate in CHIP’s From-Conception-to-End-of-Pregnancy Option. So far, 23 states have done so, including Republican-controlled states such as Texas and Tennessee.

Federal Medicaid dollars can also be used to help pay for emergency care for people in the country illegally. Every state has some form of such an emergency Medicaid program.

The executive order doesn’t spell out which programs are affected. Instead, it says that the head of each federal agency must “identify all federally funded programs administered by the agency that currently permit illegal aliens to obtain any cash or non-cash public benefit, and, consistent with applicable law, take all appropriate actions to align such programs with the purposes of this order.”

Williams, the Colorado Medicaid spokesperson, wrote in an email that state officials are evaluating the order.

“Like other executive orders, this order directs action by federal agencies and we’re awaiting guidance from CMS,” he wrote.

Could the feds use health information to target immigrants who are undocumented?

Experts The Colorado Sun consulted said it may be technically possible but it’s not necessarily likely.

Immigration authorities trying to get Colorado agencies to cough up enrollee information would enter a legal morass.

“Federal law doesn’t require that state agencies or private companies share information with immigration officials,” César Cuauhtémoc García Hernández, a law professor at Ohio State University (previously at the University of Denver), who specializes in immigration enforcement law, wrote in an email.

“A federal law bars Colorado from refusing to share information about a person’s citizenship or immigration status with (Immigration and Customs Enforcement), but that law only applies to information that the state already possesses and Colorado law has barred state officials from asking for this information since 2022.”

García Hernández said, while it’s possible that immigration authorities could obtain a court subpoena or search warrant requiring the state to hand over enrollee information, it would be unusual.

“ICE rarely does that,” he wrote.

What about information shared with federal Medicaid officials?

Historically, the U.S. Bureau of Immigration and Customs Enforcement has had a policy against using health information for enforcement purposes.

Matthew Lopez, an attorney and the director of state advocacy for the National Immigration Law Center, said the federal Medicaid agency “has pretty strong restrictions on how Medicaid information can be shared.” 

“We’re pretty confident that the way that it’s carried out now is consistent with federal laws regarding privacy within the Medicaid program,” Lopez said.

That doesn’t mean the Trump administration won’t try to change those protections, but Lopez said he hasn’t heard of anything so far suggesting it will. Still, he said, he understands why immigrants and immigrant-rights groups are nervous.

“This exists in the context of everything else that’s happening,” he said. “This is an administration whose immigration actions are designed to sow chaos and fear.”

Will the programs survive?

OmniSalud and Cover All Coloradans face uncertain futures, but for different reasons.

OmniSalud is funded out of something called the Colorado Health Insurance Affordability Enterprise, which gets its money from a fee on health insurers, as well as from a large, annual federal grant. (Colorado is still waiting on its promised grant from the feds for 2025 to arrive.)

Colorado Insurance Commissioner Michael Conway said the state amended the “terms and conditions” section of its federal grant in the waning days of the Biden administration to make clear that OmniSalud is not funded by the federal money.

“We obviously knew there would be a concern related to the incoming Trump administration,” Conway said. “It just made sense to take that issue off the table.”

But, with potential changes to health insurance funding at the federal level, Colorado could see smaller grant amounts in the coming years. The federal authorization for the grant is also due to expire during the Trump administration, making it unclear whether it will be renewed. If those federal funds were to go away, Colorado’s health insurance enterprise wouldn’t be able to pay for all the programs it currently supports.

Cover All Coloradans, meanwhile, faces more challenges. If it survives the Trump administration orders, it could still be a victim of the current state budget crisis. Members of the legislature’s Joint Budget Committee have looked at possibly axing the program, which is expected to cost around $30 million in the coming fiscal year, as a way to close the state’s roughly $1 billion budget shortfall.

Supporters of the program have argued against ending it, though, saying that the program will ultimately save the state money by providing lower-cost preventive care up front and avoiding more costly emergency care down the road.

“The impact of capping or pausing this program,” state Medicaid director Adela Flores-Brennan told the JBC last month, “is that we will further strain the safety net.”