The Trump administration is launching an investigation into Colorado Medicaid spending on undocumented immigrants, an extensive data request from federal officials reveals.

The 11 pages of requested information, which The Colorado Sun obtained through the state open records act, asks about Colorado spending and policies, and seeks personal information about Medicaid claims during the past three months, including patients’ immigration status.

In an email accompanying the data request, the federal Centers for Medicare and Medicaid Services said it intends to review claims that Colorado submitted for federal matching funds to pay for people’s medical care. Federal law generally prohibits states from using federal money to pay for nonemergency care for people without “satisfactory immigration status.” Many adult immigrants with legal status must complete a “five-year waiting period” during which they are not eligible for nonemergency services.

“The Centers for Medicare & Medicaid Services is committed to the fiscal integrity of the Medicaid program” and wants to ensure that federal money is used in accordance with the law, states the June 6 email from Dorothy Ferguson, a financial operations division director at the Centers for Medicare and Medicaid Services.

The Colorado Department of Health Care Policy and Financing, which operates the Medicaid program for people who have low incomes or disabilities, has not yet responded to the data request. State officials are “currently evaluating the requests,” department spokesman Marc Williams said in an emailed statement Tuesday. “We believe that other states have received similar requests.”

The state Medicaid program “has always been required to regularly share detailed information in order to claim federal matching funds” but this request is “lengthy and more detailed,” Williams said. Federal officials gave a July 30 deadline.

The request comes after Colorado, when former President Joe Biden was in office, expanded health coverage to immigrants living in the state, including those who do not have legal immigration status. Colorado did this through two programs, one of which is called Cover All Coloradans.

The program began this year and provides Medicaid coverage for children and pregnant and post-partum women no matter their immigration status. It has enrolled more than 21,000 people, including more than 16,000 children ages 0-18, who would qualify for Medicaid if not for their immigration status.

The program for children is funded through state dollars, but Colorado does receive a federal match for coverage for pregnant women, which is an exception under federal law.

Through a separate, longstanding program known as Emergency Medicaid, Colorado also receives federal dollars to pay for emergency health care for adults who are not citizens. This type of program exists in every state in the country, with some variation.

Colorado’s second program expanding health coverage for undocumented immigrants is called OmniSalud, and it is separate from Medicaid. The program provides a secure online marketplace for people to purchase private health insurance plans, and it provides state-funded subsidies to many to help pay for that coverage.

Nearly 14,000 people signed up for insurance plans this year through the program, the large majority of whom received subsidy help.

OmniSalud does not share information with the federal government, and a spokesperson for the program said last week that it has not received any requests to do so.

Three Republican members of Colorado’s Congressional delegation last week sent a letter to Gov. Jared Polis urging him to end both OmniSalud and Cover All Coloradans, saying the programs could put Colorado at risk of losing some federal funding under the massive federal tax and spending bill currently being debated.

Colorado provided more than 36,000 noncitizens with emergency care last month

The federal request focuses mainly on emergency care for adults who are undocumented or who have not had legal status for at least five years. Colorado Medicaid paid for emergency medical care for 36,834 noncitizens in May, according to data provided by the department Tuesday.

Federal funding for emergency health care for undocumented immigrants is allowed under federal law because without it, hospitals would have to absorb the cost of care since they are not allowed to turn anyone away during an emergency.

The request seeks data that federal investigators can use to “replicate the process” the state used to determine how Colorado separated emergency claims from nonemergency claims.

It asks for spreadsheets listing adults with “unsatisfactory immigration status,” including coverage eligibility data, benefits and funding. It also requests Colorado’s Medicaid codes for emergency medical services and a “description of how Colorado determines an emergent condition that would be eligible for federal match.”

The spreadsheets must include the person’s immigration status, Medicaid identification number, birth date, and the reason they were eligible for Medicaid — such as a disability, pregnancy, income status, the request says. Federal officials also asked for copies of all of Colorado’s policies, laws, audits and procedures to ensure that federal money is not spent on any nonemergency care for adults who do not have legal status.

The data request does not seek information about beneficiaries who are younger than 19.

Concern that federal health officials will share the data with ICE

The request comes from federal Medicare and Medicaid Services, which is responsible for investigating fraud, and not from the Department of Homeland Security, which includes U.S. Immigration and Customs Enforcement.

It’s unclear, however, whether the federal health agency would share the information it might receive from the request with other federal agencies. The Associated Press reported this month after obtaining an internal memo that federal Medicare and Medicaid officials shared Medicaid data from California, Washington, Illinois and Washington, D.C., after being ordered to do so by the Department of Homeland Security. Centers for Medicare and Medicaid Services officials were given less than an hour to comply with the directive, the AP reported.

Immigrant and health advocacy groups have called on Colorado officials not to comply with the data request.

“This data request is not about health or program integrity — it’s about authoritarian surveillance,” said Annie Martínez, litigation director of the Colorado Center on Law and Policy. “Public health data must never be used to criminalize sickness, poverty or immigration status.”

The request targeting Colorado Medicaid spending on immigrants came after the Colorado Department of Labor and Employment received a subpoena from ICE ordering the state agency to turn over personal information about people who are providing homes for unaccompanied immigrant children.

The details of the April 24 subpoena were revealed this month in a lawsuit filed by a director in the labor department who argues that turning over the information is a violation of state law. Polis was sued by Scott Moss, who is director of the state Division of Labor Standards and Statistics, after Polis requested that Moss comply with the subpoena.

Moss argues that complying would violate state laws that Polis signed in 2021 and 2025 that prohibit government agencies and their employees from sharing personal identifying information for the purpose of assisting in federal immigration enforcement. ICE maintains it is attempting to protect children, including from trafficking.

Staff writer John Ingold contributed to this report.