What to do
Check your card for the CO-DOI marking
That marking means the Division of Insurance regulates the plan, so Colorado's rules apply to it. Confirm the current rules with the Division directly — insurance regulation numbers change, and a number you read anywhere, including here, should be checked against the live Code of Colorado Regulations.
If there is no marking, confirm the plan type
A self-funded employer plan is federal territory and Colorado's rules do not reach it, however strong they are.
Check the Division of Insurance coverage guide
Colorado publishes an annually updated plan-by-plan guide to gender-affirming care coverage. Use the current edition rather than a copy.
Contact Division of Insurance Consumer Services
Call 303-894-7490 or email [email protected]. Filing a complaint is free and creates a regulatory record. The Division answers questions about prior authorization, appeals, denials, and external review.
For Medicaid, use the Health First Colorado rules
One provider letter for surgery, no 60-day pre-surgery letter window, no counseling requirement for hormones.
What the benchmark covers
Colorado's essential-health-benefit benchmark covers eye and lid modifications, face tightening, facial bone remodeling for facial feminization, breast and chest construction and reductions, and laser hair removal, alongside benefits already covered, effective 1 January 2023. That list is CMS's own wording from its approval announcement, and CMS benchmark documents now run through plan years 2025 to 2027.
In May 2025 the Governor signed HB25-1309, Protect Access to Gender-Affirming Health Care, which extends coverage requirements to fully insured large-group plans and bars denying or limiting medically necessary gender-affirming care as determined by a treating provider.
The limit worth knowing
None of this reaches a self-funded employer plan, and a large share of people who work for large employers are on one. Colorado's strength is real and it stops at the line between insured and self-funded coverage.
Common questions
- Does Colorado's benchmark protect me if I work for a large national employer?
- Only if the plan is insured rather than self-funded. Ask HR which it is; that single answer decides whether any of this applies.
- Where do I complain?
- Colorado Division of Insurance Consumer Services, 303-894-7490 or [email protected], for plans it regulates. For a self-funded plan, the federal Department of Labor — or CMS if it is a government plan.
Better covered elsewhere
- Colorado Division of Insurance — Gender-Affirming Care Coverage Guide
Updated annually. Use the live guide rather than any copy, including this page.
- One Colorado — insurance coverage for gender-affirming care
Plain-language consumer explainers for Colorado specifically.
Where to go next
Sources for the legal points on this page
- Colorado includes gender-affirming care in its essential-health-benefit benchmark
Colorado — individual and small-group · effective 2023-01-01
CMS press release, Coverage of LGBTQ+ Care as an Essential Health Benefit in Colorado (cms.gov) — procedure list and 1 Jan 2023 effective date confirmed verbatim; CMS benchmark summary documents run through plan years 2025-2027
Status: settled · source-checked 2026-08-06 · primary source verified: 2026-08-06
- Colorado bars gender-identity discrimination in the plans its Division of Insurance regulates
Colorado — DOI-regulated plans · effective in force
SUBSTANCE CORROBORATED, NUMBER UNCONFIRMED. 3 CCR 702-4 Series 4-2 (Accident and Health, General) contains gender-identity nondiscrimination text — carriers may not discriminate on the basis of race, color, national origin, disability, age, sex, gender identity, or sexual orientation. But three retrievable CCR snapshots of that series top out at Regulation 4-2-57 and none contains a 4-2-62. The current version (effective 12 Dec 2025) could not be retrieved, so the number is neither confirmed nor refuted. The Division of Insurance's own gender-affirming care page (archived 2026-01-05) cites NO regulation numbers at all, so the citation does not originate from the Division's consumer material either
Status: contested · source-checked 2026-08-06 · primary source verified: never
- Health First Colorado expanded gender-affirming care in 2023
Colorado Medicaid · effective 2023-08-30
Health First Colorado benefit expansion, 2023-08-30 — NOT VERIFIED. Three routes tried and each failed for a different reason: direct fetch is CloudFront geo-blocked (403, non-US traffic); the IPRoyal residential proxy exits in Colorado but blocks .gov domains at the proxy itself; and the Wayback Machine holds no snapshot after the August 2023 expansion (its newest capture of the page is a 404). Clearing this needs someone on a normal US connection to read the page
Status: contested · source-checked 2026-08-06 · primary source verified: never
- Colorado HB25-1309 extends coverage to the large-group market
Colorado — large group (fully insured) · effective signed 2025-05-23; effective date not established
Colorado HB25-1309, Protect Access to Gender-Affirming Health Care (leg.colorado.gov bill page); Division of Insurance / Milliman coverage analysis, 1 April 2025
Status: settled · source-checked 2026-08-06 · primary source verified: 2026-08-06 (partial — title and signing verified, effective date not)