
By Jen Schumann | Rocky Mountain Voice
Colorado now requires hospitals to open their books, but the reports still don’t show how 340B savings are used or how much uncompensated care is migrant-related. That gap has turned Colorado into a proving ground for reforms that define the patient, disclose the spread and require hospitals to prove the savings reach care.
Colorado’s uncompensated care surge
UCHealth says it is drowning under the weight of migrant care, reporting $17 million in uncompensated costs in just three months last year. Denver Health added another $10 million in the same surge, and a Common Sense Institute analysis put the metro total for emergency care at $48 million by late 2024, averaging $2,931 per encounter.
Colorado’s own ledger underscores the scale. In 2023, uncompensated care statewide totaled $544.9 million—2.3 percent of hospital operating costs. Most of it sits in self-pay ($310.3 million) and CICP/Other ($132.5 million), categories that don’t capture immigration status but almost certainly include many new arrivals.
More than a quarter of that total landed at Denver Health, piling the weight on the same region that has absorbed most of the migrant surge.
Separate budget documents confirm the pressure. The Joint Budget Committee’s FY2025-26 budget report includes projections for the Cover All Coloradans program. Launched in 2022, it extends Medicaid-style benefits to undocumented immigrants under 19 and pregnant women. What began as a $2 million program is now expected to cost $32 million by FY2025-26.
Enrollment has surged from about 3,600 to 14,000, with expectations of 15,000 in the next fiscal year. In four years, the program’s price tag has jumped sixteen-fold. And it comes on top of the uncompensated care hospitals already report.
The difference matters. Cover All Coloradans is a state-funded benefit, but hospitals also report separate uncompensated care costs that topped $544.9 million in 2023.
At the same time UCHealth is calling migrant care “unsustainable,” it has faced its own scrutiny. In November 2024, the U.S. Department of Justice announced UCHealth would pay $23 million to settle allegations it fraudulently billed Medicare and TRICARE by upcoding emergency visits. Federal officials said the case showed how health systems can misuse public programs while pleading hardship on uncompensated care.
UCHealth acknowledged that 340B savings are part of how it manages uncompensated care. “Not only do some of our hospitals qualify for 340B because of the amount of uncompensated care that they provide, but 340B makes that uncompensated care possible… It certainly doesn’t completely cover the cost… but it makes that much more possible,” spokesperson Dan Weaver told the Denver Business Journal in December 2024.
National pattern of abuse
The problems aren’t limited to Colorado. In Virginia, lawmakers advanced a 340B expansion bill only to see Gov. Glenn Youngkin veto it, warning that hospitals were exploiting loopholes.
One Virginia hospital was caught buying a cancer drug for about $3,400 and charging insurers more than $25,000 for the same treatment, seven times the purchase price, as reported by the Washington Examiner.
The uproar isn’t just about balance sheets. Critics say 340B has been twisted into funding social agendas that have nothing to do with indigent care.
In Michigan, Henry Ford Health faced allegations of egregious markups and was spotlighted by President Trump as proof the program had morphed into corporate greed. In North Carolina, a state audit showed hospitals billing the state health plan nearly 85 percent more for cancer drugs than non-340B hospitals.
And in Illinois, Chicago’s Howard Brown Health has advertised that 340B funds support gender-affirming care and LGBTQ services—far from the program’s original mission of serving indigent patients.
Voices of frustration
Ask healthcare entrepreneur Dutch Rojas,what he thinks of 340B and he’ll give you the unvarnished version. His complaint is simple: hospitals take the discounts, then turn around and bill Medicare, insurers and patients at the higher rate.
“They buy drugs at steep discounts… but still bill Medicare and commercial insurance for the full price, so the savings never reach the patient,” Rojas said in a recent video. He went further, calling the entire system “the world’s greatest grift ever of all time.”
Dr. Anthony DiGiorgio, a neurosurgeon and policy voice, has called the American Hospital Association’s defense of 340B “a masterclass in gaslighting,” as he wrote in a post on X.
The Alliance for Integrity and Reform of 340B has been just as blunt. “There are no requirements to track whether 340B discounts are passed on to the patients… rural communities, seniors, Medicaid patients, and the uninsured are left with little to no benefit,” the group posted in August.
A new Health Affairs analysis adds an uncomfortable wrinkle: more than 80 percent of so-called “rural” 340B beds are actually in urban facilities making billions.
Federal reform push
President Trump has signed a string of executive orders aimed at pulling hidden costs into daylight and cutting off backdoor subsidies.
One directs HHS to survey what hospitals actually pay for outpatient drugs and adjust Medicare payments to acquisition cost — cutting off the spread hospitals pocket through programs like 340B.
Another ties U.S. prescription drug prices to the lowest rate paid by peer nations, forcing manufacturers to give Americans the same deal they give Europe and Canada.
The White House also ordered Treasury, Labor and HHS to enforce hospital price posting rules that were ignored under the last administration, with analysts projecting up to $80 billion in savings if transparency is fully implemented.
And in February, Trump signed an order barring federal programs from acting as a backdoor subsidy for illegal immigration, instructing agencies to block taxpayer-funded benefits from flowing to migrants here unlawfully.
In testimony before Congress, HHS Secretary Robert F. Kennedy Jr. admitted what critics have argued for years: “The 340B program is not straightforward… It was originally intended for 100 institutions serving very poor communities. It’s now grown to 27,000 institutions… The patients themselves seldom get the benefits of the drug reduction.”
Trump’s allies point to numbers that should make anyone pause. In 2022, hospitals reported $44.1 billion in 340B revenue while spending only $18.5 billion on discounted drugs. By comparison, 340B purchases in 2009 totaled just $4 billion. Today they exceed $66 billion, as reported by the Washington Examiner.
Colorado’s transparency test
In 2023, Colorado lawmakers tried to get ahead of the debate by passing HB23-1226, a sweeping hospital transparency law that is already in effect. The law requires hospitals to disclose audited financials, cash transfers in and out of Colorado, executive incentive metrics, significant “other revenue” that normally only shows up in Medicare cost reports–and quarterly income statements and balance sheets.
The law does not require hospitals to track or report uncompensated care specifically tied to migrants, but the new disclosures give policymakers and the public better tools to test whether programs like 340B are truly offsetting charity and self-pay care or simply padding reserves and expansions.
But less than half of Colorado hospitals earned a Good rating for price transparency in CDPHE’s Spring 2025 review, and nearly one in five were rated Poor. Just over three-quarters of hospitals met the machine-readable rule, and fewer than half earned a Good rating—a sign of how difficult it still is for patients and lawmakers to verify uncompensated care claims.
What the numbers really show
Hospitals insist migrant care is “unsustainable.” The state’s own data says the burden is real—$544.9 million in unpaid care—yet most of it sits in self-pay lines that blur who is being helped and how. Add UCHealth’s $17 million, Denver Health’s $10 million and the Common Sense Institute’s $49 million estimate—and the trend line is undeniable.
The state’s reporting shows the scale of uncompensated care, but it does not separate out how much is tied to migrants. That gap leaves both policymakers and the public without a full picture. Reform advocates say the way forward is transparency that defines the patient, discloses the spread and requires hospitals to show that 340B savings directly reduce patient costs.
President Trump has also moved on that front, signing an executive order that bars federal programs from acting as a backdoor subsidy for people in the country unlawfully. Taken together, Colorado’s state data and recent federal actions mark a shift from partial reporting to accountability.
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