Colorado Healthcare Employer Compliance Checklist
A Guide for Organizations with 5–50 Employees
Running a healthcare practice or facility in Colorado means juggling state employment law, federal requirements, and clinical-setting rules — often all at once. This checklist is organized by compliance category so your team can work through it operationally, rather than trying to track down individual statutes. Each item below notes when it applies and how often it needs attention.
Important: This checklist is for general informational and operational planning purposes only. It is not legal advice. Colorado employment law changes frequently — wage rates, leave rules, and thresholds are often adjusted annually or by new legislation. Confirm current requirements with the Colorado Department of Labor and Employment (CDLE), the Colorado Department of Public Health and Environment (CDPHE), and your employment counsel before relying on this guide.
1. Foundational Registration & Insurance
These apply to virtually every Colorado employer, including PEO/ASO co-employment arrangements — confirm which entity holds each obligation under your service agreement.
| Requirement | Frequency / Notes | |
|---|---|---|
| ☐ | Colorado Workers' Compensation insurance in force | Required from the 1st employee, including part-time |
| ☐ | Unemployment Insurance (UI) employer account registered with CDLE | At time of first hire |
| ☐ | Colorado wage withholding account (state EIN) active | Ongoing |
| ☐ | New hire reporting to Colorado State Directory of New Hires | Within 20 days of hire |
| ☐ | Federal EIN and applicable federal payroll tax accounts current | Ongoing |
2. Wage & Hour (COMPS Order / CDLE)
Governed primarily by the Colorado Overtime and Minimum Pay Standards (COMPS) Order.
| Requirement | Frequency / Notes | |
|---|---|---|
| ☐ | Pay at or above current Colorado state (and Denver/local, if applicable) minimum wage | Rate adjusts annually — verify current-year rate with CDLE |
| ☐ | Overtime paid for hours over 40/week AND over 12/workday (or 12 consecutive hours) | Per pay period |
| ☐ | Paid 10-minute rest period provided per 4 hours worked | Per shift |
| ☐ | Unpaid (or paid, per policy) 30-minute meal break for shifts over 5 hours | Per shift |
| ☐ | Job postings include compensation range and general benefits description | Equal Pay for Equal Work Act — every posting |
| ☐ | Internal promotion opportunities are posted to existing employees | Equal Pay for Equal Work Act |
| ☐ | Final wages paid immediately on involuntary separation; by next regular payday on voluntary separation | At separation |
| ☐ | Itemized, compliant pay statements provided each pay period | Every payroll run |
3. Leave & Statutory Benefit Programs
Several Colorado leave laws apply regardless of employer size, but two have hard employee-count triggers worth flagging for a 5–50 employee employer.
| Requirement | Frequency / Notes | |
|---|---|---|
| ☐ | Healthy Families and Workplaces Act (HFWA) paid sick leave — accrual of 1 hour per 30 hours worked, up to 48 hrs/year, front-load option available | Applies to all employers, size 1+ |
| ☐ | Supplemental HFWA public health emergency leave provided when a PHE is declared | Only while a PHE is in effect |
| ☐ | Colorado FAMLI Division registration and employee premium withholding/remittance | Applies to all employers; size-based rules affect employer share, not registration |
| ☐ | Colorado SecureSavings Program registration or exemption certification on file | Mandatory trigger at 5+ employees, 2+ years in business, no qualifying retirement plan offered |
| ☐ | Jury duty leave policy in place | As needed |
| ☐ | Voting leave (up to 2 hours paid) policy in place | Election days |
| ☐ | Leave for victims of domestic violence, stalking, or sexual assault | As needed — confirm current size threshold with counsel |
| ☐ | Bereavement leave available via HFWA accrued sick leave | As needed |
4. Anti-Discrimination, Pay Equity & Hiring
| Requirement | Frequency / Notes | |
|---|---|---|
| ☐ | Colorado Anti-Discrimination Act (CADA) policies and training in place | Applies to employers with 1+ employees |
| ☐ | No salary history inquiries of applicants; pay ranges disclosed on request/posting | Equal Pay for Equal Work Act |
| ☐ | Job Application Fairness Act — no age, dates of attendance, or graduation-date requests on initial application | Every application/posting |
| ☐ | Criminal history inquiry restrictions (ban-the-box) followed on initial application | Every application |
| ☐ | Form I-9 completed and work authorization verified for every hire | Within 3 business days of start |
| ☐ | EEO/harassment prevention policy distributed and acknowledged | Onboarding + annually |
5. Healthcare-Specific Requirements
These apply on top of the general employer obligations above and are the items most specific to clinical/healthcare settings.
| Requirement | Frequency / Notes | |
|---|---|---|
| ☐ | Written Workplace Violence Prevention Plan for healthcare employers (risk assessment, incident reporting/log, employee training) | Colorado healthcare workplace violence law — establish + review at least annually |
| ☐ | OSHA Bloodborne Pathogens Exposure Control Plan maintained and reviewed | Annual review minimum |
| ☐ | Hepatitis B vaccination offered to at-risk employees at no cost | Within 10 days of assignment to at-risk duties |
| ☐ | Sharps injury log maintained (Needlestick Safety and Prevention Act) | Ongoing; annual device evaluation |
| ☐ | TB screening / respiratory protection program per CDPHE guidance for the care setting | Per hire + periodic, per setting risk level |
| ☐ | Immunization records for clinical staff tracked (e.g., MMR, varicella, flu per policy) | Onboarding + annual (flu season) |
| ☐ | HIPAA Privacy & Security Rule training completed | Onboarding + annually |
| ☐ | Mandatory-reporter training completed for staff with reporting duties (abuse/neglect) | Onboarding + per state renewal cycle |
| ☐ | Clinical staff licensure verified at hire and monitored for renewal (primary source verification) | At hire + ongoing monitoring |
| ☐ | Facility licensure/certification with CDPHE current (if operating a licensed facility) | Per license renewal cycle |
6. Postings & Recordkeeping
| Requirement | Frequency / Notes | |
|---|---|---|
| ☐ | Required Colorado + federal workplace posters displayed (minimum wage/COMPS, HFWA, FAMLI, UI, workers' comp, OSHA "Job Safety and Health," EEO) | Physical + remote-worker equivalent |
| ☐ | Form I-9 retained per federal schedule | 3 years after hire or 1 year after termination, whichever is later |
| ☐ | Payroll and time records retained | Minimum 3 years under Colorado law |
| ☐ | Personnel file inspection requests honored | Employees may inspect on a reasonable schedule |
| ☐ | OSHA 300/300A recordkeeping current (if applicable to headcount/industry) | Annual posting Feb–Apr |
7. Planning Ahead: Thresholds Triggered at 50 Employees
Worth tracking proactively as headcount approaches the top of this range — several federal obligations attach at exactly 50 employees.
| Requirement | Frequency / Notes | |
|---|---|---|
| ☐ | FMLA unpaid job-protected leave becomes applicable | 50+ employees within 75 miles |
| ☐ | ACA Applicable Large Employer (ALE) determination begins | Measured on full-time + FTE basis, 50+ |
| ☐ | Affirmative recordkeeping for potential future EEO-1 filing (triggers at 100) | Good practice to start early |
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Prepared by Comploy HR (ComployHR.com) as a general operational reference for PEO/ASO clients. Not legal advice — verify current requirements with CDLE, CDPHE, and employment counsel before acting.
