AARP’s Push to Protect Family Caregivers from Medicaid Work Requirements Gets a Boost

We successfully advocated for a broader definition of caregiver to help preserve benefits

Miriam Cross,

AARP

Comments

Published June 03, 2026

a checklist on a clipboard with a stethoscope next to it

AARP (Getty Images)

Key takeaways

States will require Medicaid enrollees ages 19 to 64 to log 80 hours of work, school, or volunteering monthly by 2027.
Exemptions exist for certain groups, including caregivers and those with disabilities or serious illnesses, but proving eligibility may be difficult depending on documentation rules.
AARP lobbied for family caregiver protections, many of which were folded into the new guidelines.

AARP spent months pressing federal and state governments to ensure family caregivers could keep their Medicaid coverage as massive changes to the program threatened to take it away.

This week, the Centers for Medicare & Medicaid Services (CMS) published a rule that made clear a wide range of caregivers will qualify for exemptions from new work requirements that could put their health care at risk.

“Caregiving is work — and a Medicaid work requirement should recognize that,” said AARP Chief Advocacy and Engagement Officer Nancy LeaMond in a statement. “AARP made that case to CMS throughout the rulemaking process, and we're glad the agency listened: the rule takes important steps to protect certain family caregivers from the new requirements and draws on AARP's own research to help states identify them.”

Millions of family caregivers rely on Medicaid as they step back from the workforce to tend to loved ones. By January 2027 – or earlier if a state chooses – Medicaid participants between the ages of 19 and 64 must prove they are employed, volunteering or enrolled in school at least 80 hours a month to keep their coverage. For some Americans, the changes are already — or will soon be — a reality. Nebraska rolled out its work requirements on May 1; other states plan to launch theirs before the January 2027 deadline.

Join Our Fight for Caregivers

Here’s what you can do to help:

Sign up to become part of AARP’s online advocacy network and help family caregivers get the support they need.
Find out more about how we’re fighting for you every day in Congress and across the country
AARP is your fierce defender on the issues that matter to people 50-plus. Become a member or renew your membership today

Reaching those 80 hours could pose a challenge for these family caregivers, who spend an average of 35 hours each week looking after loved ones without pay. AARP had pushed the administration to allow family caregivers to receive a broad exemption from meeting the work requirements. Those who care for dependent children age 13 and under or people with disabilities were released from the requirements from the start. More than 7 million of the estimated 63 million family caregivers in the U.S. are under age 65 and rely on Medicaid for their own health coverage.

Clarity for family caregivers

The Medicaid work requirements for enrollees were adopted in 2025 as part of the One Big Beautiful Bill Act.

Most Popular

Nearly 5 million people ages 50 to 64 are included in the group of adults subject to the new Medicaid rules, which AARP opposed due to its predicted impact on older adults.

Many Medicaid enrollees ages 50 and 64 live with chronic health conditions or have significant caregiving responsibilities. That makes it more difficult for them to hold down a job. Aging adults may be less able to handle physically demanding roles, or face age discrimination when trying to reenter the workforce. 

Medicaid is key for people who gave up day jobs with group health insurance to care for a loved one. For many family caregivers, their unpaid labor is an unofficial full- or part-time job. While the law exempts caregivers of dependent children ages 13 and under or people with disabilities, the new rule defines “disabled individual” broadly. Importantly, it could include older adults who need help with day-to-day activities such as bathing and dressing.

Family caregivers, as well as caregivers who live with their care recipient, will not need to document the number of hours they spend supporting their relatives, according to CMS, as long as their caregiving happens on a regular rather than occasional basis. Those who regularly care for friends, neighbors or others they are not related to and do not live with can qualify for the exemption if they provide at least 80 hours of care a month. Such caregivers who provide fewer hours can count them toward the 80-hour minimum.

The law also acknowledges that family caregivers may have to use informal sources of data to confirm their status. The CMS rule flagged research from AARP about how states can identify caregivers.  

Worrying signs for older adults  

While many family caregivers may be able to breathe a sigh of relief, the guidelines place restrictions on other Medicaid enrollees. It may be harder for those with medical conditions to get an exemption from working to retain their health coverage.

People deemed “medically frail” — in other words, those with physical, mental or behavioral health conditions — are exempt from complying with the new law. But the new rule clarifies that this applies only if their condition “significantly impairs” their ability to do so.

States must first try to verify that someone is “medically frail” using existing records such as case files or claims. If that isn’t enough, they can ask for other documentation, “which is hard to verify if you don’t have health insurance coverage or if you’re not going to a doctor,” says Jordan Endicott, a government affairs director at AARP.

States have the authority to design the portal or systems that people will use to log their work hours or their exemptions, meaning it will vary from state to state when it comes to how simple it is to keep your coverage, even if you abide by the rules.

“People who qualify for Medicaid could still lose their health care under these requirements — not because they've done anything wrong, but because they missed a deadline or got caught in red tape,” LeaMond said. “That's a real risk.”

States may also let someone attest that they are unable to work due to health conditions — but there are limits on when and how often they can do this. 

“Getting the caregiver exemption right is only part of the answer,” LeaMond said. “AARP will stay at the table with CMS and the states to make sure no one loses coverage simply because the system is hard to navigate.”

%{postComment}%

The key takeaways were created with the assistance of generative AI. An AARP editor reviewed and refined the content for accuracy and clarity.

Miriam Cross is a writer for AARP covering advocacy issues. She previously worked at American Banker and Kiplinger’s Personal Finance.