AARP Hearing Center
Medicaid Now Recognizes Caregiving as Work
AARP’s successful advocacy will help preserve benefits for many people providing family care
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Key takeaways
- States will require certain Medicaid enrollees ages 19 to 64 to log 80 hours a month of work, school or volunteering by 2027.
- The new guidelines include exemptions for caregivers, but proving eligibility could 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.
In June, the Centers for Medicare & Medicaid Services (CMS) published a rule clarifying that a wide range of caregivers will qualify for exemptions from new work requirements that could otherwise put their health care at risk.
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“Caregiving is work — and a Medicaid work requirement should recognize that,” AARP Chief Advocacy and Engagement Officer Nancy LeaMond said 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.”
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Despite the positive developments on the family caregiver exemption, AARP followed up with a letter to CMS on July 31 to make recommendations as the agency finalizes its guidelines and to outline remaining concerns. The recommendations included further clarifying some definitions used in the exemption for family caregivers, removing obstacles that could lead people with serious illnesses to lose their coverage, helping states get their new programs up and running, and placing guardrails on artificial intelligence usage, such as ensuring that decisions to disenroll Medicaid users won’t be relegated to AI.
“AARP is very concerned that under the new requirements, many Americans could lose coverage, not because they are not eligible for Medicaid, but because of administrative barriers and red tape,” wrote Megan O’Reilly, vice president for health and family for AARP government affairs, in the letter.
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, often because they must step back from work, and sacrifice income, to tend to loved ones.
By January 2027 — or earlier if a state chooses — Medicaid expansion participants ages 19 to 64 must prove they are employed, volunteering or enrolled in school at least 80 hours a month to keep their coverage. (Forty states and the District of Columbia have adopted Medicaid expansion, which broadens eligibility so that adults under 65 qualify by income alone if they earn below 138 percent of the federal poverty level.) For some Americans, the changes are already a reality. Nebraska rolled out its work requirements on May 1, and Montana did the same on July 1.
Reaching the 80-hour threshold could pose a challenge for family caregivers, who spend an average of 35 hours each week looking after loved ones without pay. The 2025 law that established the work threshold exempted people caring for dependent children up to age 13, but AARP pushed CMS to recognize the crucial work of family caregivers and allow them to receive a broad waiver from the work requirements.
Clarity for family caregivers
The Medicaid work requirements for enrollees were adopted in 2025 as part of the One Big Beautiful Bill Act.
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 to 64 live with chronic health conditions or have significant caregiving responsibilities. That makes it more difficult for them to keep working. Aging adults may be less able to handle physically demanding jobs 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.
The law automatically exempts caregivers of people with disabilities. Importantly, the new CMS rule clarifies the definition of “disabled individual” and could include older adults who need help with day-to-day activities such as bathing and dressing.
Also under the new rule, family caregivers, as well as other 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. 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 cited research from AARP on how states can identify caregivers, but AARP is pressing for more clarity: In her letter, O’Reilly urged CMS to clarify what counts as “regular” caregiving and recommend data sources that states could use to identify family caregivers. She also urged CMS to let family caregivers attest to their status if documentation is not available.
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 expansion enrollees. It may be harder for those with medical conditions to get an exemption from working in order to retain their health coverage.
People deemed “medically frail” — those with physical, mental or behavioral health conditions — are exempt from complying with the new law. But the new CMS rule clarifies that this applies only if their condition “significantly impairs” their ability to work or complete other qualifying activities.
AARP asked CMS to remove this extra hurdle , pointing out that people with complex illnesses risk losing their Medicaid coverage if they have to prove their condition is so serious that they can’t work, volunteer or attend school. It also forces states and medical providers to make a call about whether someone’s condition merits an exemption — something they may not be prepared to do.
“A medical frailty exemption that is too narrow, or too difficult to verify, will cause eligible people with cancer, Parkinson's disease, chronic pain, end-stage organ failure and other severe conditions to lose Medicaid because of paperwork, not because they are ineligible,” O’Reilly warned.
States must first try to verify that someone is “medically frail” using existing records such as case files. 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 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. AARP asked for more flexibility, especially if Medicaid users struggle to get documentation from their health care providers in a timely manner.
“Getting the caregiver exemption right is only part of the answer,” LeaMond said in her statement. “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.”
The key takeaways were created with the assistance of generative AI. An AARP editor reviewed and refined the content for accuracy and clarity.
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