Why Medicaid Work Requirements Could Hurt Older Adults the Most

New regulations will bring unique challenges to people with chronic conditions, caregivers and more

Miriam Cross,

AARP

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Published January 22, 2026

Glenn Harvey

Low-income adults who rely on Medicaid for health coverage are eyeing coming changes that could put their health care at risk. New rules that require older adults to work in order to qualify for Medicaid could be especially burdensome.

The One Big Beautiful Bill Act, signed into law by President Trump in July, calls for certain Medicaid enrollees between the ages of 19 and 64 to work, volunteer, undergo job training or enroll in school for at least 80 hours per month to continue receiving benefits. People who are 50 to 64 will face unique challenges complying when these rules roll out in January 2027, or earlier in some states.

That’s because adults ages 50 to 64 have higher rates of chronic conditions and caregiving responsibilities than younger generations, making it harder to hold down a job but crucial to maintain health coverage. Older adults may find it difficult to handle physically demanding roles they may have held when younger, or they may face age discrimination when trying to reenter the workforce.

“Asking someone to work when they are 61 years old, maybe retired from a blue-collar job that they can’t work any longer, hits differently than for those in a younger demographic,” says Andrea Callow, a policy adviser at AARP’s Public Policy Institute. “Any barrier to them accessing their insurance and the health care services they need will be that much more detrimental.”

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Although the new law exempts some people, including parents of children 13 and under and those enrolled in educational programs, these exemptions are less relevant to adults over 50. Exemptions for caregivers of other people are less clear in the law. People deemed “medically frail” are excused from work requirements, but it is currently unclear which conditions or disabilities will count.

Those who do qualify for exemptions will likely need to provide proof, whether that means navigating an online portal or collecting and uploading the right documentation.

‘The red tape was so bad’

A handful of states, including Arkansas, Kentucky, Michigan and New Hampshire, have experimented with work requirements for Medicaid enrollees in the past. But as recipients struggled to comply with the rules and tens of thousands were cut off or projected to lose Medicaid, most programs shut down or never got off the ground.

“A lot of the people who lost coverage were working or eligible for an exemption, but the red tape was so bad that they couldn’t navigate it,” says Nari Rhee, director of the Retirement Security Program at the University of California Berkeley Labor Center.

For example, more than 18,000 enrollees in the Arkansas Works program were dropped less than a year after it launched in 2018; a federal judge shut down the program in 2019. Health policy research nonprofit KFF found that many people in the program, which applied to recipients up to age 49, were already working. But they struggled to report their hours. Others faced physical or mental health challenges that did not qualify for exemptions but hindered their ability to work.

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Currently, Georgia is the only state that requires some of its Medicaid recipients to engage in 80 hours of work, volunteering or job training. The program launched in 2023, but far fewer people have enrolled than the state originally expected.

“There are people who are eligible but not able to make it through the application process in Georgia,” says Jennifer Tolbert, deputy director of the Program on Medicaid and the Uninsured for KFF. “There is no reason to think that will be any different when this gets implemented nationwide.”

The stakes are particularly high for people between the ages 50 and 64.

About one-third of the 5 million adults who are at risk of losing Medicaid due to work requirements — specifically, those who work less than 80 hours per month or are unemployed and nonexempt — are between the ages of 50 to 64, according to a Yale School of Medicine study published in the October Journal of the American Medical Association. Two-thirds of that specific group of older adults have three or more chronic conditions, while 1 in 5 take five or more prescription drugs, the research found.

“Those medications just go away if they don’t have Medicaid,” says Alissa Chen, an instructor in general internal medicine at Yale School of Medicine. “That means untreated chronic conditions like hypertension and diabetes, which could mean having a stroke, or kidney damage, or a heart attack. These could be preventable if people stay on Medicaid.”

AARP opposes adding new burdens to enrollment, like work requirements, as a condition for receiving Medicaid, but “the reality is that states will have to comply,” says Jordan Endicott, a government affairs director at AARP.

The law exempts caregivers for people with disabilities. But AARP recently urged the Centers for Medicare & Medicaid Services to make it clear that all family caregivers are exempt from meeting these conditions as well, considering that 7.3 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. Moreover, family caregivers average 35 hours of unpaid care each week, including essential tasks such as bathing, dressing and handling finances. A January report from AARP’s Public Policy Institute recommended ways that states can comply with the work requirements process while ensuring family caregivers maintain their Medicaid health care coverage. We also mobilized members to send 115,000 messages to Congress about Medicaid and SNAP cuts in June.

AARP state offices are also lobbying for states to make it clear that family caregivers are exempt and for other measures that make it easier for people to keep their health coverage. For example, AARP Montana is pressing its state government to allow people to simply attest that they are caregivers rather than providing documentation, and to beef up the number of counselors who can help applicants navigate the process.

How Medicaid work requirements will take shape

The Department of Health and Human Services will release its work requirements regulation by June 2026. That gives states six months to iron out their plans before the January 2027 implementation deadline, including building new systems and educating people on how to use them. States can roll out these changes earlier if they choose or apply for an extension.

The timeline is “extremely accelerated,” Callow says.

When KFF surveyed state Medicaid officials this past summer, respondents voiced concern about overhauling their systems on such a tight timeline. Some predicted a strain on state budgets and coverage loss among recipients.

States will have some flexibility under the law and depending on what path they choose, the new rules could make it easier or more difficult for individuals to comply.

For example, when people apply for Medicaid coverage, all states will have to “look back” to ensure that applicants have been complying with work requirements for at least one month. But they can choose to look back up to three months. States must check that enrollees are still eligible for Medicaid every six months, at minimum. But they can opt to do so more frequently. States may also provide exceptions for people experiencing short-term hardships, like those in counties with high unemployment rates or in areas where a disaster has been declared.

There are also many outstanding questions, such as how these systems will account for people with seasonal jobs or gig positions.

“People’s lives aren’t clean,” Callow points out. “They work for a few months and don’t work for a few months.”

If someone loses their Medicaid coverage because they fall through the cracks of the new system, options for affordable health care are slim. Starting in January 2027, people won’t qualify for premium tax credits on Affordable Care Act plans if they are denied Medicaid due to work reporting requirements.

Those who are employed with robust health coverage have reason to worry as well.

“An extremely important population is everyone else who is currently working, has insurance through their job, loses their job and needs insurance while trying to find a new job,” Callow says. “This isn’t just bad for people who have Medicaid now. It’s bad for anybody who might ever need a hand after they lose a job.”

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