Recent updates to Medicaid policies, introduced through President Donald Trump’s "One Big Beautiful Bill Act", include significant changes that will impact millions of Americans. Among the most notable provisions are new work requirements for Medicaid beneficiaries ages 19 to 64. However, family caregivers who meet certain criteria are exempt from these new rules, a move that acknowledges their critical role in providing unpaid care.
New Work Requirements Introduced
The changes, enacted in July 2025, require Medicaid recipients in the specified age group to complete at least 80 hours per month of employment, training, or other qualifying activities to maintain their coverage. These "community engagement" requirements apply to individuals enrolled in Medicaid expansion programs under the Affordable Care Act, which was designed to extend coverage to eligible low-income individuals.
Proponents argue these requirements could encourage more people to enter the workforce while also reducing federal spending on health care programs. However, critics warn that some individuals may lose their coverage due to the complexity of reporting and compliance processes.
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Family Caregivers Exempt from Work Mandate
One group spared from these new conditions is family caregivers who are responsible for children under the age of 13 or individuals with disabilities of any age. These caregivers will not need to meet work requirements to maintain their Medicaid benefits. According to data from AARP, approximately 7.3 million family caregivers aged 18 to 64 were Medicaid beneficiaries in 2025. These caregivers provide an average of 35 hours of unpaid care per week, contributing to an estimated $600 billion in unpaid care annually.
Megan O’Reilly, vice president of government affairs for health and family at AARP, stressed the importance of caregiver health in supporting their ability to provide care. "The health of a family caregiver is critical to their ability to provide care to their loved ones", O’Reilly said.
Implementation and State-Level Preparation
States have until January 1, 2027, to implement these work requirements, although extensions of up to two years are available if they demonstrate progress toward compliance. The federal government has allocated $200 million to help states prepare for these changes.
To ensure a smooth implementation, AARP research highlights steps states can take to protect family caregivers and ensure they maintain uninterrupted Medicaid access. This includes educating caregivers about the exemptions and simplifying the process for proving eligibility. "One thing we know about family caregivers is that they’re exhausted", O’Reilly said. "That outreach component is going to be critically important to ensure that people don’t get lost."
States are encouraged to limit the administrative burden on caregivers, such as allowing self-attestation or simplified checkboxes on forms to confirm exemption eligibility. They may also use existing data sources, including health records and applications for other benefits, to verify caregiver status.
Avoiding Coverage Gaps
To minimize disruptions, AARP suggests states adopt less frequent verification requirements for caregiver exemptions. For example, compliance checks could be conducted annually or during coverage renewal periods instead of more frequent intervals. This approach could reduce "coverage churn", where individuals temporarily lose access to Medicaid due to missteps in the compliance process.
The Centers for Medicare and Medicaid Services is expected to issue additional guidance in an interim final rule by June, providing further clarification on the implementation of these policies.
As states prepare for these changes, the focus remains on balancing federal cost-saving measures with the need to protect vulnerable populations, including family caregivers who play a vital role in supporting loved ones and the broader health care system.