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Ensure Family Caregivers are Exempt from Medicaid Work Requirements
On December 8, 2025, CMS issued guidance to states regarding implementation of work requirements (often referred to as “community engagement”) in Medicaid programs across the U.S. Work requirements will unduly burden family caregivers and have a devastating impact on those who rely on family caregivers to live in their homes.
Work requirements are a result of H.R. 1, the budget reconciliation bill, Pub. L. 119-21, that was signed into law in July 2025. This law outlined a small group of those who can be exempted from work requirements – including family caregivers. As defined by the RAISE Family Caregivers Act, a family caregiver is “an adult family member or other individual who has a significant relationship with, and who provides a broad range of assistance to, an individual with a chronic or other health condition, disability, or functional limitation.”
Advocacy Opportunity – Now is the Time to Act!
As states begin to operationalize work requirements and reporting requirements, we encourage family caregiving advocates to contact their Governor, State Medicaid Director, and State Aging Departments.
The Caregiver Nation Coalition created a template letter that outlines several strategies that state policymakers can take to broadly exempt family caregivers from burdensome Medicaid work requirements. We encourage state advocates to personalize this letter through state-specific messaging, caregiver data, and personal stories.
Identifying Your State Policymakers
Messaging Resources
- Caregiver Nation Coalition sign-on letter urging CMS to exempt family caregivers from work requirements in implementation guidance, (November 4, 2025)
- National Alliance for Caregiving policy brief, “The Invisible Workforce: How Medicaid Work Requirements Overlook the Labor of Family Caregiving” (May 2025)
- National Alliance for Caregiving policy brief, “The Role of Medicaid in Supporting Family Caregivers” (February 2025)
- Justice in Aging Medicaid Defense Resources and Mitigating the Harms of Medicaid Work Requirements for Older Adults: Tools for State Advocates
- AARP Letter to CMS urging exemption of family caregivers from Medicaid community engagement requirements (November 7, 2025)
- Other NAC and Caregiver Nation Coalition resources on Medicaid