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President Donald Trump’s “big beautiful bill,” enacted in July, requires adults ages 19 to 64 who rely on Medicaid for health coverage to meet certain work requirements.
One notable group exempt from those changes is qualifying family caregivers.
About 7.3 million family caregivers ages 18 to 64 were Medicaid beneficiaries in 2025, out of 63 million total caregivers in the U.S. that year, according to data from the AARP, a nonprofit, nonpartisan organization that advocates for Americans ages 50 and over.
Both affected beneficiaries and the states responsible for implementing the changes have some time before the One Big Beautiful Bill Act provisions go into effect.
States have until Jan. 1, 2027, to adopt the new work requirements.
How states implement those changes is crucial to ensuring uninterrupted Medicaid access for family caregivers, according to new research from AARP.
Family caregivers enrolled in Medicaid provide an average of 35 hours of unpaid care per week, AARP data shows. Family caregivers provide an estimated $600 billion annually in unpaid care, according to the nonprofit’s research.
“The health of a family caregiver is critical to their ability to provide care to their loved ones,” said Megan O’Reilly, vice president of government affairs for health and family at AARP.
How Medicaid changes affect caregivers
The OBBBA includes “community engagement” requirements, also called work requirements, for Medicaid beneficiaries ages 19 to 64.
The work requirements apply to enrollees in Medicaid expansion programs. Certain states expanded their Medicaid programs under the Affordable Care Act to make all individuals below certain income levels eligible for coverage.
Proponents of the new work requirements have said the change could incentivize people to find work and also help curb federal spending. Critics have said some workers may lose health insurance coverage under the restrictions due to complicated reporting requirements.
The new federal law includes $911 billion in Medicaid cuts, with work requirements accounting for the largest share at approximately $326 billion, according to the Congressional Budget Office.
Per the law, individuals will need to have at least 80 hours per month of employment, training or other qualifying activities to qualify for Medicaid coverage.
Notably, family caregivers who are responsible for children ages 13 and under or disabled individuals of any age are exempt from that requirement.
It will be up to those caregivers to prove they qualify for the exemption. States can help to make that process easier, according to AARP’s new research.
What states may consider as they implement changes
While states have until Jan. 1, 2027, to adopt the Medicaid community engagement requirements, they should take the full period leading up to that date to make sure they are fully prepared, according to the AARP.
That initial implementation deadline does come with some flexibility, AARP notes, as states that demonstrate they are working toward compliance with the changes may seek a one-time extension of up to two years, or until 2029.
The One Big Beautiful Bill Act also provides $200 million to states to support those implementation efforts.
As states work toward compliance, there are ways they can implement the law to help ensure family caregivers are exempt from the Medicaid work requirements, according to the AARP.
That includes efforts to help ensure family caregiver enrollees in Medicaid know about the new changes and what they need to do to comply. States may partner with health plans, providers and community-based organizations to help ensure caregivers get the information they need, the AARP research notes.
“One thing we know about family caregivers is that they’re exhausted,” O’Reilly said, and may be caring for both children and aging parents.
“That outreach component is going to be critically important to ensure that people don’t get lost,” she said.
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States may limit the documentation and verification process that family caregivers must undergo to prove they qualify, according to AARP, such as through self-attestation or checkboxes on online or paper registration forms.
States may also consider making it so that compliance verification for both new and existing Medicaid enrollees requires one month of qualifying activity, the shortest possible time period under the new law, according to AARP.
The new law requires states to complete compliance verifications both when an individual first enrolls in Medicaid and when they renew their coverage. While states have discretion to complete those verifications more frequently, in its research, the AARP points to less frequent rechecks as a way to “potentially limit coverage churn and provide some stability for caregiver enrollees.”
To help ensure all Medicaid enrollees who qualify for the caregiver exemption receive it, states may also draw from multiple sources of data, according to the AARP, such as state units and area agencies focused on aging; applications for Medicare, Social Security, Veterans Affairs and other benefits that disclose caregiver status; and health records that document family caregiving situations.
More clarification on the new Medicaid community engagement requirements is expected when the Centers for Medicare and Medicaid Services issues an interim final rule, due by June.