The 2025 budget reconciliation package—also known as H.R.1 or the One Big Beautiful Bill Act—will force changes to the Medicaid program in less than a year. Beginning in January 2027, continued eligibility will hinge on additional requirements: completing 80 hours of “community engagement” (employment or a qualifying volunteer commitment) each month and documenting the activity as part of an official report. Because of these time-consuming and potentially confusing administrative hurdles, New York State estimates over one million residents on Medicaid could be at risk of losing their coverage.
Some groups will be exempt from the work requirements, including people with disabilities and those who are pregnant or deemed “medically frail.” Family caregivers will also be exempt from the new work requirements, but this exemption focuses on caregivers of children 13 years old and younger as well as caregivers of family members with a disability.
The new work requirements will extend to Medicaid enrollees up to age 64, creating an undue burden for a demographic that routinely faces age discrimination when navigating the job market. This group includes family caregivers of older adults—many of whom tend to be above 50.
Over four million New Yorkers are family caregivers. They contribute to the care continuum and provide uncompensated services estimated at an annual economic value of 39 billion dollars. Family caregivers typically report high levels of stress, financial burdens, and health problems resulting from their caregiver role. Lapsed health insurance coverage will only exacerbate these issues for caregivers and make it harder for them to provide vital care for their loved ones.
As the implementation of new Medicaid rules begins, New York State can take several steps to ensure that more people—especially a group as essential as family caregivers of older adults—can stay enrolled in their health coverage. The first step is to define the term caregiver.
Defining “Caregiver”
Legislation from 2018—named the RAISE Family Caregivers Act and signed into law by President Donald Trump—provides a broad definition of caregiver: “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.” The RAISE definition was briefly referenced in last year’s H.R. 1 reconciliation bill, but emphasis was on caregivers of dependents 13 and under.
As we anticipate the start of 2027, many questions remain, including:
- How will the new Medicaid work rules be rolled out?
- How will caregivers be defined?
- Could enrollees, including caregivers of older adults, potentially slip through the cracks and lose their Medicaid coverage?
States will need to implement the new work requirements in less than a year. A clear and well-communicated definition of family caregiver for exemptions will be very important to ensuring more caregivers can stay enrolled.
Keeping Caregivers Covered
In addition to an inclusive definition of caregiver, New York State can help this group keep their Medicaid coverage in a number of ways:
- Provide fair timelines and accessible information about the rollout of new rules and procedures
- Ensure the implementation process is appropriately funded, staffed, and resourced
- Conduct extensive community outreach about any and all changes to the Medicaid program
New York State must ensure that the implementation process for the new Medicaid work requirements is humane and strategic so that hardworking caregivers of all ages won’t lose their Medicaid coverage—through no fault of their own.
