Medicaid Work Requirements & Family Caregivers

Medicaid is an important source of health insurance coverage for many of the 40 million family caregivers in the United States who do not have access to other affordable coverage options. However, many states are in the process of designing or implementing policies that require family caregivers and others who are eligible for Medicaid to work a certain number of hours per month or qualify for an exemption to maintain their health coverage. Low-income family caregivers may be unable to work sufficient hours at a paid job because of their caregiving responsibilities and may not qualify for the state’s exemptions. As a result, many will lose access to health care they need to maintain their own health, harming both their own well-being and the well-being of the older adults they care for.

A new Justice in Aging issue brief provides a state-by-state survey of how Medicaid work requirements apply to family caregivers and explains the harms they will cause to family caregivers and the older adults they care for. Here are the key facts and findings.

Key Facts and Findings:

How Work Requirements Apply to Family Caregivers:

  • 17 states are either implementing or have a written plan to impose work requirements as a condition of Medicaid eligibility.
  • For Medicaid enrollees under 65 who are not working, having caregiving responsibilities is a primary reason why they don’t work outside the home.
  • Though all states that plan to impose work requirements do provide some exemptions for family caregivers, these exemptions vary widely and are often unclear.
  • The majority of states limit the caregiver exemption to caring for a dependent, a relative/family member, or a household member.
  • Only 5 states explicitly count caregiving hours towards meeting the work requirement.

The Impact:

  • Work requirements are extremely burdensome for beneficiaries to navigate and for states to administer.
  • In addition to having to gather documentation and timely report compliance, barriers include difficulty communicating and understanding the requirements, lack of internet access to report compliance, and lack of transportation to find or get to work.
  • Requiring family caregivers to report caregiving hours to maintain their Medicaid coverage puts the greatest burden on those who already face the most stressful situations of caring for a loved one with significant and complex needs.
  • Requiring family caregivers to verify that they are either working or exempt from the requirement will inevitably lead to Medicaid-eligible individuals losing their coverage.
  • Without Medicaid coverage, family caregivers will have greater difficulty maintaining their own health, thus compromising their ability to provide care to others.
  • Because family caregivers are more likely to be low-income, older, women, and people of color, compromising Medicaid coverage for this population will increase the health disparities they already face.
  • Taking away Medicaid coverage from family caregivers also puts more older adults at risk of being institutionalized because their family or friends can no longer care for them at home and in their communities.

Find out the details about the caregiver exemption in each of the 17 states and what these policies mean for family caregivers and older adults in the full issue brief.

Work Requirements in States that Have Expanded Medicaid

State & Waiver StatusHours of work requiredCaregiving Hours Counted?"Good Cause Exemption" for having immediate family member w/disability or serious illnessCaregiver ExemptionsAge Exemptions
Arkansas (In Effect)80 hours/monthyesyes“Caring for an incapacitated person”50+
Arizona (Awaiting CMS Decision)20 hours/weeknono"Caregivers of a family member who is enrolled in the Arizona Long-Term Care System"55+
Indiana (Approved)0-20 hours/week (phased in over 18 months), including “Caregiving services for a non-dependent relative or other person with a chronic, disabling health condition, including individuals receiving FMLA to provide caregiving”yesyes"Beneficiaries who are a primary caregiver of…a disabled dependent"60+
Kentucky (Invalidated by Court Awaiting New CMS Decision)80 hours/month Including "caregiving services for a non-dependent relative or other person with a chronic, disabling health condition"yesyes“Primary caregivers of a dependent, including either a dependent minor child or disabled adult dependent (limited to only one exemption per household)”65+
Michigan (Submitted to CMS)80 hours/monthyesyes“A caretaker of a dependent with a disability who needs full-time care based on a licensed medical professional’s order (this exemption is allowed one time per household); A caretaker of an incapacitated individual even if the incapacitated individual is not a dependent of the caretaker”63+
New Hampshire (Approved)100 hours/month including “Caregiver services for a nondependent relative or other person with a disabling medical or developmental condition.”yesyes“A parent or caretaker as identified in RSA 167:82, II(g) where the required care is considered necessary by a licensed physician, APRN, board-certified psychologist, physician assistant, or licensed behavioral health professional who shall certify the duration that such care is required.”65+
Ohio (Awaiting CMS Approval)80 hours/monthno good cause exemption for "illness of another requiring presence of the member""Caring for a disabled/incapacitated household member" "Good Cause Exemption illness of another requiring the presence of the member50+
Virginia (Expansion takes effect January 2019; not yet submitted to CMS20-80 hours/month increasing over time including "caregiving services for a non-dependent relative or other person with a chronic, disabling health condition"yesGood cause exemption for individuals "who reside with an immediate family member who experiences a hospitalization or serious illness""Primary caregiver for an adult dependent with a disability or a non-dependent relative"(Good Cause exemption for individuals “who reside with an immediate family member who experiences a hospitalization or serious illness”)65+ no duals

Work Requirements in States that Have Not Expanded Medicaid

State & Waiver StatusHours of work requiredCaregiving Hours Counted?"Good Cause Exemption" for immediate family member w/disability or serious illnessCaregiver ExemptionsAge Exemptions
Alabama (Awaiting CMS Approval)35 hours/week 20 a week for parents/caretakers to a child under sixnounclear-good cause exemptions along the lines of those for TANFAnyone required to care for a disabled child or adult (unclear: good cause exemptions along the lines of those for TANF)60+
Kansas (Awaiting CMS Approval)20-30 hours/week depending on number of adults and whether children under six in householdnono"Caretakers for dependent children under six years or those caring for a household member who has a disability"…"Certain caretakers of KanCare members 65 years and older who meet the criteria specified by the state."65+
Maine (Awaiting CMS Approval)20 hours/weeknono"Providing caregiver services for an incapacitated adult"65+
Mississippi (Awaiting CMS Approval)20 hours/weeknono"primary caregiver " for: " aperson diagnosed with a mental illness" "a disabled family member" 65+
Oklahoma (not yet a formal waiver Application)80 hours/monthnono"A parent or caretaker personally responsible for the care of an incapacitated person"51+
South Dakota (limited to 2 counties; Awaiting CMS Approval) 80 hours/month or achieve monthly milestones in individualized emplouyment and training plan, which may include "caregiving for an elderly or disabled individual"yesno"nonparent caretaker relatives" and "primary caregivers of elderly or disabled individuals living in the caretaker's residence"60+
Utah (income limit would be 100% of FPL for "expansion population"30 hours/week Or job search/training if not workingnoyes"Responsible for the care of an incapacitated person"60+
Tennessee (not yet submitted to CMS)20 hours/weeknoyes"Individuals who are providing caregiver services for a household member (child or adult) with a disability or incapacitation" 65+
Wisconsin (income limit is 100% of FPL for childless adults. Waiver approved)80 hours/monthnono"primary caregiver for a person who cannot care for himself or herself" 50+