On behalf of the Caregiver Nation Coalition (CNC), powered by the National Alliance for Caregiving (NAC), 67 national organizations sent a letter to the Centers for Medicare & Medicaid Services (CMS) urging federal regulators to protect family caregivers as states implement new Medicaid work requirements included in the FY 2025 budget reconciliation law, OBBBA (Pub. L. 119-21).
With up to 8 million family caregivers relying on Medicaid for their healthcare coverage, the coalition letter calls on CMS to ensure that family caregivers who rely on Medicaid are not penalized under the new work requirement provisions. The OBBBA references the RAISE Family Caregivers Act’s broad definition of family caregiver, allowing states flexibility to exempt eligible family caregivers.
“Caregiving isn’t just work—it’s the work that holds our entire healthcare system together,” said Jason Resendez, President and CEO of the National Alliance for Caregiving. “CMS must act decisively to protect the 8 million family caregivers who depend on Medicaid ensuring they can continue providing care without sacrificing their own access to healthcare.”
The Caregiver Nation Coalition, representing more than 120 organizations across the caregiving, aging, disability, and health advocacy communities, urged CMS to take four key steps as it develops implementation guidance:
- Leverage existing statutory flexibility to exempt eligible family caregivers;
- Automatically exempt caregivers in consumer-directed, self-directed, or Veterans-directed care programs;
- Simplify verification processes through self-attestation and use of existing data sources; and
- Encourage stakeholder engagement during federal and state rulemaking.
America has more than 63 million family caregivers providing ongoing complex care. According to a 2021 study, family caregivers provide an estimated $600 billion in unpaid care annually. Family caregivers are the backbone of our healthcare and long-term care systems. Up to 8 million of these caregivers depend on Medicaid for their own health coverage. Without careful implementation, work requirement mandates risk creating unintended consequences: adding administrative burdens to family caregivers already navigating complex healthcare systems while simultaneously jeopardizing both their coverage and their loved ones’ care.
The coalition stands ready to work with CMS to ensure implementation of the OBBBA prevents these unintended consequences, honors the contributions of America’s family caregivers, and safeguards their access to essential care and services.
Read the full letter.


