Washington, D.C. — In response to the interim final rule from the Centers for Medicare & Medicaid Services (CMS) on Medicaid work requirements, the National Alliance for Caregiving issued the following statement:
At a pivotal moment for Medicaid, the interim final rule takes an important step by exempting many family caregivers from work requirements — including those caring for children, adults with disabilities, and aging parents — and by giving states meaningful flexibility in how they verify eligibility as these requirements first take effect. We appreciate CMS’s recognition that caregiving is demanding work.
We remain concerned, however, that the rule offers caregivers no guaranteed way to confirm their status through self-declaration, even as CMS acknowledges that family caregivers rarely have documentation. As the stricter documentation standard takes effect in 2028, eligible caregivers risk losing coverage not because they fail to qualify, but because of paperwork, data-matching, and other administrative barriers.
We are especially concerned by the rule’s narrow definition of medical frailty, which is more restrictive than many states expected. A qualifying diagnosis is no longer enough — individuals must have a condition that significantly impairs their ability to work, and states may not expand the definition or exempt people based on diagnosis lists alone. This tighter standard will lower the share of enrollees who qualify, force states to rebuild systems already underway, and put people with serious health conditions like cancer and rare diseases at greater risk of losing coverage.
“Caregiving is work, and CMS was right to recognize it. But exemptions only matter if people can actually claim them,” said Jason Resendez, President and CEO of the National Alliance for Caregiving. “Between the looming documentation requirement and a medical frailty standard that’s more restrictive than states expected, the people most likely to lose coverage are the ones already holding our care system together.”
The National Alliance for Caregiving urges Congress, the Administration, and the states to give family caregivers and the people they care for the support they need as these requirements take effect, so that those who qualify can get and keep their coverage. As implementation moves forward, policymakers should prioritize clear pathways for caregiver verification, minimize administrative barriers, and protect individuals with serious health conditions from losing access to essential care. Without these safeguards, families risk facing additional stress, financial strain, and caregiving responsibilities at a time when many are already at a breaking point.
To support family caregivers and advocates navigating these changes, NAC has developed resources on the importance of protecting home and community-based services and strengthening other caregiver support programs, including the Older Americans Act funded National Family Caregiver Support Program. NAC remains committed to working with state leaders and policymakers to strengthen these protections and ensure family caregivers get the support they need. The care they provide is complex and demanding—and it saves Medicaid and Medicare billions of dollars annually.
