Can Caring for Grandkids Count Toward Medicaid Work Rules?

There are two separate questions to think about.

1. Does the Medicaid community engagement requirement apply?

Before asking whether caring for grandchildren counts as “work,” the first question is whether the individual is actually subject to the requirement.

According to CMS, the community engagement requirement generally applies to certain non-pregnant adults ages 19 through 64 who are not entitled to or enrolled in Medicare and who receive Medicaid through the adult expansion group or certain demonstration programs. States generally must implement the requirement by January 1, 2027.

The federal rule also identifies several groups that are excluded from or excepted from the requirement, including, among others:

• pregnant or postpartum people,
• people who are disabled, medically frail, or have special medical needs,
• parents, guardians, caretaker relatives, or family caregivers of a dependent child age 13 or younger or a disabled person,
• American Indians and Alaska Natives,
• former foster care youth,
• veterans with a total disability rating,
• people in drug or alcohol treatment,
• certain people who already meet TANF or SNAP work rules,
• and some others.

So before asking whether grandchild care counts as “work,” the first question is whether the person is covered by the work rule in the first place.

2. How does the rule treat family caregiving?

The regulation defines “work” broadly. In addition to paid employment, qualifying activities may include self-employment, certain in-kind work, and some forms of unpaid work.

The rule also specifically addresses family caregiving. Depending on the circumstances, caregiving may count as qualifying unpaid work, or it may qualify someone for a caregiver-related exclusion from the work requirement.

The federal rule recognizes caregiving for a dependent child or a disabled individual. For this rule, CMS defines a dependent child as a child age 13 or under who relies on another individual for care.

CMS describes three general ways someone may qualify as a family caregiver:

1. The caregiver primarily lives with the dependent child or disabled person and provides regular care.
2. The caregiver is a relative of the dependent child or disabled person, provides regular care, and does not have to live with them.
3. The caregiver is not related and does not live with the person receiving care, but provides at least 80 hours of care per month.

For relatives—including grandparents caring for grandchildren—the federal regulation does not establish a minimum number of caregiving hours. Instead, the caregiving generally must be regular and more than merely incidental. The 80-hour threshold is primarily relevant to non-relative caregivers who do not live with the person receiving care.

So, can caring for grandchildren count?

Potentially, yes. If a grandparent is providing regular care for a grandchild who is a dependent child under the federal definition, that caregiving may qualify the grandparent for the caregiver exclusion from the community engagement requirement, depending on the facts and how the state verifies the caregiving. In other situations, unpaid caregiving hours may also count toward satisfying the monthly community engagement requirement. The applicable pathway depends on the individual’s circumstances and the state’s implementation of the federal rule.

Because Medicaid eligibility and compliance determinations are made by the state Medicaid agency based on an individual’s specific facts and documentation, the agency makes the final determination regarding how the federal rule applies in a particular case.