Short answer: No. The IRS annual gift tax exclusion has nothing to do with Medicaid. A gift that owes no gift tax can still be a penalized transfer if it falls in the 60-month look-back.
The Medicaid transfer rules in federal law penalize any transfer for less than fair market value made in the look-back period. There is no carve-out for gifts within the gift tax exclusion, for birthday or holiday gifts, or for helping grandchildren with tuition.
Families often hear “you can give a certain amount per person each year” and assume it is safe. For Medicaid, every such gift in the 60-month window is added up and divided by the Texas daily divisor ($262.37 per day for cases decided on or after 09-01-2025) to set the penalty.
The family can try to show a transfer was made exclusively for a reason other than qualifying for Medicaid, but the burden is on them. Planning gifts around a possible nursing home stay is an elder-law question.