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No. 102October 18, 2026

States face a 2027 deadline to prepare direct care compensation reports

Beginning July 9, 2028, states must annually report to CMS the share of Medicaid payments for specified home and community-based services spent on direct care worker compensation.

1 development · 3 cited sources

The question

How will states collect the data needed to show what share of Medicaid payments reaches direct care workers?

The read

States must report separately for each service and, within each service, separately on self-directed services and services delivered in a provider-operated physical location for which facility-related costs are included in the payment rate. States are responsible for collecting the necessary data, and providers and managed care plans in states with managed care delivery systems are anticipated to be key partners. The reporting obligations are intended to give CMS visibility into whether payment rates translate into adequate direct care worker wages. SMD 26-005 is about reporting only and does not set a minimum share.

What happens next

States are encouraged to engage with their HCBS providers and managed care plans, if applicable, to determine roles and responsibilities and establish processes and procedures for collecting necessary data.

What could change this read

This read would change with state readiness reporting, which is required by July 9, 2027.

Developments in this issue

Reference paths

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