Alliance Warns MACPAC’s HCBS Draft Recommendation Would Add To Provider Burden

On Thursday, the Medicaid and CHIP Payment and Access Commission (MACPAC) unveiled a draft recommendation calling for states to ramp up data reporting on hourly wages for home and community-based services (HCBS) workers – a proposal that drew criticism from the National Alliance for Care at Home (the Alliance).

MACPAC’s drafted recommendation would increase administrative burden on HCBS providers, the Alliance said.

Specifically, the draft recommended that the Secretary of Health and Human Services instruct the Center for Medicare and Medicaid Services (CMS) to require states to report biannual data on hourly wages for HCBS workers providing services such as personal care, home health aide, homemaker and habilitation. The reports should include statistical details such as mean, median and range, and be broken down by worker type and location. CMS should compile this data into a public repository.

The draft recommendation is intended to support the HCBS workforce, whose shortages hinder states’ ability to meet the long-term care needs of people in their homes or communities. Many states are considering using Medicaid rate-setting to boost the HCBS workforce and reduce worker turnover.

According to MACPAC, this recommendation was made because wage data are essential for HCBS rate development, and states have highlighted the need for better wage data to support rate calculations. It arrived at this recommendation after reviewing a compendium of Section 1915(c) waiver policies, stakeholder interviews and a technical expert panel.

This approach would provide states with more detailed and accurate wage data, including comparative data from nearby states. They would also retain the flexibility to determine how to set rates and specific payment amounts.

MACPAC noted that this recommendation should not require much additional state effort, as it uses data that states are already required to collect under the access rule and might even help states reduce data collection.

Implications

MACPAC said its recommendation will not affect federal spending, those enrolled in plans or the plans themselves. However, providers might face a minimal direct impact since they may be required to report more data under this recommendation than under the access rule alone.

MACPAC stated that enrollees could benefit from this recommendation, as higher payment rates attract more workers and improve access to HCBS.

However, the Alliance voiced concern about the draft recommendation in a statement released after the meeting.

“Rather than seeking to address the root cause of low worker wages, MACPAC’s recommendation instead focuses on collecting additional information that would further describe the issue,” the Alliance said in the statement. “This approach increases administrative burden on states and providers without actually proposing solutions to this problem.”

The Alliance urged MACPAC and its commissioners to be “bold and recommend structural changes to federal Medicaid law and regulations that mandate payment policies ensuring access to HCBS through livable wages for direct care workers.”

It commented that CMS should have the authority to require states to perform rate studies every five years, submit a copy of the rate review report and recommendations with any waiver renewal or state plan amendment and make that information publicly available. The draft also recommended that states be required to justify any variance between the report recommendations and actual established payment rates.

The Alliance also suggested that CMS should be authorized to disapprove rate methodologies that do not clearly account “for all statutory and regulatory requirements of delivering services.”

The draft recommendation will be subject to a vote at its October meeting, where staff will present a draft chapter for the March 2026 report to Congress.