The Medicaid and CHIP Payment and Access Commission (MACPAC) released its March 2026 Report to Congress, which includes a single recommendation with significant implications for home- and community-based services (HCBS) providers.

MACPAC recommends that the Secretary of the U.S. Department of Health and Human Services (HHS) direct the Centers for Medicare & Medicaid Services (CMS) to amend 42 CFR § 441.311(e)(2) to require states to report hourly wages paid to HCBS workers providing the following services:

• Personal care
• Home health aide
• Homemaker
• Habilitation

Under the recommendation, states would be required to submit descriptive wage data for each service, with additional detail based on workforce characteristics defined by HHS. This includes, at a minimum:

• Licensed nurses versus other direct care workers
• Rural versus urban settings

CMS would be directed to build on existing or planned data collection efforts and publish this information publicly on its website.

Alignment with Existing Medicaid Access Rule

These four services are already subject to reporting requirements under the Ensuring Access to Medicaid Services Final Rule (2024). Current regulations require states to report annually on the percentage of total payments spent on direct care worker compensation for these services.

However, MACPAC’s recommendation appears to go further by emphasizing actual hourly wage reporting, rather than percentage-based spending metrics, and by requiring additional data stratification, particularly by licensure and geography.

At this time, it remains unclear how CMS would distinguish these new requirements from existing reporting obligations beyond these added layers of detail.

Intersection With the 80/20 Requirement

Three of the four services identified — personal care, home health aide, and homemaker — are also subject to the 80/20 Medicaid payment passthrough requirement, which mandates that at least 80% of Medicaid payments for these services be spent on direct care worker compensation.

Stakeholders, including HCAF and national partners, are actively engaging with CMS regarding repeal of this requirement. While the future of the passthrough policy remains uncertain, CMS has indicated it may retain reporting requirements regardless of whether the 80/20 provision is ultimately rescinded.

MACPAC’s recommendation may further reinforce the case for maintaining and expanding HCBS wage reporting at the federal level.

What This Means for Providers

If adopted, this recommendation could lead to:

• Increased transparency into HCBS workforce wages
• Additional state reporting requirements
• Greater federal focus on workforce compensation and access to care

HCAF will continue monitoring federal developments and engaging with CMS and national partners to ensure that any new requirements are implemented in a way that supports providers while preserving access to care.

The full MACPAC March 2026 Report to Congress is available here.