​Through this proposal, CMS is requesting stakeholder input on several key areas, including:

• Which measures should be added to or removed from the HCBS Quality Measure Set
• How CMS should further standardize quality measurement across state HCBS programs
• A proposed subset of measures that would become mandatory for states to report
• Technical elements such as data sources, reporting methods, and stratification requirements
• Whether states should be allowed to use alternative measures (such as HEDIS or FASI equivalents) for certain LTSS measures

 
Presumably, CMS’s broader goal is to create a more uniform, comparable system for evaluating HCBS quality nationwide. While much of the notice is technical, the decisions made here will directly shape how quality is defined and measured in Medicaid home- and community-based care.
 
What This Could Mean for Your Agency
If finalized, these proposals could affect home care providers in several ways:

• Expanded data collection and reporting expectations
• Increased administrative and compliance burden
• Greater reliance on participant surveys and standardized tools
• Potential downstream impacts on oversight, program evaluation, and future policy decisions

 
Our Focus: Proposed Mandatory Measures (Table 4)
 
HCAOA is specifically seeking member input on the measures CMS is proposing to make mandatory for state reporting. These measures are listed in Table 4 of the notice and represent the most immediate and consequential part of the proposal.
 
To more closely examine Table 4, please click here and scroll to page 9.
 
Below is HCAOA’s best attempt at a plain-English summary of those the proposed mandatory measures contained in Table 4.
 
Proposed Mandatory HCBS Quality Measures
 
1. Participant Experience (HCBS CAHPS Survey)
Collected through standardized beneficiary surveys

• Choice of Services
  Whether individuals feel they can choose the services that matter most to them
• Safety and Respect
  Whether individuals feel safe and are treated with respect by caregivers
• Physical Safety
  Whether individuals report feeling physically safe in their home
• Transportation to Medical Appointments
  Whether individuals can reliably get to medical appointments

 
What this means: States would rely heavily on standardized patient surveys to evaluate quality and provider performance.
 
2. Care Planning and Assessment (LTSS Measures)
Collected through case management or assessment systems; required reporting with stratification

• LTSS-1: Comprehensive Assessment
  Whether required needs assessments are completed and documented on time
• LTSS-2: Person-Centered Care Plan
  Whether care plans are developed, updated, and include required person-centered elements

 
What this means: Increased expectations around documentation, assessments, and care planning processes, even where home care agencies may not control those functions.
 
3. Facility Use and Transitions (Administrative Data)
Based on Medicaid claims and enrollment data; required reporting with stratification

• Admissions to Facilities (LTSS-6)
  Tracks how often individuals receiving HCBS enter institutional settings
• Length of Stay in Facilities (LTSS-7)
  Measures how quickly individuals return to the community after entering a facility
• Successful Return to the Community (LTSS-8)
  Tracks whether individuals remain in the community after discharge

 
What this means: Providers may be evaluated based on broader system outcomes that are often outside their direct control.
 
4. Participant Experience (NCI-AD – Aging & Disability Survey)
Survey-based measures

• Whether individuals are as active in the community as they want to be
• Whether individuals feel safe around support staff
• Whether individuals have transportation for medical and non-medical needs
• Whether service plans reflect their preferences and choices

 
5. Participant Experience (NCI-IDD – Intellectual/Developmental Disabilities Survey)
Survey-based measures

• Satisfaction with community participation
• Social connectedness (for example, not feeling lonely)
• Access to transportation
• Respect for personal space at home
• Whether personal goals are reflected in service plans

 
6. Quality of Life Outcomes (CQL Personal Outcome Measures)
Survey-based measures

• Freedom from abuse, neglect, or exploitation
• Ability to choose services and supports
• Participation in community life
• Ability to achieve personal goals

 
We Want to Hear From You
Your feedback will directly inform HCAOA’s comments to CMS and therefore national Medicaid policy.
 
As you review these proposed mandatory measures, please consider using the following as a metric for evaluation:

• Which measures would be most burdensome or difficult to report?
• Do any measures rely on data you do not currently collect?
• Are there measures that do not apply to non-medical home care providers?
• Could any measures create access challenges or unintended consequences?
• Do any measures fail to accurately reflect quality in a home care setting?

 
If you are unsure whether a measure applies to your organization, feel free to note that.
 
Please send your feedback to eric@hcaoa.org no later than COB Friday, May 22, 2026.
 
As always, thank you for your advocacy on behalf of our industry!

This extension provides additional time to work with your CPA to compile the documentation required under the HCSF financial reporting law that applies to this renewal. 
 
Audit requirements 
As a reminder, under current law an HCSF is required to submit an audit, in addition to a financial statement, if it: 
 
Received more than $250,000 for the provision of NJ Medicaid Personal Care Assistance in 2025 

• An audit must be submitted every three (3) years. 

• For HCSFs registered prior to July 1, 2022, an audit is due 2026, 2029, 2032, etc. 

• For HCSFs registered after July 1, 2022, an audit is due three years after initial registration and every three years thereafter.
  
  

Generated $10 million or more in gross income in a year. 
An HCSF is required to submit an audit after any year from when gross income was $10 million or more (i.e., a HCSF that generates $10 million or more in gross income each year will be required to submit an audit with each registration renewal. 
 
For more information, read the division’s FAQ about HCSF Financial Reporting Requirements. 
 
Toward a Legislative Solution: S3463 / A4790
The good news: Legislation has been introduced to help mitigate the negative effects of some of these onerous reporting requirements. 
S3463 / A4790 would modernize New Jersey’s financial reporting framework while maintaining accountability. 

Key reforms include: 

• Raising the Medicaid audit threshold from $250,000 to $500,000 

• Extending audit deadlines to September 30 

• Modernizing compensation reporting thresholds 

• Streamlining and clarifying reporting requirements 

• Allowing corrective action opportunities 

• Permitting qualified out-of-state accountants to conduct audits 

This legislation represents a balanced, common-sense approach, reducing red tape without sacrificing oversight. 
 
Take Action 
HCAOA is actively advocating for passage of these reforms, but provider voices are critically needed. 
 
Please ask your New Jersey senator and assemblyperson to support these bills in their respective chambers. 
We encourage all New Jersey providers to stay informed, share their experiences, and act to support these much-needed reforms. If you have any questions, please contact HCAOA Director of Government Relations Allison Cramer or join our monthly Government Relations Office Hours. These informal drop-in sessions offer members an opportunity to ask questions, share challenges, and discuss policy and advocacy issues. 

UPDATE
The revised HCSF audit bill is now scheduled for a hearing before the Senate Health, Human Services and Senior Citizens Committee Monday, May 11 at 1 p.m. in Trenton.

The hearing is an opportunity to deliver relief from the financial reporting requirements that have generated widespread frustration. Provider presence at the committee hearing will carry real weight. Even a modest turnout from agency owners can send a powerful signal to legislators about the urgency of this issue. If you are able to attend, your voice matters.

At the same time, you’re navigating a shrinking direct-care workforce, external pressure around fraud, waste, and abuse, and being asked to implement new strategies and ongoing change initiatives.
 
You’re not just leading anymore. You’re interpreting complexity in real time.
 
For many leaders I’ve worked with, this shift hasn’t happened all at once. It’s been gradual, but persistent. And over time, it creates something that isn’t always named but is widely felt: leadership strain.
 
Applying a Different Lens
It’s easy to see this as a capacity issue, and in many ways, it is. But there’s another layer worth paying attention to.
 
Part of what’s emerging here is a development opportunity. Not in the form of more training or additional tools, but in how leaders experience and respond to pressure as it’s happening. Because in moments of tension, most responses aren’t intentional — they’re automatic. A quick reaction. A push to resolve. Moving forward because there isn’t time to pause.
 
Those patterns make sense. They’ve likely helped you navigate a lot, but over time, they can also lead to fatigue, reactivity, and misalignment.
 
Where Leadership Starts to Shift
What begins to change things isn’t adding more; it’s seeing more clearly in the moment.
That shift is subtle, but important: the ability to notice when tension is building, to create even a brief pause, and to choose a response rather than defaulting to one.
 
Organizations can support this not only by adding resources, but by shaping the environment leaders are operating in:

• Creating space to pause, even briefly, before action
• Reinforcing self-awareness as a core leadership skill
• Allowing for autonomy in how leaders respond, rather than relying on rigid approaches

 
Leaders don’t necessarily need more tools.  They need clarity in how and when to use them. They need the ability to discern which response is needed — and when.
 
A Place to Start
In the middle of everything you’re carrying, you don’t need to overhaul how you lead.
Just begin here:

• What do you notice about your immediate reaction in moments of tension?
• What shifts when you pause — even briefly — before responding?

 
The role may not be getting lighter, but how you lead within it can evolve. And often, that shift begins with a moment of pause. Try taking that pause in the next tense moment.

The amendment, which is expected to pass:

• Requires home care agencies to provide eight paid hours of initial training and annual continuing education to caregivers who provide direct care.
• Makes initial training of a caregiver provided by a different employer within three years portable.
• Requires the Department of Consumer Protection to create a list of training programs on topics including nonmedical services to a person with Alzheimer's disease or dementia for home care agency employees and enforce the new training requirements.
• Requires registries to ensure caregivers they supply, refer or place with consumers to comply with the training requirements.
• Allows agencies to state in advertising that they comply with all such training requirements, which may include references to the specific training program topics.

 
Agencies will be required to train caregivers beginning January 1, 2027.
 
To meet the requirements of the bill, DCP will need to hire a special investigator who will ensure compliance with the new trainings and investigate complaints. Funds of almost $190,000 for salary and benefits for the position over two years are included in the state budget recommended by the Appropriations Committee.
 
Several changes to the original bill, as requested by HCAOA Connecticut, had previously been approved by the committee. They included: removing CPR and First Aid training requirements, reducing the required training hours from ten to eight, allowing approved training to transfer across employers, exempting certified home health aides from duplicative training, and limiting the requirement to direct care staff.
 
The legislative session adjourns May 6.

Training and competency are the agency's responsibility.
Under the proposed rule, the agency — not the aide, not a third party — is responsible for both training home health aides and evaluating whether they're competent to care for each specific patient. That evaluation must be tied to the child's individualized plan of care, and training must be sufficient for the aide to safely perform every delegated task.
 
The RN role in training is more clearly defined.
The updated draft clarifies how registered nurses fit into the required 76 hours of training, though the full details are in the rule text itself. If your agency uses RNs to oversee or deliver portions of that training, review the updated language carefully to ensure your program aligns.
 
New tasks added to the training curriculum.
The rule expands the list of tasks aides must be trained to perform. Two additions stand out: assistance with total parenteral nutrition (TPN), and training on recognizing and reporting physical or behavioral changes in the patient — not just observing appearance but knowing what to communicate and when.
 
Adverse incident reporting gets a formal definition.
The rule now defines what counts as an adverse incident for purposes of reporting, pulling directly from Florida Statute 400.54(2). An adverse incident is an event that agency personnel could have controlled, is connected to a medical intervention (rather than the patient's underlying condition), and results in harm. A draft incident report form is also available for review.
 
Read the full proposed rule and the most recent changes. Review the draft adverse incident report form (AHCA Form 3110-0011). If you have questions or concerns about the proposed rule, contact HCAOA Director of Government Relations Allison Cramer. The association is actively engaged in this process and will include member perspectives in any formal comments submitted.

Advocacy Day began with a welcome reception, followed by a policy briefing and scheduled meetings on Capitol Hill. Advocates shared firsthand experience from their communities, highlighting the need for policies that support access to care, a stable workforce, and program integrity.
 
During meetings, participants focused on HCAOA’s federal priorities, including:

• Supporting families through the Credit for Caring Act
• Expanding access to Continuous Skilled Nursing
• Creating a home care visa to address workforce shortages
• Strengthening program integrity through targeted, risk‑based oversight
• Ensuring veterans can access high‑quality care at home with sustainable reimbursement and stable provider networks

Advocacy Day provides an opportunity for policymakers to hear directly from home care providers about how federal policy decisions affect patients, families, caregivers, and businesses nationwide. The conversations held during this year’s event helped reinforce the importance of home care as part of the broader healthcare system.
 
HCAOA thanks all members who participated and shared their time and experience. Advocacy efforts will continue throughout the year as we work with lawmakers to advance our policy priorities.

See more photos of the event on our National Home Care Advocacy Day page.

This expansion of National Home Care Advocacy Day enables everyone — home care leaders, staff, caregivers, even friends and family — to speak up for home care at the same time our members are meeting with Congress, amplifying the message. 

In just a few minutes, you can send a message directly to your Members of Congress in support of policies that strengthen access to care, address workforce shortages, and protect providers. Specifically, we're advocating for these priorities:

• Reintroduce the Homecare for Seniors Act
• Establish a home care visa
• Repeal the Medicaid 80/20 provision
• Improve care for veterans
• Strengthen Medicaid program integrity

Getting involved is easy. Go to our campaign page, fill out the form with your information, and we'll generate a message to send directly to your members of Congress. It's a quick action that makes a lasting impact.

Questions about the campaign? Contact Director of Government Relations Allison Cramer.

HCAOA's comments urged CMS to ground any new regulatory framework in empirical data and calibrate enforcement to demonstrated risk, rather than applying uniform requirements across all provider types. Our key points:

• Risk stratification: CMS' own data shows improper payments are concentrated in complex billing environments. HCAOA argued home- and community-based services present lower risk due to simpler billing structures and lower per-beneficiary expenditures.
• Existing safeguards: Agency-based providers already operate within auditable frameworks, including W-2 employment records, care plans and Electronic Visit Verification (EVV) systems that capture real-time service data.
• Documentation vs. fraud: Approximately 82 percent of Medicaid improper payments stem from insufficient documentation rather than intentional misconduct, according to CMS data cited in the comments.
• Access to care: HCAOA cautioned that additional administrative burdens could discourage provider participation in Medicaid at a time when demand for home care workers is projected to grow 17 percent through 2034.

The comments also offered five recommendations:

1. Standardize EVV across states.
2. Improve federal-state data sharing.
3. Expand provider education and technical assistance on billing compliance and documentation.
4. Use existing data sources for outlier detection.
5. Engage directly with the home care sector when creating and refining program integrity policies.

Read the full comments for more details.

The South Carolina Department of Health and Human Services (DHHS) has requested $14.9 million in funding for Home and Community-Based Services (HCBS), including a $1.00 reimbursement rate increase for personal care and private duty nursing services.

This funding is critical to:

• Supporting care for more than 40,000 South Carolinians
• Strengthening the direct care workforce
• Reducing waitlists and access gaps
• Ensuring individuals can remain safely in their homes

But the House version of the budget did not fully fund this request. The Senate now has an opportunity to ensure this investment is included, but they need to hear from the home care community.

Sending a message takes less than a minute and helps demonstrate the importance of protecting access to home-based care across South Carolina.

👉 Contact Your State Senator
​
If you have any questions, please contact HCAOA Director of Government Relations Allison Cramer or join our monthly Government Relations Office Hours. These informal drop-in sessions offer members an opportunity to ask questions, share challenges, and discuss policy and advocacy issues.

The bill requires the Commissioner of Social Services, within available appropriations, to increase the fee schedule for homemaker-companion services by 13% for the next two fiscal years and 10% for the following three fiscal years.
 
HCAOA Connecticut strongly supports the bill and is urging members and Medicaid providers to testify in support of it and to ask their legislators and fellow members to support it as well.
 
The increases would help address chronic underinvestment in Medicaid reimbursement and help agencies remain competitive and stabilize, retain, invest in and recruit a quality home care workforce.
 
The committee held a public hearing on the bill March 17 but will continue to receive written comments electronically.

Background: Michigan’s 2019 auto no-fault reform
For decades, Michigan’s no-fault system provided unlimited lifetime personal injury protection (PIP) benefits for individuals injured in automobile accidents. Providers were reimbursed for “all reasonable charges” for medically necessary care, and disputes centered largely on whether a charge was reasonable.

In 2019, Michigan enacted sweeping reforms intended to reduce auto insurance premiums. Among other changes, the law:

• Introduced tiered PIP coverage options
• Established statutory reimbursement caps
• Created a new fee schedule structure tied either to Medicare rates or to a provider’s 2019 average charges

Under MCL 500.3157, reimbursement for post-reform services depends on whether Medicare has an “amount payable” for the service in question:

• If Medicare has an amount payable → reimbursement is capped at a percentage of Medicare (currently indexed to approximately 190%).
• If Medicare does not have an amount payable → reimbursement is capped at a percentage of the provider’s 2019 average charge.

Since 2019, a central dispute has been which subsection applies to home health aide and skilled nursing services.
 
The court’s decision
 In West Michigan Home Care Services, Inc. v. Meemic Insurance Company (October 20, 2025), the Michigan Court of Appeals addressed whether Medicare has an “amount payable” for home health aide and skilled nursing services.
 
The insurer argued that because Medicare often uses a prospective or bundled payment system, there is no discrete billable “amount payable” for these services, meaning the lower 2019 charge-based cap should apply.
 
The Court rejected that argument. The Court held that:

• Medicare covers both home-health-aide and skilled-nursing services.
• Medicare’s payment methodology (prospective vs. fee-for-service) does not determine whether an “amount payable” exists.

 
Therefore, MCL 500.3157(2), the Medicare-based reimbursement cap, applies.
 
Because the opinion is published and no appeal was filed, it is now binding statewide precedent. This interpretation will govern reimbursement under the current statute unless the legislature amends the law.
 
What the decision does and does not do
 What it does:

• Clarifies that the Medicare-based reimbursement cap governs covered home care services.
• Resolves a key statutory interpretation dispute that has been litigated across multiple cases.
• Provides binding appellate guidance for lower courts.

 
What it does not do:

• Set specific hourly reimbursement rates.
• Order insurers to pay a particular amount in all cases.
• Determine whether a provider’s charges are reasonable.
• Eliminate ongoing factual disputes about payment calculations.

 
In other words, the court determined which statutory framework applies, not the final reimbursement amount owed in every situation.
 
Considerations for home care providers
Under MCL 500.3157, reimbursement is limited to charges that are reasonable and for services that are reasonably necessary, subject to the applicable cap.
 
Because the Court determined that subsection (2) applies, reimbursement for covered home health aide and skilled nursing services is now governed by the Medicare-based framework set forth in the statute, rather than the 2019 charge-based limitation.
 
Importantly, the statute establishes a ceiling, not a guaranteed payment amount. Actual reimbursement remains dependent on:

• Whether the services are reasonably necessary,
• Whether the provider’s charges are determined to be reasonable, and
• How the Medicare-based cap is calculated and applied in individual cases.

 
As insurers and providers implement the decision, reimbursement disputes may still arise. Some providers are continuing to litigate rates on a case-by-case basis to resolve disagreements regarding reasonable charges.
 
We want to hear from you
We encourage Michigan providers to share what you are seeing operationally. Please let us know by emailing your thoughts to allison@hcaoa.org. Thank you.

​
Alabama
Providers are contending with workforce instability, reimbursement misalignment, and increased regulatory scrutiny without clear operational guidance. Recruitment and retention of caregivers remain top priorities.
 
Arizona
The state is working through budget pressures in its developmental disability system, including significant supplemental funding requests. A hastily implemented assessment tool was withdrawn after stakeholder pushback, and multiple funding bills related to reimbursement and residential services remain in play.
 
California
The chapter has been building strong relationships with regulators around enforcement, and the state recently secured funding for additional agents to combat unlicensed operators. Advocacy continues on closing referral loopholes and strengthening consumer protections.
 
Connecticut
Connecticut's chapter is engaged on multiple fronts: caregiver training requirements, Medicaid reimbursement advocacy, a proposed caregiver tax credit, and registry implementation and enforcement issues.
 
Florida
Florida is working through proposed changes to its family caregiver program, including limited controlled-substance administration. Budget discussions are ongoing around private duty nursing rates, and the chapter is pursuing rural health transformation funding while pressing for greater transparency in nurse registry models.
 
Georgia
Georgia is navigating complex budget negotiations in an election year. While Medicaid waiver funding remains stable, broader aging services funding faces pressure. The chapter is also engaged on audit reforms, fingerprinting consolidation, and structural Medicaid policy changes.
 
Hawaii
As a newer chapter, Hawaii is focused on education and awareness. Home care has been left out of several recent legislative proposals — including caregiver tax credits, workforce funding, and dementia training — and the chapter is actively advocating for inclusion. A promising initiative targeting seniors who don't qualify for Medicaid but can't afford private pay is gaining traction.
 
Illinois
After successfully addressing hospital referral practices, Illinois is now targeting transparency in assisted living referrals. The chapter also secured inclusion of home care workers in worker protection legislation. Gray market activity remains a persistent concern.
 
Kansas
HCAOA is actively submitting comments on Kansas's proposed revisions to Home Health Agency Regulations, advocating for rules that reflect operational realities, minimize administrative burden, and protect access to care without compromising quality standards.
 
Kentucky
Kentucky providers face significant headwinds: lengthy licensure delays, outdated administrative processes, and low Medicaid reimbursement rates. The chapter is building key legislative relationships and exploring veteran-focused advocacy pathways as a strategic entry point.
 
Maryland
Gov. Wes Moore has issued a directive requiring the Maryland Department of Health to create a statewide registry of home care workers employed by Residential Service Agencies. The registry would publicly list caregiver information and be accessible to employee organizations, which raised serious privacy, operational, and workforce concerns. HCAOA, in coordination with local partners, is advocating to address administrative burden, data protection risks, and broader labor implications.
 
Michigan
Michigan is managing split legislative control and budget uncertainty. Workforce cost pressures tied to minimum wage and earned sick time laws are adding strain, and the chapter is monitoring broader Medicaid budget implications alongside fallout from recent auto no-fault changes.
 
New Jersey
New Jersey's chapter is adjusting to a new gubernatorial administration, with several regulatory proposals — including domestic worker regulations — currently on pause for review. The chapter is advancing audit reform legislation and working to secure exemptions from overlapping regulatory requirements.
 
New York
New York providers face a tough environment: wage compression, heavy regulatory oversight, and growing competition from unlicensed providers. The chapter is calling for shared advocacy playbooks and stronger coordination to address reimbursement pressure and compliance complexity.
 
Ohio
Ohio is pursuing legislation to allow home care caregivers to administer medications, aligning state policy with existing Department of Aging standards. The chapter is also monitoring direct-to-consumer Medicaid proposals and continuing to engage state leadership.
 
Pennsylvania
HCAOA is initiating conversations — in coordination with local partners — around a proposed Medicaid state budget request to increase provider reimbursement rates. Early engagement is underway to build a coalition and shape the conversation.
 
South Carolina
South Carolina is pressing for a Medicaid rate increase for personal care and private duty nursing, supporting the Department of Health and Human Services budget request, and pursuing updates to in-home care licensure regulations. An in-person advocacy day is planned to reinforce these priorities.
 
South Dakota
HCAOA worked closely with stakeholders to strengthen language in the state’s home care licensure legislation, securing clearer definitions and better alignment with provider realities. The bill successfully passed both the House and Senate during the 2026 legislative session and is currently awaiting action by the governor.

Tennessee
Tennessee is focused on ensuring home care is included in Medicaid home- and community-based service expansions and on securing improved rate alignment. Certificate of need and Medicaid sustainability are central issues for providers.
 
Texas
Texas providers are dealing with unlicensed competition, persistently low Medicaid reimbursement, and significant VA rate cuts. The state recently approved substantial funding for dementia research. Regulatory modernization, overtime rule impacts, and ongoing issues with the state's e-licensure system remain priorities.
 
Virginia
Virginia is tracking minimum wage legislation and expanded paid sick leave proposals moving through the General Assembly — both carry real cost implications and administrative requirements for providers.
 
Washington
Washington's chapter won a significant advocacy victory, successfully converting a proposed state-level 80/20-style spending requirement into a reporting model instead. The state faces a major budget deficit after prior surplus spending, and a proposed employer healthcare tax is also under review.
 
West Virginia
West Virginia secured significant Medicaid rate increases over the past 14 months and is now working to codify an annual rate study. The chapter is monitoring managed care proposals, certificate of need changes, and sales tax interpretations affecting personal care services.
 
No matter what state you operate in, we want to hear what issues matter to you. Join HCAOA’s monthly Government Relations Office Hours, held the second Wednesday of each month, to ask the HCAOA Government Relations Team questions or raise an issue we should be watching.

Watch the full Chapter Town Hall meeting recording (run time: 1 hour, 24 minutes)

How much has been implemented?
The VA has fully implemented 25 of 72 sections. Officials cited the law's complexity and gaps in dedicated funding as contributing factors.

What provisions were examined?
Several are directly relevant to home care and caregiver support:

• Caregiver mental health grants (Sec. 122): $10 million was appropriated in each of the 2025 and 206 fiscal years; no grants have been issued. The Government Accountability Office (GAO) found caregivers continue to face challenges accessing mental health services.
• Physician pay waivers (Sec. 142): Zero of 300 authorized waivers have been issued. The VA said criteria could be in place within one to two months.
• Assisted living pilot (Sec. 127): The VA is still developing purchasing authority and a fee schedule.
• Rural ambulance coverage (Sec. 143): Not fully implemented; the provision sunsets in September.
• Staffing models (Sec. 146): Not yet developed. GAO called them "incredibly important" for aligning resources with program needs — a recommendation that remains open.

What does this mean for HCAOA members?
Unissued caregiver grants, incomplete staffing models, and stalled rural provisions all affect the environment in which home care providers operate. GAO's finding that community care administrative processes remain labor-intensive is also relevant for providers within VA referral systems.

What's next?
HCAOA will monitor developments. The rural ambulance provision's September sunset is the most immediate deadline.

Following advocacy by HCAOA Connecticut, the committee approved several changes to the original proposal, including removing CPR and First Aid training requirements, reducing the required training hours from ten to eight, allowing approved training to transfer across employers, exempting certified home health aides from duplicative training, and limiting the requirement to direct care staff.
 
HCAOA Connecticut continues to work with lawmakers and state agency officials on additional issues, including allowing agencies to advertise caregiver competencies based on training, applying the training requirements to registries, and securing Medicaid reimbursement for training costs for HCBS providers.
 
Members can discuss caregiver training requirements and other key home care policies with lawmakers, fellow chapter members and industry leaders at Care at Home Day at the Capitol March 18 at 10:30 a.m., organized in collaboration with Connecticut Association for Healthcare at Home.