Centers for Medicare and Medicaid Services (CMS) guidance released to states October 9, 2026 via a State Medicaid Director Letter (SMDL) and Technical Specifications PDF relates to provisions from the Medicaid Access Rule that includes the requirement that states to collect and report to CMS data on wages and benefits paid to direct care workers providing homemaker, home health, and personal care services.

States must be prepared for the reporting requirement to begin July 9, 2028 and the report readiness to CMS by July 9, 2027.

With that in mind, CMS issued the SMDL and technical specifications to help states establish their infrastructure for collecting data and reporting to CMS.

Guidance on this provision is a necessary precursor to the 80/20 wage pass-through requirement that remains in the Access Rule with an effective date of July 9, 2030.

While LeadingAge continues to urge the administration to reverse the 80/20 passthrough, even if that were to happen,  we anticipate that this reporting requirement would remain in place.

The SMDL contains useful examples to help states consider how to establish reporting infrastructure and rate attribution, along with reminders that information technology (IT) system upgrades are available for enhanced federal funding.