KFF: Medicaid pay transparency now covers home-care hourly rates

States must now post Medicaid fee-for-service payment information that includes average hourly rates for personal care, home health aide, homemaker, and habilitation services—the same service lines that employ many direct care workers and DSPs.

KFF’s Nov. 6, 2026 issue brief walks through the fee-for-service transparency pieces of CMS’s 2024 Ensuring Access to Medicaid Services final rule that took effect July 1, 2026. The brief uses 2023 T-MSIS claims to show how little of noninstitutional fee-for-service spending is covered by the narrower Medicaid-to-Medicare comparative rate analysis, and it flags limits in how useful the new public postings will be across states.

What the Access rule requires on payment transparency

CMS’s April 22, 2024 fact sheet on the Access rule (CMS-2442-F) says states must:

• Publish all fee-for-service Medicaid fee-schedule rates on a public website and update them within a month of a rate change.
• Compare fee-for-service rates for selected primary care, obstetric/gynecologic, and outpatient mental health and substance use disorder services with Medicare rates and publish that analysis every two years, with the first analysis due by July 1, 2026.
• Publish the average hourly rate paid for personal care, home health aide, homemaker, and habilitation services every two years, starting July 1, 2026.
• Convene an interested-parties advisory group on direct care payment rates for those home-care services at least every two years.

A separate 2024 managed care rule adds plan-level payment analyses for rating periods beginning on or after July 9, 2026, with the new analyses due in Network Adequacy and Access Assurances Reports six months after each rating period ends; reports submitted on or after Jan. 1, 2028 must include them. KFF puts those managed care and long-term care transparency pieces outside the scope of this brief.

What KFF found in the claims data

For the fee-for-service comparative rate analysis, CMS specified 68 evaluation-and-management billing codes. KFF estimates those codes accounted for about 2% of noninstitutional fee-for-service spending and 5% of noninstitutional fee-for-service claims or services in 2023 T-MSIS data. Children were overrepresented among enrollees using the selected codes (31% versus 22% of all fee-for-service enrollees).

KFF also notes that states’ broader fee-schedule postings are not standardized—some offer searchable databases, others post downloadable PDFs or spreadsheets—so cross-state comparisons of comprehensive rates remain hard even after the July 2026 deadline. Usefulness will vary with how much of a state’s Medicaid runs through fee-for-service versus managed care, and with whether fee-for-service rates still set the floor for plan payments.

How this relates to direct care pay reports

The Access rule’s home-care hourly-rate disclosure is separate from the later percentage-of-payments-to-workers reporting and the 80/20 payment-adequacy path for homemaker, home health aide, and personal care. CMS explained the compensation-percentage methodology in State Medicaid Director Letter SMD 26-005 (Oct. 9, 2026). CMS’s Nov. 5, 2026 CARE proposed rule would trim some institutional payment-transparency reports for nursing facilities and ICF/IIDs; that proposal does not erase the Access rule’s fee-for-service home-care hourly-rate and fee-schedule duties described here.

What this means for providers and DSPs

Agency finance and compliance teams should confirm their state’s July 2026 fee-schedule page and home-care average hourly rate disclosure are live and match the rates they are actually paid. Advocates and provider agency associations can now compare published personal care, homemaker, home health aide, and habilitation hourly averages across states—but should treat the 68-code Medicare comparison as a narrow clinical-service snapshot, not a picture of HCBS wage pass-through. DSPs and other direct care workers gain a public benchmark for what Medicaid fee-for-service is paying for their service categories every two years; whether that moves wages still depends on state rate-setting, managed care contracts, and the later compensation-percentage and 80/20 rules.