Direct Care Worker
Wage Review
State and federal workforce initiatives increasingly require agencies to demonstrate that funding intended for direct care workers is reaching the workforce and supporting program objectives. We help agencies evaluate wage-related programs, validate provider reporting, and assess compliance with applicable requirements while promoting transparency and accountability.
Supporting Transparency & Accountability in
Direct Care Workforce Funding
States are increasingly focused on strengthening the direct care workforce by ensuring that reimbursement policies translate into meaningful wage improvements for frontline staff. Federal rulemaking, including the Medicaid Access Rule (CMS-2442-F), sets the requirements for wage transparency, provider reporting, and accountability in how Medicaid payments support direct care workers.
We support state agencies and program administrators in designing and implementing direct care wage reporting and compliance frameworks that promote accountability, improve data quality, and support policy objectives.
Oversight & Validation of Wage-Related Funding
Direct care wage initiatives often involve complex reporting, payment, and monitoring requirements. Our team provides independent review and analysis to help agencies assess whether wage investments are being implemented as intended and supported by reliable documentation.
What We Do
We provide end-to-end support for direct care wage initiatives, from program design through ongoing oversight and monitoring.
Program Design & Implementation
We assist states in establishing the structure and processes needed to support direct care wage initiatives, ensuring alignment with federal requirements and state-specific policy goals.
Provider Reporting & Data Collection
Accurate and consistent data collection is critical to evaluating the effectiveness of wage initiatives. We support large-scale provider reporting efforts across diverse service settings.
Audit & Compliance Oversight
We conduct audits and reviews to assess whether funds are being directed appropriately to direct care workers and whether providers are meeting program requirements.
Monitoring & Performance Analysis
Beyond compliance, states are increasingly focused on understanding the impact of wage initiatives on workforce outcomes. We support agencies in monitoring and evaluating program effectiveness.
Supporting Federal Compliance & Transparency Requirements
Evolving federal regulations require states to enhance transparency around provider reimbursement and direct care wages, including reporting on the proportion of payments directed to frontline workers and establishing stakeholder engagement processes. We help states align with these requirements by:
Key Issues & Considerations in Direct Care Wage Initiatives
Direct care wage investments are designed to strengthen the workforce, improve retention, and support access to care. Effective oversight requires agencies to balance policy objectives with practical implementation, reporting accuracy, and accountability for public funds.
Recent federal rulemaking has increased expectations for transparency and accountability in how Medicaid payments support the direct care workforce. These requirements include reporting on the proportion of payments directed to direct care workers and enhancing public visibility into rate-setting methodologies.
States must operationalize these requirements through new reporting structures, documentation standards, and oversight processes, often within tight implementation timelines. Ensuring that data is complete, consistent, and auditable is critical to demonstrating compliance.
One of the most significant challenges states face is defining what constitutes “direct care wages” and ensuring consistent application across provider types and service settings. Variability in any of the following can complicate both reporting and audit efforts.
Establishing clear definitions and standardized reporting frameworks is essential to ensuring comparability and accuracy across providers.
Direct care wage initiatives often require large-scale provider reporting, introducing operational challenges for both agencies and providers. Common issues include:
States must balance the need for detailed data with practical considerations around provider burden, while also implementing validation processes to ensure data reliability.
Wage transparency requirements are closely tied to broader reimbursement structures. States must ensure alignment between:
This alignment is critical not only for compliance but also for evaluating whether reimbursement policies are achieving intended workforce outcomes.
As federal and state oversight increases, agencies must be prepared to demonstrate that wage-related requirements are being implemented effectively. This includes:
Proactive audit readiness helps reduce compliance risk and supports defensible program outcomes.
Beyond compliance, many states are focused on whether wage initiatives are achieving broader policy goals, such as improving workforce recruitment and retention. This requires the ability to analyze:
Integrating wage data with broader program metrics allows states to assess effectiveness and inform future policy decisions.
Our experience spans a wide range of providers and service settings, including:
Experience Supporting Workforce Funding Oversight
Our team combines expertise in Medicaid financing, provider reimbursement, compliance, and data analytics to help agencies evaluate direct care wage initiatives and workforce-related funding programs.
Direct care wage initiatives intersect with broader Medicaid financing, rate setting, and program integrity efforts. Our work reflects an integrated understanding of:
Our direct care wage review services are designed to support:
We understand the operational and policy challenges associated with implementing direct care wage initiatives. Our approach emphasizes scalable solutions, clear documentation, and practical processes that can be implemented efficiently across large provider networks.
We work with state agencies and program administrators to strengthen oversight, improve transparency, and support long-term workforce sustainability. Our focus is on delivering solutions that help ensure funding intended for direct care workers is used effectively and achieves its intended impact.
Connect With Our Team
Partner with experts who understand the complexities of health and human services programs. Let us guide your organization through the industry’s unique challenges and opportunities.
Bob Hicks, CPA
Member
Email: bhicks@mslc.com
Phone Number: 816-957-6220
Tamara Basso Bensky, CPA
Member
Email: tbensky@mslc.com
Phone Number: 410-581-4549
Mark Korpela, CFE
Principal
Email: mkorpela@mslc.com
Phone Number: 410-581-4550
Tammy Martin, CPA
Member
Email: tammym@mslc.com
Phone Number: 208-378-4100
Jerry Dubberly, PharmD
Principal
Email: jdubberly@mslc.com
Phone Number: 404-524-9519
Tim Guerrant, CPA
Member
Email: tguerrant@mslc.com
Phone Number: 317-815-2935
Krista Stephani, CPA
Member
Email: kristas@mslc.com
Phone Number: 208-378-1400
In the Words of our Clients…
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