Key Takeaways
- The April 20 update extends 2025 LS300 and certification deadlines to June 15, 2026, for licensed home care services agencies (LHCSAs), fiscal intermediaries (FIs) and certified home health agencies (CHHAs) and the annual certification deadline for Medicaid managed care organizations (MMCOs) to June 30, 2026.
- The October 1 LS301 deadline and the requirement for audit or agreed-upon procedures (AUP) support remain unchanged.
- The state’s framework is focused on independent verification of the wage parity hours and expenses reported on LS300. A U.S. Generally Accepted Accounting Principles (GAAP) financial statement audit does not satisfy that requirement unless it specifically addresses the LS300 wage parity information.
- Wage parity applicability is based on Medicaid-billable home care aide services and covered contractual arrangements, not merely on which entity receives Medicaid funds first.
The New York State Department of Health (DOH) reissued its March 9, 2026 wage parity guidance on April 20, 2026, updating key compliance deadlines for home care providers. While the revised guidance extends certain LS300 filing and annual certification deadlines for 2025, it does not change the core wage parity compliance framework, including LS301 reporting requirements, the October 1 deadline for audit or agreed-upon procedures (AUP) support or the requirement for independent verification of wage parity hours and expenses.
For licensed home care services agencies (LHCSAs), fiscal intermediaries (FIs), certified home health agencies (CHHAs) and Medicaid managed care organizations (MMCOs), the message is clear: deadlines may have shifted, but compliance expectations and scrutiny remain unchanged.
Background
On March 9, 2026, the Department of Health issued guidance addressing wage parity compliance forms and certification submission dates. The guidance applies to LHCSAs, former FIs, the statewide FI, CHHAs and MMCOs.
The guidance was later reissued with an “UPDATED: April 20, 2026” notation. The updated version did not replace the overall wage parity structure. Rather, it revised certain 2025 compliance deadlines while leaving the audit/AUP framework intact.
April 20, 2026, Update: What Changed
The April 20 update changed the following 2025 compliance deadlines:
- For LHCSAs and FIs: The LS300 deadline changed from May 31, 2026, to June 15, 2026, and the 2025 annual certification deadline changed from May 31, 2026, to June 15, 2026.
- For CHHAs: The LS300 deadline changed from April 30, 2026, to June 15, 2026, and the 2025 annual certification deadline changed from May 31, 2026, to June 15, 2026.
- For MMCOs: The annual certification deadline changed from May 31, 2026, to June 30, 2026.
What Did Not Change
The April 20 update did not change the October 1 LS301/AUP deadline. For 2026 and subsequent years, LHCSAs and the statewide FI must provide LS301 and audited financial statements or AUPs to contracted MMCOs and CHHAs by October 1 each year for the previous calendar year. CHHAs must provide the same to contracted MMCOs by October 1 each year for the previous calendar year.
The April 20 update also did not change the underlying AUP framework. The guidance continues to state that AUPs developed by the DOH and Department of Labor (DOL) may be used to satisfy the wage parity audited financial statements requirement.
For calendar years 2021, 2022, 2023, 2024 and 2025, the guidance continues to allow AUPs or other audited financial statements to be completed for the entire agency rather than by each managed care contract. The report must still be shared with each contracted MMCO and CHHA.
Misconception 1: A U.S. GAAP Financial Statement Audit Automatically Satisfies the Requirement
A common misunderstanding is that the reference to audited financial statements means any U.S. Generally Accepted Accounting Principles (GAAP) financial statement audit satisfies the wage parity requirement. That is not how the guidance is structured.
The guidance states that AUPs may be used to satisfy the wage parity audited financial statements requirement. It also states that the certified public accountant (CPA) practitioner performs specific procedures on employee wages and that successful completion of the AUPs allows the LHCSA, FI or CHHA to complete the revised LS301 form.
Attachment 1 is even more specific. It states that the New York State Home Care Worker Wage Parity AUPs are designed to verify the information on the Wage Parity LS300 Form.
Accordingly, the issue is not whether audited financial statements exist; the issue is whether the independent work verifies the wage parity hours and expenses reported on LS300. A U.S. GAAP financial statement audit would not satisfy that requirement unless it specifically addressed the LS300 wage parity information.
Misconception 2: AUPs Are the Only Possible Method
The state is not mandating AUPs as the only method. Attachment 1 states that AUPs are an optional method and that other acceptable methods and reports may include Examination Reports and Compliance Reports as defined by the American Institute of Certified Public Accountants (AICPA).
That said, the alternative must still verify the LS300 wage parity information. In practice, providers should not assume that an existing financial statement audit is sufficient unless the auditor specifically performed procedures over the LS300 wage parity hours and expenses.
Misconception 3: Payment Through a Related Party Removes the Requirement
Another common misunderstanding is that wage parity does not apply if Medicaid funds are first received by a parent, affiliate, related entity or other intermediary before being paid to the operating provider.
The official framework does not support that conclusion. The LS300/AUP structure is built around Medicaid-billable home care aide services and the wage parity hours reported by the provider. Attachment 1 defines the required HCA database to include “Hours for the HCA,” which includes all Medicaid billable hours worked by the specific HCA, and “Wage Parity Hours without Overtime for the HCA,” which also includes all Medicaid billable hours worked by the HCA without overtime.
The analysis therefore turns on the services performed and the Medicaid-billable wage parity hours being reported, not simply on the path of the payment.
Misconception 4: Filing LS300 Is Just Administrative
Filing LS300 is significant because the AUP procedures are designed to test the information reported on LS300. Procedure 1.3 requires the practitioner to obtain all LS300 forms completed by the provider for the scope period and calculate total HCA hours worked and total wage parity expenses from those forms. Procedure 1.4 then requires the practitioner to agree HCA hours to the LS300 totals. Procedure 1.5 requires the practitioner to agree HCA expenses to the LS300 totals.
That means LS300 is the core reporting document for the AUP process. Once an entity completes LS300, it is reporting Medicaid-billable wage parity hours and expenses that must be independently supported through LS301 and the related report.
Practical Implications for Providers
Providers should evaluate whether they have completed, or are required to complete, LS300 for calendar years 2021 through 2025. For those years, the guidance allows the AUPs or other audited financial statements to be completed at the agency level rather than by each managed care contract.
“Agency level” does not mean the years are blended together, however, or that separate annual LS300 information can be ignored. The AUP procedures still require the practitioner to obtain the LS300 forms for the scope period and agree wage parity hours and expenses back to the supporting HCA database and records.
Organizations should begin gathering payroll data, LS300 support, wage parity expense detail, benefit support and reconciliation schedules early. The AUP procedures require payroll register support, general ledger support and management’s reconciliation of payroll costs between the payroll register and general ledger.
Moving Forward
The April 20 update gave providers more time for certain 2025 LS300 and certification submissions, but it did not change the October 1 LS301/AUP deadline or the underlying verification requirement.
The key questions for providers remain:
- Did the organization report Medicaid-billable wage parity hours on LS300?
- Was independent work performed that specifically verifies the LS300 wage parity hours and expenses?
If the answer to the second question is no, the provider should expect to need the New York State Home Care Worker Wage Parity AUPs or another acceptable independent report that directly addresses the LS300 wage parity information.
The April 20 update is important, but not a substantive retreat from the wage parity verification framework. It is primarily a deadline update. The core compliance obligation remains independent support for LS300 wage parity hours and expenses through LS301 and the related AUP or other acceptable independent report.
Contact Us
If you have any questions or need assistance, please contact your PKF O’Connor Davies client service team or:
Keith Solomon, CPA
Partner, Health Care Practice Leader
ksolomon@pkfod.com
Dorothea A. Russo, CPA
Partner
drusso@pkfod.com
Parvesh Lal, CPA
Manager
plal@pkfod.com