Key Takeaways
- The New York State Department of Health’s June 4, 2026, wage parity update narrows the immediate compliance scope for home care providers by stating that Form LS301 is not required at this time for calendar years 2021 through 2024.
- Calendar year 2025 is now the primary wage parity compliance year, with Forms LS300 and LS301, along with audited financial statements or agreed-upon procedures, due November 1, 2026.
- The prior-year filing relief does not eliminate wage parity record retention requirements, and providers should begin preparing for more detailed contract-level reporting requirements beginning in 2027 for calendar year 2026.
The New York State Department of Health’s (DOH) June 4, 2026, wage parity update significantly changes the immediate compliance scope for home care providers. It effectively removes the immediate requirement to complete Form LS301 for calendar years 2021 through 2024. For many providers, that changes the conversation entirely.
Since the DOH issued the current wage parity reporting and independent verification framework, organizations have been evaluating how to address multiple years of wage parity reporting, supporting documentation and independent verification requirements. The June 4 guidance narrows that focus, allowing providers to concentrate their near-term efforts on calendar year 2025 rather than attempting to address five years simultaneously.
What Changed
The guidance specifically states that Form LS301, the Independent Auditor’s Statement Verifying Employer’s Wage Parity Hours and Expenses, for calendar years 2021, 2022, 2023 and 2024 is not required at this time.
The state established November 1, 2026, as the due date for calendar year 2025 Department of Labor Forms LS300 and LS301, together with audited financial statements or agreed-upon procedures. For many organizations, that effectively shifts the immediate compliance focus to a single reporting year rather than multiple historical years.
From a planning perspective, this should allow providers to direct resources toward preparing support for calendar year 2025 rather than allocating substantial time and effort toward historical filings that are not currently required.
What Did Not Change
Although the June 4 update provides meaningful relief, providers should not interpret the guidance as eliminating the importance of prior years. It specifically states that the Office of the Medicaid Inspector General, the New York State Department of Labor (DOL) and the New York State DOH reserve the right to request records related to wage parity compliance activities in connection with monitoring reviews, audits, investigations or complaints. The guidance also reiterates that wage parity records remain subject to the ten-year retention requirement.
As a result, the June 4 update should be viewed as a filing relief measure rather than a record retention relief measure. The state removed the current requirement to submit Form LS301 for 2021 through 2024, but it did not eliminate the obligation to maintain the supporting records.
Why 2025 Matters
With the historical filing requirement narrowed, calendar year 2025 becomes the focal point of the wage parity process. DOL Forms LS300 and LS301, accompanied by audited financial statements or agreed-upon procedures, are due November 1, 2026. For most providers, this will be the first year subject to the current filing timeline under the revised guidance.
As a practical matter, providers now have a defined target year and a defined deadline. That clarity is valuable. It allows organizations to focus on the year that currently matters most from a filing perspective while continuing to maintain historical records as required.
LS300 Guidance for 2025 and Beyond
The June 4 guidance also provides important insight into how the wage parity reporting framework will evolve. For calendar year 2025, the guidance does not impose a contract-level agreed-upon procedures requirement. That changes beginning with calendar year 2026.
Beginning in 2027 for calendar year 2026, licensed home care services agencies and the statewide fiscal intermediary should prepare for contract-level agreed-upon procedures for each contract with Medicaid managed care organizations or certified home health agencies.
The distinction is significant. 2025 remains the final year before the contract-level requirement takes effect; 2026 introduces a different reporting structure.
While additional guidance may emerge as implementation approaches, providers should recognize that the compliance framework is moving toward more granular reporting. Organizations with multiple managed care contracts should begin evaluating how contract-specific reporting could affect future compliance processes.
Why This Matters for Providers
The June 4 update creates a clearer compliance roadmap. Instead of dividing attention across five separate reporting years, providers can now focus on one. At the same time, the guidance signals that the long-term direction of the wage parity framework is toward greater detail and greater contract-specific accountability. For that reason, providers should view 2025 as more than just a filing year: it is also a transition year.
Organizations that use this period to evaluate their reporting processes, supporting documentation and contract-level reporting capabilities will likely be better positioned when the calendar year 2026 requirements become effective.
Bottom Line
The June 4, 2026 wage parity guidance significantly changes the immediate compliance scope. Form LS301 is not required at this time for calendar years 2021 through 2024. Calendar year 2025 is now the primary compliance year, with Department of Labor Forms LS300 and LS301 due November 1, 2026.
The relief for historical filing requirements should not be confused with relief from record retention requirements. The Office of the Medicaid Inspector General, the New York State Department of Labor and the New York State Department of Health continue to reserve the right to request wage parity records and the 10-year retention requirement remains in place.
Most importantly, the guidance confirms that the reporting environment will become more detailed beginning with calendar year 2026. Providers should use the additional clarity provided by the June 4 update to focus on 2025 while preparing for the contract-level reporting requirements that begin in 2027.
We Can Help
PKF O’Connor Davies works with home care providers to evaluate wage parity reporting requirements, prepare supporting documentation and address audit or agreed-upon procedures needs. As the reporting framework shifts toward calendar year 2025 filings and future contract-level requirements, providers should assess whether their current records, systems and processes can support both near-term compliance and more detailed reporting expectations.
Contact Us
For questions about the June 4, 2026, wage parity update or preparation for the November 1, 2026, deadline, please contact your PKF O’Connor Davies client service team or:
Keith Solomon, CPA
Partner, Health Care Practice Leader
ksolomon@pkfod.com
Parvesh Lal, CPA
Manager
plal@pkfod.com