State profile — Tier 2

Utah

Utah has ∼22,000 home care aides earning ∼$15.90/hr — $3.19 below the MIT living wage. No state OT protections exist beyond federal FLSA; no DWBOR. Utah partially expanded Medicaid in 2020 after a 2018 ballot initiative (Prop 3) was legislatively modified to a partial expansion (SB 96). $7.25 minimum wage (federal floor). Right-to-work state. Fast-growing population (youngest median age nationally). Rural gaps in southern/eastern UT.

∼22K

Home health & personal care aides (est. BLS May 2024)

∼$15.90

Estimated median hourly wage — below national $16.78

Partial (2020)

Medicaid expanded (Prop 3 modified by legislature)

∼50%

HCBS share of LTSS spending (est.)

Category 1

The Economic Reality

#	Metric	Utah	Status
1.1	BLS median hourly wage (SOC 31-1120)	∼$15.90/hr	Estimated
1.2	PHI median hourly wage (all DCW, ACS)	TBD	Gap
1.3	Median annual earnings (DCW)	TBD	Gap
1.4	MIT living wage (1 adult, 0 children)	$19.09/hr	Proxy
1.5	Wage gap (living wage minus BLS median)	∼$3.19/hr below living wage	Estimated
1.6	State minimum wage (2026)	$7.25/hr (federal floor)	Public
1.7	Local minimum wage (highest city)	N/A (state preempts local minimum wage)	Public
1.8	Low-income household rate (<200% FPL)	TBD	Gap
1.9	Public assistance reliance (state-specific)	∼49% (national proxy)	Proxy
1.10	Housing cost-burdened rate	TBD	Gap
1.11	Uninsured rate (DCW)	Partial — Medicaid expanded 2020 (Prop 3 ballot initiative 2018, modified by SB 96)	Public
1.12	PHI Overall State Index ranking	TBD	Gap
1.13	Wage competitiveness vs. similar jobs	TBD	Gap
1.14	Genworth median home health aide rate	TBD	Gap
1.15	Genworth median NF semi-private rate	TBD	Gap
1.16	Family Care capitation PMPM (NH LOC)	TBD	Gap
1.17	Blended HCBS avg cost (all acuity)	TBD	Gap
1.18	NF private pay monthly avg	TBD	Gap
1.19	HCBS-to-NF cost ratio (state-specific)	TBD	Gap
1.20	Exemption aggregate savings (national est.)	$500-700M/yr (∼0.2% of HCBS)	Estimated
1.21	Per-worker OT loss (50hr/wk worker)	TBD	Gap

Category 2

The Workforce Crisis

#	Metric	Utah	Status
2.1	Headline caregiver vacancy rate	TBD	Gap
2.2	Open caregiver positions	TBD	Gap
2.3	Available job seekers (entire labor market)	TBD	Gap
2.4	Annual turnover rate	∼79.2% (national proxy)	Proxy
2.5	Individuals denied/delayed services	TBD	Gap
2.6	Agencies unable to staff all hours	TBD	Gap
2.7	Nursing homes closed since 2016	TBD	Gap
2.8	NF beds empty due to staffing	TBD	Gap
2.9	Total direct care workers	∼22,000 (est.)	Estimated
2.10	New jobs projected (2022–2032)	TBD	Gap
2.11	Total openings incl. separations (2022–2032)	TBD	Gap
2.12	Population 75+ growth projection	TBD	Gap
2.13	Workforce demographics: % women	∼87% female (est.)	Estimated
2.14	Workforce demographics: % people of color	∼25% POC (est.)	Estimated
2.15	Workforce demographics: % immigrants	TBD	Gap
2.16	Health insurance offered by agencies	TBD	Gap
2.17	Family caregivers providing 80%+ of all care	TBD	Gap
2.18	Unpaid caregiver hours/economic value	TBD	Gap

Category 3

Legal & Policy Framework

#	Metric	Utah	Status
3.1	State companionship/OT exemption status	NO state OT law beyond federal FLSA. Utah follows federal exemptions.	Public
3.2	State overtime threshold	40 hrs/wk (federal FLSA only; UCA 34-40 defers to federal OT)	Public
3.3	Domestic Workers Bill of Rights	No DWBOR	Public
3.4	Paid sick leave law	No state paid sick leave law	Public
3.5	Paid family/medical leave	No state paid family/medical leave	Public
3.6	Primary self-directed Medicaid program	Aging waiver; New Choices Waiver (NF transition); Community Supports waiver (I/DD); Acquired Brain Injury waiver	Public
3.7	Self-directed program enrollment	TBD	Gap
3.8	Primary managed LTC program	Utah Medicaid primarily FFS; ACO-based managed care for some populations	Public
3.9	Managed LTC enrollment	TBD	Gap
3.10	Combined HCBS enrollment	TBD	Gap
3.11	HCBS share of LTSS spending	∼50% of LTSS spending (est.)	Estimated
3.12	HCBS waiting lists status	TBD	Gap
3.13	Spouses as paid Medicaid caregivers	Yes (Self-Administered Services within Aging and DD waivers)	Public
3.14	Parents of minors as paid caregivers	Yes (participant-directed services with FMS)	Public
3.15	COVID family caregiver relaxations permanent?	No significant home care protection bills pending	Public
3.16	SDPC maximum wage (self-directed)	TBD	Gap
3.17	OT rate cap in self-directed programs	TBD	Gap
3.18	IRIS/SDPC weekly hour cap	TBD	Gap
3.19	Minimum fee schedule for HCBS	TBD	Gap
3.20	Wage pass-through requirement	TBD	Gap
3.21	MCO contract wage floor provisions	TBD	Gap
3.22	Union representation (home care workers)	None — right-to-work state; no home care union presence	Public

Category 4

The Geographic Divide

#	Metric	Utah	Status
4.1	Travel time/mileage reimbursement mandate	TBD	Gap
4.2	Caregiver-to-senior ratio by county	NOT COMPILED	FOIA
4.3	Counties with zero/limited home care agencies	NOT COMPILED	FOIA
4.4	Rural broadband coverage (for EVV compliance)	TBD	Gap
4.5	EVV system & vendor	TBD	Gap
4.6	EVV offline/low-connectivity accommodation	TBD	Gap
4.7	EVV hard launch date (personal care)	TBD	Gap
4.8	Rural vs. urban NF admission rates	NOT COMPILED	FOIA
4.9	Rural nursing home closures since 2016	TBD	Gap
4.10	Rural HCBS alternatives (adult day, ALF)	TBD	Gap
4.11	Projected NF bed shortage (statewide)	TBD	Gap

Category 5

State Medicaid Toolkit & Reform Levers

#	Metric	Utah	Status
5.1	Medicaid rate-setting authority model	Aging, New Choices, Community Supports, ABI waivers via DHHS/DSPD	Public
5.2	Minimum fee schedule exists?	TBD	Gap
5.3	Fee schedule codified in statute or budget?	TBD	Gap
5.4	Wage pass-through % requirement	TBD	Gap
5.5	State-level 80/20 compensation rule?	No (federal CMS rule faces rescission)	Public
5.6	MCO contract cycle & next renewal	No wage pass-through requirement	Public
5.7	MCO workforce adequacy reporting required?	TBD	Gap
5.8	IRIS IBA formula inputs reflect market wages?	TBD	Gap
5.9	Premium pay structure for extended hours?	No statewide premium pay identified	Estimated
5.10	State domestic service OT exemption status	No state OT law; federal FLSA only	Public
5.11	Legislative path to eliminate state OT exemption?	No state backstop — federal rollback directly reduces protections	Analysis
5.12	Federal Medicaid loss projection (10yr)	TBD	Gap
5.13	Annual new cost to state taxpayers	TBD	Gap
5.14	State-directed payment limit impact (eff. 2028)	110% Medicare cap; exact impact TBD	Pending
5.15	Provider tax moratorium status	TBD	Gap
5.16	NF staffing rule moratorium (10yr)	Applies (est. 13,000 add'l deaths/yr nationally)	Public
5.17	Work requirements effective date	Partial expansion (Prop 3 modified); unique waiver structure — vulnerable	Analysis

Category 6

Federal FLSA & Companionship Exemption Status

#	Metric	Utah	Status
6.1	2013 DOL rule status (as of March 2026)	Technically in effect; enforcement suspended July 25, 2025 (FAB 2025-4)	Public
6.2	Proposed rescission rule published?	Yes — July 2, 2025 (90 FR 28976)	Public
6.3	Final rescission rule published?	No (as of March 2026)	Monitor
6.4	Chevron deference status	Eliminated — Loper Bright v. Raimondo (2024)	Public
6.5	Private litigation still viable?	Yes — 2013 rule provisions still invocable by private parties	Public
6.6	DOL estimated annual transfer (2013 RIA)	.8M (medium scenario, 7% discount)	Public
6.7	Adjusted current estimate	-700M annually	Estimated
6.8	GAO post-implementation finding	Hour caps, not cost absorption; pay did not increase; workforce declined 11.6%	Public
6.9	Familial caregiver % in self-directed programs	50-78% nationally; CA IHSS >70%	Public
6.10	Disparate impact demographics	85% female; 67% POC; 27% Black; 26% Hispanic	Public
6.11	CMS 80/20 Access Rule status	Finalized May 2024; faces likely rescission/non-enforcement	Public

Data sourcing

Every metric links to its primary source. Public = publicly available. Derived = calculated from public sources. Proxy = proxy or imprecise. Estimated = estimated value. FOIA = requires FOIA request. Partial = partially available. Gap = data not available. Full methodology and source registry available on the Methodology page.