Vermont leads on HCBS rebalancing with ∼70% of LTSS in community settings via the Choices for Care 1115 waiver. State law exempts domestic workers from OT (21 V.S.A. Section 383), but federal FLSA protections apply. AFSCME Local 4802 represents 5,000+ independent home care workers with a ratified CBA. A small but aging state facing acute rural workforce shortages.
| # | Metric | Vermont | Status |
|---|---|---|---|
| 1.1 | BLS median hourly wage (SOC 31-1120) | ∼$15.54/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) | TBD | Gap |
| 1.5 | Wage gap (living wage minus BLS median) | TBD | Gap |
| 1.6 | State minimum wage (2026) | $14.01/hr | Public |
| 1.7 | Local minimum wage (highest city) | N/A (no local minimum wage preemption issues) | 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) | TBD | Gap |
| 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 |
| # | Metric | Vermont | 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 | ∼75% (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 | ∼5,000-6,000 | 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 | ∼85% (national proxy) | Proxy |
| 2.14 | Workforce demographics: % people of color | TBD | Gap |
| 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 |
| # | Metric | Vermont | Status |
|---|---|---|---|
| 3.1 | State companionship/OT exemption status | State exempts domestic workers (21 V.S.A. Section 383); federal FLSA OT applies (post-2015 DOL rule) | Public |
| 3.2 | State overtime threshold | 40 hrs/wk (federal FLSA; state exempts domestic workers) | Public |
| 3.3 | Domestic Workers Bill of Rights | No DWBOR; 2024 PRO Act extended collective bargaining to domestic workers | Public |
| 3.4 | Paid sick leave law | Yes — Vermont Earned Sick Time Act (2017) | Public |
| 3.5 | Paid family/medical leave | Yes — Vermont Paid Family and Medical Leave (PFML) program | Public |
| 3.6 | Primary self-directed Medicaid program | Choices for Care (1115 waiver — integrated LTSS) | Public |
| 3.7 | Self-directed program enrollment | TBD | Gap |
| 3.8 | Primary managed LTC program | State acts as MCO under Global Commitment 1115 waiver (unique nationally) | Public |
| 3.9 | Managed LTC enrollment | TBD | Gap |
| 3.10 | Combined HCBS enrollment | TBD | Gap |
| 3.11 | HCBS share of LTSS spending | ∼70.3% | Public |
| 3.12 | HCBS waiting lists status | TBD | Gap |
| 3.13 | Spouses as paid Medicaid caregivers | Yes (self/family-directed options under Choices for Care) | Public |
| 3.14 | Parents of minors as paid caregivers | Yes (Choices for Care allows participant direction) | Public |
| 3.15 | COVID family caregiver relaxations permanent? | TBD | Gap |
| 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) | AFSCME Local 4802 — VT Homecare United (5,000+ members; CBA ratified July 2024) | Public |
| # | Metric | Vermont | 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 |
| # | Metric | Vermont | Status |
|---|---|---|---|
| 5.1 | Medicaid rate-setting authority model | Choices for Care 1115 waiver (integrated institutional + HCBS) | 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 | TBD | Gap |
| 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 | State exempts domestic workers from OT (21 V.S.A. Section 383); federal FLSA provides coverage | Public |
| 5.11 | Legislative path to eliminate state OT exemption? | State exemption exists; federal protections apply independently | 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 | Dec 31, 2026 (childless adults) | Public |
| # | Metric | Vermont | 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 |