The nation’s most HCBS-rebalanced state — 94.8% of LTSS spending directed to community-based care — facing a 27.8% caregiver vacancy rate and $6.4–$16.8 billion in projected federal Medicaid losses.
| # | Metric | Wisconsin | Status |
|---|---|---|---|
| 1.1 | BLS median hourly wage (SOC 31-1120) | $16.41/hr | Public |
| 1.2 | PHI median hourly wage (all DCW, ACS) | $14.98/hr | Public |
| 1.3 | Median annual earnings (DCW) | $23,378 | Public |
| 1.4 | MIT living wage (1 adult, 0 children) | $21.88/hr | Public |
| 1.5 | Wage gap (living wage minus BLS median) | −$5.47/hr (~$11,378/yr) | Derived |
| 1.6 | State minimum wage (2026) | $7.25 (federal floor) | Public |
| 1.7 | Local minimum wage (highest city) | N/A (state preempts) | Public |
| 1.8 | Low-income household rate (<200% FPL) | 32% | Public |
| 1.9 | Public assistance reliance (state-specific) | Not published (32% proxy) | Proxy |
| 1.10 | Housing cost-burdened rate | 31% | Public |
| 1.11 | Uninsured rate (DCW) | 9% | Public |
| 1.12 | PHI Overall State Index ranking | 22/51 (Tier 2) | Public |
| 1.13 | Wage competitiveness vs. similar jobs | −$3.19/hr | Public |
| 1.14 | Genworth median home health aide rate | $238/day ($86,944/yr) | Public |
| 1.15 | Genworth median NF semi-private rate | $331/day ($120,815/yr) | Public |
| 1.16 | Family Care capitation PMPM (NH LOC) | $4,968.18 ($59,618/yr) | Public |
| 1.17 | Blended HCBS avg cost (all acuity) | $133–150/day ($48K–$54K/yr) | Public |
| 1.18 | NF private pay monthly avg | $10,708/mo ($128,502/yr) | Public |
| 1.19 | HCBS-to-NF cost ratio (state-specific) | ~2.2:1 (NH LOC vs NF Medicaid) | Derived |
| 1.20 | Exemption aggregate savings (national est.) | $500–700M/yr (~0.2% of HCBS) | Estimated |
| 1.21 | Per-worker OT loss (50hr/wk worker) | $3,120–$3,640/yr (at WI wages) | Derived |
Every dollar not spent on a $48,000 HCBS participant risks generating a $128,000 nursing home resident. Wisconsin’s State Developmental Disability Centers cost $1,519 per day ($554,435/yr) — roughly 10× the cost of Family Care/IRIS services. The substitution research shows people without HCBS are 5× more likely to enter nursing homes.
| # | Metric | Wisconsin | Status |
|---|---|---|---|
| 2.1 | Headline caregiver vacancy rate | 27.8% (2022; up from 20% in 2018) | Public |
| 2.2 | Open caregiver positions | 23,165 | Public |
| 2.3 | Available job seekers (entire labor market) | 19,600 (fewer than openings) | Public |
| 2.4 | Annual turnover rate | ~50% | Public |
| 2.5 | Individuals denied/delayed services | 18,482 | Public |
| 2.6 | Agencies unable to staff all hours | 70% (daily); 93% (fill all positions) | Public |
| 2.7 | Nursing homes closed since 2016 | ~40 of ~350 | Public |
| 2.8 | NF beds empty due to staffing | ~25% of beds | Public |
| 2.9 | Total direct care workers | 100,910 | Public |
| 2.10 | New jobs projected (2022–2032) | 12,680 | Public |
| 2.11 | Total openings incl. separations (2022–2032) | 178,800 | Public |
| 2.12 | Population 75+ growth projection | +41% by ~2030 | Public |
| 2.13 | Workforce demographics: % women | 86% | Public |
| 2.14 | Workforce demographics: % people of color | 31% | Public |
| 2.15 | Workforce demographics: % immigrants | 6% | Public |
| 2.16 | Health insurance offered by agencies | 29.5% (vs 60.2% national) | Public |
| 2.17 | Family caregivers providing 80%+ of all care | Yes (Survival Coalition) | Public |
| 2.18 | Unpaid caregiver hours/economic value | 549K caregivers; 588M hrs; ~$6B value | Public |
| # | Metric | Wisconsin | Status |
|---|---|---|---|
| 3.1 | State companionship/OT exemption status | PARTIAL: OT for agency (for-profit); exempt for household & nonprofit | Public |
| 3.2 | State overtime threshold | 40 hours (for-profit agency workers only) | Public |
| 3.3 | Domestic Workers Bill of Rights | Not enacted | Public |
| 3.4 | Paid sick leave law | No | Public |
| 3.5 | Paid family/medical leave | No | Public |
| 3.6 | Primary self-directed Medicaid program | IRIS (1915(c) standalone) | Public |
| 3.7 | Self-directed program enrollment | IRIS: 28,053 (Sept 2025) | Public |
| 3.8 | Primary managed LTC program | Family Care (1915(b)/(c)) | Public |
| 3.9 | Managed LTC enrollment | 57,000+ (Family Care) | Public |
| 3.10 | Combined HCBS enrollment | 85,000–90,000 | Partial |
| 3.11 | HCBS share of LTSS spending | 94.8% (#1 nationally) | Public |
| 3.12 | HCBS waiting lists status | Eliminated March 2021 | Public |
| 3.13 | Spouses as paid Medicaid caregivers | Conflicting sources (verify w/ DHS) | Gap |
| 3.14 | Parents of minors as paid caregivers | Likely yes (CLTS waiver); unconfirmed | Gap |
| 3.15 | COVID family caregiver relaxations permanent? | Not definitively confirmed | Gap |
| 3.16 | SDPC maximum wage (self-directed) | $7.25–$16.47/hr | Public |
| 3.17 | OT rate cap in self-directed programs | Cannot exceed Medicaid PC rate | Public |
| 3.18 | IRIS/SDPC weekly hour cap | 40hr default; exception to 60hr | Public |
| 3.19 | Minimum fee schedule for HCBS | Yes — $258M/yr; $15.75/hr wage floor | Public |
| 3.20 | Wage pass-through requirement | No (rate-to-agency, not rate-to-worker) | Public |
| 3.21 | MCO contract wage floor provisions | Not currently required | Gap |
| 3.22 | Union representation (home care workers) | No statewide bargaining | Public |
| # | Metric | Wisconsin | Status |
|---|---|---|---|
| 4.1 | Travel time/mileage reimbursement mandate | No mandate; IRIS = discretionary budget item | Public |
| 4.2 | Caregiver-to-senior ratio by county | NOT COMPILED | FOIA |
| 4.3 | Counties with zero/limited home care agencies | NOT COMPILED (30/72 counties rural) | FOIA |
| 4.4 | Rural broadband coverage (for EVV compliance) | Available via PSC maps; SW/NW underserved | Partial |
| 4.5 | EVV system & vendor | Sandata (free; open model) | Public |
| 4.6 | EVV offline/low-connectivity accommodation | Sandata app: offline after initial setup | Public |
| 4.7 | EVV hard launch date (personal care) | May 1, 2023 | Public |
| 4.8 | Rural vs. urban NF admission rates | NOT COMPILED at county level | FOIA |
| 4.9 | Rural nursing home closures since 2016 | Majority of ~40 closures in rural areas | Partial |
| 4.10 | Rural HCBS alternatives (adult day, ALF) | 80% of areas near closed NFs lack adult day; 50% lack ALF | Academic |
| 4.11 | Projected NF bed shortage (statewide) | >7,300 beds by 2030 | Public |
| # | Metric | Wisconsin | Status |
|---|---|---|---|
| 5.1 | Medicaid rate-setting authority model | MCO capitation + FFS NF per diem | Public |
| 5.2 | Minimum fee schedule exists? | Yes — $258M/yr (eff. Oct 2024, ARPA-funded) | Public |
| 5.3 | Fee schedule codified in statute or budget? | Budget appropriation (vulnerable to expiry) | Public |
| 5.4 | Wage pass-through % requirement | None (rate-to-agency only) | Public |
| 5.5 | State-level 80/20 compensation rule? | No (federal CMS rule faces rescission) | Public |
| 5.6 | MCO contract cycle & next renewal | Verify with DHS (current cycle) | FOIA |
| 5.7 | MCO workforce adequacy reporting required? | Not currently required | FOIA |
| 5.8 | IRIS IBA formula inputs reflect market wages? | Built on $14–16/hr; market needs $17–20/hr | Analysis |
| 5.9 | Premium pay structure for extended hours? | No (hard 40hr cap, not tiered rate) | Proposal |
| 5.10 | State domestic service OT exemption status | Yes — Wis. Stat. 103.01(2)(d) | Public |
| 5.11 | Legislative path to eliminate state OT exemption? | Requires statute change (GOP legislature) | Analysis |
| 5.12 | Federal Medicaid loss projection (10yr) | $6.4B–$16.8B (69% on EBD) | Public |
| 5.13 | Annual new cost to state taxpayers | $142M/yr at full implementation | Public |
| 5.14 | State-directed payment limit impact (eff. 2028) | 110% Medicare cap; exact impact TBD | Pending |
| 5.15 | Provider tax moratorium status | Hospital tax locked in ($1.1B/yr); NF exempt but frozen | Public |
| 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 |
Federal action is foreclosed. These levers are available through state Medicaid program design: codify the fee schedule in statute, implement a 75–80% wage pass-through requirement, raise the IRIS SDPC wage ceiling to $20/hr, and create a tiered premium pay structure for hours 41–60 instead of a hard cap.
| # | Metric | Wisconsin | 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) | $321.8M (medium scenario, 7% discount) | Public |
| 6.7 | Adjusted current estimate | $500–700M 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 |