New York Department of Health Issues Updated Guidance on Wage Parity Compliance Forms and Certification Submission Dates

Why It Matters

The clarified timelines and audit options reduce regulatory risk and operational ambiguity for Medicaid‑funded home‑care agencies, directly affecting cost management and compliance costs.

Key Takeaways

• DOH sets firm 2025 LS300 deadline May 31, 2026.
• LS301 audit due Oct 1 annually for prior year.
• AUPs can replace full audits for wage parity reporting.
• 2027 requires contract‑level AFS/AUP for LHCSAs and SFI.
• Certifications submitted via eMedNY portal by Dec 1 annually.

Pulse Analysis

The New York Department of Health’s March 2026 update resolves a year‑long ambiguity that plagued licensed home‑care agencies, Medicaid Managed Care Organizations, and certified home health agencies. By anchoring LS300 reporting to a May 31, 2026 deadline for the 2025 calendar year and standardizing LS301 audit submissions to October 1 each year, the state provides a predictable compliance calendar. This predictability is crucial for budgeting, staffing, and ensuring that wage‑parity obligations—mandated by the 2020‑2021 budget law—are met without costly last‑minute scrambles.

A notable shift in the guidance is the endorsement of Agreed‑Upon Procedures (AUPs) as a viable alternative to full‑scale financial audits. Certified public accountants can now verify payroll records, wage‑parity hours, and supplemental benefits through a focused set of procedures, streamlining the audit process and potentially lowering professional‑service fees. Providers must still retain independent auditors for verification, but the flexibility to choose AUPs offers a strategic tool for managing compliance expenditures while maintaining rigorous oversight.

Looking ahead, the guidance signals an escalation in oversight starting in 2027, when LHCSAs and the Statewide Fiscal Intermediary must conduct AFSs or AUPs for each individual contract rather than agency‑wide. This granular approach aligns with broader state efforts to tighten Medicaid spending controls and ensure that home‑care workers receive the statutory wage and benefit protections. Organizations that proactively adjust their audit strategies and integrate the new portal submission timelines will be better positioned to avoid penalties and sustain operational efficiency in a tightly regulated market.