Oregon's home health care industry operates in a progressive regulatory environment with strong worker protections, robust HCBS programs, and a unique three-tiered minimum wage structure. From the urban Portland metro area to the rural eastern counties, agencies must navigate state-specific licensing requirements, understand the K Plan and APD waiver programs, and adapt to recent CNA certification changes while developing effective workforce strategies.

Home Health Agency Requirements in Oregon

Oregon regulates home care agencies through separate licensing pathways for home health agencies and in-home care agencies. The Oregon Health Authority (OHA) Public Health Division's Health Care Regulation and Quality Improvement Section (HFLC) oversees these licensure programs.

Home Health Agency Licensing

Home health agencies providing skilled services must be licensed under OAR chapter 333, division 027. Key requirements include:

  • Compliance with ORS 443.065 general requirements for home health agencies
  • Nursing services provided by an Oregon-licensed registered nurse
  • Adherence to Oregon State Board of Nursing Administrative Rules (OAR chapter 851)
  • Annual licensure surveys conducted by Oregon DHS's Health Division

In-Home Care Agency Licensing

In-home care agencies providing non-skilled services must be licensed under OAR chapter 333, division 536. Agencies can apply for licensure through:

  • Direct in-home care agency licensure under OAR 333-536
  • Home health agency with in-home care service designation per ORS 443.305

The OHA provides the In-Home Care Agency License Application Form and related fact sheets for agencies seeking initial licensure. This separate licensing pathway for non-skilled home care has been effective since February 1, 2003.

Certified Nursing Assistant (CNA) Certification

Oregon's CNA certification is administered by the Oregon State Board of Nursing. Significant changes took effect July 1, 2025, consolidating the certification structure.

July 2025 Certification Changes

As of July 1, 2025, Oregon consolidated CNA 1 and CNA 2 into a single CNA certification. Under this new structure:

  • The former CNA 1 and CNA 2 levels are now unified
  • Advanced skills previously taught in CNA 2 programs are now "additional authorized duties"
  • Additional authorized duties are taught and validated on the job by a Registered Nurse

This consolidation simplifies the certification pathway while maintaining access to advanced skills through on-the-job training.

Training Requirements

To become a CNA in Oregon, candidates must complete a state-approved training program with the following requirements:

  • Minimum 155 hours of total training
  • At least 80 hours of classroom and lab instruction
  • At least 75 hours of supervised clinical practice
  • Current adult CPR certification

Training covers essential topics including infection control, patient safety, basic nursing care, communication skills, and resident rights.

Eligibility Requirements

  • Minimum age of 18 years (some programs accept 16-year-olds)
  • High school diploma or GED
  • Complete digital fingerprinting through Fieldprint Inc. for state and federal background checks
  • Meet physical health standards

Certification Exam

After completing training, candidates must pass the state-approved competency evaluation consisting of:

  • Written exam: Tests knowledge of essential caregiving principles
  • Skills test: Assesses practical proficiency in hands-on care

Candidates must pass both tests within one year of training completion. Up to three attempts are allowed; after three failed attempts, retraining is required. Certification is valid for two years.

Oregon CNA Compensation

Oregon offers competitive CNA wages. As of 2025, the average CNA hourly wage in Oregon is approximately $26, equating to an annual salary of around $58,854. This is significantly higher than the national average and reflects Oregon's progressive wage structure.

Home Health Aide (HHA) Requirements

Home health aides in Oregon typically work under the supervision of licensed nurses and must meet training requirements established by their employing agencies and any applicable federal requirements for Medicare-certified agencies.

Federal Requirements

For Medicare-certified home health agencies, HHAs must complete at least 75 hours of training covering health-related topics and demonstrate competency in required skills. Oregon agencies may have additional state-specific requirements.

Oregon Medicaid and Home Care Services

Oregon's Medicaid program, the Oregon Health Plan (OHP), provides comprehensive home and community-based services through multiple mechanisms including the K Plan and HCBS waivers.

K Plan (Community First Choice)

Oregon's Community First Choice (CFC) Option, also known as the K Plan, is a 1915(k) State Plan authorized by the Affordable Care Act. Key features include:

  • Makes home and community-based services available to all who are eligible
  • No budget neutrality requirement (unlike HCBS waivers)
  • Provides the majority of in-home services for eligible Oregonians
  • Can be combined with waiver services without duplication

The K Plan represents a significant expansion of Oregon's commitment to community-based care, ensuring that eligible individuals have access to services without the enrollment caps typical of waiver programs.

Aged and Physically Disabled (APD) Waiver

Oregon operates two CMS-approved waivers for Aging and People with Disabilities (APD) services, both approved through 2026.

Waiver Programs

  • 1915(c) #0185 APD Waiver: Provides waiver case management for eligible individuals and community transition services
  • 1915(b)(4) Case Management Freedom of Choice Waiver: Allows Area Agencies on Aging (AAAs), APD offices, and federally recognized Tribes to provide waiver case management

2026 Financial Eligibility

For HCBS Waivers including the APD Waiver:

  • Income (Single): $2,982 per month
  • Assets (Single): $2,000
  • Income (Married, both applying): $5,964 per month combined
  • Assets (Married, both applying): $4,000 combined
  • Community Spouse Resource Allowance: $162,660 for non-applicant spouse

Program Capacity

Unlike Nursing Home Medicaid, the APD Waiver is not an entitlement program. Oregon's APD Waiver has approximately 44,600 enrollment spots per year as of 2025. Once spots are filled, additional applicants are placed on a waitlist.

Agency with Choice: January 2026 Implementation

Oregon is implementing a significant new service model beginning January 2026. House Bill 4129 (2024) directed APD to create an Agency with Choice (AwC) service model for in-home services.

Key Features

  • New service option for in-home consumers
  • Updated APD rate methodology for Adult Foster Homes and Residential Care Facilities
  • HB 4129 limits the number of AwC providers to two statewide
  • Effective date: January 1, 2026

The public comment period for these changes closed September 1, 2025. Agencies should prepare for this new service model and understand how it may affect their operations and consumer relationships.

Electronic Visit Verification (EVV)

Oregon has implemented Electronic Visit Verification (EVV) for personal care services and home health care services as required by the 21st Century Cures Act. The state's EVV system captures required data including service type, recipient, provider, date, time, and location of service delivery.

Medicare Home Health in Oregon

Medicare-certified home health agencies in Oregon must meet federal Conditions of Participation and operate under the Patient-Driven Groupings Model (PDGM) for reimbursement.

Oregon-Specific Considerations

Oregon's diverse geography, from the Portland metro area to the rural eastern counties, creates varying service delivery challenges. Agencies must consider travel distances, workforce availability, and regional cost differences when planning service areas.

Oregon Labor Laws for Home Care

Oregon has comprehensive labor protections for home care workers, including a unique three-tiered minimum wage system based on geography.

Three-Tiered Minimum Wage (July 2025)

Oregon operates a geographic minimum wage system under ORS 653.025. As of July 1, 2025:

  • Portland Metro ($16.30/hour): Clackamas, Multnomah, and Washington counties
  • Standard Counties ($15.05/hour): Benton, Clatsop, Columbia, Deschutes, Hood River, Jackson, Josephine, Lane, Lincoln, Linn, Marion, Polk, Tillamook, Wasco, and Yamhill counties
  • Non-Urban Counties ($14.05/hour): Baker, Coos, Crook, Curry, Douglas, Gilliam, Grant, Harney, Jefferson, Klamath, Lake, Malheur, Morrow, Sherman, Umatilla, Union, Wallowa, and Wheeler counties

These rates are adjusted annually, and agencies must ensure compliance based on the location where services are provided.

2026 Homecare Worker Wage Increase

SEIU Local 503 homecare workers will receive a $1.25 per hour wage increase beginning with the pay period starting January 1, 2026. This increase reflects Oregon's commitment to supporting the home care workforce through collective bargaining.

Overtime Requirements

Oregon has specific overtime rules for domestic service workers:

  • Live-out employees: Must be paid 1.5x hourly rate for all hours over 40 in a workweek
  • Live-in employees: Must be paid 1.5x hourly rate for all hours over 44 in a workweek

Note that Oregon provides overtime protections for live-in workers, unlike the federal exemption.

Rest Period Requirements

Oregon law provides significant protections for domestic service workers:

  • 24 continuous hours off required each work week
  • Three paid personal days off per year for workers averaging 30+ hours per week

Paid Sick Leave

Oregon's paid sick leave law applies to employers with 10 or more employees (6 or more in Portland). Most household employers fall below these thresholds, but agencies typically must comply.

Homecare Worker Rights

Under ORS 410.614, home care and personal support workers have specific rights including:

  • Right to organize and collectively bargain
  • Protection from retaliation
  • Access to workplace rights information

While home care workers are not considered state employees (ORS 410.619), they have significant labor protections under Oregon law.

Record-Keeping Requirements

Employers must maintain payroll and tax records for at least three years, including timesheets, pay stubs, tax withholdings, and employment agreements.

Workforce Challenges and Strategies

Oregon agencies face unique workforce dynamics shaped by progressive labor laws, competitive wages, and geographic diversity.

Key Challenges

  • Regional Wage Variations: Managing compensation across the three-tiered minimum wage structure
  • Competition with Healthcare Systems: High CNA wages ($26/hour average) reflect intense competition
  • Rural Coverage: Non-urban counties face workforce shortages despite lower minimum wages
  • Certification Changes: Adapting to the July 2025 CNA consolidation

Recruitment Strategies

  • Community College Partnerships: Work with Oregon's community college CNA programs at institutions like Lane, Chemeketa, Klamath, and Oregon Coast
  • Competitive Wages: Oregon's high CNA wages require agencies to offer market-rate or above compensation
  • Training Investment: The 155-hour training requirement is substantial; consider employer-sponsored programs
  • On-the-Job Skills Training: Leverage the new "additional authorized duties" framework for advanced skills development

Retention Strategies

  • Union Collaboration: Work constructively with SEIU Local 503 representing many homecare workers
  • Career Advancement: Create pathways from HHA to CNA to LPN/RN
  • Schedule Flexibility: Honor required rest periods while accommodating worker preferences
  • Mileage and Travel: Provide adequate compensation for rural service delivery
  • Professional Development: Support workers in gaining additional authorized duties certifications

Technology Solutions

  • EVV systems integrated with payroll for accurate wage and hour compliance
  • Mobile apps for scheduling and communication across dispersed service areas
  • Online training platforms for required continuing education
  • Geographic tracking to ensure correct minimum wage tier compliance

Resources for Oregon Home Care Agencies

  • Oregon Health Authority (OHA): Health Facility Licensing & Certification for agency licensure
  • Oregon State Board of Nursing: CNA certification and registry information
  • Oregon DHS Aging and People with Disabilities: APD waiver and K Plan information
  • Area Agencies on Aging (AAAs): Local contacts for waiver case management
  • Oregon ADRC: (855) 673-2372 for consumer referrals and program information
  • Oregon Bureau of Labor and Industries (BOLI): Domestic worker rights and compliance guidance

The Bottom Line

Operating a home health or home care agency in Oregon requires navigating a progressive regulatory environment with strong worker protections. The state's three-tiered minimum wage system ($14.05-$16.30), generous overtime rules for live-in workers, and robust K Plan/waiver programs create a distinctive operating environment. The July 2025 CNA certification consolidation and January 2026 Agency with Choice implementation represent significant changes agencies must adapt to. Success in Oregon requires competitive compensation (average CNA wage: $26/hour), effective partnerships with community colleges and labor unions, and efficient operations across diverse geographic areas. Agencies that embrace Oregon's progressive framework while maintaining operational excellence will thrive in this well-funded, worker-friendly market.