Wisconsin has one of the Midwest's largest aging populations, with approximately 1.06 million residents aged 65 and older, representing 18% of the state's total population. Within two decades, approximately one in every five Wisconsin residents will be age 65 or older. For many rural counties in the northern tier of the state, this is already the case, with some counties projected to have nearly half their population over age 65.

This demographic reality creates both tremendous demand and significant operational challenges for home health agencies. Wisconsin faces a severe direct care workforce crisis, with one in four caregiver positions currently vacant and 70% of personal care agencies unable to staff all hours of care that residents need. The state has invested American Rescue Plan Act (ARPA) funds in workforce development, but systemic challenges persist. This guide covers everything agencies need to know about providing home health services in Wisconsin, from DHS licensing requirements to ForwardHealth Medicaid reimbursement and strategies for building a sustainable caregiver workforce.

Wisconsin Home Health Agency Licensing Requirements

Home health agencies in Wisconsin are regulated by the Wisconsin Department of Health Services (DHS) Division of Quality Assurance. The state maintains specific licensing requirements for agencies providing skilled home health services.

Regulatory framework. Home health agencies in Wisconsin are governed by Wisconsin Admin. Code ch. DHS 133, Home Health Agencies, and Wisconsin Admin. Code ch. DHS 12, Caregiver Background Checks. If the agency is certified for Medicare and/or Medicaid, 42 Code of Federal Regulations 484 also applies. The DHS Division of Quality Assurance oversees all licensing and certification activities.

Application requirements. To apply for a Wisconsin HHA license, agencies must submit the completed Wisconsin Home Health Agency License Application (F-62674), along with credentials showing that the administrator and substitute administrator meet position requirements per Wis. Admin. Code DHS 133.06. The application fee is $300, payable to The Division of Quality Assurance, plus background check fees of $15 per individual.

Additional documentation. Applicants must also provide an organizational chart including any other entities owned by the proposed HHA, a proposed operating budget for the first 90 days of operation using the Model Balance Sheet (F-62674A), financial references showing adequate funding (bank statements, letters from financial institutions, evidence of stock ownership, or verification of other income), and a copy of the IRS letter showing the Employer Identification Number.

Provisional licensure. The department may issue a provisional license for a term of 90 days. The department may, upon the agency's request, renew that license for additional 90-day terms not to exceed one year from the original issuance date. During the provisional period, the home health agency shall actively serve at least 10 patients requiring skilled nursing care or other therapeutic services in Wisconsin. At least seven of the 10 patients shall be actively receiving skilled nursing services when the home health agency submits a written request for an on-site licensure survey, and at least 3 patients shall be receiving skilled nursing services at the time of the on-site survey.

Background check requirements. Wisconsin requires comprehensive background checks under DHS 12 for all caregivers. Criminal records checks must be completed before employment begins, and certain convictions will disqualify individuals from working as caregivers. Agencies must maintain documentation of background check policies and results.

2025 portal transition. To prepare for the transition to the new DHS DQA Provider Portal, the Division of Quality Assurance will not accept any new background check applications for entity operators, non-client residents, or other required individuals for new or renewing entity license/certification applications as of November 22, 2025. DQA will resume accepting background check applications on December 15, 2025, through the DHS DQA Provider Portal. Caregiver background checks completed by entities for employees and contractors are not affected by this transition.

Home Health Aide Certification Requirements

Wisconsin has some of the most rigorous home health aide training requirements in the nation, significantly exceeding federal minimums. This reflects the state's commitment to quality care but also creates barriers to workforce entry that agencies must address.

Training hours. Wisconsin requires home health aides to complete a state-approved training program with at least 120 hours of coursework and clinical practice. This requirement significantly exceeds the federal minimum of 75 hours. The 120-hour program must include at least 32-40 hours of clinical training, depending on the specific program structure.

Training curriculum. The HHA training curriculum covers personal care techniques, home safety, infection control, communication, emergency response procedures, body mechanics, nutrition basics, and documentation requirements. The primary instructor must be a registered nurse who has had training in supervising nurse aides and/or teaching adult learners.

Competency evaluation. After completing training, candidates must pass competency evaluations including written examinations and skills demonstrations. Candidates may take the National Nurse Aide Assessment Program (NNAAP) examination, administered by Pearson VUE, which consists of both clinical skills evaluation and a written or oral examination component.

Eligibility requirements. Candidates must undergo a criminal background check, including fingerprinting, before being eligible to work as a home health aide. Many employers also require HHAs to have CPR certification. Physical exam, TB testing, and proof of immunizations may be required depending on the employer and clinical training site requirements.

Maintaining certification. Home health aides in Wisconsin must have qualifying work experience every two years to maintain their certification. Failure to maintain this work experience necessitates retesting through the competency evaluation process.

Program costs. Training programs in Wisconsin range from approximately $500 to $2,000 depending on the institution and program format. The longer 120-hour requirement typically takes 3-4 weeks to complete, which represents a significant time investment compared to states with shorter training requirements.

Salary expectations. The average annual pay for a home health aide in Wisconsin is approximately $33,899 a year, which works out to be approximately $16.30 an hour. According to Indeed, the average salary is $17.93 per hour with $4,000 in overtime annually. Wages range from $14.09 (25th percentile) to $18.17 (75th percentile). Wisconsin ranks 50th out of 50 states nationwide for HHA salaries, presenting significant recruitment challenges.

Certified Nursing Assistant (CNA) Requirements

Certified Nursing Assistants in Wisconsin provide a higher level of care and are regulated by the Wisconsin Department of Health Services. While Wisconsin does not require HHAs to hold CNA certification, many employers prefer candidates with these credentials, particularly for skilled home health services.

Training requirements. Wisconsin requires completion of a state-approved CNA training program with at least 75 hours, including a minimum of 16 hours of supervised clinical practice. The program includes at least 59 hours of classroom and lab instruction and at least 16 hours of supervised resident care in a nursing facility. CNA programs must receive approval from the Wisconsin Department of Health Services.

Age and education requirements. Applicants must be at least 18 years old. Unlike some states, Wisconsin does not require a high school diploma or GED for CNA certification, though many employers prefer it. Candidates must pass a criminal background check, and trainees with specific criminal convictions will not be allowed to practice as a CNA.

Training curriculum. The 75-clock hour CNA Training Program covers body mechanics, nutrition, anatomy and physiology, human disease processes, infection control, communication skills, and resident rights. Students master personal care skills including how to help patients bathe, eat, and groom themselves. The program must cover communication and interpersonal skills, infection control, safety and emergency procedures, promoting residents' independence, and residents' rights during the first 16 hours of classroom training.

Competency examination. Individuals must pass both a written and skills test within one year of successfully completing a training program. The Wisconsin Certified Nurse Aide Exam includes a Knowledge Test consisting of 75 multiple-choice questions to be completed within 60 minutes. The Skills Demonstration Test requires completion of three or four Wisconsin-approved nurse aide skill tasks within a maximum of 30 minutes. To pass, candidates need a score of 71% or higher on the Knowledge Test and must correctly perform all key steps and at least 80% of the non-key steps on each task assigned.

Exam costs. The examination fees are $125 for both the Wisconsin CNA Knowledge Test and Skills Test, $130 for both the oral knowledge test and skill test, $93 for the skill test only, $32 for the knowledge test only, and $37 for the oral knowledge test only.

Certification renewal. Each CNA must renew their certification every 24 months. To be eligible for renewal, the CNA must have worked for at least 8 paid hours as a nurse aide at a registered health care setting, such as a nursing home or hospital. There is no renewal fee required.

Out-of-state reciprocity. Active out-of-state CNAs can apply for Wisconsin certification through reciprocity. Applicants must have completed a minimum 75-hour state-approved nurse aide training program to be considered for the Wisconsin Nurse Aide Registry.

Program costs. CNA training programs in Wisconsin cost anywhere from $500 to $2,000, depending on the program. For example, the American Red Cross program costs approximately $1,300. These fees do not include classroom materials, uniforms, or textbooks. Some nursing facilities offer free training to prospective employees.

Medicaid Reimbursement in Wisconsin

Wisconsin's Medicaid program, administered through ForwardHealth, provides coverage for eligible residents through both fee-for-service and managed care arrangements. The state offers several long-term care programs that provide home health services.

ForwardHealth portal. For most services, Wisconsin Medicaid reimburses providers the lesser of the billed amount or the maximum allowable fee established by the Wisconsin Department of Health Services based on legislative directives. Maximum allowable fee information is available on the ForwardHealth Portal in an interactive fee schedule format with information on service coverage, pricing, and special coverage considerations, as well as downloadable fee schedules in text and CSV formats.

Managed care considerations. Wisconsin is one of only 2 states (along with Michigan) where the fee-for-service rate represents the maximum payment rate for managed care plans for home care services. This provides some rate predictability for providers working with managed care organizations.

Family Care program. Family Care is Wisconsin's primary Medicaid long-term care program for older adults and adults with disabilities. The goal is to help members receive the services they need to live in a home setting when possible. Managed care organizations coordinate services for the Family Care program, and when a person enrolls, they become a member of an MCO. Services include long-term care services such as adult day care, home modifications, home delivered meals, and supportive home care; health care services including home health, skilled nursing, mental health services, and occupational, physical, and speech therapy; and assistance coordinating primary health care.

IRIS program. IRIS (Include, Respect, I Self-Direct) is Wisconsin's self-directed Medicaid long-term care program for older adults and adults with disabilities. Self-direction means IRIS participants or their legal decision makers are responsible for choosing supports and services they need within their budget, hiring and managing providers, and following program rules. IRIS program benefits include live-in caregiver, adult day care, meal delivery, nursing services, home modifications, vehicle modifications, non-medical transportation, and personal care assistance. Unlike most HCBS Waivers, IRIS is considered an entitlement program, meaning all eligible applicants are guaranteed to receive benefits.

Minimum fee schedule. The Wisconsin Department of Health Services has created a minimum fee schedule for adult home and community-based services (HCBS). The schedule is a list of the lowest rates managed care organizations can pay providers of certain adult long-term care services in Family Care, Family Care Partnership, and the Program of All-Inclusive Care for the Elderly (PACE).

Eligibility for long-term care programs. To be eligible for IRIS or Family Care, individuals must live in Wisconsin, be at least 18 years old, be an older adult or an adult with a disability, be enrolled in Medicaid, and live in a home, apartment, adult family home, or residential care apartment complex. Applicants must also be functionally eligible, meaning they require a nursing facility level of care.

Application process. To apply for any of the HCBS waiver programs in Wisconsin (Family Care, Partnership, or IRIS), individuals should contact their local Aging and Disability Resource Center. For IRIS assistance, the IRIS Call Center is available at 888-515-4747.

Medicare Home Health Coverage

With Wisconsin's large elderly population and high rates of chronic illness, Medicare remains a crucial payer for home health services. Medicare certification allows agencies to serve beneficiaries and diversify their payer mix beyond Medicaid.

Eligibility requirements. To qualify for Medicare home health coverage, beneficiaries must be homebound (leaving home requires considerable effort due to illness or injury), need skilled nursing care on an intermittent basis or require physical therapy, speech-language pathology services, or continued occupational therapy, have a physician certify the need for home health care and establish a plan of care, and receive services from a Medicare-certified home health agency.

2025 rate updates. CMS's Calendar Year 2025 Home Health Prospective Payment System Final Rule includes a 2.7% home health payment update, which is offset by an estimated 1.8% decrease reflecting the permanent behavior adjustment and an estimated 0.4% decrease reflecting the updated fixed dollar loss ratio. CMS estimates that Medicare payments to HHAs in CY 2025 would increase in the aggregate by 0.5%, or $85 million, compared to CY 2024.

PDGM adjustments. The CY 2025 rule finalized a permanent prospective adjustment of -1.975% to account for the impact of implementing the Patient-Driven Groupings Model (PDGM). The 2.7% market basket update is offset by productivity adjustments and PDGM budget neutrality requirements.

Wisconsin geographic adjustments. Medicare payment rates are adjusted based on geographic location through the wage index. Wisconsin's various Core-Based Statistical Areas (CBSAs) have different wage indices that affect the final payment amount. Agencies should consult CMS's wage index tables for specific adjustments applicable to their service areas.

Plan of care requirements. Medicare requires a plan of care signed by a physician that specifies the services needed, frequency, and duration. The plan must be reviewed at least every 60 days.

Electronic Visit Verification (EVV) Requirements

The 21st Century Cures Act requires each state to collect visit information using an electronic visit verification system. Wisconsin has implemented comprehensive EVV requirements with full enforcement now in effect.

Federal mandate. The 21st Century Cures Act, passed in 2016, requires each state including Wisconsin to collect visit information using an EVV system. If Wisconsin doesn't follow this law, the state will lose money for Medicaid services. The law helps ensure that members and participants receive the services they need.

Implementation timeline. EVV in Wisconsin changed to the hard launch phase on May 1, 2023. As of January 1, 2024, EVV for home health care services (HHCS) and personal care nurse supervisory code 99509 is required in Wisconsin. Service claims must have a corresponding EVV record, and fee-for-service claim details without required verified EVV data will be denied.

Services requiring EVV. EVV is federally required for Medicaid-covered personal care, applicable supportive home care, and home health care services. This includes services authorized through Medicaid and BadgerCare Plus fee for service, HMOs, MCOs, and IRIS.

System requirements. The Wisconsin Department of Health Services selected the Sandata EVV system that can be used by all DHS programs and impacted provider agencies, HMOs, MCOs, Family Care fiscal employer agents (FEAs), and IRIS FEAs. Individual organizations do not need to purchase an EVV solution. However, organizations may choose to use a different or alternate EVV system as long as it integrates with Wisconsin's official EVV aggregator.

How EVV works. Workers check in at the beginning and check out at the end of each visit, using a smartphone or tablet, small digital device, or landline telephone. The system captures the type of service performed, the individual receiving the service, the date of service, the location of service delivery, the individual providing the service, and the time the service begins and ends.

Live-in worker exemption. The Centers for Medicare & Medicaid Services issued guidance providing states flexibility to decide if live-in workers and services rendered in the community are subject to EVV requirements. DHS acknowledges the unique role of live-in workers and will not require live-in workers to use EVV.

Consequences for non-compliance. Claims that cannot be matched by the payer to an EVV record are denied. Fee-for-service detail units billed exceeding the verified EVV visit units available will also be denied. Agencies must ensure proper EVV documentation to maintain cash flow.

Contact information. Wisconsin EVV Customer Care is available at 833-931-2035 or [email protected] Monday through Friday, 7 a.m. to 6 p.m.

Labor Laws and Wage Requirements

Wisconsin follows federal minimum wage standards and FLSA overtime guidelines. Understanding these requirements is essential for compliance and competitive compensation strategies.

Minimum wage. The minimum wage in Wisconsin for 2025 is $7.25 per hour, matching the federal minimum wage. This rate has not changed since 2009, making Wisconsin one of the few states that still follows the federal minimum wage instead of setting a higher state rate. The low minimum wage contributes to workforce recruitment challenges as caregivers can often earn more in retail or food service positions.

Tipped employees. The tipped minimum wage in Wisconsin is $2.33 per hour. Employers may take a tip credit of up to $4.92, but total compensation must meet $7.25 per hour when tips are combined. Home health aides are generally not tipped employees.

Youth minimum wage. Wisconsin allows a youth minimum wage of $5.90 per hour under specific conditions. New hires under 20 may be paid $5.90 per hour for their first 90 calendar days of employment. After 90 consecutive calendar days, or when the employee reaches 20 years old, whichever comes first, they must receive a minimum wage of $7.25 per hour.

Local variations. Local wage laws are mostly prohibited at the state level, but Milwaukee has set higher rates: $12.00 per hour for large employers and $11.00 per hour for small employers. Agencies operating in Milwaukee should be aware of these local requirements.

Overtime requirements. Under Wisconsin labor laws, non-exempt employees are entitled to overtime pay at 1.5 times their regular hourly rate for every hour worked beyond 40 hours in a workweek, aligning with federal FLSA guidelines. Wisconsin law does not specify a daily overtime limit.

Salary threshold for exemption. Following the 2024 federal court ruling, the overtime-exempt salary threshold for 2025 is $684 per week ($35,568 annually). Employees earning less than this threshold are entitled to overtime regardless of job duties. For highly compensated employees, the threshold remains at $107,432 per year.

Exemptions from overtime. Executive, administrative, professional, and outside sales positions may be exempt from overtime requirements. Specific roles like live-in caregivers may have exemptions, but most home health aides working scheduled shifts are entitled to overtime pay when exceeding 40 hours per week.

Wisconsin's Workforce Challenges

Wisconsin faces one of the most severe direct care workforce crises in the nation, driven by its large aging population, low wages relative to competing industries, and challenging working conditions.

Vacancy rates. Wisconsin's direct caregiving workforce is in crisis. Today, one in four direct caregiver positions is vacant. The shortage of paid caregivers is a crisis now, and the need for these workers is projected to increase by an additional 20,000 workers by 2026.

Unstaffed care hours. Currently, 70% of personal care agencies are unable to staff all hours of care that Wisconsinites need on a daily basis. This means eligible residents are not receiving the care they qualify for due to workforce shortages.

Family caregiver burden. A shortage of paid caregivers for people with disabilities and older adults is causing an unsustainable strain on unpaid family caregivers. Family members provide 80% of the care for people with disabilities and older adults in Wisconsin, with 60% of family caregivers spending more than 40 hours a week providing care. About 20% of family caregivers are working less at their regular jobs and about 40% have left the workforce entirely because of caregiving duties. There are an estimated 580,000 family caregivers in Wisconsin who shoulder 80% of all care in the state, providing 490 million hours of care annually.

Wage competition. The median hourly wage for home care workers in Wisconsin is $13.65, while the average HHA salary is around $16.30-$17.93 per hour. As one agency leader noted, "We're competing with the Kwik Trips of the world." Wisconsin's $7.25 minimum wage means caregivers can often find less demanding work at similar or higher wages in retail, food service, or warehouse positions.

Workforce poverty levels. An estimated 29% of Wisconsin's Home and Community Based waiver workforce (those working in people's homes and community settings through programs like Family Care and IRIS) are below 100% Federal Poverty Level and rely on Medicaid-funded BadgerCare for access to health care. Additionally, 35% of nursing home workers are below the poverty level. Many caregivers cannot afford the care they provide to others.

Demographic pressures. Within two decades, approximately one in every five Wisconsin residents will be age 65 or older. The elderly population (age 65+) is projected to nearly double from 2010 to 2040, and the very elderly population (age 85+) is projected to increase 140% during the same period. Some counties in Wisconsin will have almost half of their population over age 65.

Dementia care crisis. An aging population combined with caregiver shortages means Wisconsin faces a dementia crisis. There's a particular shortage of caregivers trained for dementia care, especially in rural Wisconsin where transportation and distance present additional barriers.

State workforce initiatives. Wisconsin is tackling the healthcare crisis using American Rescue Plan Act (ARPA) funds to recruit, support, and retain health care workers. The Certified Direct Care Professional (CDCP) Program improves the competency of direct care workers with training in 14 core areas. This free program, offered in partnership with the University of Wisconsin-Green Bay, only takes about 30 hours to complete and provides a credential that can help with recruitment and retention.

Strategies for Wisconsin Agencies

Given Wisconsin's specific market dynamics characterized by severe workforce shortages, competitive wage pressures, and rigorous training requirements, agencies must adopt targeted strategies to recruit and retain caregivers.

Pay significantly above minimum wage. With Wisconsin's minimum wage at just $7.25 per hour and average HHA wages around $16-18 per hour, paying at the higher end is essential. The median home care worker wage of $13.65 per hour is often not competitive with retail and food service positions. Consider offering $18-20 per hour in competitive markets to attract quality candidates who might otherwise work at gas stations or fast food restaurants.

Address the training barrier. Wisconsin's 120-hour HHA training requirement is among the highest in the nation. Consider partnering with training programs to subsidize costs, offer paid training time, or provide signing bonuses that cover training expenses. The significant time and cost investment required for certification is a major barrier to workforce entry.

Leverage CDCP certification. The free Certified Direct Care Professional (CDCP) Program offered through UW-Green Bay provides additional training in 14 core areas in just 30 hours. Encourage existing workers to complete this program and use it as a recruitment tool showing commitment to professional development.

Build career pathways. Create clear pathways from HHA to CNA and beyond. Wisconsin's training requirements (120 hours for HHA, 75 hours for CNA) create opportunities for stackable credentials. Partner with community colleges and nursing programs to offer tuition assistance tied to employment commitments.

Address benefits gaps. With 29% of Wisconsin's home care workforce below the poverty level and relying on BadgerCare, benefits can be a significant differentiator. Even modest offerings such as paid time off, health insurance contributions, or retirement matching can attract caregivers. Same-day pay options can address financial stress among workers living paycheck to paycheck.

Ensure EVV compliance. With Wisconsin's EVV hard launch in effect since May 2023 and claims being denied without matching EVV records, ensure your agency is properly set up with Sandata or an approved alternative vendor. Train staff thoroughly on proper check-in/check-out procedures.

Focus on retention. Every retained caregiver saves significant replacement costs. With one in four positions vacant statewide, retention is critical. Invest in thorough onboarding, consistent scheduling, supervisor support, and recognition programs. Exit interviews can identify fixable issues driving turnover.

Pursue Medicare certification. Diversifying beyond Medicaid to include Medicare patients can improve your agency's financial sustainability. Medicare rates often provide better reimbursement than state Medicaid programs, allowing agencies to potentially offer more competitive wages.

Build rural strategies. Wisconsin's northern tier counties already have very high senior population percentages, but face severe workforce shortages. Consider travel time reimbursement, mileage payments above the IRS rate, and local community recruiting rather than expecting workers to commute from distant areas.

Partner with Aging and Disability Resource Centers. Wisconsin's ADRC network can connect agencies with referral sources and community resources. Building relationships with these organizations strengthens your presence in local markets and can provide access to Family Care and IRIS program referrals.

Key Resources and Contacts

Agencies operating in Wisconsin should maintain relationships with these key regulatory and support organizations:

Wisconsin Department of Health Services - Division of Quality Assurance
Home health agency licensing under DHS 133
Caregiver background checks under DHS 12
Website: dhs.wisconsin.gov/regulations/hha

Wisconsin Nurse Aide Registry
CNA certification and registry
Competency testing through Pearson VUE
Website: dhs.wisconsin.gov/caregiver/nurse-aide

ForwardHealth
Medicaid provider enrollment and fee schedules
Interactive maximum allowable fee schedule
Website: forwardhealth.wi.gov

Wisconsin EVV Customer Care
Electronic Visit Verification support
Phone: 833-931-2035
Email: [email protected]
Hours: Monday-Friday, 7 a.m. - 6 p.m.

IRIS Call Center
Self-directed long-term care program assistance
Phone: 888-515-4747

Aging and Disability Resource Centers
Local entry points for long-term care programs
Family Care and IRIS enrollment assistance
Find your local ADRC at dhs.wisconsin.gov/adrc

Certified Direct Care Professional (CDCP) Program
Free 30-hour training program
Offered through UW-Green Bay
Website: dhs.wisconsin.gov/arpa/hcbs-directcareworkforce.htm

The Bottom Line

Wisconsin presents significant challenges for home health agencies serving one of the Midwest's largest aging populations. The state's 1.06 million seniors and demographic trajectory toward 2040 ensure sustained demand for home health services, but the current workforce crisis with one in four positions vacant creates immediate operational challenges.

Navigating Wisconsin requires careful attention to compliance. The state's 120-hour HHA training requirement is among the nation's highest, creating a significant barrier to workforce entry. EVV enforcement is in full effect, with claims denied without matching visit records. Background check requirements under DHS 12 must be carefully followed, with attention to the 2025 portal transition timeline.

Workforce challenges in Wisconsin are severe. The median home care worker wage of $13.65 per hour struggles to compete with retail and food service positions, particularly given the demanding nature of caregiving work. With 70% of agencies unable to staff all authorized care hours, recruitment and retention strategies must be aggressive.

Success in Wisconsin requires understanding the DHS licensing framework, leveraging ForwardHealth fee schedules and the Family Care/IRIS programs, ensuring EVV compliance to avoid claim denials, and investing in competitive compensation significantly above the state's $7.25 minimum wage. Agencies that address training barriers, build career pathways, and create supportive workplace cultures will be best positioned to serve Wisconsin's growing senior population and build sustainable businesses in the Badger State.