Wage Equity Add-On FAQs

FREQUENTLY ASKED QUESTIONS

 

1. Is overtime/double time included in the calculation to determine the average hourly rate?

2. As part of trying to eliminate the use of agency staff, we may be hiring more inexperienced aides which decreases our weighted average hourly rate. I’m not sure how we account for the wage scale increase when that happens since the average will appear as if we did not spend the funds.

3. If a facility has purchased a service (e.g. Laundry and Housekeeping) and they bring it in house, what do they use as a starting hourly wage? Is it what they hire them at or the hourly wage being paid in purchased services as the starting wage? Do all the wages count for the first year or do they not count until they give them a raise after hiring them down the road where the incremental wages then count?

4. Are we limited to only giving out a 4 dollar per hour raise? Are we allowed to give more than that?

5. What happens if we don’t spend all the funds? I understand we will need to return it but would there be any penalty associated with it?

6. The information says we need to use the last 2 payrolls for 2021 to compute the average rates. Does that mean the last 2 paychecks or the last 2 pay periods?

7. For CHOWs between 7/1/22 and 6/30/23, do the two owners combine their report? Or would each owner be required to file for the period that they owned the building? 

8. What if a facility closes between 7/1/22 and 6/30/23? Do they still need to complete this worksheet?

9. What if we do not have any data for a specific job class?

10. Is the Facility Monthly Census Tab required?

11. How do we calculate average wage?


Answers

Is overtime/double time included in the calculation to determine the average hourly rate?

The overtime and double time is included in the hours. However, only the base wage is used and not any additional pay for those hours.

 

As part of trying to eliminate the use of agency staff, we may be hiring more inexperienced aides which decreases our weighted average hourly rate. I’m not sure how we account for the wage scale increase when that happens since the average will appear as if we did not spend the funds.

The Wage Equity Funding Worksheet is data collection to illustrate how money was used and not necessarily a collection of unspent funds exercise. However, the department is requiring backup documentation of the calculation of maximum, minimum, and average wages.  For example, per job classification reported on the Wage Equity Funding Worksheet the average wage calculation would be a calculation of related total eligible wages divided by related total eligible hours.  Backup documentation calculations of the maximum and minimum wage would be the array of related hourly wages per job class reported on the Wage Equity Funding Worksheet and calculating the maximum and minimum wage from the array.

 

If a facility has purchased service Laundry and Housekeeping and they bring it in house. What do they use as a starting hourly wage? Is it just what they hire them at, or the hourly wage being paid in purchased services as the starting wage? Do all the wages count for the first year or do they not count until they give them a raise after hiring them down the road where the incremental wages then count?

The agency/purchased services wages for staff that are brought in-house do not get used for wages paid in Dec 2021 to calculate the max, min, and average wage, but then all brought in-house non-agency/purchased service wages will be used for the time period of 7/1/22 to 6/30/23 to calculate the max, min and average wage. In some cases, we may use comparable facilities for a baseline wage. 

 

Are we limited to only giving out a 4 dollar per hour raise? Are we allowed to give more than that?

There is no limit to the raises direct care staff can receive. However, the wage equity funding was earmarked by the Legislature as only for raises up to four dollars per hour on average. Raises over that average must be paid by the facility. These raises should be included on the cost report and would become part of the base rate if and when the rate is rebased using that year's costs. 

 

What happens if we don’t spend all the funds? I understand we will need to return it but would there be any penalty associated with it?  

There is no penalty associated with underspent wage equity funding. As with any money owed to the Department, if the repayment is not timely there may be a lateness penalty. 

 

The information says we need to use the last 2 payrolls for 2021 to compute the average rates. Does that mean the last 2 paychecks or the last 2 pay periods? 

The maximum, minimum, and average wage calculations for 12/31/2021 is from the hours worked for the month of December 2021.

 

For CHOWs between 7/1/22 and 6/30/23, do the two owners combine their report? Or would each owner be required to file for the period that they owned the building? 

Each facility will be responsible for completing the form for the time that they are or were licensed. Please note: this is a change from previous FAQ direction and is in line with the proposed rule language filed. If you would like to submit comments on this or any other language about this proposed rule, you may find the ways to do so on the CR-102 form

 

What if a facility closes between 7/1/22 and 6/30/23? Do they still need to complete this worksheet?

If a facility closes between 7/1/22 and 6/30/23 that results in less than a full FY23 of data, the licensed owner on the last day of operation is responsible for collecting and reporting both their wage data by combining and calculating a maximum, minimum, and average wage and hours for the month of December, 2021 and for the time period between 7/1/22 and 6/30/23. The worksheet is due with the closing cost report for a facility that closes. 

 

What if we do not have any data for a specific job class? 

The Wage Equity Worksheet Funding tab is inclusive of all wages that fall under the intent of the wage equity funding. Providers are not required to input data for any particular job class if that class did not receive wage increases during the time period. 

 

Is the Facility Monthly Census Tab required? 

The Facility Monthly Census tab is not a required worksheet. It is very similar in layout to the cost report Schedule N so that providers can easily understand how to input the data, should they choose to do so. If a provider chooses to use the worksheet, they would complete the first two columns highlighted in yellow. The information from this worksheet will populate the relevant cells on the Wage Equity Worksheet tab. 

How do we calculate monthly wage?

To spend the money provided for both Direct and Indirect Care the provider must show that the “average wage” rate increased using December 2021 as the base period and July 1, 2022, through June 30, 2023, as the monitoring period.   The “average wage” is the base average hourly wage and does not include overtime wages or fixed fee bonuses.  The “average wage” does include shift differentials and other amounts paid on an hourly basis.  Consider the following amounts paid to a fictional worker:

Base Wage @ $20/hr for 50 hours = $1,000         [50 hours * $20/hr]

Half time for over 40 hours / week = $100             [10 hours * $10/hr]

Shift Differential for weekend                                  [paid as $2/hr * 16 hours]

Sign on bonus = $1,000                                               [paid as flat amount after 90 days]

To calculate the average wage the provider should use the base wage and the shift differential = $1,032 [$1,000+$32] and divide by hours worked [50 hours] for an “average wage” of $20.64. 

The same calculation would be used during the entire monitoring period.