Tag Archives for ADUs

General Assembly considers “Granny Flats” proposal

Published in RINewsToday on April 24, 2023

By Herb Weiss

After AARP Rhode Island’s successful efforts to pass legislation last year, giving more flexibility to the types of structures and arrangements that would quality as accessory dwelling units (ADUs), during this year’s legislative session the state’s largest aging group is working closely with state lawmakers, aging and house groups to advance H 6082. Introduced by Rep. June Speakman (D-District 68, Bristol/Warren), the bill makes further improvements to enable more Rhode Islanders an opportunity to develop ADUs on their property. 

ADUs, sometimes called “in-law apartments” and “granny flats,” are accessories to existing housing, either as a conversion of part of a house (such as with a walkout basement), an attachment to a house or a smaller, detached dwelling. They have become increasingly popular around the nation in recent years as states and municipalities grapple with expanding the existing housing stock while preserving the feel of residential neighborhoods. Seniors, especially, have taken to ADUs as a way to downsize their living space while staying independent in the community.

H 6082 was written in collaboration with AARP Rhode Island, for whom increasing production of ADUs has been a primary policy goal for several years.

Encouraging the Construction of ADUs

H. 6082 would provide homeowners the right to develop an ADU on any lot larger than 20,000 square feet, provided that the design satisfies building code and infrastructure requirements. H 6082 would also provide homeowners on lots smaller than 20,000 square feet to construct an ADU within the existing footprint of the primary structure or existing secondary attached or detached structure that does not expand the footprint of the structure, provided that the design satisfies building code, size limits and infrastructure requirements.

The purpose of H. 6082 is to encourage the development of rental units that are likely to be affordable, and also provide opportunities for homeowners with extra space to generate income that helps them maintain ownership of that property.

To ensure that the bill achieves its goal of housing Rhode Islanders, the legislation prohibits ADUs constructed under this provision from being used as short-term rentals and streamlines the permitting process.  Speakman considers H 6082 to be a small but important part of the much broader effort that Rhode Island must adopt to encourage the development of affordable housing.

“Our housing crisis is very complex, and we must be creative and identify all the tools we can to create housing that makes the most of our resources. This particular bill removes some of the obstacles to building ADUs while respecting municipal land use policies,” says Speakman in a statement announcing her sponsorship of the ADU legislation.

“For many people, especially single people, and older adults, ADUs provide just enough space and could be a more affordable option than a larger, traditional apartment. For some, they might make it possible to stay in their neighborhood after downsizing from their own home, or they might be an opportunity to live in a neighborhood where apartments are scarce or are otherwise out of their price range,” notes Speakman, calling for more rental units.

“Accessory dwelling units are a great option to enable seniors to live at home independently and with dignity near their loved ones. They are also a very simple way to increase housing stock. Like several of the other pieces of legislation in the housing package I’ve put forward this year, this bill was developed based on feedback: in this case, from AARP, who made the ADU legislation one of their top priorities for this session,” stated House Speaker K. Joseph Shekarchi (D-District 23, Warwick). “I am proud to support and co-sponsor this legislation because I know what a difference it will make for many seniors in Rhode Island to safely age in place,” he said.

Hearing puts spotlight on housing bills

On March 16th, the Municipal Government and Housing Committee held a hearing on H 6082, part of a 14-bill housing package had earlier in the month by Shekarchi to encourage housing production. The legislation in the package stems from the work of the House Commission to Study the Low and Moderate Income Housing Act, which Speakman has led since its inception in 2021, and another commission studying all aspects of land use and development.

In her testimony, AARP Rhode Island State Director Catherine Taylor stated that passing H 6082 would be a “great step forward” to improve the existing ADU legislation and to provide municipalities with guidance on how to apply the law in their locality.

ADUs can potentially improve the lives of seniors, caregivers, and people of all ages, too, says Taylor. According to AARP Rhode Island’s November 2021 Vital Voices survey over 54% of Rhode Islanders over age 45 would consider creating an ADU if the space was available.  In addition, a strong majority (84%) of Rhode Islanders aged 45 and over strongly or somewhat support town ordinances that makes it easier for property owners to create an ADU.

“Allowing ADUs by right where the proposed ADU is located within the existing footprint of the primary structure or existing secondary attached or detached structure and does not expand the footprint of the structure will provide the housing options and security that Rhode Island residents are looking for,” notes Taylor.

Warwick resident Keri-Lynn Edge and her husband contemplated building an addition on her property for her widowed mother who required constant care and assistance with activities of daily living. “Buying a home or condo, even if closer to us, would leave us in a similar predicament. It would take me away from my home to care for her and handle her affairs. So, an ADU seemed like the perfect solution,” she told the Committee. 

“Unfortunately, I am currently at a standstill with how to progress, and I am hopeful that this talk of ADUs comes to fruition,” says Edge, noting that the City of Warwick only allows one dwelling on a property and even though it is aware of H 6082 it won’t authorize building of ADUs until legislation is enacted.

In comments, retired Registered Nurse Timothy Tobin spoke of his long-standing plan to build an ADU on his daughter’s property in Bristol to live closer to her and his five grandchildren. Ultimately, he found out that in Rhode Island’s economic climate, specifically in his town, this project was too costly. “Between restrictive town and state building codes and very high prices for the actual building to comply with the codes, our dream is all but dashed,” he said.

RI Housing, the Housing Network, RI Realtors, and the Rhode Island Chapter of the American Planning Association (offering comments to make the bill clear) submitted testimony supporting the expansion of ADUs. Governor Dan McKee, sending his blessing and support for the passage of H 6082, noted it will “clarify and noting that it will streamline permitting processes, standardize notice and advertising requirements, and incentivize creative ways to build more housing in Rhode Island.   

And RI AARP members sent dozens of emails from all corners of the state urging the Municipal Government and Housing Committee to pass the ADU legislative proposal, too.

Although there was no opposition at the committee hearing for the legislative proposal, the House GOP caucus supports the concept, but expressed concerns about its impact on Rhode Island communities.  “While ADUs have been a fabric of housing throughout Rhode Island including the rural districts that I represent, they bring with them some concerns that should not be overlooked,” says House Minority Leader Michael Chippendale (R-District 40, Foster, Glocester).” The current proposal can be modified into an effective tool to help combat the housing shortage, but it requires input from all of our municipalities – particularly those like the ones in my remote district,” he notes.

Chippendale says that this legislative proposal currently before the Assembly isn’t inherently bad, but it needs to consider the challenges it creates for all  39 municipalities. “For example – if there is not sufficient off-street parking, which this bill severely limits, towns like Foster, Glocester, Western Coventry and others can have problems. Issues such as snow plowing an already narrow roadway, the passage of large vehicles such as fire trucks, garbage trucks and others that can be impacted by cars parking on the roads.  Further, they can represent a drain on limited resources such as drinking water when more people are being allowed to draw from an existing aquifer that may already be operating under duress. The same applies to neighborhoods that have water districts with limited water supply,” he adds. 

Ultimately, no action was taken at the hearing, noted House Communications Director Larry Berman, noting that it’s the usual practice to receive input at the first hearing. “We expect a second hearing to be held in the coming weeks in which it will likely be voted on and moved to the full House for consideration,” he said.

According to Berman, the Senate has not yet duplicated this bill, but he anticipates that the upper chamber will before the end of the session in June. “It won’t be included in the budget because it doesn’t have a fiscal impact on the state,” he stated, noting .

Speakman has backing from House leadership.  In addition to Speaker Shekarchi, it is co-sponsored by Majority Whip Katherine Kazarian of East Providence, who is the number three ranking member in House leadership, and also by Chairman Stephen Casey of Woonsocket, who chairs the House Municipal Government and Housing Committee where the bill is the being considered.  Of course, Speakman chairs the House Commission on Low and Moderate Income Housing as well.

Other H 6082 cosponsors are: Rep. Megan Cotter (D-District 39, Exeter, Richmond); Rep. Jason Knight (D-District 67, Barrington; Rep. Susan R. Donovan (D-District 69, Bristol and Portsmouth; Rep. Teresa A. Tanzi (D-District 34, Narragansett, South Kingston); Rep. Cherie Cruz (D-District 58, Pawtucket); Rep. Terri Cortvriend (D-District 72, Middletown, Portsmouth).

While the House mulls over Speakman’s legislative proposal, Smithfield just passed an ADU ordinance allowing property owners of single-family and multi-family homes to construct ADUs up to 900 square feet.  Other communities might consider following this community’s lead. 

With strong support of House Democratic caucus and no fiscal impact on the state coffers, there’s a very good chance that H 6082 might just make it to the legislative finish line.  Now it is time for the Senate to quickly act and pass a companion measure.  Expanding ADUs in every Rhode Island community is sound housing policy that will provide access to much needed housing. It’s the right thing to do.  

RI Seniors, aging advocates call for an “age friendly” budget

Published in RINewsToday on March 27, 2023

Over two months ago, Gov. Dan McKee unveiled a sweeping $13.7 billion budget for the upcoming fiscal year.  After its release, the Senior Agenda Coalition of RI (SACRI), representing 21 organizations, called this budget “unfriendly to seniors,” charging that it “short-changed” seniors.  In an e-blast that was sent to 1,800 seniors and aging advocates SACRI urged them to contact their lawmakers asking that they put more funding into the delivery of aging programs and services.  

As the House Finance Committee continues to hold hearings on bills that might ultimately be rolled into the upcoming FY 2024 Budget, last week the SACRI brought 220 seniors, aging advocates and professionals in the aging network to the Warwick Crown Plaza to personally urge House Speaker Joe Shekarchi (D-Warwick) and Senate President Dominick Ruggerio (D-Providence, North Providence to hammer out an “age-friendly” budget.

SACRI Board Chair George Neubauer began this year’s Legislative Leaders Forum by quoting President Joe Biden’s call to Congressional lawmakers at the annual State of the Union Address to maintain Medicare and Medicaid. The President urged lawmakers to “stand up for seniors”.  Setting the stage for why this event was organized, Neubauer told the packed room: “Today, we are here to speak up for ourselves.”

Painting a Portrait of Rhode Island Seniors

“Effective advocacy includes good data and good stories,” said Maureen Maigret, a SACRI Board member and policy advisor for the group setting the stage for the speakers. She presented demographic data on the state’s graying population, discussed the increased needs of state’s aging programs and services to keep people at home, and detailed SACRI’s budget policy fixes.

“We speak up for 200,000 seniors and our numbers are growing,” says Maigret, also a former State  Representative and Director of the RI Department of Elderly Affairs. By 2030, 1 in 5 Rhode Islanders will be aged 65 and over,” she says.

While many think that seniors are a drain on the economy, they are not. According to Maigret, $3 billion dollars in Social Security benefits are pumped into the state’s economy. Twenty percent of seniors are still working and paying taxes and employers are very aware that seniors have extensive job experience skills and are usually very reliable employees.

“Additionally, seniors are part of an invisible workforce of unpaid caregivers who take care of family members and friends, also,” says Maigret, noting that AARP Rhode Island recently released a study reporting that there are 121,000 unpaid caregivers, with the value of their unpaid care estimated to be $2.1 billion dollars (just under $19 per hour).

“Seniors also contribute thousands of hours of volunteer work to their local communities, lending a helpful hand to senior centers, friendly visitor programs, Meals on Wheels, and to the Village Common of RI at four Village communities and multiple other agencies,” adds Maigret.  

“An overwhelming 70% of Rhode Island seniors want to age in place and remain in their communities,” says Maigret, noting that “after age 65, 3 out of 5 of these individuals will need some support to stay in their homes.”

SACRI survey on areas of concern for seniors

With Rhode Island’s top House and Senate leadership listening, Maigret touched on the findings of a SACRI survey that identified an array of concerns expressed by their older constituents.  Health and care issues came up on the top of this list, followed by isolation and loneliness, lack of knowledge of community support services, the need for transportation, loss of mobility, high housing costs, and lack of income.

The survey findings indicate that needed information is not reaching older adults to navigate the long term care system, says Maigret. Forty percent do not know about programs and services offered by Rhode Island’s Office of Healthy Aging (OHA) and The Point, the state’s aging and disability resource center.  She noted that the Governor’s FY 2024 budget didn’t allocate any state dollars to operate The Point, whose mission is to direct seniors to needed programs and services.

“Even with Social Security, a large number of seniors have low incomes,” says Maigret, with 50% of older households living on less than $50,000 a year, another 27% living on less than $25,000. “The cost of long-term care is staggering and unaffordable with semi-private rooms in nursing facilities going for $94,900 a year,” she pointed out. “Assisted living facilities is out of reach for many, too, costing about $54,000 a year. Bringing a home care aide 40 hours per week into a person’s home costs a whopping $56,160,” she adds.

Maigret urged Shekarchi and Ruggerio to reallocate more state dollars to home care services.  While other states, on average, spend 45% of Medicaid long-term care dollars on home care, Rhode Island only spends 22% with hundreds of seniors having to wait over 3 months to get home care services.

Maigret says that SACRI supports a legislative agenda that calls on the Rhode Island General Assembly to craft a “Better Budget for Better Care,” which will result in a permanent investment to improve the care provided to seniors.  SACRI also urges that lawmakers raise direct workers pay to $20 per hour to attract workers into home care agencies and nursing facilities. To assist seniors to access needed programs and services, $500,000 must be allocated into the House budget to better market available information and referral services offered by The Point.  

“Meanwhile, SACRI also is pushing to add five new positions at the OHA, with two being assigned to its Adult Protective Services Unit to increase increased caseloads,” says Maigret.  By allocating funding to help more lower income Medicare beneficiaries pay their Medicare Part B premiums, seniors will have more money to pay their bills.     

Telling Powerful Stories

SACRI pulled together a few “real life” stories to illustrate why Rhode Island lawmakers must craft an “Age Friendly” FY 2024 Budget.

Jeanne Gattegno, working in the elder abuse sector, shared her thoughts as to why OHA’s Adult Protective Service Unit (APSU) is underfunded.  “Elder abuse is a crime and anyone suspecting abuse must report it.  When its reported it must be investigated by the APSU,” she says.

According to Gattegno, in 2021, there were over 6,200 calls to OHA, over 1,400 calls were elder abuse complaints, and 2,800 were investigated as self-neglect. “There are five workers in the APSU. Just do the math. It’s an incredibly difficult job and it’s life and death and there are not enough people to help,” warns Gattegno.

Allyson Manning, an overworked Registered Nurse at a local nursing facility, highlighted her typical day working with two Certified Nursing Assistants to take care of 26 residents.  Due to low wages, the facility can’t fill the third CNA position to assist the other two CNAs on the shift. 

Serving as Team Leader, Manning says that there is not enough time to take care of her 26 residents.  During this shift her chief responsibility is to pass medications, perform treatments and assessments.  She often finds that her primary functions as an RN are late or difficult to carry out, due to the need to assist the CNAs with their tasks of toileting, washing, dressing and feeding residents.

“We are not attracting the people we need to these [CNA] positions.  They are low paid jobs, but it is really rewarding work but it is hard work., she says.  When hired, CNA’s are not staying long, turnover is high says Manning. While initially working full-time, she now only works two days a week.  

Giving Their Thoughts…

RI Speaker of the House, Joe Shekarchi remarked that he clearly understood the very powerful stories shared by Gattegno, Manning and others. “I didn’t need to hear those stories because I live those stories every day.  When his 97-year-old father recently fell at home and broke his pelvis, he was admitted to the Bethany House.

“I see how hard they work and the limited staff they have,” says the House Speaker, understanding the labor shortage’s impact on nursing facilities. “I see when my father hits the call button and it takes a long time [to answer] not because they are slow, but because they are doing three or four things at the same time,” he says.

“It’s important that seniors have options so they can choose what’s best for them,” says Shekarchi. “We need to provide supports for seniors to age in place and remain in their homes living independently,” he added, acknowledging that it is not always easy to do.

Shekarchi also recognized his effort with the Senate President made historic investments to require minimum staffing last year. Unfortunately, it hasn’t happened because the nursing facilities are now facing labor shortages, he says. 

According to Shekarchi, last year the General Assembly also provided more funding to make home care more accessible for seniors.  Lawmakers also provided tax relief on pensions for older taxpayers and military veterans, strengthened laws to protect seniors from financial exploitation, and made it easier to apply for SNAP benefits and expanded property tax relief for seniors. He expects to continue his efforts this legislative session.

Shekarchi also reported that he has introduced a bill, supported by AARP RI, to allow zoning for constructing Accessory Dwelling Units (ADUs) in garages or basements. He called on seniors and aging organizations to support his housing bill.

The House Speaker also discussed proposed legislation by Rep. Lauren Carson (D-District 75, Newport) proposed legislation that would create a House Study Commission to coordinate Rhode Island’s programs and services for seniors, expressing the need for such a study commission.  

Like Shekarchi, Senate President Dominick Ruggerio outlined a number of legislative successes last year.  He recognized passage of Sen. Josh Miller’s legislation authoring the creation and implementation of a pharmaceutical redistribution program. Former Sen. Cindy Coyne’s legislation became law, too, lowering the age at which a victim can be considered an elder under the state’s financial exploitation law from 65 to 60.

With the state’s growing number of seniors, Senate President Ruggerio stated that senior issues are more important than ever.

“We need to do everything we can to ensure seniors and retirees can enjoy their older years with dignity and security,” he said. “Because after a lifetime of hard work and contributing to our communities… older Rhode Islanders deserve nothing less.”

“The Senior Agenda Coalition is a powerful tool in its work.  At the Statehouse we rely on your voices to help guide us as leaders,” says Ruggerio, noting “we don’t have all the answers and appreciate your input.”

To watch SACRI’s 2023 Legislative Leaders Forum, go to  https://ritv.devosvideo.com/show?video=7cd34a907d29&apg=c7e3a6c7.

Lawmakers can do more for Seniors next year

Published in RINewstoday on July 11, 2022

Just days before July 1, 2022, Gov. Dan McKee was joined for the signing of the $13.6 billion state budget (2022-H7123aa) for fiscal year 2023 by Lt. Gov. Sabina Matos, House Speaker K. Joseph Shekarchi, Senate President Dominick J. Ruggerio, House Finance Committee Chairman Marvin L. Abney and Senate Finance Committee Chairman Ryan W. Pearson.

Taking a Look at the Budget’s Dollars and Cents

Let us take a look as ho the state’s FY2023 budget, signed by McKee on June 27, 2022, impacts older Rhode Islanders.

The budget doubled the funding for the Livable Homes Modification Program, from $500,000 to $1 million, which reimburses half the total retrofit costs, up to $4,000, to support home modifications and accessibility enhancements to allow individuals to remain in community settings. The increase is intended to address an anticipated surge in applications.

For retirees, the Assembly raised from $15,000 to $20,000 the amount of annual pension income that is exempt from state taxation.

The FY 2023 Budget also allocated an additional  $200,000 to the Office of Healthy Aging’s budget for senior centers, bringing total funding to $1 million. That is a 25% increase.

The budget also makes significant investments in the quality of healthcare for seniors, providing rate increases to many kinds of providers of health care, nursing homes, home and community-based services for elderly (increase in starting pay to $15 hour), in addition to seeking a study by the Office of the Health Insurance Commissioner on appropriate reimbursement rate levels into the future.  The budget also includes substantial increase to reimbursement rates for Meals on Wheel meals ($400,000), ensuring that the program is able to provide high-quality therapeutic and culturally appropriate meals to participants.

Lawmakers also added $4 million to increase the “circuit breaker” tax credit available to qualifying elderly and disabled residents, raising the maximum credit from about $400 to $600 beginning in tax year 2022 and indexing that amount to inflation. They also made credit available to more Rhode Islanders by increasing the income threshold for eligibility from $30,000 to $ 35,000.

Those with military pensions will no longer have to pay any income taxes on them, beginning in the 2023 tax year. The governor had proposed phasing out military pension taxation over five years, but legislators instead made them tax-free in their entirety in one year.

Lawmakers also kept the Governor’s plan to invest $168 million in upgrades to Eleanor Slater Hospital, including $108 million to construct a new long-term care acute care hospital at the Zambarano campus in Burrillville.

The plan accelerates the six-year phase-out of Rhode Island’s motor vehicle excise tax, eliminating what would have been the final year of the tax next year.  The amended budget provides replacement license plates for free.

The state budget included a year-long pilot program to provide free service on the Rhode Island Public Transit Authority’s business route, the “R” line that runs from Pawtucket to Cranston.

It also added $11.5 million general revenue funds to launch a retail Supplemental Nutrition Assistance Program (SNAP) pilot program, beginning Jan. 1, 2023.  Eligible households would receive an incentive payment of 50-cents for every dollar spent on fruits and vegetables, subject to limits.  The state also requested a waiver from the Federal Nutrition Service to streamline the application process for elderly and disabled individuals seeking assistance from the SNAP program.

Lawmakers also allocated $10 million for rebalancing the state’s long-term care continuum, for funding home care agency workforce recruitment, retention and training.  Also, money in Rhode Island’s new budget includes $8.1 million to increase Medicaid Dental rates to increase access to dental services for older adults.

Finally, lawmakers kept in the $250 million total from the American Rescue Plan Act (ARPA) federal funds in the approved budget to address state’s affordable housing crisis.

Taking a peek at new state laws

The Rhode Island General Assembly passed H-7942/S-2623 which increases access and utilization of Accessory Dwelling Units (ADUs) and provides age-friendly housing options for older adults, family caregivers, and people of all ages and abilities.

McKee also signed the Let RI Vote Act into law. This new law makes voting safer, easier, and more accessible for all Rhode Islanders. Some of the major provisions of the bill include no-excuse mail ballots and emergency voting; online mail ballot applications; permanent absentee list opt-in for nursing home residents; no witness or notary requirement to vote by mail;  multilingual voter information hotline, community ballot; and voter registration list maintenance.

A new law also seeks to develop broadband in Rhode Island by creating a Broadband Advisory Committee. It’s director will be responsible for connecting with federal agencies to access funds for broadband infrastructure deployment pursuant to federal grants, facilitating broadband service adoptions, expanding digital literacy for residents (especially seniors), experiencing economic hardship, and for future economic development.

Following the passage of S-2228, the definition of an elderly person in regard to exploitation has changed from someone 65-years-old to someone who is 60 years old, making the definition of an elderly person consistent with state law.

Finally, the proposed Perry Sullivan one-year exemption has been eliminated. This preserves $38.6 million for home and community-based services for 2023.

Gearing up for next year’s legislative session

“Despite the lack of passage of H-7616 sponsored by Rep. Lauren Carson to elevate the Rhode Island Office of Healthy Aging to full Department status, I’m confident that it will be reintroduced early in 2023. I also anticipate broad community conversations to fine tune the design and identify the needed resources,” says Vin Marzullo, a well-known aging advocate who served as a federal civil rights and national service administrator.

“AARP Rhode Island worked hard on Smith Hill during the 2022 legislative session to achieve a number of important wins for the age 50 and over Rhode Islanders,” stated Catherine Taylor, AARP Rhode Island State Director. “We will find it easier to vote, have access to more housing options and assistance for accessibility modifications, see our direct care workforce better paid and better trained, and so much more. And, as always, AARP Rhode Island is committed to ensuring that those age 50 and our families know about these changes and how they will improve our lives,” she says.

 “Although there was some very good news for seniors coming out of the 2022 legislative session, overall, the results were modest when we think about the projected growth of our older population, that 42% of older Rhode Island households have income less than $ 40,000 and that our Office of Healthy Aging is under resourced. So much advocacy work remains,” warns Maureen Maigret, chair of the Aging in Community Subcommittee of the Long-Term Care Coordinating Council and Policy Advisor for the Senior Agenda of Rhode Island, representing 21 organizations to mobilize people to enhance the quality of life of older Rhode Islanders.

However, Maigret sees a big win in the state budget language calling for rate review for state contracted providers as far too many services important for all ages have become so difficult to access due to poor payment rates to providers for many years. One example is that dental rates under Medicaid have not increased since the early 1990’s so older adults have had an extraordinarily hard time getting detail care, she says.

“Another big win that the Senior Agenda worked tirelessly for was removing the suspension of the $38.6 millions of “Perry-Sullivan” funds for FY 2023 that was in Gov. McKee’s proposal,” says Maigret.

However, Maigret expressed disappointment that the state’s budget only calls for minimum wage for home care direct care staff of $15 per hour. “Advocates tried to get this up to at least $17 to address the homecare workforce crisis that leaves some seniors waiting months for service,” she says.

According to Maigret, other items that will help older adults and persons with disabilities with rising housing costs are the expansion of the Property Tax Relief program sponsored by Rep. Ruggiero and Sen. Coyle.

“While we are appreciative overall for the gains that have been made for Rhode Island’s seniors in this legislative session, it is just a start toward what our state needs to do to meet the needs of our aging population,” says Bernie Beaudreau, Executive Director of Senior Agenda Coalition of Rhode Island. “I am disappointed that the minimum wage of $15 per hour was set so low.  This wage level will not do much to attract workers and solve the severe workforce shortages that home care agencies are facing. We also have to be vigilant about the administration of this new law as we have already seen a draft regulation suggesting that $15 will be the “average wage,” not the “minimum wage” of home care workers.