CMS Proposes 2028 Medicaid Quality Measures

The Centers for Medicare & Medicaid Services (CMS) is seeking public comment on proposed updates to the Medicaid Home- and Community-Based Services (HCBS) Quality Measure Set for 2028. You can read the official notice from CMS here. Comments from the public are due on May 28, 2026.

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​Through this proposal, CMS is requesting stakeholder input on several key areas, including:

• Which measures should be added to or removed from the HCBS Quality Measure Set
• How CMS should further standardize quality measurement across state HCBS programs
• A proposed subset of measures that would become mandatory for states to report
• Technical elements such as data sources, reporting methods, and stratification requirements
• Whether states should be allowed to use alternative measures (such as HEDIS or FASI equivalents) for certain LTSS measures

 
Presumably, CMS’s broader goal is to create a more uniform, comparable system for evaluating HCBS quality nationwide. While much of the notice is technical, the decisions made here will directly shape how quality is defined and measured in Medicaid home- and community-based care.
 
What This Could Mean for Your Agency
If finalized, these proposals could affect home care providers in several ways:

• Expanded data collection and reporting expectations
• Increased administrative and compliance burden
• Greater reliance on participant surveys and standardized tools
• Potential downstream impacts on oversight, program evaluation, and future policy decisions

 
Our Focus: Proposed Mandatory Measures (Table 4)
 
HCAOA is specifically seeking member input on the measures CMS is proposing to make mandatory for state reporting. These measures are listed in Table 4 of the notice and represent the most immediate and consequential part of the proposal.
 
To more closely examine Table 4, please click here and scroll to page 9.
 
Below is HCAOA’s best attempt at a plain-English summary of those the proposed mandatory measures contained in Table 4.
 
Proposed Mandatory HCBS Quality Measures
 
1. Participant Experience (HCBS CAHPS Survey)
Collected through standardized beneficiary surveys

• Choice of Services
  Whether individuals feel they can choose the services that matter most to them
• Safety and Respect
  Whether individuals feel safe and are treated with respect by caregivers
• Physical Safety
  Whether individuals report feeling physically safe in their home
• Transportation to Medical Appointments
  Whether individuals can reliably get to medical appointments

 
What this means: States would rely heavily on standardized patient surveys to evaluate quality and provider performance.
 
2. Care Planning and Assessment (LTSS Measures)
Collected through case management or assessment systems; required reporting with stratification

• LTSS-1: Comprehensive Assessment
  Whether required needs assessments are completed and documented on time
• LTSS-2: Person-Centered Care Plan
  Whether care plans are developed, updated, and include required person-centered elements

 
What this means: Increased expectations around documentation, assessments, and care planning processes, even where home care agencies may not control those functions.
 
3. Facility Use and Transitions (Administrative Data)
Based on Medicaid claims and enrollment data; required reporting with stratification

• Admissions to Facilities (LTSS-6)
  Tracks how often individuals receiving HCBS enter institutional settings
• Length of Stay in Facilities (LTSS-7)
  Measures how quickly individuals return to the community after entering a facility
• Successful Return to the Community (LTSS-8)
  Tracks whether individuals remain in the community after discharge

 
What this means: Providers may be evaluated based on broader system outcomes that are often outside their direct control.
 
4. Participant Experience (NCI-AD – Aging & Disability Survey)
Survey-based measures

• Whether individuals are as active in the community as they want to be
• Whether individuals feel safe around support staff
• Whether individuals have transportation for medical and non-medical needs
• Whether service plans reflect their preferences and choices

 
5. Participant Experience (NCI-IDD – Intellectual/Developmental Disabilities Survey)
Survey-based measures

• Satisfaction with community participation
• Social connectedness (for example, not feeling lonely)
• Access to transportation
• Respect for personal space at home
• Whether personal goals are reflected in service plans

 
6. Quality of Life Outcomes (CQL Personal Outcome Measures)
Survey-based measures

• Freedom from abuse, neglect, or exploitation
• Ability to choose services and supports
• Participation in community life
• Ability to achieve personal goals

 
We Want to Hear From You
Your feedback will directly inform HCAOA’s comments to CMS and therefore national Medicaid policy.
 
As you review these proposed mandatory measures, please consider using the following as a metric for evaluation:

• Which measures would be most burdensome or difficult to report?
• Do any measures rely on data you do not currently collect?
• Are there measures that do not apply to non-medical home care providers?
• Could any measures create access challenges or unintended consequences?
• Do any measures fail to accurately reflect quality in a home care setting?

 
If you are unsure whether a measure applies to your organization, feel free to note that.
 
Please send your feedback to [email protected] no later than COB Friday, May 22, 2026.
 
As always, thank you for your advocacy on behalf of our industry!

Share Your Feedback by may 22