HCAOA Promotes Fair HCBS Reporting Framework in CMS Comments

​Home care providers shouldn't be penalized for outcomes driven by Medicaid reimbursement rates, workforce shortages, or housing availability — factors well outside their control. That's the key message in HCAOA's formal comments to the Centers for Medicare & Medicaid Services responding to the agency's proposed 2028 Medicaid HCBS Quality Measure Set (see our recent blog gathering member feedback).

HCAOA supports CMS' goal of improving quality, consistency, transparency, and accountability across Medicaid home- and community-based services programs. The association encouraged CMS to ensure the final framework is practical and grounded in the realities of home care delivery.
 
Some proposed measures — including those covering transportation access, community participation, facility admissions, and successful transitions back to the community — reflect state-level or system-level performance, not individual provider quality. HCAOA cautioned CMS against allowing states or managed care plans to use these measures to rank or penalize providers for outcomes they don't fully control. Rural access barriers, managed care authorization practices, family support systems, and housing availability all shape these outcomes in ways no single agency can determine.
 
The association urged CMS to:

• Use existing data sources rather than creating new, duplicative reporting systems
• Maximize CMS-conducted T-MSIS analyses for administrative measures
• Keep reporting at the aggregate state level during early implementation and avoid premature provider-level requirements
• Build in privacy protections and small-number suppression
• Account for rural workforce and access challenges when interpreting data
• Coordinate with existing Medicaid, managed care, EVV, and licensing systems — rather than layering on top of them

 
HCAOA also asked CMS to ensure the framework works for medically complex patients, including those receiving private duty or continuous skilled nursing at home, where staffing access and reimbursement rates most directly drive outcomes.
 
Home care agencies already operate in a heavily documented environment that includes service plans, visit documentation, EVV, managed care oversight, audits, and state licensing. Any new reporting requirements should build on that infrastructure, not duplicate it.
 
HCAOA will continue engaging with CMS as implementation moves forward. Read the full comments.