CMS Proposes 2028 Medicaid HCBS Quality Measure Set
On Monday, April 27, 2026, the Center for Medicaid and Chip Services (CMCS) released a notice for public comment regarding the 2028 Medicaid Home and Community Based Quality Measure Set (HCBS QMS). The public comment period is open from April 28, 2026 through May 28, 2026.
CMS is soliciting public comment and feedback on the proposed measure set – both mandatory and voluntary measures, the feasibility and burden of collecting data for the measure set, for which measures stratified data should be reported, the proposed populations the measures are to be reported for, and the proposed reporting schedule.
Inclusion of LTSS – 1 and LTSS – 2 as Mandatory Measures
The proposed measure set includes LTSS-1 and LTSS-2, which CMCS describes as “focus[ing] on the quality and comprehensiveness of the person-centered planning process.” The agency acknowledges that an independent HCBS Quality Measure Set Review Workgroup, established by the Ensuring Access to Medicaid Rule and comprising representatives from State agencies, managed care plans, beneficiary advocates, providers and provider associations, researchers, measure developers, and other subject matter experts, recommended removal of LTSS-1 and LTSS-2, considering them “’compliance’ measures rather than quality measures,” focused on documentation rather than person-centeredness. CMCS suggests that “the exclusion of measures that focus on the quality and comprehensiveness of the person-centered planning process would result in a critical gap in the HCBS Quality Measure Set, with inadequate representation of measures assessing service coordination and individualized care.”
Stratification of Data Requirements
The HCBS QMS establishes a phase-in schedule for stratified reporting that requires States to provide stratified data for 25 percent of the measures in the HCBS Quality Measure Set by July 9, 2028, 50 percent by July 9, 2030, and 100 percent by July 9, 2032. To meet this requirement, States were required to provide stratified data for 25 percent of the mandatory measures in the 2028 HCBS Quality Measure Set. CMCS is soliciting comments on whether to require States to report stratified data for only five of the mandatory measures instead of all the mandatory measures. This proposal would mean that the measures from the Experience of Care Surveys, including NCI-IDD In Person Survey measures, would not require data stratification for reporting.
Aggregate Reporting
CMCS is soliciting feedback on aggregate reporting across all of the applicable HCBS programs subject to the requirements. While not proposing to require States to report separately for each HCBS program or authority, the agency says it will consider allowing States, at their option, to report at the program, authority, delivery system, or managed care plan level. However, States would still be expected to report at the aggregate level.
Subset of Measures for 2028
CMS is considering using a subset of the HCBS QMS for 2028 reporting. This subset aligns with the set of mandatory measures in the 2028 HCBS Quality Measure Set that Money Follows the Person (MFP) grant recipients have been required to report on in 2026, with the exception of two experience of care measures–HCBS CAHPS: Planning Your Time and Activities composite measure; and Personal Outcome Measures® (POM: People Live in Integrated Environments).
FMI: The Federal Register notice is available at https://www.federalregister.gov/documents/2026/04/28/2026-08190/medicaid-program-2028-medicaid-home-and-community-based-services-quality-measure-set.