On April 28, 2026, the Centers for Medicare & Medicaid Services (CMS), a division of the Department of Health and Human Services (HHS), issued a notice with comment period in the Federal Register. This action initiates a crucial public engagement phase regarding the development of the 2028 Medicaid Home and Community-Based Services (HCBS) Quality Measure Set. The primary objective of this measure set is to establish nationally standardized quality metrics for Medicaid-funded HCBS, thereby promoting consistent reporting across states, facilitating comparative quality data, and driving continuous improvement in the care and outcomes for individuals receiving these vital services.
Public comments on this proposal are due by May 28, 2026, and can be submitted electronically or via mail. This outreach allows stakeholders to provide feedback on several critical aspects, including the proposed mandatory and voluntary measures, how states will collect and report data, required stratified data elements like rural/urban status, the specific stratification factors, the populations covered, and the proposed reporting schedule.
The Landscape of Medicaid Home and Community-Based Services
Medicaid HCBS programs are designed to enable beneficiaries to receive necessary support and care in their own homes and communities, offering an alternative to institutional settings. These services vary by state and often encompass a range of medical and non-medical supports such as case management, personal care, adult day health, and respite care. HCBS cater to diverse populations, including older adults, individuals with intellectual and developmental disabilities (IDD), physical disabilities, mental health or substance use disorders, and those with complex medical needs. In fiscal year 2023, 8.4 million Medicaid beneficiaries accessed HCBS, representing a significant expenditure of $145.9 billion.
Evolution of the HCBS Quality Measure Set
The current initiative is part of an ongoing effort by CMS to refine and standardize quality measurement in HCBS. The first official version of the HCBS Quality Measure Set was introduced in July 2022. Subsequently, in April 2024, CMS updated this set, now referred to as the 2024 HCBS Quality Measure Set. Concurrently, new reporting requirements were established for the 41 states and territories participating in the Money Follows the Person (MFP) demonstration program. Beginning in fall 2026 and biennially thereafter, MFP grant recipients are mandated to report on the HCBS Quality Measure Set for all Medicaid-funded HCBS programs, not just those participating in MFP. This reporting includes specific mandatory measures derived from experience of care surveys, assessment/case management systems (e.g., LTSS-1, LTSS-2), and administrative data-based rebalancing measures (e.g., LTSS-6, LTSS-7, LTSS-8).
Formalizing Reporting Requirements: The "Access Rule"
Further solidifying the commitment to standardized quality reporting, CMS issued a final rule on May 10, 2024, titled "Ensuring Access to Medicaid Services" (89 FR 40542), commonly known as the "Access rule." This rule codified biennial reporting requirements for states regarding section 1915(c) waiver programs and extended these requirements to HCBS furnished under sections 1915(i), (j), and (k) of the Social Security Act. Specifically, starting July 9, 2028, states must report every other year on the mandatory measures identified in the HCBS Quality Measure Set, following the format and schedule prescribed by the Secretary. States also have the option to report on additional voluntary measures. A key provision requires states to establish performance targets, subject to CMS review and approval, for mandatory measures and those for which CMS reports on their behalf. States must also outline quality improvement strategies to meet these targets. For a subset of measures, CMS will report on behalf of states.
Implications and Future Outlook
The solicitation of public comment for the 2028 HCBS Quality Measure Set represents a critical step in federal efforts to enhance accountability and quality in Medicaid's long-term care landscape. By standardizing measures, CMS aims to provide a clearer, more consistent picture of program performance across states. This allows for comparative analysis, identifies best practices, and spotlights areas needing improvement. For states, this initiative means a formalized framework for data collection and reporting, requiring robust systems and strategic planning to meet performance targets. Providers will likely experience increased scrutiny and a greater emphasis on outcomes as reported measures highlight service quality. Ultimately, beneficiaries stand to gain from this push for standardization, as consistent measurement and targeted quality improvement initiatives are intended to lead to better care and improved quality of life. The implementation of the 2028 measure set, guided by public input, will shape how the federal government and states jointly ensure effective, high-quality HCBS for millions of Americans.
