Argentum submitted comments on the Centers for Medicare & Medicaid Services’ (CMS) proposed 2028 Medicaid Home and Community-Based Services (HCBS) Quality Measure Set, a new federal framework intended to standardize how states measure and report on the quality of HCBS programs. The proposal would require states, beginning in 2028, to report on a defined set of quality measures every two years, spanning areas such as experience of care, person-centered planning, safety, and community integration.
While the HCBS quality measures set does not directly impact senior living providers, we are concerned that it could have downstream impacts. In our comments, we noted the proposal must be implemented in a way that reflects the diversity of HCBS programs and the realities facing providers, and that states administer HCBS programs differently and may vary in their capacity to collect and report data, making flexibility essential to successful implementation. Our comments includes the following concerns and recommendations:
- Preserve state flexibility: CMS should allow states discretion in selecting data sources, survey tools, and reporting approaches, particularly for outcome and experience-of-care measures.
- Minimize administrative burden: Argentum warned that new reporting requirements—while directed at states—will ultimately fall on providers, potentially straining resources and discouraging participation in Medicaid HCBS programs if not carefully designed
- Ensure measures fit diverse settings: Not all proposed measures are equally applicable across HCBS settings, particularly in residential environments like assisted living. Argentum urged CMS to tailor or adapt measures to avoid misleading or incomplete assessments of quality.
- Phase in complex requirements: Requirements such as data stratification should be introduced gradually, with adequate technical guidance to ensure accuracy and feasibility.
- Align with existing systems: To prevent duplication, CMS should coordinate the measure set with current federal and state quality initiatives and reporting frameworks.
- Provide resources and technical assistance: Successful implementation will require investments in data infrastructure, workforce training, and operational support at both the state and provider levels.
Our comments underscored that overly burdensome requirements could have unintended consequences, including reduced provider participation and diminished access to HCBS for Medicaid beneficiaries. We called on CMS to finalize a measure set that is flexible, feasible, and aligned with existing systems, while supporting continued access to high-quality care in assisted living and other residential settings.