Earlier today, CMS released its proposed 2028 Medicaid Home and Community-Based Services (HCBS) Quality Measure Set, which would require states to report on 23 mandatory measures, with three additional measures offered on a voluntary basis. Argentum is reviewing the proposal and will be engaging with our members to submit formal comments to CMS, emphasizing the importance of flexibility, clear guidance, and a balanced approach that protects access to assisted living and other residential-based HCBS for Medicaid beneficiaries nationwide.
The proposal is intended to standardize quality measurement across state Medicaid HCBS programs and support quality improvement and transparency. It covers experience of care surveys, assessment and case management, and administrative “rebalancing” indicators, with specified requirements for data stratification (including rural/urban status) and a standardized reporting schedule. Under existing regulations finalized in 2024, states will be required to report on mandatory HCBS measures every other year beginning July 9, 2028, with stratified reporting phased in through 2032.
Argentum supports CMS’s goal of advancing high-quality, person-centered care through the proposed Quality Measure Set and appreciates the agency’s efforts to promote consistency while recognizing state burden and feasibility. We will work with our members to submit comprehensive comments ahead of the 30-day comment deadline.