Cms Unveils Proposed 2028 Hcbs Quality Measure Set: What It Means For Home Care Providers

The Centers for Medicare & Medicaid Services (CMS) has proposed a new set of quality measures for Medicaid home- and community-based services (HCBS) for 2028. While the proposal’s 23 mandatory measures target state-level reporting, experts say its impacts would likely ripple down to HCBS providers.

The proposed measures, published on Monday, are not likely to add significant administrative burden or additional costs around data collection or submissions, but their effects may be felt downstream and would vary from state to state.

“For providers, the important thing to consider is that while the measures are not specific to the entity delivering care, there are questions that touch upon operations, training and staffing,” Damon Terzaghi, vice president of Medicaid advocacy and programs at the National Alliance for Care at Home, told Home Health Care News in an email. “Many of the questions are relevant to providers – i.e. are members being treated with respect; are they safe and free from abuse; and are the services meeting their needs and goals. Reviewing the measure set and making sure that your operations align with the goals will be important.”

Under the Ensuring Access to Medicaid Services rule (Access rule), states are required to submit data on a HCBS quality measure set determined by CMS, Terzaghi said. The measures are statewide by program and are reported in aggregate, rather than based on a specific HCBS provider. These measures are primarily collected via administrative data and interviews with service recipients, he continued. 

The measures do not institute direct requirements for providers, and tend to focus on systems-level outcomes, Terzaghi said. Still, providers may feel some changes if the proposed measures are finalized. One potential downstream impact would be if states or health plans incorporate provider-level performance on these measures into pay-for-performance metrics, Terzaghi said.

State-level variation, measures and comment period

The proposed quality measures’ impacts will vary from state to state, according to Bill Hanna, practice director of ATI Advisory’s payer strategy and program design practice and a former state Medicaid director.

“The federal measure set is standardized, but the level of disruption for providers will be driven almost entirely by how states choose to implement it,” Hanna told HHCN in an email. “States will need to decide which surveys they use, how much they delegate to [managed care organizations] (MCOs), and whether they invest in the data and care‑management infrastructure behind the numbers.”

Providers can utilize the measures as either a compliance checklist or as a platform for value.

“If states pair new reporting expectations with realistic timelines, technical assistance and rate and contract strategies that recognize the cost of better assessments, care planning and transitions, providers can leverage the HCBS measures to demonstrate value and improve outcomes,” Hanna said. “If they don’t, we’ll see wide variation: some markets where quality expectations and financing move in tandem, and others where thinly capitalized home‑ and community‑based providers are asked to do more with less. That’s where states, MCOs and providers will need practical support to translate these requirements into workable strategies – from measure design and contract requirements to implementation and operational change.”

 CMS’ proposed quality measure list is scheduled to be published in the Federal Register on Tuesday. Comments must be submitted within 30 days after its publication in the Federal Register. 

The proposal includes 23 mandatory measures:

– HCBS CAHPS: Choosing the Services That Matter to You Composite Measure

– HCBS CAHPS: Personal Safety & Respect Composite Measure

– HCBS CAHPS: Physical Safety Single-Item Measure

– HCBS CAHPS: Transportation to Medical Appointments Composite Measure

– LTSS-1: Long-Term Services and Supports Comprehensive Assessment and Update

– LTSS-2: Long-Term Services and Supports Comprehensive Person-Centered Plan and Update

– LTSS-6: Long-Term Services and Supports Admission to a Facility from the Community

– LTSS-7: Long-Term Services and Supports Minimizing Facility Length of Stay

– LTSS-8: Long-Term Services and Supports Successful Transition after Long-Term Facility Stay

– NCI-AD: Percentage of People Who are as Active in Their Community as They Would Like to Be

– NCI-AD: Percentage of People Who Feel Safe Around Their Support Staff

– NCI-AD: Percentage of People Who Have Transportation to Get to Medical Appointments When They Need to

– NCI-AD: Percentage of People Who Have Transportation When They Want to Do Things Outside of Their Home

– NCI-AD: Percentage of People Whose Service Plan Includes Their Preferences and Choices

– NCI-IDD PCP5: Satisfaction with Community Inclusion Scale (The Proportion of People Who Report Satisfaction with the Level of Participation in Community-Inclusion Activities)

– NCI-IDD CI-1: Social Connectedness (The Proportion of People Who Report that They Do Not Feel Lonely Often)

– NCI-IDD CI-3: Transportation Availability Scale (The Proportion of People Who Report Adequate Transportation)

– NCI-IDD HLR-1: Respect for Personal Space Scale (The Proportion of People Who Report that Their Personal Space is Respected in the Home)

– NCI-IDD PCP 2: Person-Centered Goals (The Proportion of People Who Report their Service Plan Includes Things that are Important to Them)

– POM: People are free from abuse and neglect

– POM: People Choose Services

– POM: People Participate in the Life of the Community

– POM: People Realize Personal Goals

The proposal also includes three voluntary measures:

– LTSS-4: Reassessment and Person-Centered Plan Update after Inpatient Discharge

– MLTSS-5: Screening, Risk Assessment, and Plan of Care to Prevent Future Falls

– Any HCBS CAHPS, NCIAD, NCI-IDD, or POM measure not included in the proposed list of mandatory measures

Click here to read the full document, which includes instructions on how to submit comments. 

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