The Centers for Medicare & Medicaid Services (CMS) has released a proposed 2028 Medicaid Home and Community-Based Services (HCBS) Quality Measure Set, marking the next phase in federal efforts to standardize how states evaluate Medicaid-funded home care.

While the proposal is directed at states — not individual providers — its implications will extend directly to home health agencies across the country.

Providers should pay close attention — and take action. CMS is accepting comments through Thursday, May 28, at 11:59 PM ET.

What CMS is Proposing

The proposed measure set includes 23 mandatory measures and additional voluntary options. These measures will be reported at the state level, typically in aggregate, and will be implemented beginning in 2028 under CMS’ Ensuring Access to Medicaid Services final rule.

The framework focuses heavily on:

• Patient experience and satisfaction
• Safety and respect
• Person-centered planning
• Community integration and access
• Transitions between care settings

Much of the data will come from surveys — such as the Consumer Assessment of Healthcare Providers and Systems Home and Community-Based Services (HCBS CAHPS®) Survey and National Core Indicators — administrative claims, and case management systems.

Importantly, states will not necessarily report all 23 measures — most are expected to report between nine and 19 measures, depending on populations served and survey selection.

Why This Matters for Providers

Even though the reporting requirements are technically placed on states, providers will feel the impact.

These measures are designed to evaluate whether:

• Patients feel safe, respected, and heard
• Services align with individual goals and preferences
• Care plans are comprehensive and updated
• Transitions between settings are effective
• Community participation and access are supported

In practice, this means provider operations, staffing, training, documentation, and care delivery will increasingly be evaluated — directly or indirectly — through these metrics.

Over time, these measures are likely to:

• Influence managed care contracting and performance expectations
• Inform pay-for-performance models
• Shape state oversight and quality initiatives
• Drive new documentation and reporting expectations

In short, what is currently a state-level reporting framework will become a provider-level reality.

State Implementation Will Drive Impact

The degree of disruption will vary significantly by state, as states will have flexibility in:

• Which surveys they use
• How they collect and validate data
• Whether they push requirements down to managed care plans
• How aggressively they tie performance to payment or oversight

This creates two potential paths:

• Aligned implementation, where expectations, funding, and infrastructure support quality improvement
• Misaligned implementation, where providers are asked to meet new expectations without additional resources

That distinction will be critical — and it is being shaped right now.

Key Policy Considerations

CMS is also seeking input on several important design questions, including:

• Which measures should be mandatory versus voluntary
• How data should be collected and reported
• Which populations should be included
• How measures should be stratified (e.g., rural vs. urban)
• Whether states should report in aggregate or at more granular levels

These decisions will directly influence provider burden, operational feasibility, and how quality is measured in the field.

Opportunity for Provider Input

The proposed HCBS Quality Measure Set represents a significant step toward standardized, outcome-driven oversight of Medicaid home care, with long-term implications for providers — particularly in contracting, compliance, and performance expectations.

This is not a finalized rule — CMS is actively soliciting feedback, and provider input will be critical in shaping implementation.

HCAF strongly encourages home care providers to submit comments addressing:

• Operational feasibility and administrative burden
• Workforce and staffing implications
• Documentation and reporting challenges
• Alignment between quality expectations and reimbursement
• State-level implementation concerns

Comments may be submitted electronically by clicking here, or by mail to the following address:

Centers for Medicare & Medicaid Services
Department of Health and Human Services
Attention: CMS-2453-NC
P.O. Box 8016
Baltimore, MD 21244-1850

Please allow sufficient time for mailed comments to be received before the close of the comment period.

HCAF will be submitting formal comments and welcomes member input to help shape its response. Please send feedback, concerns, or examples to Kyle Simon, Senior Director of Policy, Advocacy & Communications, at ksimon@homecarefla.org by Friday, May 22 at 5:00 PM ET.

Related: CMS Unveils Proposed 2028 HCBS Quality Measure Set: What it Means for Home Care Providers (Home Health Care News, 4/27/26)