NAMD Comments on the 2028 Medicaid Home and Community-Based Services Quality Measure Set Notice

On May 27, 2026, NAMD submitted comments on CMS’ notice on the 2028 Medicaid Home and Community-Based Services (HCBS) Quality Measure Set. In this notice, CMS collected feedback on:

• proposed mandatory and voluntary measures for the 2028 HCBS Quality Measure Set;
• how States collect, calculate, and report data on the measures in the proposed 2028 HCBS Quality Measure Set;
• the proposed measures in the 2028 HCBS Quality Measure Set for which States are required to report stratified data, including rural/urban status;
• the proposed stratification factors for each of the measures in the 2028 HCBS Quality Measure Set for which States are required to report stratified data;
• the populations for which States are proposed to report the measures in the 2028 HCBS Quality Measure Set; and
• the proposed reporting schedule.

Medicaid agencies support the continued development of a nationally standardized HCBS quality measure set and recognize the importance of improving quality measurement, data comparability, and outcomes for individuals receiving HCBS. However, as states and territories undertake significant systems, operational, and programmatic changes driven by recent federal rulemaking, federal legislation, and individual program priorities, NAMD urges CMS to provide greater technical assistance and consider a phased approach to the public reporting of HCBS measures commensurate with available implementation assistance provided to states and territories.

Read NAMD’s full comments here.