In May 28, 2026, comments on 2028 Medicaid Home and Community-Based Services (HCBS) Quality Measure Set, LeadingAge tells the Centers for Medicare and Medicaid Services (CMS) that we support the goal of establishing consistent standards for comparing service quality, access, timeliness, and participant satisfaction across HCBS programs. However, we warn that states and providers could face significant implementation hurdles, and explain how and why.