The Centers for Medicare and Medicaid Services (CMS) on April 27, 2026, posted revised quality measures (QMs) for states’ home and community-based services (HCBS) programs. Introduced in 2022, HCBS QMs were optional. States opting in early to administer participant surveys and crunch administrative data to assess their HCBS programs via standardized QMs will now be ahead of the curve.

In 2024, the Biden Administration finalized the Medicaid Access Rule, which set a July 2028 deadline for states to select from a list of HCBS QMs and adopt a quality reporting strategy to CMS. Within the Access Rule, CMS laid out their frequency of review and updates to the standardized list of mandatory HCBS QMs and provide states with options for additional quality measure reporting with optional measures. By reviewing administrative data, states can establish the average times to access services, understand the percentages of services plans reviewed annually, and better prescribe policy solutions to improve their programs. In short, the measures provide states with a baseline from which to assess program status and identify areas for improvement. For CMS, the measures allow comparison across states, giving CMS an option to highlight best practices and review new state-level data sources.

The updated quality measure set provides 23 mandatory measures, though states will not need to report on all of them. States can select measures in each domain to report on program success and will need to select four or five participant-reported measures, three administrative data measures, and two case management measures in their QM reporting strategy. CMS is allowing states to elect QMs that align with the state’s individual goals and data capabilities within their Medicaid HCBS program. Some measures will require states to stratify data submissions by population age and eligibility. reporting stratified data will be phased in starting with the requirement for 25% of measures in 2028, and full stratification reporting in 2032. In these measures CMS says they have attempted to balance the obligation of reporting with consideration for actionable and meaningful measures that are not overly burdensome to collect or analyze.

Measures will be reported on the aggregate, with no provider or individual level data available. While some measures require states to submit stratified data by population age or eligibility, the purpose of adopting a QM framework is to allow state policy review, not individual provider quality review. CMS has proposed a phased roll in of stratified data reporting to allow states preparation and transition time.

States have been considering QM adoption and strategies for participant surveys and data analysis since the release of the Medicaid Access rule, and anticipating this release of updates to CMS’ list of Mandatory HCBS QMs.

As providers think about ongoing attention to HCBS program integrity, supporting states in standing up their QM collection and reporting is in the best interest of the provider industry. Collaboration and stakeholder engagement among states and provider partners will be key to bolstering participant response rates and increasing data viability. More transparency into service delivery will generate data to counter misattributed claims of rampant fraud in HCBS programs, and provide states with more information to better monitor program integrity.

These recently released updates to QMs join a very long list of other Medicaid policy priorities states are juggling and could further strain already short-staffed Medicaid policy offices.