HCBS Quality Measure Set Next Steps

Regulation | August 11, 2022 | by Meredith Chillemi

On July 21, 2022, CMS released the first ever set of Medicaid home and community-based services (HCBS) quality measures in State Medicaid Director Letter (SMD 22-003), which will provide quality of care and outcomes comparison data built around the pillars of access, rebalancing, and community integration, with a focus on equity. CMS and HCBS quality experts are beginning to share information on the next steps of implementation.

During the August CMS Long-Term Services and Supports Open Door Forum, Jennifer Bowdoin, Director, Division of Community Systems Transformation, provided an overview of the HCBS Quality Measure Set. Although state participation will be mostly voluntary, measures will be used in evaluation for state directed payments in MLTSS and will be the first step in looking at quality measures in Section 1115 and Money Follows the Person demonstrations. Data will come from experiences of care surveys as well as claims data.

  • Bowdoin noted that due to feedback received from the Request for Information, CMS made substantial changes to the organization of the final Measure Set, to better support states. CMS will be releasing an additional operational guidance document, that will provide details like numerator and denominator information and provide states with additional information on how the Measure Set will be able to be implemented in meeting required reporting for 1915(c) assurances and sub assurances.
  • The additional guidance will also focus on how the Measure Set aligns with the National Quality Forum HCBS domains.
  • Bowdoin concluded her presentation in saying that updates to the Measure Set will occur in the future, as there are measures in development and there will be additional HCBS measures that will be available over time. CMS is mindful that too frequent changes to the Measure Set would make it difficult for states to use.

 A HCBS Quality Measure Set  webinar hosted by HMA featured panelists who shared information especially useful from the provider perspective.

  • The focus of the Measure Set is population health to assess the system at large; the Measure Set is not intended to be used for evaluation purposes at the provider level.
    • A caveat may be that the Measure Set could be applied to MTLSS value-based payment, although the value proposition may not be a good fit with non-clinical, non-medical services.
  • States will be evaluating how to use the data they already collect, and are expected to implement new Measure Set surveys during 1915(c) renewals, and as a way to monitor Settings Rule compliance. States may also add Measure Set data requirements into MLTSS procurement RFPs. HCBS providers have a role in stakeholder engagement with states and health plans to advocate in the selection of quality measures, and to align their planning and program designs with those quality measures.

LeadingAge will continue to engage with CMS as we work together to advance HCBS quality across the country. Please reach out to Meredith Chillemi, Director of Medicaid and Home and Community-Based Services Policy, with feedback, questions, and comments surrounding the HCBS Measure Set at mchillemi@leadingage.org.