"CMS’ 2028 HCBS Quality Measures: How ‘People-Centered’ Metrics Signal a Shift to Value-Based Care & State-Level Payment Changes"

(Alternative options if needed:)

1. "What CMS’ 2028 HCBS Measures Really Mean: A Roadmap to Value-Based Payments & Provider Challenges"
2. "Beyond Cost Savings: CMS’ 2028 HCBS Quality Measures Prioritize Community, Goals & Transportation—Here’s What Providers Must Do"
3. "2028 HCBS Quality Measures Decoded: How CMS’ ‘Soft’ Metrics Could Reshape Medicaid Payments & Provider Success"

CMS’ Proposed 2028 HCBS Quality Measures: A Shift Toward Value-Based Care and Community Outcomes

The Centers for Medicare & Medicaid Services (CMS) has proposed a new set of quality measures for Medicaid home- and community-based services (HCBS) that will capture effect in 2028. Unlike traditional metrics focused on cost avoidance—such as minimizing facility length of stay—the proposed measures emphasize outcomes like People Realize Personal Goals and People Participate in the Life of the Community. This shift signals a broader redefinition of quality in HCBS, one that prioritizes patient-centered goals over institutional metrics.

Published in the Federal Register on April 28, 2026, the proposed measures include 23 mandatory and 3 voluntary metrics. States will initiate reporting data in 2028, with updates required every two years thereafter. Whereas individual providers will not be directly judged on these measures initially, the aggregated data will inform state-level comparisons and could eventually influence payment models.

This marks a pivotal moment for HCBS providers, who must now prepare for a future where performance on these measures may directly impact funding and contracting opportunities. The measures are designed to align with the broader trend toward value-based care (VBC), where reimbursement is increasingly tied to outcomes rather than volume of services.

Why These Measures Matter: The Bridge Between Measurement and Money

According to Bill Hanna, Practice Director of Payer Strategy and Program Design at ATI Advisory and a former Wisconsin Medicaid Director, the proposed measures represent the foundational building blocks for value-based care in HCBS.

If states pair new reporting expectations with realistic timelines, technical assistance, and rate and contract strategies that recognize the cost of better assessments, care planning, and transitions, providers can leverage the HCBS measures to demonstrate value and improve outcomes. Bill Hanna, Practice Director, ATI Advisory

Hanna emphasizes that while the measures themselves do not directly alter payment structures, they create a framework for states to justify shifting from fee-for-service to value-based payment models. States and managed care organizations (MCOs) may begin rewarding providers based on performance, requiring specific capabilities to qualify for better rates, or prioritizing referrals to high-performing organizations. For thinly capitalized providers, this transition could mean doing more with less—unless they adapt early.

The proposed measures are not just about compliance; they signal what CMS and states are defining as value in HCBS. Providers who ignore these shifts risk falling behind as payment models evolve.

Themes in the Measure Set: Community, Transportation, and Personal Goals

An analysis of the proposed measures reveals four dominant themes: people, transportation, community, and personal outcomes. These themes reflect a shift away from clinical or financial metrics toward holistic, person-centered care.

Community engagement is a core focus, with measures such as:

• Percentage of People Who are as Active in Their Community as They Would Like to Be
• Satisfaction with Community Inclusion Scale
• People Participate in the Life of the Community

Transportation, surprisingly, is the second-most emphasized theme. Measures include:

• Transportation to Medical Appointments Composite Measure
• Percentage of People Who Have Transportation When They Desire to Do Things Outside of Their Home
• Transportation Availability Scale

For providers, Which means transportation may soon become a critical operational priority. Whether through direct service provision, partnerships, or coordination with local transit, addressing transportation barriers could become a differentiator in future contracts, and reimbursement.

State-Level Variability: A Patchwork of Expectations

States will have significant discretion in how they implement these measures, leading to a patchwork of expectations across the country. While CMS provides a standardized framework, each state will decide:

• Which voluntary measures to adopt
• How much responsibility to delegate to MCOs
• Whether to use the measures as a foundation for value-based care

This variability creates both challenges and opportunities for providers, particularly those operating across multiple states. Multi-state providers must develop flexible strategies to navigate differing definitions of quality and payment structures. The result could be a fragmented landscape where what works in one state may not apply in another.

For example, states may adopt additional voluntary measures, invest in data infrastructure, or tie performance to payment in ways that vary widely. Providers should begin preparing now to adapt to these differences, as the measures could reshape how quality is defined and rewarded in HCBS.

What’s Next: Public Comment and Implementation

CMS opened a 30-day public comment period on the proposed measures, which closed on May 28, 2026. The final rule is expected later this year, with states required to begin reporting data in 2028. Providers should monitor updates from CMS and state Medicaid agencies to stay informed about implementation timelines and potential policy changes.

For further details, visit:

• CMS HCBS Quality Measures Overview
• Measuring Quality in HCBS
• CMS Proposal Summary (Home Care Magazine)

Providers are encouraged to engage in the public comment process, collaborate with peers, and begin assessing their readiness for the 2028 reporting requirements. The shift toward value-based care in HCBS is underway, and early preparation will be key to success.

Have questions or insights? Share your thoughts in the comments below or connect with us on social media for updates.