May 28, 2026
Daniel Brillman
Director, Center for Medicaid and CHIP Services and
Deputy Administrator, Centers for Medicare & Medicaid Services
Department of Health and Human Services
Hubert H. Humphrey Building
200 Independence Ave. SW
Washington, DC 20201
Attention: CMS-2453-NC
Dear Mr. Brillman:
The National Committee for Quality Assurance (NCQA) thanks you for the opportunity to provide feedback on the 2028 Medicaid Home and Community-Based Services (HCBS) Quality Measure Set.
NCQA is a private, 501(c)(3) not-for-profit, independent organization dedicated to improving health care quality through our Accreditation and measurement programs. We are a national leader in quality oversight and a pioneer in quality measurement. Leveraging our strengths as a trusted third party, we are committed to helping organizations navigate the challenges associated with improving the health care system. Our mission to improve the quality of health for all Americans propels our daily work.
We applaud CMS’s efforts to prioritize streamlined, nationally standardized quality measures in HCBS programs. We agree that standardizing requirements across these programs will create opportunities for CMS and states to have comparative quality data and drive improvement in quality of care and outcomes.
NCQA supports the proposal for LTSS-1: Comprehensive Assessment and Update and LTSS-2: Comprehensive Person-Centered Plan and Update to remain mandatory measures in the 2028 HCBS Quality Measure Set. Further, we encourage CMS to finalize its proposal to allow states to report on the HEDIS equivalent of these measures to meet the proposed mandatory reporting requirement. It is our understanding per the 2024 HCBS Quality Measure Set Informational Bulletin that states are already allowed to do this, which helps states to maintain standardization, reduce oversight burden and keep individuals in their preferred setting of care.
These measures are used as part of NCQA’s accreditation for LTSS Distinction, which is required across 13 states. NCQA’s LTSS Distinction establishes a framework for managed care oversight of long-term services and supports, ensuring robust care coordination and person-centered care planning for the LTSS population. NCQA accredits 60 health plans that report LTSS HEDIS measures, including Comprehensive Assessment and Update, Comprehensive Care Plan and Update, Care Plan with Primary Care Practitioner, and Reassessment/Care Plan Update after Inpatient Discharge. Aligning the HCBS measure set with existing HEDIS LTSS measures would advance CMS’s goals of reducing administrative burden for providers that leverage NCQA’s Accreditation programs and support high-quality LTSS measurement and delivery for optimal patient care.
As CMS continues to strengthen the HCBS Quality Measure Set, we recommend there be a greater focus on person-centered outcomes for individuals receiving HCBS by the continuous assessment of care planning outcomes. NCQA’s Person-Centered Outcome (PCO) measures are designed for individuals with complex needs, including those receiving HCBS, and provide a standardized approach to documenting person-identified goals, tracking progress and assessing goal achievement over time. Connecticut’s Medicaid HCBS program demonstrates the feasibility of this approach by integrating the PCO measures into its value-based payment HCBS initiative and incentivizing providers to link person-centered goals directly to payment. CMS should consider the voluntary or mandatory reporting of the PCO measures as they advance meaningful accountability for quality of health care received for HCBS patients.
Thank you for the opportunity to comment. We welcome a discussion on our recommendations and remain committed to working with CMS to build a more efficient and responsible American health care system. If you have any questions, please contact Kara Martin-Huang, Manager of Federal Affairs, at (202) 464-6311 or at kmartin@ncqa.org.
Sincerely,
Eric Musser, MPH
Vice President, Federal Affairs
National Committee for Quality Assurance
