NHeLP Comments on Proposed 2028 Medicaid Home and Community-Based Services Quality Measure Set

Executive Summary

These comments offer NHeLP’s general support for the HCBS Quality Measure Set, but express some concerns related to a proposal to remove two mandatory measures related to measuring community inclusion and integration, the failure to require states to report certain measures stratified by race and ethnicity, and the divergence between the recommendations made by the stakeholder advisory group and the changes CMS has proposed in the rule.