New HCBS Quality Measures Impact Home Healthcare Billing

Workforce pressures on billing for home health services are impacted every time The Centers for Medicare & Medicaid Services (CMS) adds documentation or reporting requirements. This is no different for a new proposed rule coming out of the agency. 

The proposed 2028 HCBS Quality Measure Set introduces an additional layer for revenue cycle teams already managing billing for home health services and facing workforce challenges like shortages, training, and retention. Healthcare leaders who want to enter 2028 in a stronger position will need to understand the structure of the proposal, the state-level variables, and the industry concerns currently shaping it. 

Read on to get started building a deeper understanding of the proposal and its potential implications.

On April 28, 2026, CMS published a notice with a comment period in the Federal Register [1].

It proposes a nationally standardized quality measure set for Medicaid-funded home and community-based services (HCBS). The program targets the 8.4 million Medicaid beneficiaries who received HCBS in fiscal year 2023. It accounts for $145.9 billion in expenditures, with the goal of building consistent quality data across states and driving measurable improvement in care outcomes. 

A few highlights of the measure: 

• The proposed 2028 set includes 26 total measures: 23 mandatory and 3 voluntary. 
• Mandatory measures draw from experience-of-care surveys, assessment and case management systems, and administrative claims data, covering areas including person-centered planning, personal safety, and transportation access.
• For organizations overseeing billing for home health services, the administrative data requirements, which are derived from claims and encounter records, carry the most immediate operational weight.
• For many providers, this also increases pressure on documentation accuracy, OASIS coding consistency, and claims-data alignment.
• States won't report on all 23 mandatory measures. The actual count per state ranges from 9 to 19 depending on the populations served and survey instruments selected.
• Mandatory reporting takes effect July 9, 2028, with stratified data requirements phasing in through 2032.

The federal framework standardizes the measure set, but provider impact will vary considerably based on how individual states implement it. 

Bill Hanna, practice director at ATI Advisory and a former state Medicaid director, told Home Health Care News that "the level of disruption for providers will be driven almost entirely by how states choose to implement it" [2]. States will need to determine which surveys to deploy, how much to delegate to managed care organizations, and how much to invest in underlying data infrastructure.

For revenue cycle teams managing home healthcare billing across multiple states, that variability adds real complexity, especially organizations balancing documentation workflows, OASIS coding consistency, and staffing shortages across distributed operations.

Hanna noted that in markets where quality expectations and financing don't move in tandem, home and community-based providers could face pressure to absorb new reporting requirements without additional resources. This is a dynamic that directly affects billing for home health services operations and staffing decisions.

CMS is accepting public comments through May 28, 2026 [3]. This is 30 days after Federal Register publication. Comments can be submitted electronically at regulations.gov (docket CMS-2026-0332), by regular mail, or by express mail to CMS in Baltimore. 

The comment period covers proposed mandatory and voluntary measures, data collection methods, stratification requirements, and population-specific reporting schedules. Organizations involved in home health coding or billing for home health services have standing to address feasibility and administrative burden. Several industry groups are actively directing members to submit feedback before the deadline closes.

Industry response has been supportive in direction but cautious on execution [4]. 

LaShuan Bethea, executive director of the National Center for Assisted Living, acknowledged the proposal's goals while raising a concern that has echoed across the sector: “Overly complex reporting without additional funding can create operational strain, particularly for small and rural communities.”

Argentum plans to submit comments pressing for flexibility and clear implementation guidance. Senior vice president of public policy Maggie Elehwany noted that quality measurement should reflect outcomes providers can actually influence and support continuous improvement without adding unnecessary administrative strain. 

LeadingAge's Georgia Goodman pointed to the two-year implementation window as a practical pressure point, observing that layering these requirements onto already packed Medicaid policy agendas will challenge many state teams.

For revenue cycle leaders tracking home healthcare billing obligations, the state timeline and funding questions carry direct operational weight. Providers that begin aligning their billing for home health services infrastructure now, including home health coding capacity and documentation workflows, will face considerably less pressure as 2028 approaches.

3Gen Consulting's workforce and coding services give revenue cycle teams the capacity to handle growing complexity from changes like HCBS quality measures – from home healthcare billing operations and OASIS coding support to audit-ready documentation standards that hold up under increased scrutiny. Reach out to learn how 3Gen can support your preparation ahead of the 2028 deadline.