HCBS Request for Information (RFI) Summary

The Centers for Medicare & Medicaid Services (CMS) is proposing to develop standard measures to use across the home and community-based services (HCBS) system for voluntary use by states, managed long-term services and supports (LTSS) plans, providers and other entities to address the gaps and recommendations identified in the report. Specifically, it recommends that the Department of Health & Human Services (HHS) should develop a core set of standardized measures.

This action is based on an HHS commissioned report, “Quality in Home- and Community-Based Services to Support Community Living: Addressing Gaps in Performance Measurement,” by the National Quality Forum,(NQF)

The measures will be organized into a set of base measures that includes a small set of measures to be used in their entirety, and an extended set of measures that will be a larger set of measures for which the States, plans, and providers  can select to supplement the base set in accord with their priorities and needs.

The measures will be categorized using eleven quality domains described in the NQF report.

  • Service effectiveness and delivery
  • Person-centered planning and coordination
  • Choice and control
  • Community inclusion
  • Caregiver support
  • Workforce
  • Human and legal rights
  • Equity
  • Holistic health and functioning
  • System performance and accountability
  • Consumer leadership in system development

The following criteria for measure selection will be used by the measure developers. However, the criteria will used as a guide rather than a standard.

  • Importance to measure and report
  • Scientific acceptability of the measure properties (validity and reliability)
  • Feasibility- data that is readily available and/or does not impose an undue burden
  • Usability
  • Related and Competing measures-extent to which there are related and/or competing measures in the measure set.
  • Applicability
  • Type of measure (process, structure, or outcome measure)

Measures that are in the public domain and rely on publicly available instruments will be prioritized. However, many of these  measure concepts and instruments are propriety and require a fee to use.   CMS also recognizes that applying measures to statewide, delivery systems (FFS,. managed care, self-directed), and population level may not be possible, but measures that can be taken will take priority. The types of quality measures could include process, structure, and outcome measures.

CMS views the initial development of both the base and extended measure sets as an important step forward in our efforts to strengthen HCBS quality measurement and reporting nationally, but recognizes that there are a number of limitations of the measure set and HCBS quality measurement overall. These limitations include:

  • A lack of available quality measures to include in the base set and/or the extended set for some NQF domains;
  • High measurement burden and other challenges associated with some quality measures;
  • A lack of publicly available information on the extent to which some quality measures are currently in use;
  • A limited number of outcome measures that have been tested and validated; and
  • A limited number of quality measures that have been tested and validated at the statewide, delivery system, and population levels.

Throughout the report, CMS poses several questions related to the area of discussion within the RFI  The questions are also listed at the end of the report.

The recommended measures come from a variety  of measure sets, such as, the National Core Indicator (NCI), National Core Indicators-Aging and Disabilities (NCI-AD),  MLTSS measures etc.  You can do a web search for information on these measure sets. They are currently in place for voluntary use.

Comments are due November 18 ,2020. Comments are to be submitted to: HCBSMeasuresRFI@cms.hhs.gov.