HCBS compensation reporting guidance separates 2027 readiness from 2028 reports
Oct 11, 2026 edition · GC-2026-0272 · Published 2026-10-11 · Version 3 · Final
SMD 26-005 separates readiness, applicability, and annual submission windows for HCBS compensation reporting. July 9, 2028 begins fee-for-service applicability; it is not the letter's annual-report submission deadline.
What happened
States must email CMS by July 9, 2027 describing readiness to collect direct-care compensation data. The requirement covers specified HCBS authorities under sections 1915 and 1115, with stated exceptions, and excludes section 1905(a) services. Fee-for-service applicability begins July 9, 2028; managed care begins with the first contract rating period starting on or after that date. These are different implementation gates, not one simultaneous provider filing deadline.
CMS expects an annual reporting window around September 1 through December 31 beginning in 2028, measuring the preceding calendar year. Thus the first 2028 report concerns provider payments during 2027. The anticipated collection form remains subject to PRA review. States retain responsibility for collecting data and may involve providers and managed-care plans. Readiness work therefore needs authority-specific data ownership and state instructions, rather than one assumed filing date for every provider.
Scope and timing
- Authority status
- Final
- Applicability
- Directly applicable
- Audience
- Health systems, Provider networks
- Jurisdiction
- Federal
- Affected functions
- Finance, Managed Care, Clinical Operations, Compliance
- Responsible owner
- Finance
- Recorded date
- 2027-07-09
- Date type
- compliance
Why it matters
The guidance reaches specified 1915 and 1115 HCBS authorities in fee-for-service and managed care. It excludes the section 1905(a) personal care, home health and case management benefits. It does not make the separate 80 percent compensation rule immediately operative.
Recommended action
Map service authorities and data owners now; validate provider compensation data and managed-care reporting contracts against state instructions. Playbook dates are recommended internal targets, except any explicitly identified agency date.
Implementation playbook
- Identify HCBS service authorities and provider populations covered by compensation reporting. Managed Care · Due 2026-10-25
- Inventory compensation and payment data sources and document gaps in contractor reporting. Finance · Due 2026-11-15
- Establish a state-guidance dependency and test representative reporting data before scaling. Compliance · Due 2026-12-15
Published long lead justification
The newly issued state guidance requires compensation data and managed-care contract preparation before July 2027 readiness reporting; provider data dependencies warrant early planning beyond the 180-day horizon.
Sources
- SMD 26-005, HCBS compensation reportingOfficial · CMS · 2026-10-09 · Source review 2026-10-11
Complete edition and supplemental material
This finding in the complete approved report →Regulatory horizons, CIA trends and implementation trackers remain in the full report.
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