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CMS found about 450 Medicaid quality requirements for 258 measures. 38 states pledged to cut toward outcomes.

A May 2026 CMS analysis of Medicaid managed care contracts in 42 states counted about 450 quality reporting requirements for 258 unique measures. As of Oct 29, 38 states had signed CMS's Medicaid Quality Pledge. For companies that run Medicaid plans and D-SNPs, the pledge and the federal Medicaid quality rating system due by December 31, 2028, now sit on one calendar.

Grant Whitaker · 4 min read
A red check mark in the top box of a three-box checklist on white paper, against a pale blue background
Photo: Tara Winstead / Pexels

CMS says Medicaid managed care quality reporting has grown to about 450 requirements for 258 unique measures across 42 states, and 38 states have now signed a pledge to cut toward health outcomes. Many parent companies run both Medicaid managed care plans and Medicare Advantage D-SNPs. For them, the pledge and the federal Medicaid quality rating system already in regulation set the operations work for the next two years.

Chart: 38 states have signed CMS’s Medicaid Quality Pledge, one more than the 37 at launch. Tile map of 50 states by pledge status as of Oct 29, 2026. Pledged states cover about 56M Medicaid and CHIP beneficiaries and about $701B in FY2024 Medicaid spending, per Medicaid.gov. Source: CMS, Medicaid.gov State Partners page, as of Oct 29, 2026.

CMS announced the pledge on Sep 25, 2026, with a founding group of 37 state partners. Medicaid.gov lists 38 states as signed as of Oct 29, 2026. The page puts coverage at about 56M Medicaid and CHIP beneficiaries across pledged states and about $701B in Medicaid spending for FY2024 across those states. CMS said the goal is to move quality measurement toward outcomes and away from paperwork.

Arkansas is on the Medicaid.gov State Partners table as a pledged state, with 773,838 Medicaid and CHIP enrollees in May 2026. CMS’s Sep 25 release counted 37 founding states without listing them, and CMS has not said when each state signed. Twelve states had not signed as of Oct 29, per the same table.

What CMS counted in the May 2026 analysis

The two CMS sources describe the same work in slightly different terms. The press release describes a May 2026 analysis of Medicaid managed care programs across 42 states that found “approximately 450 reporting requirements corresponding to roughly 260 unique quality measures.” Medicaid.gov describes a May 2026 analysis of managed care contracts across 42 states and programs that identified “approximately 450 quality reporting requirements representing 258 unique quality measures.” We use the Medicaid.gov figure of 258. The press release rounded it to roughly 260.

Chart: about 450 requirements for 258 measures

CMS said the measures focus largely on processes and utilization. Medicaid.gov said a smaller share is directly tied to improvements in beneficiaries’ health outcomes. The Sep 25 press release gives diabetes as an example: “measures of diabetes control may be captured using different blood sugar levels (e.g., three different types of A1c cutoffs), making it difficult to compare performance across states.” That is a measurement design problem before it is a performance problem.

What states signed

The pledge rests on four principles, quoted here as CMS wrote them:

  • “Prioritize health outcomes over process, with a focus on prevention, chronic disease management, and behavioral health.”
  • “Streamline quality measure inventories to reduce burden without sacrificing accountability.”
  • “Advance digital quality measurement, using near-real-time data instead of claims and chart abstraction where feasible.”
  • “Align financial accountability with outcomes-oriented measures.”

CMS said participating states commit to use these principles to set targets for health outcomes and to add outcomes-oriented measures to state quality strategies and upcoming procurements. CMS said it will hold workshops later this year on measure prioritization and value-based arrangements, reduced reporting burden, and digital quality measurement.

Medicaid.gov invites states, health plans and other quality stakeholders to sign, and the page has a Health Plan Partners section. CMS names state governments, managed care organizations, measure stewards and providers as the groups it needs. CMS Administrator Dr. Mehmet Oz said Medicaid “has measured whether boxes are checked instead of whether patients are getting healthier.”

Why this lands on MA and D-SNP plans

Medicaid managed care quality rules reach dual eligible members, and CMS’s own rule text says so. Parent companies that run both Medicaid plans and D-SNPs answer to both sets of measures. A state that rewrites its Medicaid quality measures under the pledge changes the Medicaid side of those companies directly. It reaches D-SNP operations through the members the two programs share.

The federal Medicaid quality rating system adds a fixed deadline. Under 42 CFR Part 438 Subpart G, states “Must implement such managed care quality rating system by the end of the fourth calendar year following July 9, 2024.” Medicaid.gov puts the date at December 31, 2028. States that cannot fully meet certain methodology and website display requirements can ask CMS for a one-time, one-year extension on those pieces, to December 31, 2029. Section 438.505(c) directs CMS to align the mandatory measure set “to the extent appropriate” with the Medicare Advantage and Part D quality rating system. Section 438.520(a)(2)(v) requires state ratings “stratified by dual eligibility status, race and ethnicity, and sex.” Section 438.520(a)(3)(vi) covers plans that offer “a highly or fully integrated Medicare Advantage D-SNP.” For those, the state site must show that an integrated plan is available and link to the plan’s most recent rating under the Medicare Advantage and Part D 5-Star Rating System.

The subpart does not apply to D-SNPs that contract with states only for Medicaid coverage of Medicare cost sharing, per section 438.505(b).

What to watch

The workshops later this year will show how CMS and the states rank measures for removal. State quality strategies and procurements will show which outcome measures get written into contracts and how much payment rides on them. The quality rating system measure set will show how far CMS takes alignment with Medicare Advantage and Part D ratings, and how states build the dual eligibility cut.

For plan leaders, the first job is to map current Medicaid quality reporting against each state’s list and flag the process and utilization measures most exposed to removal. The second is to check how each state contract ties payment to outcomes. Parents that run D-SNPs should put the pledge work and the December 31, 2028, rating system deadline on one calendar.

The pledge is voluntary. The rating system deadline is not, and both now sit on the same operating calendar for plans that serve dual eligible members.

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The NumberUnique quality measures behind about 450 quality reporting requirements in Medicaid managed care contracts across 42 states and programs, CMS analysis, May 202638 states signed CMS's Medicaid Quality Pledge as of Oct 29, 2026, up from 37 founding states on Sep 25. Source: CMS press release, CMS Refocuses Medicaid Quality on Health Outcomes, Launches Innovative Partnership With 37 States, Sep 25, 2026
Sources
  1. CMS press release, CMS Refocuses Medicaid Quality on Health Outcomes, Launches Innovative Partnership With 37 States, Sep 25, 2026 (cms.gov)
  2. Medicaid.gov, Investing in Health Outcomes (medicaid.gov)
  3. Medicaid.gov, Investing in Health Outcomes, State Partners (as of Oct 29, 2026) (medicaid.gov)
  4. Medicaid.gov, Medicaid and CHIP Quality Rating System (medicaid.gov)
  5. eCFR, 42 CFR Part 438 Subpart G, Medicaid and CHIP managed care quality rating system (ecfr.gov)
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