Medicaid plans are about to be publicly rated—are you ready?

Medicaid quality measurement is entering a new era —not because the measures themselves are new, but because the stakes are. New regulations are pushing quality data out of the background and into public view. CMS’s 2024 Medicaid and CHIP Managed Care final rule accelerates a shift from behind-the-scenes reporting toward public-facing transparency. For Medicaid managed care organizations (MCOs), this shift brings real operational complexity and a chance to stand out.

The shift: From quality reporting to public comparison

For years, states have voluntarily reported quality data through the Medicaid and CHIP Child and Adult Core Sets, often drawing on CAHPS surveys to understand member experience. But as of Federal Fiscal Year 2024, much of this reporting is no longer optional. States must report standardized measure sets annually, strengthening consistency and comparability across the country. 

A significant change comes with the Medicaid and CHIP Quality Rating System (MAC QRS). Beginning with Measurement Year 2026 and displayed online by December 31, 2028, states must publish standardized, plan-level ratings for Medicaid and CHIP managed care plans. Five of the mandatory measures come directly from the CAHPS Health Plan Survey—highlighting key aspects of member experience, including access to care, communication with doctors, customer service, and overall plan rating. These CAHPS-based measures, long used primarily for quality improvement or accreditation, will soon play a visible role in how plans are publicly compared.

Shortly after, another requirement takes effect: annual enrollee experience surveys for all Medicaid managed care plans starting with rating periods on or after July 9, 2027. While separate from QRS and Core Sets, these surveys rely on many of the same foundational data elements and further expand how states assess experience of care across their programs.

Taken together, these initiatives signal an important shift: Member-reported experience will increasingly shape how plans are evaluated, compared, and held accountable—both by states and by the public, including Medicaid members and their families.

3 things plans can do now

Although these regulations apply to states, plans provide the data and experiences that ultimately drive results. Preparing early will help plans influence their performance and the narrative surrounding it.

1. Monitor state decisions and timelines closely

States have flexibility in how they structure survey operations, vendor requirements, sample frames, and reporting processes. States could already be updating EQRO scopes of work, issuing new guidance, or modifying contracts to support these emerging requirements. Staying aligned with your state’s direction, especially around who fields surveys, which tools are used, and how results will be displayed, will help minimize operational surprises and ensure readiness.

2. Strengthen your survey strategy and infrastructure

Whether your state centralizes CAHPS administration or requires plans to coordinate with survey vendors directly, you still own the member experience behind those results. Plans should ensure they have:

• An NCQA-certified CAHPS vendor (where applicable)
• Reliable processes for data submission and response-rate improvement
• Clear ownership of CAHPS trend analysis and member experience initiatives

Reviewing historical CAHPS performance now can help identify gaps well ahead of QRS public display and the upcoming annual enrollee survey requirement.

3. Prepare for transparency—operationally and reputationally

Once plan-level ratings are displayed publicly, performance becomes both a quality measure and a communication responsibility. Plans should begin thinking now about how they will contextualize results for members, providers, community partners, and other stakeholders—particularly in areas related to access, customer service, and care coordination.

Proactive communication can help frame results constructively, highlight strengths, and demonstrate ongoing commitment to improvement.

The move toward mandatory reporting, public plan ratings, and annual experience surveys marks a pivotal moment for Medicaid managed care. Plans that treat these shifts as more than compliance exercises and, instead, as opportunities to strengthen member experience, align operations, and demonstrate transparency will be better positioned to lead in this new landscape. If your organization is preparing for MAC QRS, strengthening CAHPS operations, or navigating overlapping survey requirements, our team is ready to support your strategy. Speak with an expert today.