The HOPE Assessment Tool Series: Compliance Saves Money
Written by Dr. Jennifer Kennedy
CHAP is invested in helping hospice providers succeed with implementing the HOPE assessment tool later in 2025. We began the HOPE Assessment Tool blog series in 2024 to provide targeted information and education about the tool that dovetails with education offerings from CMS and your electronic medical record (EMR) vendor. We will continue this blog series to highlight different aspects of the HOPE assessment tool and invite readers to provide feedback about topics they would like us to cover.
In CHAP’s HOPE Assessment Tool blog series thus far, we covered an introduction to the HOPE assessment tool, prepping for implementation on October 1, 2025, and understanding the required timed visits. This blog will discuss compliance with HOPE record submission and acceptance and tips for avoiding costly penalties. The cost of running an organization is rising every year and no hospice provider can afford a payment reduction in this healthcare environment. In addition to increasing costs, Medicare sequestration remains in place and reduces payments by 2% for every claim submitted. Adding a reduction for non-compliance with quality data submission could result in significant financial challenges for many organizations.
Data Collection and Submission Cycle
The Hospice Quality Reporting Program (HQRP) is a “pay-for-reporting” program, which means the submitting and acceptance of required data determines compliance with HQRP requirements. The HQRP reporting cycle includes data collection and submission in a calendar year, compliance determinations, and payment impact two years later in the federal fiscal year. For example, HOPE data collection and submission in calendar year 2026 will be processed for compliance determinations in CY 2027 and affect Annual Payment Updates (APU) in fiscal year 2028 which begins October 1, 2027. CMS will send letters through Medicare Administrative Contractors (MACs), and electronically via the QIES-CASPER system to hospice providers in July/August as notification of non-compliance with HQRP requirements. Providers can submit a reconsideration request of the initial non-compliance decision within thirty (30) days after the date documented on the non-compliance notification letter distributed electronically using QIES. CMS will not accept requests submitted after the thirty (30) day deadline. The request for reconsideration must be accompanied by supporting documentation demonstrating compliance with QRP data. CMS delivers reconsideration decisions in September before the start of the new fiscal year on October 1st. If a hospice is determined non-compliant it is subject to a reduction in their payment rate in a coordinating annual payment update year.
The current data submission measured for HQRP compliance is the Hospice Item Set and CAHPS data. Failure to submit this data will result in a 4% payment reduction in a coordinating annual payment update fiscal year. When the HOPE assessment tool is implemented on October 1, 2025, HQRP compliance will be measured using HOPE and CAHPS data submission.
HOPE Compliance Requirements
Hospice providers must complete the HOPE assessment tool for all patient admissions regardless of the payer source, patient age, where the patient receives hospice services, or the patient’s length of stay. And, providers must submit an admission record, two HOPE Update Visit (HUV) records, depending on the length of stay, and a discharge record for each patient within the prescribed submission timeframe to be compliant. Data reported in HOPE must accurately reflect the patient’s status when the data was collected during the clinician’s visit. CMS recommends providers complete and attempt to submit HOPE records early, before the submission deadline of 30 days. Submitting records early allows the organization more time to address technical issues like fatal errors. Providers must submit at least 90% of all their HOPE records by the 30-day submission deadline to be compliant for an FY APU reporting year and all subsequent reporting years.
Non-compliance with HOPE data submission is characterized in two different ways. Some hospice organizations choose not to submit data with the full understanding they will receive a payment reduction in a coordinating APU year. Other providers do submit their data but fail to achieve the 90% threshold by the end of the calendar year. In the latter case, providers must use available reports to validate that their submitted records are accepted without errors.
Submission and Acceptance of HOPE Records
Providers must create electronic HOPE records and submission files using software that creates files that meet the requirements detailed in the current HOPE data submission specifications. Providers must have an account in the CMS system and request a user role to submit HOPE records. Each provider should have the ability via iQIES for two staff members to submit data to CMS. HOPE records must be submitted in sequence and within the specified timeframe (see Figure 9: Submission Deadlines from the CMS HOPE Guidance Manual, v1.0)
The HOPE Final Validation Report (FVR) will show a warning when a HOPE record is submitted out of sequence.
When HOPE records are submitted, the CMS system will perform validation checks to determine whether the data meets the required specifications. HOPE records are evaluated to verify:
- clinical responses are within valid ranges and consistent with other items in the record,
- dates are reasonable, and
- submitted records are in the proper sequence.
The FVR will indicate the acceptance or rejection of records. Consistently using the FVR to check for acceptance of records is a crucial step for ensuring compliance as submission of a HOPE record does not equal acceptance of a HOPE record.
Tips for Compliance
- Ensure staff who will complete the HOPE assessment tool items:
- are trained to understand the item and how to complete it
- complete all applicable items and it is completed timely
- Submit HOPE records in sequence and timely for each patient
- Consistently utilize the FVR to ensure all records are accepted without errors
Non-compliance with HOPE record submission is avoidable and expensive. Ensure your HOPE assessment tool implementation plan includes processes for compliant data collection, submission, and acceptance.
Stay tuned for the next installment in the HOPE Assessment Tool blog series.
References
The Centers for Medicare and Medicaid Services. (2025, Oct 1). Hospice outcomes and patient evaluation (HOPE) guidance manual – v1.00. https://www.cms.gov/files/document/hope-guidance-manualv100.pdf
The Centers for Medicare and Medicaid Services. (2024, Nov 25). Reconsideration requests. https://www.cms.gov/medicare/quality/hospice/hqrp-reconsideration-requests
Congressional Research Services. (2023, Nov 14). Medicare and budget sequestration. https://crsreports.congress.gov/product/pdf/R/R45106