HOPE Assessment Tool Blog Series: Managing HOPE Records

It is hard to believe that HOPE implementation on October 1, 2025, is only a few weeks away. Hopefully, your clinicians are feeling confident in completing the HOPE items in the assessment and your organization is feeling ready to submit your first HOPE records to CMS. The CHAP HOPE blog series started in 2024 and walked through the HOPE manual to discuss the key points of each section and connected the dots to other key regulatory and compliance considerations. This last pre-implementation blog will focus on highlights of HOPE record management and data submission to iQIES. CHAP closely follows the guidance from CMS and will develop post-implementation blogs as needed in the coming months. We developed a CMS HOPE Quick Guide which is a one-stop shop for CMS HOPE user materials, education, technical information, frequently asked questions and questions & answers, and CMS help information.

View Quick Guide

Goodbye HIS Submission

Feeling sentimental about the Hospice Item Set (HIS)? No tissues are needed as items from the HIS are in the HOPE tool, so you will not really be saying goodbye to the content. But you will say goodbye to HIS data submission; your last HIS records will be submitted on September 30, 2025. HIS records submitted before October 1, 2025, will be available for modifications and inactivations within the QIES system through February 15, 2026.

CMS’s Submission System: iQIES

CMS mandated that HOPE data be submitted via the Quality Improvement and Evaluation System (iQIES) beginning October 1, 2025. The Internet Quality Improvement and Evaluation System (iQIES) is a web-based platform developed by CMS and serves as a centralized system for managing provider information, patient assessment data, and survey/certification data. CMS improved their QIES system (now iQIES) to reduce provider burden and enhance the CMS ability to serve their customers.

iQIES will require a new user management system because virtual private network (VPN) and CMSNet are not needed to access the iQIES system. All users will have to create an account and establish credentials in the HCQIS Access Roles and Profile system (HARP), which is a secure identity management portal provided by CMS. At least one PSO must be selected, and CMS recommends designating two PSOs to increase the likelihood of availability for approving or rejecting iQIES access requests. Access will only be granted if a PSO approves the request.

To receive access to iQIES, your organization must complete the steps on the HOPE iQIES webpage no later than September 10, 2025.

The HOPE Validation Utility Tool (VUT) for vendor testing is available at https://iqies.cms.gov/vut. Once on the page select a provider data specification and upload a test file to validate assessment upload compatibility. Results will be displayed in the Final Validation report within the VUT.

Section Z: Record Administration

This section includes signatures from those completing the HOPE record and from the verifier. Section Z should be archived by the provider following their patient information policies. The hospice is responsible for the accuracy of all items on HOPE, irrespective of how they are completed or auto populated in the HOPE record. As a reminder, the time points for required record submission include admission, HUV1, HUV2, and discharge.

Item Z0400 – Signature(s) of Person(s) Completing the Record

Item Z0400 logs HOPE data and uses signatures to confirm accuracy and authorization. Signatures in Z0400 represent the hospice staff members who completed the HOPE items, regardless of whether they are the same clinicians who performed care processes documented in the clinical record. Depending on the timepoint record, different clinicians may be completing the HOPE record.

Fast facts about Z0400 include the following:

Electronic staff member signatures are acceptable.
A staff member who completes several HOPE sections can sign Z0400 once and list the completed sections in the “Sections” field.
Multiple staff members may complete different items in the same HOPE record section. They just need to note which items they completed.

If a staff member is unable to sign and date Z0400 on the same day that a section or portion of the HOPE record is completed, the staff member should indicate the original completion date of the HOPE record when signing Z0400.
The signature-block section (Z0400) is for hospice provider use and is not submitted as part of the HOPE record to CMS. The provider should develop or refer to organizational policies and procedures related to patient information for completing and retaining Z0400.

Item Z0500 – Signature of Person Verifying Record Completion

Item Z0500 records the staff member’s signature confirming that all sections of the HOPE assessment are complete. This signature does not certify the accuracy of sections completed by other hospice staff, only the completion of the items in the record. The signature-block section (Z0500) is for hospice provider use and is not submitted as part of the HOPE record. The provider should develop or refer to organizational policies and procedures related to patient information for completing and retaining Z0500.

Fast facts about Z0500 include the following:

The designated staff member signs and dates Z0500 after verifying that all items in the record are complete and that Item Z0400, Signature(s) of Person(s) Completing the Record, contains attestation for all HOPE sections.
If the staff member verifying record completion is unable to sign Z0500A on the date HOPE is completed, the staff member should enter the date in Z0500B when they sign Z0500A.
In the case of a Modification or Inactivation Request, Z0500B should contain the original date on which the record was completed. Providers should not change Z0500B unless the date in Z0500B in the original record was incorrect and the modification request is to correct the date in Z0500B.

Chapter 3: Submission And Correction of Hope Records

This chapter covers HOPE record submission, corrections, and hospice data requirements effective October 1, 2025. Hospice providers must complete and submit the mandated four HOPE records to CMS to achieve compliance. Providers must utilize software capable of generating electronic HOPE records and submission files that adhere to the specifications outlined in the Final HOPE Data Submission Specifications.

It is critical to understand that a submitted record does not equal an accepted record. Compliance is measured using accepted records.

When CMS receives a submission file, the system runs validation checks to ensure the data meets required specifications. HOPE records are reviewed to confirm clinical responses are valid and consistent, dates are appropriate, and the record is properly ordered with previously accepted CMS records for the same patient. The provider receives a Final Validation Report (FVR) indicating record acceptance, rejection, or warnings when the timing criteria have not been met.

Timeliness Criteria

All HOPE records should be submitted and accepted electronically within 30 days of completion as follows:

Admission records – the submission date may be no later than 30 days from the Admission Date (Item A0220).
HOPE Update Visit (HUV) records – the submission date may be no later than 30 days from the date assessment was completed (Item Z0350).
Discharge records – the submission date may be no later than 30 days from the discharge date (Item A0270).

Table 11: HOPE Completion and Submission Timing Example in the HOPE manual provides an example of completion and submission record timing.

Submission Sequence

Providers will receive a warning on the FVR from the submission system when a HOPE record is submitted out of sequence. Examples of possible warnings include:

Submitting an admission record where the prior record submitted was also an admission record and there was no discharge record submitted in between.
Submitting an admission record for a patient after the submission of a discharge record indicating that the patient died.
Submitting an HUV record before an Admission record.

Additional examples are provided in the HOPE manual in this section.

Record and File Validation

The submission system is structured to monitor submission timeliness and verify that uploaded records adhere to the HOPE Data Submission Specifications. Upon completion of an upload, the system issues a notification indicating either success or failure. The HOPE manual comprehensively outlines the processes for validating, storing, and reporting records within a submission file. Sections within 3.4. Validation of Records and Files include:

Section title and number	Content highlight
3.4.1. Initial Submission Confirmation	After records are uploaded in a zip file, a success or failure notification will indicate if the upload was successful. This notification only indicates if the upload was successful, not whether the patient records have been processed.
3.4.2. Validation and Editing Process	After the records have been successfully uploaded, the View Report link will be enabled after the zip file has been processed.The submitter can refresh their browser until the View Report link is enabled. The FVR is automatically generated in the CMS system within 24 hours of the submission of a file and will verify acceptance or rejection of records, as well as warnings and any fatal errors.Errors and warning messages detailed in the FVR are explained further in the HOPE Error Message Reference Guide.All warnings (non-fatal errors) are reported to the provider in the FVR. The provider must evaluate each warning to identify necessary corrective actions.
3.4.3. Record Storage	If there are any fatal record errors, the record will be rejected and will not be stored in the CMS system. If there are no fatal record errors, the record is stored by CMS, even if the record has warnings (non-fatal errors).

CHAP recommends that providers carefully review all content in 3.4. Validation of Records and Files in the HOPE manual.

HOPE Correction Policy

The HOPE record must be accurate before submission to CMS. If errors are found in an accepted record, providers must correct them quickly. Amendments to a provider’s HOPE record following CMS acceptance will only be acknowledged if they are made to the electronic version and subsequently resubmitted. Providers must correct errors in accepted HOPE records via the HOPE Correction Policy. A correction may be submitted for any accepted record within 24 months of the discharge date, regardless of whether subsequent records for the patient were submitted and accepted. Hospice providers are responsible for correcting errors to the record prior to submission or re-submission of the record to CMS.

Section title and number	Content highlight
3.6. Correcting Errors in HOPE Records That Have Not Been Accepted by CMS	HOPE records in this category include records that have been submitted and rejected, or records that have not been submitted at all. Records that have been submitted and rejected can usually be corrected and resubmitted without any special correction procedures because they were never accepted by the system.
3.7. Correcting Errors in HOPE Records That Have Been Accepted by CMS	An error identified in a HOPE record must be corrected to ensure the information accurately reflects the patient’s hospice record. Inaccurate information in the system may affect hospice quality reporting results. A HOPE record may be corrected even if subsequent records have been accepted for the patient.Providers should retain a copy of submitted HOPE records, and corrected versions, to track what was modified. Providers should keep a copy of inactivated records (can be maintained in electronic format).
3.7.1. Modification Requests	A Modification Request record (A0050 = 2) is used when a HOPE record is accepted by CMS but the information in the record contains clinical or non-key demographic errors. There are items that cannot be corrected with a Modification Request; the invalid record must be inactivated with an Inactivation Request record or manually deleted, and a new record submitted to the CMS system.See detail in HOPE manual for Items that cannot be corrected with a Modification Request
3.7.2. Inactivation Requests	An Inactivation Request record (A0050 = 3) must be used when a record has been accepted but the corresponding event did not occur (for example, a Discharge record was submitted for a patient, but there was no actual discharge) or when an error is found with one or more of the event identifiers or patient identifiersSee detail in HOPE manual for an inactivation request

Special Manual Record Deletion Request

A special Manual Record Deletion Request is needed only when a CMS-accepted record has an incorrect state code (STATE_CD) or facility ID (FAC_ID) that can’t be fixed with Modification or Inactivation. These control item errors can happen during software installation when initializing the software, not regular data entry. If a HOPE record contains the wrong STATE_CD or FAC_ID, it must be deleted entirely and resubmitted on a newly submitted record with accurate information. Providers should contact the iQIES Service Center at iQIES@cms.hhs.gov or 1-877-201-4721 if this error occurs.

Watch for the CMS HQRP webpage, QRP Announcements & Spotlight area for more information about the HOPE implementation.

CHAP wishes providers a successful implementation and keep your momentum moving forward for October 1, 2025.