Prepping for the Hospice HOPE Tool: Starting the Journey
Written by Jennifer Kennedy
The Centers for Medicare and Medicaid Services (CMS) recently finalized the implementation date of the hospice HOPE assessment tool in the FY 2025 Hospice Payment Update final rule. This quality requirement signals a new beginning for hospice providers related to quality measurement and future payment reform. Implementation is scheduled for October 1, 2025, so the clock is ticking, and the interval is short for provider and software vendor preparation for compliance.
Abt, CMS’s contractor, began developing the Hospice Outcomes and Patient Evaluation (HOPE) assessment tool in 2019 by gathering information from hospice experts and stakeholders. They tested and refined a draft tool via pilot, alpha, and beta testing with volunteer hospice providers between 2020 and 2023, and it made its public debut in FY 2025 proposed rulemaking. The HOPE tool is a standardized assessment that checks many boxes for hospice providers and CMS. Providers will gain a better understanding of patient needs, which will assist in building a more individualized plan of care. CMS will obtain clinical data that will inform future quality measure development and could inform future payment modification.
The HOPE assessment will not impact the § 418.54 Condition of participation (CoP): Initial and comprehensive assessment of the patient requirement. The assessment content of this CoP will continue to be required in addition to the HOPE data items. It will be important for providers to ensure their documentation software vendor maintains CoP content while building HOPE content. The HOPE tool will replace the Hospice Item Set (HIS) content, but the essence of the HIS data items is captured in the HOPE. CMS posted a changes table that provides a comparison between HIS and HOPE data elements.
The tool is designed to collect data in real-time to assess patients and families related to their interactions with the hospice team while adapting their clinical needs and gathering additional information to contribute to the patient’s care plan throughout the hospice stay. The tool includes several domains that are new or expanded relative to HIS, including:
- Sociodemographic (updated)
- Diagnoses (expanded)
- Symptom Impact Assessment
- Imminent death
Data elements represent other domains, such as:
- Administrative
- Preferences for Customary Routine Activities
- Active Diagnoses
- Health Conditions
- Medications
- Skin Conditions
The tool will also collect data at multiple time points in the patient’s hospice stay. Like the HIS, the HOPE tool collects data at admission and discharge. Data will also be collected on symptom update visits throughout the hospice. Up to three of these visits may be required depending on the patient’s length of stay.
Providers should become familiar with the draft HOPE assessment tool content now and plan conversations with staff about changes in assessment practices in the coming months. The draft manual is available on the CMS Hospice Quality Reporting Program’s (HQRP) website and is written in a similar format to the HIS manual.
While CMS will facilitate training about tool utilization, data completion, and record submission, providers should educate staff about the HOPE tool’s impact on assessment and documentation practices within their organization. Providers should not wait for CMS or documentation software vendor training to start these discussions.
CMS is finalizing two process measures, which are tested and reviewed through CMS’s Measures Under Consideration process. The first measure is based on pain symptom severity and impact and will be determined based on hospice patients’ responses to the pain symptom impact data elements within HOPE. The second measure is non-pain symptom severity and impact. It will be determined based on patient responses to the HOPE data elements related to shortness of breath, anxiety, nausea, vomiting, diarrhea, constipation, and agitation. These two measures will determine whether a follow-up visit occurs within two (2) days of an initial assessment of moderate or severe symptom impact. Public reporting of these measures is slated for no earlier than November 2027 (FY 2028).
CMS will measure compliance with HOPE data submission with the same methodology as the HIS. After the HIS is phased out, hospices will continue to submit 90% of all required HOPE records within 30 days of the completion date (patient’s admission, discharge, and based on the patient’s length of stay up to two update visit time points. Providers who fail to meet at least 90% submission of all required HOPE assessments to CMS will be subject to a 4-percentage point reduction of the annual market basket for the coordinating fiscal year.
Starting the journey to HOPE utilization will be a big undertaking for hospice providers, and thoughtful planning will be key to an organization’s success. The following tips will help providers organize and focus on taking first steps on the HOPE tool implementation road.
- Know your baseline performance and measure it consistently moving forward (i.e., iQIES, CASPER, PEPPER)
- Be proactive in determining clinical practice gaps with current CA of the patient and family status and needs
- Regularly review clinician documentation for trends or issues overall and with individuals
- Assess to determine issues now with the CA process
- Track/trend refusal of services to determine if an update in the process needs to occur
- Ensure clinicians have proper CA completion training and evaluation of competency
- Work closely with your EMR/EHR vendor on the development of your assessment tool
- Stay updated about the HOPE tool and HQRP:
- CMS websites and list serves
- CMS Proposed/Final Wage Index Rules (NOT just Hospice!)
- Webinars/Conferences
- State/National Associations
- Start staff education now
- Provide staff/IDG training and updates; Consider developing competency (like OASIS competency/evaluations to ensure accuracy and consistency)
- Ensure staff attend CMS HOPE training
Resources
References
CMS – Hospice Outcomes & Patient Evaluation (HOPE) Frequently Asked Questions https://www.cms.gov/files/document/hope-faqfinaldecember-2019.pdf