Clinical Compliance

Checking In on HOPE: Is it Working for Your Hospice Organization?

01/13/2026

Introduction

Hospice leaders are stepping into a new data era as the Centers for Medicare and Medicaid Services (CMS) rolls out the Hospice Outcomes & Patient Evaluation (HOPE) tool effective October 1, 2025, replacing the Hospice Item Set (HIS) for all new admissions on/after that date. HOPE requires assessment at admission (no later than five calendar days after election; election date is Day 0), at defined update windows in the first month (HOPE Validation Utility Tool1 (HUV1) days 6–15; HUV2 days 16–30, when applicable), and at discharge, with HOPE submissions routed through the Internet Quality Improvement and Evaluation System (iQIES).

Records must be submitted and accepted by CMS by the 30-day submission deadlines (Admission Date +30; HUV assessment date +30; Discharge Date +30). The Hospice Quality Reporting Program (HQRP) remains pay-for-reporting: providers must submit at least 90% of required HOPE records timely to avoid the 4-percentage-point Annual Payment Update (APU) reduction, with the first full HOPE performance year (CY 2026) impacting FY 2028 payment. CMS also clarified iQIES sequencing edits (including how out-of-sequence HUV submissions are handled) and provided transition guidance for cross-over patients admitted before Oct 1 but discharged on/after Oct 1 (HIS Admission to QIES + HOPE Discharge to iQIES; no HUVs required).

Clinical Impact of HOPE

Clinically, HOPE shifts hospices from primarily retrospective reporting to standardized, visit-based assessment and follow-up—especially around symptom impact and care planning. When pain or non-pain symptom impact is rated moderate or severe during an Admission or HOPE Update Visit, CMS expects a separate, in-person Symptom Follow-Up Visit (SFV) to occur within two calendar days. CMS has established two HOPE-based HQRP process measures—Timely Follow-up for Pain Impact and Timely Follow-up for Non-Pain Symptom Impact—signaling that timely symptom follow-up will be a key performance focus as HOPE data mature. In practice, this cadence supports faster plan-of-care updates, clearer symptom escalation pathways, and documentation that aligns with HOPE reporting expectations and survey readiness.

Revenue Considerations

Financially, the near-term picture blends modest rate relief with meaningful compliance risk. CMS finalized a 2.6% hospice payment update for FY 2026 and set the aggregate cap at $35,361.44, effective October 1, 2025. As always, those increases are available only to providers that meet Hospice Quality Reporting Program (HQRP) requirements; late or insufficient HOPE submissions place agencies at risk for the 4-percentage-point annual payment update reduction in a future payment year. In short, the margin opportunity is real—but it is increasingly tied to disciplined execution.

Looking ahead, CMS will analyze calendar year 2026 HOPE data during 2027, with the earliest public reporting of HOPE measures on Care Compare expected in fall 2027 (FY 2028), following a provider preview period in summer 2027. Once those measures are public, early performance may begin to shape referral confidence, payer conversations, and broader market perception—well before payment methodologies evolve further.

Early implementation has been uneven for some agencies, which is not unusual for a national rollout of this scale. In the initial months, national hospice associations documented submission errors, timeliness concerns, and iQIES configuration challenges, and advocated for temporary flexibility as providers adjusted. CMS has continued to communicate through Hospice QRP announcements and HOPE updates, focusing on system corrections, submission guidance, preview timelines, and refresh schedules.

For hospice leaders, the takeaway is reassuring but clear: late 2025 results should be treated as a learning period, not a verdict on performance. The organizations that use data to refine workflows, align clinical and quality teams, and stabilize HOPE processes will be best positioned to welcome 2026 with confidence—operationally, clinically, and financially.

Operational Readiness: From Compliance to Confidence

Operational success under HOPE hinges on disciplined readiness rather than heroics. Agencies that are settling into HOPE most effectively are building repeatable systems that support clinicians, data integrity, and leadership oversight—rather than relying on individual workarounds.

At a practical level, that means designating a clear HOPE lead; training RNs to conduct structured HOPE interviews and complete timely symptom follow-up when moderate or severe impact is identified; and building visit templates aligned to the day 6–15 and day 16–30 update windows. On the technical side, it includes validating HOPE item sets in the electronic health record (EHR), testing iQIES submission sequencing, and monitoring timeliness and edit trends before they escalate into compliance risk.

In parallel, hospice leaders are also navigating changes to the Consumer Assessment of Healthcare Providers and Systems (CAHPS) Hospice Survey, including the revised instrument and web-mail administration mode that applies to April 2025 decedents and later. Coordinating with vendors, refreshing staff scripts, and reinforcing family education are important steps to sustain response rates and experience scores during this transition.

What we’re seeing across the country is that none of these steps are particularly complex on their own—but aligning them across clinical, quality, IT, and leadership teams takes time, focus, and shared interpretation of CMS guidance. Many agencies find value in stepping back periodically to sanity-check workflows, validate assumptions, and ensure early patterns don’t harden into long-term risk.

Call to Action: A Simple Check on How You’re Doing

As HOPE data accumulates and expectations sharpen, a useful question for hospice leaders is not “Are we compliant?” but rather “How consistently are our systems working?”

A brief, structured review—grounded in your own recent data—can help identify where processes are stabilizing and where small adjustments now could prevent bigger issues later. For some organizations, that review happens internally; for others, an external perspective helps surface blind spots and accelerate progress without disrupting operations.

Quick Self-Check: How Is HOPE Working for You?

Based on your most recent quarter of HOPE data, consider:

• Are symptom follow-up visits occurring predictably, or still requiring manual intervention?
• Are HOPE update visits (days 6–15 and 16–30) built into workflows, or dependent on individual vigilance?
• Do iQIES submission issues feel rare and manageable, or recurring and time-consuming?
• Can leadership clearly explain where HOPE performance is trending—and why?

If the answers feel mixed, that’s common at this stage. Early HOPE experience often reveals a blend of solid progress and lingering friction. A focused review can help distinguish normal growing pains from true process gaps—before small issues become harder to unwind.

For hospice leaders who would find it helpful, we offer a complimentary 30-minute question-and-answer session to talk through HOPE workflows, submission patterns, and early performance trends. It’s a working conversation, grounded in your recent experience, not a formal assessment.

Participants receive an Executive HOPE Operational Checklist to support ongoing internal review and leadership discussion. Many teams use it as a quarterly touchpoint as they move from early implementation toward long-term stability.

Whether the outcome is reassurance, clarification, or a few targeted next steps, the goal is the same: helping hospice leaders move forward with confidence.

Sources

• CMS HOPE Overview & Guidance (timepoints; objectives; iQIES): https://www.cms.gov/medicare/quality/hospice/hope

• CMS HOPE Implementation FAQs (HIS→HOPE; timelines; sequences): https://www.cms.gov/files/document/hope-implementation-faqs.pdf

• SHP/SimiTree HOPE timepoints & SFV requirements: https://shpdata.com/media/2831/frequently-asked-questions-his-to-hope-transition.pdf; https://simitreehc.com/simitree-blog/hope-tool-implementation-webinar-recap/

• SimpleLTC HOPE iQIES submission & sequence notes: https://www.simpleltc.com/wp-content/uploads/2025/02/HOPE-Frequently-Asked-Questions-V.1-Updated-Feb-17-2025.pdf