The HOPE Tool and Hospice Quality Reporting: One Year In, One in Five Hospices Is Still Non-Compliant
Key Takeaways
HOPE replaced the Hospice Item Set on October 1, 2025. For patients admitted on or after that date, only HOPE records are accepted. QIES stopped accepting HIS records and corrections after February 15, 2026.
HQRP non-compliance triggers a 4-percentage-point reduction to the annual payment update, in effect since FY 2024.
CMS-reported non-compliance rates: FY 2024 — 22.06%; FY 2025 — 23.53%; FY 2026 — 20.37%. CMS notes the persistent gap limits its ability to measure hospice quality at all.
The FY 2027 payment update is 2.3% (+$755 million) — final, and below the 2.4% CMS proposed in April 2026. Non-compliant hospices receive -1.7%.
The FY 2027 aggregate cap is $36,174.75 (final), not the $36,210.11 figure in the proposed rule.
Hospices must hit a 90% or higher timely submission rate. Every HOPE record type — Admission, HUV, Discharge — must reach iQIES within 30 days.
Two HOPE-based quality measures are finalized: Timely Follow-up for Pain Impact and Timely Follow-up for Non-Pain Symptom Impact. Public reporting comes no earlier than FY 2028; CMS expects November 2027.
The Care Compare icon flagging quality-reporting failures was finalized in CMS-1851-F, effective no earlier than FY 2028.
CY 2026 HOPE data — the year in progress right now — drives the FY 2028 APU determination.
What HOPE Is and Why the Workflow Changed
The Hospice Outcomes and Patient Evaluation instrument replaced HIS on October 1, 2025. The structural difference matters more than the item list. HIS was an abstraction tool completed from the chart. HOPE requires assessments at defined points during the stay, including in-person update visits performed inside CMS-defined windows.
Assessment time points
Time point | When | Who | Source |
|---|---|---|---|
HOPE Admission | No later than 5 calendar days after the hospice election effective date | Comprehensive assessment | CMS HOPE Implementation FAQs |
HOPE Update Visit 1 (HUV1) | Days 6-15 (election date = Day 0) | RN only | CMS HOPE Implementation FAQs |
HOPE Update Visit 2 (HUV2) | Days 16-30 | Clinical staff | CMS HOPE Implementation FAQs |
HOPE Discharge | At discharge or death | Clinical staff | CMS HOPE Implementation FAQs |
The Symptom Follow-Up Visit is the item that breaks schedules
When item J2051 codes symptom impact as moderate or severe at Admission or at a HUV, HOPE requires a Symptom Follow-Up Visit within 2 calendar days. It must be an in-person visit, it must be a separate visit from the one that triggered it, telehealth is not permitted, and it may be performed by an RN or an LPN/LVN. It is submitted as part of the triggering record.
That is a two-day clock on an unplanned visit, triggered by a clinical finding the team cannot predict when it builds the week's schedule. Interdisciplinary teams that staffed around HIS abstraction are now staffing around mandatory, deadline-bound field visits. The operational cost of HOPE sits here, not in the item set.
Submission mechanics
Requirement | Value | Source |
|---|---|---|
Submission system | iQIES | CMS HQRP |
Admission record deadline | 30 days from admission date (A0220) | CMS HOPE Implementation FAQs |
HUV record deadline | 30 days from HUV completion date (Z0350) | CMS HOPE Implementation FAQs |
Discharge record deadline | 30 days from discharge date (A0270) | CMS HOPE Implementation FAQs |
Timely submission threshold | 90% or higher | FY 2027 final rule |
Penalty for non-compliance | -4 percentage points to APU | FY 2027 final rule fact sheet |
Current guidance manual | HOPE Guidance Manual v1.02, effective October 1, 2025 | CMS |
A late HUV is still accepted in iQIES and does not by itself break compliance. The 30-day submission window is what compliance is measured on. That distinction is worth teaching to clinical managers, because the instinct to abandon a late visit rather than complete it is exactly backwards.
The Money: What Four Percentage Points Costs
The APU penalty is not a fine. It is a rate reduction applied to every day of care for a full fiscal year.
Annual Medicare hospice revenue | FY 2027 at +2.3% | FY 2027 at -1.7% | Swing |
|---|---|---|---|
$2,000,000 | $2,046,000 | $1,966,000 | $80,000 |
$6,000,000 | $6,138,000 | $5,898,000 | $240,000 |
$15,000,000 | $15,345,000 | $14,745,000 | $600,000 |
Illustrative. Applies the FY 2027 update and the statutory 4-point reduction to a flat revenue base; actual results vary with case mix, wage index, and cap position.
The cause is almost never a refusal to report. It is a 30-day deadline missed on a handful of records during a staffing crunch, discovered eleven months later in an iQIES folder nobody owns.
One-fifth of the field, three years running
Fiscal year | Hospices non-compliant with HQRP | Source |
|---|---|---|
FY 2024 | 22.06% | CMS FY 2027 final rule fact sheet |
FY 2025 | 23.53% | CMS FY 2027 final rule fact sheet |
FY 2026 | 20.37% | CMS FY 2027 final rule fact sheet |
CMS's own language is that "the consistent lack of data for approximately one-fifth of hospices limits CMS' ability to accurately measure the quality of care." Read that as a signal about where oversight attention goes next. A metric CMS cannot measure is a metric CMS eventually forces.
What the FY 2027 Final Rule Actually Settled
CMS-1851-F was issued July 30, 2026, published in the Federal Register August 3, 2026 (91 FR 49118), and took effect October 1, 2026. Several numbers moved between proposal and final, and the proposed figures are still circulating.
Item | Proposed (April 2026) | Final (July 30, 2026) |
|---|---|---|
Payment update | 2.4% (+$785 million) | 2.3% (+$755 million) |
Market basket | 3.2% | 3.2% |
Productivity adjustment | -0.8 pt | -0.9 pt |
Non-compliant hospice rate | -1.6% | -1.7% |
FY 2027 aggregate cap | $36,210.11 | $36,174.75 |
Election statement addendum | Proposed mandatory | Finalized mandatory |
Care Compare icon | Proposed, no earlier than FY 2028 | Finalized, no earlier than FY 2028 |
If a budget, a cap projection, or a board deck in your files still carries $36,210.11, it is running on the proposal. The final cap is $36,174.75, derived from the FY 2026 cap of $35,361.44 increased by 2.3%.
The Care Compare icon is a referral issue, not a compliance issue
The icon flags hospices that miss quality reporting, and it will not appear before FY 2028. That lead time is the useful part. Hospital discharge planners and families comparing hospices read symbols before they read scores. Quality reporting has moved out of the compliance department and into business development, and hospices have roughly a year to clean up reporting before the marker goes public.
What the SSVI did and did not do
The FY 2027 final rule updated the Service and Spending Variation Index with more recent claims data but made no substantive methodology changes, and CMS did not tie SSVI scores to payment. It remains a transparency and targeting tool: a 0-16 composite built from nine claims-based measures, combining a non-hospice spending score (0-8) and a utilization score (0-8). Higher is more concerning. The FY 2025 SSVI covered 6,673 hospices, 6,773,919 claims, and 156,995,825 hospice days; FY 2024 covered 6,735 hospices.
The Two New Measures and the Data Year You Are In
CMS finalized two HOPE-based quality measures: Timely Follow-up for Pain Impact and Timely Follow-up for Non-Pain Symptom Impact. Both are built directly on the Symptom Follow-Up Visit workflow described above — the measure is, in effect, whether you made the two-day visit.
Milestone | Date | Source |
|---|---|---|
HOPE data collection began | October 1, 2025 | CMS HOPE page |
QIES stopped accepting HIS records | February 15, 2026 | CMS HOPE Implementation FAQs |
First full HOPE data year | CY 2026 | CMS HOPE Implementation FAQs |
APU driven by CY 2026 HOPE data | FY 2028 | CMS HOPE Implementation FAQs |
Public reporting of HOPE measures | No earlier than FY 2028; CMS expects November 2027 | FY 2027 final rule |
One transitional detail is worth knowing if you are reviewing an FY 2027 compliance determination: CMS granted a waiver treating all HOPE records with a 2025 target date as timely. That grace does not extend into CY 2026. The year being measured right now carries no cushion.
The Controls That Prevent All of This
A monthly discipline closes the loop that a year-long feedback delay destroys.
Control | Frequency | Owner |
|---|---|---|
Check the iQIES My Reports folder | Monthly | Compliance lead |
Run the timely-submission rate against the 90% threshold | Monthly | QA |
Reconcile HOPE records completed vs. submitted | Weekly | Clinical manager |
Audit J2051 moderate/severe codes against SFV completion within 2 days | Weekly | Clinical manager |
Download and archive preview reports on release | Each cycle | Compliance lead |
Any hospice can run these. They go undone because nobody owns the iQIES inbox and the penalty arrives a year after the miss. Clean hospice bookkeeping will not submit your records, but it will show you a rate variance the month it starts instead of the year after — and it is where a four-point APU exposure gets modeled against real revenue rather than treated as an abstraction.
What to Do This Quarter
Pull your timely-submission rate for the current reporting period and compare it to 90%. If you are below, you have months rather than days to fix it — but only if you look now. Assign the iQIES My Reports folder to a named person with a calendar reminder. Reconcile every moderate or severe J2051 code against a documented follow-up visit inside two days. And correct any cap projection still carrying $36,210.11.
If you want help tying HQRP exposure to your cost report and cap position, schedule a free consultation.
Sources
CMS, Hospice Outcomes & Patient Evaluation (HOPE) — https://www.cms.gov/medicare/quality/hospice/hope
CMS, HOPE Implementation FAQs — timepoints, submission deadlines, SFV requirements, measure names — https://www.cms.gov/files/document/hope-implementation-faqs.pdf
CMS, HOPE Guidance Manual v1.02, effective October 1, 2025 — https://www.cms.gov/files/document/hope-guidance-manual-v1-02.pdf
CMS, FY 2027 Hospice Wage Index and Payment Rate Update and HQRP Requirements Final Rule Fact Sheet (CMS-1851-F), July 30, 2026 — https://www.cms.gov/newsroom/fact-sheets/fiscal-year-2027-hospice-wage-index-payment-rate-update-hospice-quality-reporting-program
Federal Register, FY 2027 Hospice Wage Index final rule, 91 FR 49118, August 3, 2026 — https://www.govinfo.gov/content/pkg/FR-2026-08-03/html/2026-15686.htm
CMS, FY 2027 Hospice Wage Index proposed rule fact sheet, April 2, 2026 — https://www.cms.gov/newsroom/fact-sheets/fiscal-year-fy-2027-hospice-wage-index-payment-rate-update-hospice-quality-reporting-program
CMS, FY 2027 Final Service and Spending Variation Index Overview — https://www.cms.gov/files/document/fy-2027-final-ssvi-overview.pdf
CMS, FY 2026 Hospice Wage Index Final Rule Fact Sheet — FY 2026 cap $35,361.44 — https://www.cms.gov/newsroom/fact-sheets/fy-2026-hospice-wage-index-payment-rate-update-hospice-quality-reporting-program-requirements-final
CMS, Hospice Quality Reporting Program — https://www.cms.gov/medicare/quality/hospice
Last updated: September 2026.
Soriaga & Associates, LLC is a CPA firm specializing in hospice and home health accounting, including Medicare cost report filing.
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