Home Health & Hospice Week

After years of more testing and tweaks, CMS is finally ready to implement the tool, it says in the 2025 hospice proposed rule released on March 28. “We propose to begin collecting the HOPE standardized patient level data collection tool on or after October 1, 2025,” the rule says.

The HOPE tool differs from the current Hospice Item Set data collection, pointed out CMS’ Jermama Keys in the agency’s April 5 Open Door Forum for home health and hospice providers. HOPE includes “expanded domains” compared to HIS, including sociodemographic items such as living arrangements and available assistance; diagnoses; and a Symptom Impact Assessment, Keys noted.

“Unlike the HIS, the HOPE tool will serve as a more comprehensive clinical assessment tool,” judges Melinda Gaboury with Healthcare Provider Solutions in Nashville, Tenn.

All payers: “HOPE v1.0 would contain demographic, record processing, and patient-level standardized data elements that would be collected by all Medicare-certified hospices for all patients over the age of 18, regardless of payer source, to support HQRP quality measures,” the rule specifies.

Hospice would collect HOPE data at three time points: admission, the hospice update visit (HUV), and discharge, the rule proposes. “The timepoint for the HOPE Update Visits (HUV), which is dependent on the patient’s length of stay (LOS), is limited to a subset of HOPE items addressing clinical issues important to the care of hospice patients as updates to the hospice plan of care,” CMS adds.

Give Your 2 Cents: Specifically, CMS wants feedback on certain Social Determinants of Health related to the HOPE tool. “This proposed rule requests stakeholder input on potential data collection items related to four SDOHs (housing instability, food insecurity, utility, and transportation challenges) that may be relevant to the hospice setting and how they may need to be adapted to be better suited for the hospice setting,” the agency notes in the rule fact sheet.

As usual, providers are skeptical about the seemingly short timeline for implementation less than six months from now, and likely under three months from the final rule’s publication.

CMS seems to try to preempt those criticisms. “CMS is committed to ensuring hospices are ready for the proposed data collection beginning on or after October 1, 2025,” the agency says in the rule. And “the draft HOPE Guidance Manual v1.0 is available on the HQRP HOPE webpage for review and the final HOPE Guidance Manual v1.0 will be available after the publication of the final rule,” the rule says.

Wait a second: “I’ve noticed a few inconsistencies between the rule itself and the HOPE tool manual,” said one provider in the April 5 forum’s question-and-answer segment. “Will there be a forum where we can ask … questions in the future?”

CMS will be furnishing forums and training, but only after the final rule, Keys indicated in response to the questions.

Keep in mind: Like OASIS in home health, the HOPE tool might eventually lead to a case-mix based payment model, industry veterans caution.

For now, HOPE data will be used for Hospice Quality Reporting Program purposes, including two new HQRP quality measures: Timely Reassessment of Pain Impact and Timely Reassessment of Non-Pain Symptom Impact, CMS proposes. CMS expects those process measures to become effective in fiscal year 2028.

‘Transformative Change’ Awaits You

Hospices should not underestimate the importance of the HOPE tool, industry experts stress.

“The HOPE Assessment Tool represents a dramatic shift in how hospice care quality is measured and reported,” National Hospice & Palliative Care Organization Interim CEO Ben Marcantonio says in a release. “We will continue working with CMS to ensure that this new tool will serve to enhance, not hinder, the delivery of compassionate, person-centered hospice care,” Marcantonio pledges.

“The adoption of the Hospice Outcomes & Patient Evaluation (HOPE) tool heralds a transformative change in data collection practices,” stresses Lexington, Ky.-based BC Healthcare Consulting in online analysis of the rule. “Hospice providers need to prepare for this transition,” the firm advises.

“This proposed rule for hospice holds immense significance,” underscores Gaboury says in her Monday Minute with Melinda vlog.

The release of the draft HOPE tool and accompanying guidance manual “is already generating great interest,” observes Katie Wehri with the National Association for Home Care & Hospice in a release.

“This proposal represents a major shift in the hospice quality landscape,” Smith Sloan observes.

Note: Links to HOPE documents are in the “Downloads” section at www.cms.gov/medicare/quality/hospice/hope.