If your hospice agency is Medicare-certified, 2025 is a year of major change. As of October 1, 2025, the Hospice Outcomes & Patient Evaluation (HOPE) system officially replaces the long-standing Hospice Item Set (HIS).
That means new record types, new systems for data submission, and new timelines for compliance under the Hospice Quality Reporting Program (HQRP).
*This article was written in consultation with Mariam Treystman.
At The Home Health Consultant, we work closely with hospice agencies navigating CMS transitions like HOPE implementation, HQRP audits, and survey readiness. We understand how tight timelines, changing systems, and evolving requirements can affect compliance and payment.
This guide breaks down exactly what HOPE requires, and when, so your team has the information they need to stay on track.
What’s Changing for Hospice Agencies Under HOPE, and What Will Continue to Use HIS?
The HOPE system replaced the HIS as the primary quality reporting tool for all Medicare-certified hospices starting October 1, 2025.
For patients admitted on or after that date, agencies will collect and submit four HOPE assessments through iQIES:
- HOPE Admission (ADM)
- HOPE Update Visit 1 (HUV1)
- HOPE Update Visit 2 (HUV2)
- HOPE Discharge (DC)
When moderate or severe symptoms are identified during an assessment, agencies must also complete a Symptom Follow-Up Visit (SFV) within two calendar days. *Important Note: SFVs are documented within the related HOPE record, not submitted separately.
For patients admitted and discharged before October 1, 2025, agencies will continue submitting HIS Admission and Discharge records through QIES until the system closes on February 15, 2026.
For cross-over patients (admitted before and discharged after October 1, 2025):
- Submit the HIS Admission to QIES, and
- Submit the HOPE Discharge to iQIES.
- HUVs are not required for cross-over cases.
Where Are HOPE Records Submitted?
- HOPE → iQIES only. HIS records cannot be submitted in iQIES.
- HIS → QIES only. HOPE records cannot be submitted in QIES.
This one-time overlap period ensures agencies can finish any remaining HIS work while adopting HOPE.
What Are the Required HOPE Assessments and When Are They Due?
The HOPE system introduces four structured assessments that occur throughout a patient’s stay.
Each assessment has specific timing and must be submitted within 30 calendar days of completion.
Remember, the number of HOPE Update Visits (HUVs) required depends on the patient’s length of stay:
- HUV1 is required if the patient remains on service through Days 6–15
- HUV2 is required if still on service through Days 16–30
What Are HOPE Update Visits (HUVs)?
HUVs (HOPE Update Visits) are new structured nursing visits that replace the single “mid-episode reassessment” model of HIS.
They ensure that each patient’s plan of care is reviewed and updated twice during the first 30 days of service.
Each HUV focuses on:
- Changes in symptoms
- Medication effectiveness
- Caregiver needs
- Plan-of-care updates
Documentation requirements:
- Must be completed within their designated day ranges
- HUV1: Days 6–15
- HUV2: Days 16–30
- Must be submitted through iQIES within 30 days.
- Late submissions are accepted but may affect HQRP timeliness scores.
- *Only registered nurses (RNs) may complete HUVs. LPNs/LVNs may not perform them.
If HUV2 is submitted before HUV1, iQIES issues a warning but still accepts both records.
What Is a Symptom Follow-Up Visit (SFV)?
A Symptom Follow-Up Visit (SFV) is triggered when a patient reports moderate or severe pain or non-pain symptoms during a HOPE assessment.
- When it happens: Within 2 calendar days of the triggering assessment (Admission or HUV).
- Where it happens: SFVs must be performed in-person and on-site.
- Who performs it: RN or LPN/LVN.
- How it’s documented: The SFV data is entered within the triggering HOPE record (not submitted separately).
- *IMPORTANT NOTE: The SFV visit cannot be combined with Admission or HUV assessments. Even though the SFV documentation is submitted with Admission or HUVs, the SFV visit must be separate.
- Purpose: To confirm whether interventions reduced the symptom and to demonstrate timely follow-up.
CMS has noted it will monitor the operational burden of SFVs and may revise requirements after initial implementation.
What Are the Submission Timelines and Timeliness Requirements?
There is a critical piece of information when it comes to understanding the HOPE submission timeframes:
"In counting days for the HOPE timepoints, the date of the hospice election would be considered Day 0."
Generally, hospices must meet the same HQRP timeliness threshold used under HIS:
- All HOPE assessments (Admission, HUV1, HUV2, Discharge) must be submitted within 30 days of their assessment date.
- At least 90% of all records must be submitted on time to avoid the 4% Annual Payment Update (APU) reduction.
- Late assessments should still be submitted; iQIES will accept them with a timeliness warning.
How Do HOPE Timelines Compare to HIS?
How Can Hospice Agencies Prepare for the Transition?
To stay compliant and avoid disruptions in data submission:
- Update internal policies to reflect HOPE assessment schedules and submission windows.
- Train staff, especially RNs, on new visit types (HUV1, HUV2, SFV).
- Ensure your EMR or third-party vendor software can generate and submit HOPE XML files to iQIES. The CMS HART tool will sunset with HIS.
- Coordinate with your EMR vendor to ensure HOPE compatibility before October 2025.
- Run mock data entry and submission exercises to identify workflow bottlenecks.
- Keep documentation current. The same mantra we’ve always used still applies: “If wasn’t documented, it wasn’t done.”
For a more in-depth look at what’s changing with HOPE, find the official CMS HOPE Implementation FAQs here.
For more guidance on strengthening your hospice operations, check out another area hospice professionals seek clarity on: Hospice Volunteer Requirements.
*Disclaimer: The content provided in this article is not intended to be, nor should it be construed as, legal, financial, or professional advice. No consultant-client relationship is established by engaging with this content. You should seek the advice of a qualified attorney, financial advisor, or other professional regarding any legal or business matters. The consultant assumes no liability for any actions taken based on the information provided.
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