HOPE has been live long enough that most hospices have stopped treating it as a project and started treating it as routine. That is usually the point at which the first year of accumulated workarounds becomes invisible. An audit now is well timed, and CMS has just given a reason to do one.
Start with the newest guidance, not the binder from launch
CMS posted HOPE Guidance Manual and item set version 1.03 on October 6, 2026, describing the changes as clarifications based on Help Desk questions and first-year implementation experience. CMS also noted that none of these changes affect the current HOPE Data Specifications. That combination matters for how you scope the work: the clarifications can change how staff should code or time something without requiring a vendor rebuild. If training materials, job aids or vendor build notes still reference an older version, identify specifically what changed and who needs to be told. A manual sitting at v1.01 in a shared drive is the quiet source of a surprising number of findings.
Audit timing and ownership
Pull a sample that spans admissions, HOPE Update Visits and discharges rather than whichever records are easiest to retrieve. For each record ask four things: who owned completion, whether the assessment happened inside the required window, whether the record was submitted and accepted, and how any rejected or warning edits were resolved. The ownership question is the one that predicts future failures. A process is not reliable if one capable person has to rescue every exception, because that process fails the week they are on leave.
Compare the clinical record with the HOPE record
Look for places where the assessment, the plan of care and the HOPE coding tell different stories about the same patient. The goal is not to make documentation match artificially. It is to find the unclear workflows, training gaps and data-entry habits that produce the divergence, because those are what weaken quality reporting over time.
Review iQIES reports rather than assuming upload equals compliance
A successful submission is not the same as an accepted, timely, complete one, and the gap between those two states is where compliance quietly erodes. CMS continues to encourage hospices to review quality and timeliness reports early. Build report review into a monthly cadence with named owners and documented follow-up, so that a problem surfaces in week three rather than at the end of a reporting period.
Turn findings into QAPI
Group errors by cause rather than by frequency: knowledge, timing, technology, handoff, staffing or documentation. The cause determines the intervention, and counting errors does not. Pick the high-risk patterns, test corrective actions and re-sample afterward. The audit should end with evidence that the system changed, not with a training attendance sheet.
Remember the financial consequence
HQRP is a pay-for-reporting programme. Hospices that do not meet reporting requirements face a 4-percentage-point reduction to their annual payment update for the applicable fiscal year. That figure is why HOPE reliability belongs on the leadership dashboard rather than only in the quality department. A reporting failure is a revenue event with a long lag, which makes it exactly the kind of risk that is easy to under-prioritise until it lands. Compliance note: CMS guidance changes. Validate all dates, item sets, submission requirements and interpretations against current CMS materials before publishing or implementing changes.
Sources used for fact-checking
- https://www.cms.gov/medicare/quality-initiatives-patient-assessment-instruments/hospice-quality-reporting/spotlight.html
- https://www.cms.gov/medicare/quality/hospice/hqrp-requirements-and-best-practices
- https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-B/part-418/subpart-G/section-418.312
- https://pfundamental.com/hospice-consulting-service/