Compliance Strategies for Forthcoming Hospice HOPE Tool

Hospices will have a learning curve when it comes to implementing the Hospice Outcomes and Patient Evaluation Tool (HOPE) tool.

The U.S. Centers for Medicare & Medicaid Services (CMS) is currently developing quality measures that will be included in the HOPE tool, which will replace the current Hospice Item Set (HIS). After years of development, the agency in its recent hospice proposed rule indicated that the HOPE tool’s implementation would begin in 2025.

Staff training will be an important compliance component as a new set of hospice quality measures inches closer, according to Jennifer Kennedy, vice president for quality, standards and compliance, at Community Health Accreditation Partner (CHAP). Hospices can lay the groundwork now for what lies ahead in compliance, starting with staff communication and education on the key drivers behind HOPE’s development, Kennedy said at the National Hospice and Palliative Care Organization’s (NHPCO) Virtual Interdisciplinary Conference.


“Now we are at this block of rulemaking [and] soon it’s going to be in its implementation period,” Kennedy said during the conference. “There will need to be a good deal of training that will need to occur for hospice providers. The concepts that are behind the development of the [HOPE] tool are to help hospice providers understand care needs of their patients through the dying process, and ensuring that safety and comfort is a primary focus and target for patients enrolled in hospice nationwide.”

CMS has thus far given clues as to HOPE’s dual objectives — providing data for the Hospice Quality Reporting Program through standardized data collection and providing clinical data that may inform potential future changes to Medicare hospice payments.

Hospices can anticipate changes in the way that patient data are submitted, Kennedy indicated. For instance, the HOPE tool will have a more broad, comprehensive and robust approach to capturing the patient and family needs in “real-time,” compared to the points of admission and discharge under the current HIS set, she stated.


A main goal of the changes is to paint a broader picture of the overall hospice experience and ensure patients and families have improved quality outcomes, Kennedy stated.

“Patients and families will be able to be more informed about not only what hospice care is and that journey through hospice, but they’ll also be more able to make decisions based on the outcomes of this type of standardized assessment in care,” Kennedy said.

Timely assessment and reassessment of pain will be among the important HOPE tool quality measures, Kennedy said. Hospices can anticipate standardized data collection requirements that capture the overall percentage of patients’ pain symptoms throughout their length of stay. Ongoing and timely reassessment of non-pain symptoms such as shortness of breath, anxiety, nausea and vomiting will also be key, she stated.

New data collection requirements could lead to longer assessment periods than hospices currently have built into their operational and clinical workflows, Kennedy indicated. To date, CMS has not specified timeframes around HOPE’s potential new patient assessments or data submission requirements.

Patient assessments could also hone focus on safety risks, examining hospitalizations and emergency department visits among hospice patients and narrowing items that address relatedness and unrelatedness of services to a terminal condition, according to Kennedy. Quality measures that standardize assessment of physical, psychosocial, emotional, spiritual and social determinants of health needs may also take shape, she added.

Preparing for the HOPE tool will take careful consideration of a hospice’s current quality metrics, according to Kimberly Skehan, vice president for accreditation at CHAP.

Examining pain points around lengths of stay, timely admission and pain and symptom management can help hospices identify potential areas with room for improvement, Skehan said. Ensuring clinicians have strong documentation and comprehensive assessment and communication skills is another key, she stated.

“You want to look now at how efficient, effective and accurate your current comprehensive process is,” Skehan said at the conference. “How often do you self-assess your current process to identify gaps in practice and performance? Do you hold staff accountable for documentation content, quality and timeliness? You really want to look at what your current processes are, and what your current accuracy and thoroughness is for documentation.”

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