The U.S. Centers for Medicare & Medicaid Services (CMS) should delay implementation of the Hospice Outcomes and Patient Evaluation (HOPE) tool, according to three national hospice and palliative care industry groups.

LeadingAge, the National Alliance for Care at Home and the National Partnership for Healthcare and Hospice Innovation (NPHI) urged CMS to delay the transition to the new quality measurement system in a letter to Administrator Dr. Mehmet Oz on Tuesday.

“Our associations remain fully committed to the [Hospice Quality Reporting Program (HQRP)], including the payment penalties for non-compliance, and recognize the critical importance of accurate, timely data submission to inform the delivery of high-quality hospice care,” the organizations stated in the letter. “However, we have serious concerns about the potential for successful implementation of the HOPE tool.”

Among those concerns is the need for vendors to develop tools for submitting data through CMS’ new reporting platform, dubbed iQIES. To date, vendors say they lack necessary information to complete that work, the organizations indicated in the letter.

LeadingAge, the Alliance and NPHI have asked CMS to hold off on implementation until at least six months after CMS education, training and final validation specifications are available and the application for iQIES access has been opened for hospices. The HOPE tool is currently set to become effective in October, when Fiscal Year 2026 begins.

“The transition from the current quality reporting tool, the Hospice Item Set (HIS), to the HOPE tool is technically complex and represents a distinct change in the timing and content of the documentation of the care delivered to hospice patients; moreover, it carries significant financial risk for hospice providers,” the groups said in the letter. “The Hospice Quality Reporting Program (HQRP) is a ‘pay-for-reporting’ program, which requires hospices to submit a high percentage (90%) of data records within a specified timeframe or receive an annual payment update penalty of 4%.”

The organizations pointed to the need for vendors to use a Validation Utility Tool to ensure their software can successfully submit data. Thus far, this tool is not yet available and might not be released until September, about 30 days before implementation.

The transition to the iQIES platform, which the organizations support, will likewise be complex for hospices, who have received little guidance and no specific deadlines for moving to the new system. This, according to LeadingAge, the Alliance and NPHI, will not allow for smooth transition. 

Hospices will have to take numerous steps to enroll in iQIES, including the need for a privacy security official and other staff, an application to access the system, background checks and other actions. CMS has not yet indicated when hospices will be able to begin this process, which could involve significant financial costs. 

“Our recommendation [of a delay] reflects our shared goal to ensure hospices are appropriately prepared to meet this important requirement and facilitate a successful transition without jeopardizing the timely delivery and accurate documentation of patient care,” the organizations said in the letter.