Hospice providers and technology vendors are not ready to transition to the Hospice Outcomes and Patient Evaluation (HOPE) tool by its Oct. 1 implementation date, according to comments on the 2026 proposed hospice payment rule by the National Alliance for Care at Home.

The Alliance in its comments recommended that the U.S. Centers for Medicare & Medicaid Services (CMS) to hold off on implementation until at least six months after the agency’s education, training and final validation specifications are available and the application for access to the iQIES reporting system has been opened for hospices.

“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 Alliance indicated in its comments. “Providers and technology vendors have shared that there is a lack of information and clarity necessary to have a smooth, successful transition to the HOPE tool and to the new platform, iQIES, required for submission of HOPE records.”

The tool will replace the HIS quality reporting system. In contrast to the HIS system, which extracts item set data from a patient’s medical record using a standardized mechanism, the HOPE tool will measure aspects of hospice care at different points in the patient’s experience.

For example, among the processes involved in the tool are Symptom Reassessment Visits (SRA). The SRA is an in-person visit expected within two calendar days as a follow-up for any pain or non-pain symptom impact rated as moderate or severe, according to CMS. As many as three of these visits may be necessary during a patient’s time in hospice.

“HOPE will provide assessment-based quality data to enhance the [Hospice Quality Reporting Program] through standardized data collection, provide a better understanding of patient care needs, contribute to the patient’s plan of care and provide additional clinical data that could inform future payment refinements,” CMS stated in the proposed rule.

Among the Alliance’s 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 organization indicated in its comments.

CMS in April 22 made available to vendors details for data specifications necessary to transition to HOPE. Other pieces of key information will not be available until September, CMS has indicated. This will be insufficient time to prepare for the transition or test new systems, according to the Alliance.

Also, a Validation Utility Tool (VUT) is not yet available. This is an essential tool used by vendors to ensure their software can successfully submit HOPE data. This too may not be available until September.

“Providers and vendors cannot be reasonably expected to prepare for this workflow change with only one month of lead time,” the Alliance said in its comments. “Without sufficient time for testing to occur, we do not believe this will lead to a successful launch.”