CMS Compliance
HOPE replaced HIS on October 1, 2025. Here's what your agency needs to do.
6 min read
Audit Defense
February 2026 · 7 min read
The envelope arrives on a Tuesday. Inside: a list of patient record numbers, claim periods, and a formal request for documentation. You have 45 days from the date on the letter to respond. That's when the clock started — not the day it arrives, not the day your biller opens it.
An Additional Development Request is not a denial. It's your MAC asking you to prove the claim. Most ADRs are survivable — if you respond correctly, completely, and on time. The agencies that lose ADR cases usually lose them because of how they responded, not because the patient didn't qualify.
Miss the deadline and you receive an automatic denial. The medical records you would have submitted become irrelevant. The patient's clinical picture becomes irrelevant. You return the payment.
The day an ADR arrives, it gets a hard due date on the calendar — 45 days from the letter date, not the received date. One person owns the response. That person escalates if the record is hard to pull or the documentation has gaps that need to be addressed.
The ADR will specify which claims are under review. Submit the complete medical record for those benefit periods: the initial certification and all recertifications, physician orders, plan of care, all visit notes from the period (every discipline, not just nursing), IDG meeting notes, lab results and diagnostic reports if referenced in the clinical record, hospital discharge summaries for any hospitalizations during the period, and medication reconciliation records.
Do not submit irrelevant records — records from outside the period, from unrelated conditions, or from prior agencies. A bloated submission that buries the relevant documentation is harder to review in your favor than a clean, organized one. But an incomplete submission is worse than a complete one with unfavorable content. Don't leave things out because they're uncomfortable.
ADR reviewers are clinical, and they're looking for specific things. They check whether the PPS scores in the record support a terminal prognosis (PPS 70 or above is a red flag). They look for documented functional decline across the benefit period — if the record shows identical clinical status at every visit, it reads as copy-paste, not genuine assessment. They verify that the face-to-face was completed on time for benefit period 3 and beyond. They check whether any documentation contradicts the prognosis.
The most common reasons claims are denied on ADR: PPS doesn't support terminal prognosis; no documented decline between visits; copy-forward narrative language on recertification; missing face-to-face; a nurse documented that the patient was "doing well" or "improving" with no clinical context explaining the good day.
This is the part that frustrates DONs most, because it's true and there's nothing to do about it after the fact: the quality of your ADR response is entirely determined by the quality of documentation that existed before the request arrived.
If your nurses are documenting specific measurements at every visit — PPS with the domains that support it, weight with the trend over time, SpO2 on room air, FAST substage with observed verbal output, ADL status by name — that record is defensible. If your charts say "patient continues to decline per plan of care" at every visit, no amount of work during the 45-day window fixes it.
The ADR is the test. The studying happened at the bedside.
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