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CMS Compliance

HOPE replaced HIS on October 1, 2025. Here's what your agency needs to do.

June 2026 · 6 min read

If you're running your agency's HQRP compliance data, you've already seen the HOPE submission rate on your dashboard. If you're not — and most DONs aren't yet — you may have no idea whether your rate is at 94% or sitting at 71% with a penalty building.

That's the thing about HOPE. The consequence doesn't arrive as a denied claim. It arrives as a line item in your Annual Payment Update — 4 percentage points off the base rate. For a mid-size agency carrying 80–100 patients, that's somewhere between $80,000 and $200,000. Per year. And it compounds if you don't catch it and fix it before the next reporting period.

The four windows — and why they're harder than they look

HOPE has four assessment types. Admission (A1), two updates (HUV1 and HUV2), and discharge (D1). Each has a specific window that does not flex:

The A1 must be completed within 2 days of admission. Not "during the first week" — 2 days. The HUV1 opens on day 6 and closes on day 15. If your patient is still on service on day 6, the window is open. Miss day 15 and it's gone. The HUV2 is days 16–30. The D1 has to be completed within 2 days of discharge or death.

The window that causes the most missed submissions is HUV1 for patients admitted in clinical crisis. You're managing the acute situation, you're short-staffed, and somewhere around day 12 the window closes without anyone noticing. That one missed submission isn't catastrophic on its own. Multiply it across a quarter and your rate drops.

"Completed" and "submitted" are not the same event

Your documentation system may mark a HOPE assessment as complete. That's not the same as it being transmitted to iQIES. They're two separate events, and CMS only counts what it receives.

Ask your software vendor or EMR directly: "Is our HOPE data being transmitted to iQIES, and can I see the transmission confirmation log?" If you get a vague answer, that's your next problem to solve before the next compliance period.

What to do this week

Pull your current HOPE submission report. Check your rate against the 90% threshold. If you're below it, look at which windows you're missing most — it's almost always A1 or HUV1. Then do three things: assign one person to own the HOPE queue each morning, build calendar alerts at days 1, 6, and 16 for every new admission, and verify your transmission pipeline is actually sending data to iQIES.

The mechanics of HOPE compliance are genuinely simple. The failure mode is not complexity — it's nobody watching the windows. Build the watch, and you keep the APU points.

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