Hospice stakeholders are urging CMS to pause a Hospice Outcomes and Patient Evaluation (HOPE) requirement that would penalize providers for late record submissions, according to a letter addressed to CMS Administrator Dr. Mehmet Oz. The letter was published by officials from LeadingAge, the National Alliance for Care at Home and the National Partnership for Healthcare and Hospice Innovation on Nov. 24, 2025.  
 
Under the HOPE tool’s timely submission requirement, hospices are required to submit 90% of their HOPE records within a calendar year or face an annual payment update penalty of 4%. And because HOPE wasn’t implemented until Oct. 1, 2025, the first quarter of implementation carries additional weight for providers. 
 
Industry leaders noted that the implementation of the HOPE tool also aligned not just with an industry-wide transition to iQIES, but with the first day of the government shutdown. This created additional burdens on providers, who were unable to contact the Hospice Quality Question Help Desk or access technical support during the beginning stages of HOPE. 
 
In order to support hospices and mitigate these financial concerns, stakeholders have requested that CMS waive the timeliness submission requirement for the first quarter of HOPE submissions. CMS has previously stated that it does not plan to use data from this quarter in public reporting. 
 
“The consequence of adverse outcomes cannot be understated,” the letter authors stated. “The risk of negative financial consequences for hospice providers is largely dependent this quarter not only on the success of two transitions — iQIES and HOPE — that are not within their control but also during a uniquely challenging government shutdown.”