As the October 1 implementation of the Hospice Outcomes and Patient Evaluation (HOPE) tool approaches, hospice providers are preparing for a new era of standardized quality measurement. To support the industry through this transition, Axxess recently hosted a webinar providing expert insights on what providers need to know to stay compliant and confident in the HOPE environment.
Moderated by Axxess Vice President of External Affairs Laura Barnett, the discussion featured Axxess Senior Director of Clinical Services Raianne Melton, RN, BSN, CHPN, Axxess Senior Implementation Consultant Rosena Clarke-Turner, RN, MSSW, and Axxess Senior Product Director Amy Rose, RN, MSN.
Key Compliance Areas
Melton started the conversation by outlining several critical areas that will shape hospice compliance moving forward. One of the most pressing points: timely submission of records.
CMS requires that at least 90% of HOPE records be submitted within a 30-day window. Providers who fail to meet this threshold will receive a 4% reduction in reimbursement.
“These are the highlights that I want you to keep in mind,” Melton said. “Number one, there is going to be the noncompliance penalty for meeting less than 90% of records submitted to CMS within the 30-day time window.”
To meet this requirement, she recommended building strong internal processes for submitting records tied to admission, HOPE Update Visits (HUVs), and discharge.
She also pointed out that HOPE requirements apply to all patients, regardless of age or payer.
“Something else that is going to be new to us is that the HOPE assessment is for all patients admitted to hospice,” Melton said. “There [are] no longer any exceptions for age or payer, so this is a paradigm shift for us and we really need to keep that in mind.”
Another nuance she underscored was the admission timeline, which spans zero to five days, where day zero is the date of election.
“The admission timeline is zero to five days with day zero being counted as the date of election,” said Melton. “When you count that [on] your fingers, it’s really going to be six fingers that you’ll have to count before you’re into the HOPE Update Visit window. Being cognizant of that and making sure that you understand that nuance I think is going to be very, very important.”
Without careful attention to how day zero is counted, providers may inadvertently complete HUV 1 on day five, the final day of the admission window, which would be too early and out of compliance. The first HUV window opens on day six and runs through day 15.
The final key compliance area Melton addressed was discharge timing, noting that if a patient is discharged during a HOPE Update Visit window, an HUV submission is not required for that window.
While understanding these operational details is essential for compliance, surveyors will ultimately assess how well they are applied in practice.
What to Expect From Surveyors
Explaining what organizations can expect from surveyors once HOPE is live, Clarke-Turner indicated that many current evaluation criteria will remain unchanged.
“They’re still going to be looking to see that you provide effective pain and symptom management, that you respect the patient’s rights and choices, [and] that you develop a care plan that is sensitive to the patient and their family,” Clarke-Turner said. “They’re going to continue to review all of those things that they always did, looking at accuracy in your documentation [and] your staff qualifications. … In addition to those things, they’re going to be checking to see that HOPE is not just a data collection tool, but rather that it’s an integral part of enhancing your assessment, that it’s personalizing the care plan based on what you’re finding, that you’re ensuring timely symptom management, and that you’re continuously improving the quality of hospice services.”
She stressed the importance of staff preparation and robust documentation practices.
“Preparing your staff for workflows and the documentation that’s going to be necessary will help you to be survey-ready,” Clarke-Turner said. “Surveyors are going to look for the patient assessment and care planning. Is it timely? Is it a thorough assessment? Is the HOPE data integrated into your care plan? They’re going to want to see what’s happening with your interdisciplinary team collaboration related to symptom management and symptom follow-up and changes in that care plan that reflect what they can now see in your documentation.”
She added that surveyors will also assess proper use of iQIES and documentation for patient exclusion.
How Technology Can Help
Addressing a common misperception, Clarke-Turner emphasized that meeting HOPE requirements does not necessitate significant changes to clinical workflows, as long as systems are in place to extract and transmit the right data.
“It is a very common perception that CMS is saying, ‘You have to do another visit,’” Clarke-Turner said. “CMS is not directing frequency. CMS is saying, ‘Give us the data that shows that you’re responsive to your patients’ needs in end-of-life care.’ … All those things that hospices have been doing forever, CMS just doesn’t have that data yet. Clinicians should only have to rely on their electronic medical record extrapolating that data to communicate to CMS that those processes are already in place.”
Rose echoed this sentiment, noting that the HOPE components in Axxess Hospice are designed to align with clinicians’ existing routines.
“What clinicians can expect from the documentation is that it is their routine documentation that they are used to today,” Rose said. “They just need to be on high alert when they get messages, when they get notifications, [and] when they have required fields.”
Highlighting built-in tools that surface key visit data and guide documentation in real time, Rose added, “That’s what good technology should do for a clinician is just really help them focus on the patient and not have to worry about, ‘Did I schedule the right visit?’”
For additional information on how to prepare for and succeed under the new HOPE model, click here.
