NEW 2026 Hospice Final Rule – HOPE Implementation Date Confirmed

by Kerry Termine, DPT, HCS-D, COS-C

On August 1, 2025, the Centers for Medicare & Medicaid Services (CMS) provided pre-publication access to the fiscal year (FY) 2026 Hospice Wage Index and Payment Rate Update and Hospice Quality Reporting Program Requirements final rule, which updates Medicare payment policies and rates for hospices.

Hospice Quality Reporting Program (HQRP) Updates – Including HOPE

This rule provides updates on the HOPE instrument, HQRP measures, and the transition to iQIES. Within this rule CMS is also eliciting feedback from providers via a Request for Information (RFI) related to the transition to digital measures, nutrition, and well-being concepts.

HOPE Implementation Date– Within this rule, CMS clarifies that there are no changes to the planned start date with the national implementation of HOPE remaining as October 1, 2025.

Publicly Reporting HOPE Data – Through this final rule, CMS informed that data collected by hospices during the four quarters of CY 2026 (for example, Q 1, 2, 3 and 4 CY 2026) will be analyzed starting in CY 2027. CMS noted that they will inform the public of the decisions about whether CMS will report some or all of the quality measures publicly based on the findings of analysis of the CY 2026 data through future rulemaking. Providers will have the opportunity to preview HOPE data before it is publicly reported, with the first HOPE-based QM public reporting anticipated to be no earlier than November 2027 (FY 2028).

The following table derived from Table 6 of the rule outlines the planned schedule for HOPE public reporting:

• • These dates are subject to change based on the quality and reportability of the data as determined based on CMS analysis; updates will be provided in the FY 2027 Hospice Rule.
  • CMS also noted in the rule that they will monitor the first quarter of HOPE data collection (quarter 4 of 2025) and provide sub-regulatory guidance on when public reporting of the two HOPE measures will begin.

New Quality Measures

New Hybrid Measures – CMS noted that they will continue to consider developing hybrid quality measures that could be calculated from multiple data sources, such as claims, HOPE data, or other data sources (for example, CAHPS Hospice Survey).

New HOPE-based Measures – CMS also informed via the rule that they intend to develop several quality measures based on information collected by HOPE after HOPE is implemented.

Hospice Transition from QIES to iQIES

CMS noted that although they did not mention the transition from QIES to iQIES in the proposed rule, they did receive comments on this topic that were addressed in this final rule:

Beginning on October 1, 2025, the new CMS submission and reporting system will begin accepting the data from HOPE, in line with the start of HOPE data collection. Provider Reports (i.e., reports related to HOPE data submission) will also be available in this system beginning October 1, 2025.

The QIES system will stop accepting HIS records for hospice admissions and discharges that occurred prior to October 1, 2025, including any corrections, after February 15, 2026. There was no mention of Quality reports in the rule other than the mention of the Care Compare Provider Preview Reports in the table above.

APU Calculation using HOPE Data

CMS noted that during the first reporting year that implements HOPE, APUs may be based on fewer than four quarters of data. They plan to provide additional sub-regulatory guidance regarding APUs for the HOPE implementation year.

Payment Updates

Related to the payment portion of this rule, CMS finalized updates to the hospice wage index; the FY 2026 hospice wage index is updated to include the wage indexes for the Northern Mariana Islands and American Samoa. There are also routine updates to the Medicare hospice payment rate. CMS has updated the final FY 2026 hospice payment update percentage of 2.6 percent. This final rule includes the final FY 2026 hospice payment rates.

Face-to-face Updates

In addition, CMS has specified within this final rule has added the physician member to the interdisciplinary group in the regulatory text. The physician member of the interdisciplinary group is among the types of physicians who can recommend a patient’s admission to hospice care.

The final rule updates attestation requirements for the certification of terminal illness to include the physician’s or nurse practitioner’s signature and date of signature on each F2F encounter attestation. It also allows the actual face-to-face encounter clinical note to satisfy the statutory requirement for the hospice physician or nurse practitioner to attest to the encounter.

Technical Corrections

There are also a few technical corrections in this rule. One correction extends the use of telehealth by a hospice physician or hospice nurse practitioner to conduct a face-to-face encounter for the sole purpose of hospice recertification through September 30, 2025. There is also a technical correction to a typographical error in the FY 2024 Hospice final rule to fix an incorrect reference to another part of the regulations.

The final rule will be published on August 5, 2025 and accessible from the Federal Register.

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