HOPE Assessment Tool Series: Managing Special Circumstances 

HOPE Assessment Tool Series: Managing Special Circumstances 

Written by Jennifer Kennedy

Welcome to the next installment in the HOPE Assessment Tool Blog Series.  We are discussing special situations such as patient transfers and traveling patients which may affect HOPE assessment tool completion.  The HOPE Guidance Manual contains examples and prompts for these situations and HOPE tool item completion, so be sure to review the manual for additional information.

Special Circumstance #1 – Patient Transfers

Let’s review patient transfers before looking at HOPE assessment tool requirements.  A patient may change hospice providers once in each election period. A transfer or change of hospice provider is not considered a revocation of the election but is a transfer of their care from one provider to another as they remain in the same benefit period.  The patient must file a signed statement with their current hospice and their newly designated hospice that includes the following information: 

  • the name of the hospice from which the individual is receiving care, 
  • the name of the hospice from which they plan to receive care, and 
  • the date the change is to be effective.

Patient transfer logistics require the receiving hospice to file a new Notice of Election and complete all assessments required by the hospice conditions of participation as described in 42 CFR 418.54.  If the patient changes hospice providers in the third or a later benefit period, a face-to-face encounter is not required by the receiving hospice provider if they can verify that the transferring hospice completed and documented the encounter.  The transferring hospice also discharges the patient from their service utilizing guidance in the CMS Chapter 11, Medicare Claims Processing Manual.

Now let’s look at patient transfer and HOPE Assessment Tool requirements.  Hospice quality reporting is managed at the CMS Certification number (CCN) level, so when the patient’s care transfers from one hospice provider to another, each hospice provider will complete HOPE records as follows:

Transferring hospice provider

  • HOPE-Admission
  • HOPE Update Visit records (as applicable) depending on when the transfer takes place in the length of stay.
    • Example: the patient chose to change hospice providers on day 16 of their length of stay.  The transferring hospice completed the HOPE Update Visit 1 (HUV) on day 14. 
  • HOPE-Discharge record – select response 05, “transferred to another hospice,” for Item A2115—Reason for Discharge

Receiving hospice provider

  • HOPE-Admission  
  • HOPE Update Visit records (as applicable) depending on when the transfer takes place in the length of stay.
    • Example: the patient chose to change hospice providers on day 16 of their length of stay.  The receiving hospice provider will plan to complete the HUV 2 record between days 16-30 depending on the patient’s date of death. 

Special Circumstance #2 – Administrative Discharges

Change in patient’s payer source

In some cases, a hospice may choose to administratively discharge a patient and readmit them when a patient’s payer source changes to Medicare from another insurance type. In this scenario, the hospice provider completes an “administrative” discharge and re-admits the patient for billing purposes.  

Face-to-Face Visit Non-compliance

Recertifications in the third and subsequent benefit periods require a face-to-face encounter.  If it is not completed timely or if documentation of the encounter is missing, the patient becomes ineligible for the Medicare Hospice Benefit.  The hospice statute requires a complete certification or recertification for Medicare to cover and pay for hospice services.  CMS requires hospice providers to discharge patients from the Medicare Hospice Benefit and care for them at their own expense until the required encounter occurs and is documented in the clinical record. The provider can then re-admit the patient to the Medicare Hospice Benefit if all eligibility requirements are met and an election statement is filed.  

In both of these administrative discharge circumstances, if the patient remains under uninterrupted hospice care, completion of a HOPE-Discharge record is not required. Hospices are only required to submit a HOPE-Discharge record once the patient discontinues hospice services or there is an interruption in care related to reasons listed in HOPE Item A2115 which include death, revocation, no longer terminally ill, moved out of hospice service area, transferred to another hospice, or discharged for cause by the hospice provider.

Special Circumstance #3 – Traveling Patients

Hospice patients are allowed by regulation to travel outside of their home hospice’s service area and may receive services from a host hospice during their travel time.  In this circumstance, the home hospice provider can contract with another Medicare-certified hospice in the patient’s travel area to provide core services to the patient during their travel.  Also, CMS hospice regulations at §418.26 – Discharge from Hospice Care allow a hospice to discharge a patient who moves out of their service area.  Submission of a HOPE record for a traveling patient depends on whether the patient’s home hospice provider discharged the patient for leaving their service area or if they are treating them as a traveler. 

If there is no discharge by the home hospice provider, no HOPE-Discharge record submission is required.  The patient remains under their management during the travel period even if there is a contract in place with a hospice provider in the patient’s travel area.  Remember, just because a patient is traveling, it does not mean the home hospice provider is exempt from submitting HUV records (as applicable) or completing symptom follow up visits (SFVs).  Planning for completing these visits (as applicable) during patient travel needs consideration.

If the home hospice provider discharges a patient who is traveling outside of their service area, they would submit a HOPE-Discharge record, and the hospice provider in the patient’s travel area (if any) would admit the patient to their service, file a notice of election (NOE) within the claims processing system and complete a HOPE-Admission record.

Tips for Success

  • Review your processes related to patient transfers, travel, and administrative discharges and determine how the HOPE assessment tool requirements will impact them
  • If you have current performance issues in any of these processes, fast track them into your QAPI program for remediation
  • Educate your staff now about how HOPE assessment tool requirements will impact these special circumstances and what your updated processes will be

While providers are accustomed to Hospice Item Set (HIS) record submission in the special circumstances discussed in this blog, the HOPE assessment tool has additional record submission and assessment requirements.  It is important to ensure your processes and staff understanding about these situations are solid before implementation of the HOPE tool.   

Stay tuned for the next installment in the HOPE Assessment Tool blog series.

References

The Centers for Medicare and Medicaid Services. (2025, Oct 1). Hospice outcomes and patient evaluation (HOPE) guidance manual – v1.00. https://www.cms.gov/files/document/hope-guidance-manualv100.pdf

The Centers for Medicare and Medicaid Services. (2018, Dec 1). Medicare benefit policy manual chapter 9 – Coverage of hospice services under hospital insurance, hospice election. https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c09.pdf

The Centers for Medicare and Medicaid Services. (2018, Dec 17). Medicare benefit policy manual chapter 9 – Coverage of hospice services under hospital insurance, timing and content of the certification. https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/Downloads/bp102c09.pdf

The Centers for Medicare and Medicaid Services. (2003). Medicare prescription drug, improvement, and modernization act of 2003, Sec. 946. Authorizing use of arrangements to provide core hospice services in certain circumstances. https://www.congress.gov/108/plaws/publ173/PLAW-108publ173.pdf