HIS Hospice Item Set Reporting: Hospice Quality Reporting Program Outline

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HIS Hospice Item Set Reporting: Hospice Quality Reporting Program Outline

HIS Hospice Item Set Reporting: Hospice Quality Reporting Program Outline

Hospice leaders are used to juggling licensure rules, Medicare billing, and the annual hospice cap. Over the past few years, though, the expectations around quality reporting have moved from a background task to a central part of Medicare participation. The Hospice Item Set, or HIS, sits at the heart of that shift.

HIS reporting under the Hospice Quality Reporting Program (HQRP) is no longer something that can be handled casually at discharge. It ties directly to the hospice’s Annual Payment Update, feeds public star ratings, and is in the middle of another significant transition with the rollout of the Hospice Outcomes and Patient Evaluation (HOPE) tool. (CMS HQRP overview)

In this article, we outline how HIS fits within HQRP, what compliance actually requires, how the data is used, and how the transition to HOPE affects reporting. As hospices prepare for new assessment tools and reporting requirements, it is essential to review workflows, train staff, and stay updated on CMS guidance. Our goal is to move HIS from a source of anxiety to a manageable part of your operational and financial planning.

How HIS Fits Inside the Hospice Quality Reporting Program

The Hospice Quality Reporting Program is CMS’s framework for collecting standardized information on hospice care. All Medicare certified hospices are required to participate in HQRP to maintain regulatory compliance and ensure continued Medicare reimbursement. To participate in Medicare, hospices must submit three core types of data:

HIS assessments, which capture patient-level clinical information.
Medicare hospice claims, which feed claims-based quality measures.
The CAHPS Hospice Survey, which measures family experience through a CMS-approved vendor.

The HQRP requires all Medicare-certified hospice providers to submit quality data through these three sources.

CMS describes HQRP as “pay for reporting” rather than “pay for performance.” In other words, what affects your payment update is whether you submit complete and timely data, not whether your quality scores are above or below a specific benchmark. (CMS HQRP description)

For fiscal year 2024 and forward, the financial consequence of failing to comply is significant. Hospices that do not meet HQRP reporting requirements receive a 4 percentage point reduction to their Annual Payment Update. (42 CFR 418.312 & CMS HQRP) A reduction of that size can easily offset any margin for agencies already managing staffing shortages and rising costs.

From a compliance perspective, HIS is one leg of a three-legged stool. You can have clean claims and strong CAHPS participation, but if HIS falls below threshold, the hospice still risks the full HQRP payment penalty. Compliance with the Hospice Quality Reporting Program (HQRP) is determined by successfully fulfilling both the HIS quality data submission requirements and the Hospice CAHPS® Survey requirements.

Understanding Hospice Care

Hospice care is a specialized approach designed to provide compassionate support, comfort, and dignity to patients facing terminal illnesses. Rather than focusing on curative treatments, hospice care prioritizes quality of life for both patients and their families during the final stages of life. Services are typically delivered wherever the patient calls home—be it a private residence, hospice center, nursing facility, or hospital—ensuring that care is accessible and tailored to individual needs.

Central to the mission of hospice care is the commitment to addressing not only physical symptoms, but also emotional, spiritual, and psychosocial needs. This holistic approach helps patients find relief from pain and distress, while offering families the support and guidance they need during a challenging time.

The Hospice Quality Reporting Program (HQRP), established by the Centers for Medicare & Medicaid Services (CMS), plays a vital role in advancing hospice quality. By systematically collecting and analyzing data on hospice outcomes, patient evaluation, and quality measures, the HQRP enables providers to assess their performance, identify areas for improvement, and demonstrate their commitment to delivering high-quality hospice care. Through this data-driven approach, hospices can ensure that every patient receives the support, respect, and quality of life they deserve in their final days.

Patient Evaluation and Assessment

A cornerstone of quality hospice care is the thorough evaluation and assessment of each patient’s needs, preferences, and goals. Patient evaluation begins at admission and continues throughout the hospice stay, ensuring that care plans remain responsive and individualized.

The Hospice Item Set (HIS) is a standardized tool used by hospice providers to document key aspects of patient care at both admission and discharge. This tool captures essential information such as pain screening, discussions about spiritual beliefs, and treatment preferences, providing a structured way to assess and document the patient’s experience. The data collected through the HIS is critical for calculating quality measures, including the Hospice and Palliative Care Composite Process Measure, which evaluates the comprehensiveness of patient assessments at the start of care.

In addition to clinical assessments, the CAHPS Hospice Survey gathers feedback from patients’ families about their experiences with hospice services. This survey covers important domains such as communication, emotional support, respect, and the overall quality of care provided. The results contribute to the Hospice Care Index and other quality measures, offering valuable insights into how well hospice organizations meet the needs of patients and families.

By integrating tools like the HIS and the CAHPS Hospice Survey into daily practice, hospice providers can ensure that patient evaluation is not just a regulatory requirement, but a meaningful process that drives quality improvement. These assessments help organizations deliver care that is compassionate, respectful, and aligned with each patient’s values—ultimately supporting better outcomes and reinforcing the commitment to excellence in hospice care.

Regulatory Foundation for HIS Reporting

The legal authority for HIS and HQRP sits in federal statute and regulation, primarily section 1814(i)(5) of the Social Security Act and its implementing regulation at 42 CFR 418.312. That regulation requires every Medicare-certified hospice to submit standardized quality data “in a form and manner, and at a time, specified by the Secretary.” (42 CFR 418.312)

A few elements of that rule are important for day-to-day operations:

Hospices must complete a standardized item set for each patient, regardless of payer or patient age. HIS reporting is mandatory for all Medicare-certified hospices regardless of the patient’s age or payer source. Historically this has been the HIS. Effective October 1, 2025, CMS will replace HIS with the HOPE tool as the standardized instrument, but the underlying legal obligation to submit data continues. (QTSO HOPE announcement)

The standardized items must be completed at admission and discharge and, under the updated rule language, at a new Hospice Update Visit. The details of that visit type are defined in CMS guidance.

CMS may grant reporting exemptions in extraordinary circumstances, such as natural disasters or widespread system failures, but these are limited and typically time-bound. Exemptions may also apply to hospices with fewer than a specified number of survey-eligible decedents.

Federal agencies are also subject to the Paperwork Reduction Act. Similar to the cost report forms, HIS and the HOPE tool must be approved by the Office of Management and Budget. CMS periodically updates the item sets and manuals and posts Federal Register notices when doing so. For example, CMS issued HIS Manual v3.02 and updated HIS Admission and Discharge forms in April 2024 with an extended expiration date and technical corrections. (CMS HIS page)

The result is a quality reporting program that is not voluntary and not one-time. It is an ongoing condition of Medicare participation that should sit alongside licensure, Conditions of Participation, and hospice cap monitoring on your compliance calendar. Different departments, such as compliance or quality departments, play a key role in ensuring ongoing HIS reporting compliance.

What the Hospice Item Set Actually Captures

As with the home health cost report, the name can be misleading if you only glance at it. The Hospice Item Set is not a billing form. It is a standardized clinical dataset that captures key aspects of the hospice admission and discharge quality reporting process. Each aspect of the HIS is designed to ensure comprehensive evaluation of hospice care quality measures and compliance tasks.

The seven primary process measures include Pain & Dyspnea, Treatment Preferences, Beliefs/Values, and Medication Safety.

The HIS admission and discharge item sets include core domains such as pain screening and follow up, dyspnea assessment and treatment, communication with the patient’s family about treatment preferences, and documentation of beliefs and values. HIS includes standard measurements for patients’ treatment preferences, beliefs, pain, dyspnea, and opioid management. CMS uses these items to construct HIS-based quality measures, such as pain screening within 24 hours of admission and treatment of shortness of breath. The technical specifications and measure definitions are available on CMS’s current measures pages. (CMS HIS manual and current measures)

HIS data is used to calculate seven primary process measures related to patient care.

From the agency’s perspective, the most important characteristics of HIS are:

It applies to all patients, not only Medicare beneficiaries. That means private pay, commercial, Medicaid, and charity-care patients are all included in the reporting universe. Each HIS record is anchored to an event date, typically the admission or discharge date. The data must be complete enough for CMS to calculate the patient-level measure outcomes and roll those into provider-level scores.

Because HIS focuses on specific quality domains, it cannot be reconstructed solely from the clinical narrative in the medical record. Hospices need documentation practices and EHR workflows that support completion of the standardized items as part of routine care, including the importance of accurate and timely HIS discharge records.

Timelines, Thresholds, and Submission Logistics

Compliance with HIS reporting has two primary dimensions: timeliness and completeness. Both are clearly defined in regulation and guidance.

For timeliness, hospices must submit each HIS record within 30 calendar days of the target event date, which is typically the admission or discharge date. Records are transmitted as electronic files to CMS’s systems. Under the current framework, hospices submit HIS through the Quality Improvement and Evaluation System using the Assessment Submission and Processing module. It is essential that a responsible person, such as the healthcare provider or designated staff member, completes and verifies the HIS data to ensure accuracy and compliance. (HQRP requirements and best practices; LegalClarity summary)

For completeness, CMS has established a data submission threshold. Hospices must successfully submit and have accepted at least 90 percent of all required HIS (or successor instrument) records within the 30-day window for the full calendar year. Failure to meet or exceed this 90 percent threshold results in a 4 percentage point reduction to the Annual Payment Update for the applicable fiscal year. Hospices with fewer than a specified number of survey-eligible decedents may have different reporting requirements or exceptions. (42 CFR 418.312(j))

The public reporting side also has its own timelines. CMS uses specific quarterly “target dates” for HIS records and sets data correction deadlines about four and a half months after the end of each quarter. For example, HIS records with target dates in the third quarter of 2025 have a public reporting data correction deadline in February 2026. (CMS key dates for providers) That gives hospices some room to correct data, but corrections after the deadline only influence future refreshes, not the current public reporting cycle.

Hospices also receive Provider Preview Reports through the CASPER system that show their HIS-based and claims-based quality measures before the data are posted on Medicare’s Care Compare site. Providers have a 30-day preview period to review these reports and can request CMS review if they believe there are calculation issues. The quality measures calculated are based on data from the HIS, Medicare claims, and the CAHPS® survey, and these calculations determine hospice performance as publicly reported. (CMS public reporting background)

Practically, this means HIS cannot be treated as a year-end clean up project. Agencies that try to “catch up” on submissions after survey or after a busy census month often find themselves trapped between the 30-day submission clock and the 90 percent annual threshold.

How HIS Data Are Used in Public Reporting and Payment

HIS is not simply a compliance box. The data flow into several downstream uses that affect how your hospice is viewed and paid.

First, CMS converts HIS items into quality measures that are publicly reported on the Care Compare website. These measures are used to evaluate care quality, encompassing patient experiences, communication, symptom management, and clinical performance. Families and referral sources can see these scores alongside CAHPS survey results and claims-based measures such as visits in the last days of life. CMS updates these public scores on a regular quarterly schedule. For example, in the August 2025 refresh, HIS-based scores reflected data from the fourth quarter of 2023 through the third quarter of 2024. (CMS public reporting background)

Second, although HQRP is officially pay for reporting, CMS uses the quality data for broader policy analysis and program oversight, much as it uses cost report data to evaluate margins in the home health and hospice sectors. Public reporting also creates reputational and market pressure. Poorly reported HIS data can depress quality scores regardless of the clinical reality and can make it more difficult to compete for referrals.

Third, HIS feeds internal quality improvement. A hospice organization that regularly reviews CASPER quality measure reports can identify patterns such as inconsistent documentation of pain screening or gaps in capturing preferences for life-sustaining treatment. Agencies can use HIS data for internal quality improvement by auditing clinical documentation and meeting standardized care protocols. Those findings support staff education, workflow redesign, and EHR optimization.

When we work with hospices that are struggling financially, we often see a parallel struggle with HIS. Limited clinical documentation, manual HIS abstraction, and irregular submission often travel together with incomplete cost information and difficulty managing the hospice cap. Addressing HIS is part of putting the entire Medicare program relationship on more stable footing.

The Shift From HIS to HOPE

The most important development in hospice quality reporting over the next two years is the transition from HIS to the Hospice Outcomes and Patient Evaluation, or HOPE, assessment.

HOPE is designed to improve care planning and quality measurement throughout the hospice episode.

CMS has announced that effective October 1, 2025, the HOPE tool will replace the current Hospice Item Set as the standardized quality assessment instrument. HOPE incorporates existing HIS items, revised versions of some items, and new content areas that align with updated quality priorities. (CMS QRP Spotlight; QTSO HOPE announcement)

From a reporting perspective, several features of this transition are critical:

HOPE assessments will be submitted through CMS’s Internet Quality Improvement and Evaluation System, or iQIES, rather than the legacy QIES environment.

HOPE introduces standardized assessment points called HOPE Update Visits (HUVs) during the first 30 days of care. HOPE aims to capture real-time patient and family care needs to support proactive, individualized care planning.

HIS records with target dates before October 1, 2025 may continue to be submitted and corrected in QIES through February 15, 2026. After that date, QIES will no longer accept new or corrected HIS records. (QTSO iQIES launch details)

The regulatory requirement to meet a 90 percent submission threshold within 30 days carries over to HOPE as the “successor instrument” under 42 CFR 418.312.

In practical terms, hospices are facing a period where both systems are relevant. Agencies must keep HIS reporting compliant through the end of the transition window while also preparing staff, systems, and vendors for HOPE implementation in iQIES. CMS has released HOPE guidance manuals, technical specifications, and training materials in its HQRP training library to help with this process. (CMS QRP Spotlight)

Hospice Item Set (HIS) data is used to calculate one composite measure, the Consensus-Based Entity (CBE) endorsed, Hospice and Palliative Care Composite Process Measure – Comprehensive Assessment at Admission. The HIS Comprehensive Assessment at Admission Quality Measure looks at the data as a group for an all-or-nothing quality measure score to indicate if an organization performed a timely and thorough assessment of all indicated areas within the indicated time frame.

For organizations that have already invested in strong HIS workflows, the HOPE transition is manageable but not trivial. It is not simply a form swap. HOPE collects information at additional time points and in greater clinical detail, which can increase documentation time without careful planning.

HIS data remains relevant in 2026 for evaluating past performance for patients admitted prior to the transition to HOPE.

Building Internal Processes That Support Reliable HIS Reporting

Hospices that consistently meet HQRP requirements tend to share a few operational characteristics. They do not rely on a single quality coordinator racing to complete forms at month end. Instead, they embed HIS and, soon, HOPE, into the fabric of daily care to ensure quality care is consistently delivered and documented.

One effective approach is to map each HIS item to a clear point in the clinical workflow, including hospice visits. Pain screening needs to be captured at admission and revisited during early visits. Treatment of dyspnea must be documented both as an assessment and as a specific intervention. Preferences about resuscitation or hospitalization need defined prompts and standard locations in the EHR. The HIS focuses on key clinical actions, including screening and treatment for pain and dyspnea, discussions about opioid risks, and documentation of spiritual, emotional, and treatment preferences.

Data collection should occur as close to the point of care as possible, using structured fields rather than free text alone. Where the electronic health record allows, building HIS-aligned templates and hard stops can reduce the risk of incomplete items that later result in rejected submissions.

On the submission side, hospices benefit from predictable routines. Daily or twice-weekly batches of HIS records, with immediate review of validation reports from CMS, make it easier to correct issues while the patient episode is still fresh. Waiting until the end of the month to submit creates avoidable stress around the 30-day deadline.

Leadership also needs visibility. Standard internal reports that show the percentage of HIS records submitted within 30 days, the share rejected by CMS, and progress toward the 90 percent annual threshold provide early warning. When that information is summarized alongside census, visit frequencies, and cap utilization, executives can see how quality reporting is interacting with clinical operations and financial performance.

For smaller hospices with lean administrative support, it is reasonable to explore outside help. As we have noted in our work on outsourced accounting and Medicare cost reporting, some functions are simply better handled by teams that focus on them every day. The same logic can apply to HIS abstraction, validation, and submission processes, provided the clinical team retains responsibility for accurate documentation.

Common Pitfalls and How to Avoid Them

In our experience with providers working through hospice caps, AHCA requirements, and Medicare reporting, the same HIS issues tend to appear across organizations of very different sizes.

One common problem is overreliance on paper or manual abstraction. Clinical teams document care in narrative notes and then, often days later, a staff member attempts to translate that record into HIS items. The result is guesswork, inconsistencies, and a higher risk of rejected records. Moving HIS completion closer to the clinical encounter, supported by EHR prompts, reduces these risks.

Another pitfall is treating HIS as a purely clerical task. Because the program is pay for reporting, some agencies assume that as long as the form is filled out and submitted on time, the content is less critical. That approach tends to collapse once public reporting, star ratings, and hospital partners begin to scrutinize hospice quality scores. Communication and support issues are also common; providing timely help to patients and families is a key domain measured by the CAHPS® Hospice Survey and directly impacts satisfaction scores.

Deadlines also trip up agencies. The 30-day submission clock is short enough that missed discharges or overlooked records can accumulate. Accurate data related to death is essential for hospice care measurements and patient outcomes, so missing or incorrect records can negatively affect quality metrics. The longer 24-month window for corrections under public reporting can create a false sense of security. Remember that corrections after the CMS data correction deadline for a particular quarter only affect future refreshes. They do not fix what is already on Care Compare today. (CMS key dates and public reporting guidance)

The HOPE transition will introduce its own issues. Some hospices may delay preparation, assuming that existing HIS workflows will carry them through. Others may underestimate the technical steps needed to set up iQIES access, test vendor interfaces, and train staff on the new assessment. As with any major regulatory change, early planning and a written implementation timeline usually pay off.

Integrating HIS Into the Bigger Compliance Picture

HIS is one element of a broader pattern we see across healthcare accounting and compliance. Whether you are navigating Florida AHCA licensing requirements, managing an assisted living facility, or monitoring Medicare hospice caps, the underlying challenge is the same. Regulators are asking for more standardized, timely data, and they are tying financial consequences to how well you respond.

Hospice quality reporting should be viewed alongside your cost reporting process, your revenue cycle, and your internal financial reporting. All of these systems feed into how Medicare views your organization and how stable your reimbursement will be over time.

For some agencies, the right move is to build stronger internal teams, invest in EHR optimization, and dedicate specific staff to quality reporting. Others find that partnering with an experienced advisory firm for HQRP strategy and periodic reviews gives them better coverage without overextending existing staff. That mirrors the logic behind outsourced accounting that we have discussed elsewhere: not every function needs to live entirely in-house to be well controlled.

Conclusion

HIS reporting within the Hospice Quality Reporting Program is one of those requirements that rarely makes headlines but quietly shapes your revenue, your public reputation, and your survey experience. The rules are now well established, the penalties for noncompliance are material, and the transition to HOPE raises the bar for documentation and data submission.

Hospices that treat HIS as an integrated clinical and operational process, rather than a form filled out at the margins, tend to find that quality reporting becomes more predictable. That predictability supports better financial planning, more constructive conversations with referral partners, and a more confident stance when regulators or surveyors review your data.

If you would like to review your current HIS or HOPE readiness, discuss how quality reporting interacts with your cost reporting and hospice cap exposure, or explore where outside support might make sense, we are here to help. Click the button below to schedule a time to chat.