HQRP Compliance Threshold

The HQRP Compliance Threshold is the standard a hospice must meet to receive its full Annual Payment Update: at least 90 percent of required HOPE records submitted within the 30-day deadline, plus satisfaction of the CAHPS Hospice Survey requirements (Timeliness Compliance Threshold Report fact sheet, January 2026, https://www.cms.gov/files/document/hospice-timeliness-compliance-report-fact-sheet-jan-2026-508c.pdf-0). The Hospice Quality Reporting Program is pay-for-reporting, so compliance turns on timely, complete data submission rather than on clinical performance.

The timeliness component requires a hospice to submit at least 90 percent of all required HOPE records within 30 days of each record's target date across the reporting year (Timeliness Compliance Threshold Report fact sheet, January 2026, https://www.cms.gov/files/document/hospice-timeliness-compliance-report-fact-sheet-jan-2026-508c.pdf-0). Admission, HUV, and discharge records are all analyzed. In parallel, a hospice must meet the CAHPS Hospice Survey requirements, which include ongoing monthly participation for hospices above the size threshold (Getting Started with the HQRP, January 2026, https://www.cms.gov/files/document/getting-started-hqrp-jan-2026-pdf.pdf). Missing either the 90 percent timeliness threshold or the CAHPS requirement results in the 4-percentage-point APU reduction. Non-compliance remains common: in the FY 2027 Hospice Proposed Rule, CMS reported that 22.06 percent of hospices were non-compliant for FY 2024, 23.53 percent for FY 2025, and 20.37 percent for FY 2026, and noted it has not seen meaningful improvement despite doubling the penalty (FY 2027 Hospice Proposed Rule, Federal Register, https://www.federalregister.gov/documents/2026/04/06/2026-06604/medicare-program-fy-2027-hospice-wage-index-and-payment-rate-update-and-hospice-quality-reporting). CMS has proposed adding an icon on the Medicare.gov Care Compare tool to flag hospices that fail HOPE reporting requirements (FY 2027 Hospice Proposed Rule fact sheet)^[1].

That roughly one in five hospices misses the threshold every year, even after the penalty doubled, indicates this is an execution problem, not a difficulty problem. The threshold is generous on paper — a 10 percent margin on timeliness — but it is measured across two independent tracks, and the CAHPS track runs through a survey vendor rather than the clinical team, creating a second failure path that is easy to neglect. The FY 2027 proposal to publicly flag non-compliant hospices on Care Compare raises the stakes beyond payment: non-compliance would become visible to referral sources and families, converting a back-office lapse into a reputational consequence. The controls that distinguish compliant from non-compliant hospices are iQIES timeliness tracking and monthly file delivery to the CAHPS vendor.