CMS Hospice Quality Reporting Program (HQRP) Explained: Compliance for 2026

Hospice agencies participating in the Medicare program must not only deliver compassionate care at the end of life but also comply with federal quality reporting requirements. The CMS Hospice Quality Reporting Program (HQRP) is a cornerstone of Medicare’s efforts to measure, improve, and publicly report the quality of hospice care nationwide. Failure to comply with HQRP requirements can lead to payment adjustments, public reporting penalties, and increased survey scrutiny. As we move into 2026, hospice providers must ensure robust systems are in place to meet ever-evolving regulatory expectations.

This comprehensive guide explains the HQRP framework, regulatory responsibilities, reporting timelines, key measures, compliance challenges, and best practices aligned with Medicare Conditions of Participation.

What Is the CMS Hospice Quality Reporting Program (HQRP)?

The CMS Hospice Quality Reporting Program (HQRP) is a mandatory data submission and quality measurement program for Medicare-certified hospice providers. CMS uses HQRP data to evaluate hospice performance, drive quality improvement, support patient choice, and ensure accountability in end-of-life care. Under this program, hospices submit standardized data on clinical processes, patient and caregiver experiences, and outcome measures. CMS then aggregates and publicly reports performance results to assist beneficiaries, families, and stakeholders in comparing hospice provider quality.

HQRP compliance is tied to Medicare payment: hospices that fail to submit required data on time or with acceptable data quality may incur a 2 percent annual payment penalty. As reporting standards evolve, 2026 compliance requires robust operational processes, education, and documentation systems within every hospice agency.

Regulatory Foundation: Medicare Conditions of Participation

Hospice Quality Reporting Program compliance aligns with the broader Medicare Conditions of Participation (CoPs) governing hospice care. These CoPs set minimum health and safety standards that hospices must meet to participate in Medicare. Relevant regulatory requirements include:

• Development of a cohesive Quality Assessment and Performance Improvement (QAPI) program

• Documentation and data systems that support quality measures

• Policies governing patient and caregiver experience surveys

• Evidence of continuous quality monitoring and corrective action

CMS expects hospice providers to integrate HQRP data into their QAPI strategy, using measure results to drive improvement and mitigate risks. Failure to integrate quality reporting into operations can lead to survey citations, financial penalties, or reputational harm.

Core HQRP Measures for 2026

For 2026 reporting, hospice providers are required to submit performance results for several standardized measures. These quality measures focus on clinical care, symptom management, patient and caregiver experience, and continuity of care. Some of the key 2026 HQRP measures include:

1. Hospice Visits When Pain is Present
   Measures the percentage of hospice patients with documented pain assessments and timely visits when pain is present.

2. Hospice and Palliative Care Composite Process Measure (CO99)
   A composite of clinical process measures including symptom management and care planning activities.

3. Consumer Assessment of Healthcare Providers and Systems (CAHPS®) Hospice Survey
   A validated patient and caregiver experience survey that assesses communication, care coordination, emotional support, and overall experience.

4. Use of Hospice Services in Nursing Facilities (facility-level variations)
   Measures access to hospice services and performance across settings.

5. Timely and Accurate Completion of the Hospice Item Set (HIS)
   Ensures required HIS data items are collected and submitted according to CMS requirements.

Each measure has specific data collection methodologies, submission deadlines, and validation rules. CMS updates these annually, and hospices must stay informed through official CMS communications and the QualityNet portal.

Reporting Mechanisms and Data Submission

Hospice quality data is primarily submitted through two platforms:

1. QualityNet Secure Portal
Hospices upload standardized HIS files and performance data for clinical measures via the QualityNet Secure Portal. The HIS is a data collection instrument that captures key clinical information for hospice patients and is foundational to several HQRP measures.

2. CAHPS® Hospice Survey Program
Hospices must contract with an approved vendor to administer the CAHPS® Hospice Survey to a representative sample of caregivers. Results are submitted to CMS according to strict protocols to ensure validity and reliability.

CMS provides detailed technical specifications and file formats for data submission. Hospices must validate data prior to submission and ensure timeliness to avoid payment penalties.

Compliance Requirements: Timeliness and Accuracy

Compliance with HQRP is measured in two critical areas:

1. Timeliness

• HIS submissions must occur within specified time windows (e.g., calendar quarterly deadlines).

• CAHPS® survey data collection and submission must align with CMS protocols.
  Late submissions are subject to the 2 percent payment penalty unless a hardship exception is granted.

2. Accuracy and Completeness

• Data must adhere to CMS formatting and reporting guidelines.

• Missing, inconsistent, or invalid data elements can lead to noncompliance.

• CMS performs data validation checks, and hospices may receive rejection notices for resubmission.

High data quality requires coordinated workflows, staff training, internal audits, and liaison with technical support teams. Hospice leadership must track deadlines proactively and provide oversight to all staff involved in data collection and reporting.

Integration With QAPI: Systematic Quality Improvement

CMS expects quality reporting to be an integral function of a hospice’s Quality Assessment and Performance Improvement (QAPI) program. QAPI standards require hospices to systematically evaluate care processes, identify performance gaps, implement corrective actions, and assess the effectiveness of improvements.

Effective QAPI integration means:

• Using HQRP measure results to identify trends (e.g., symptom management issues)

• Prioritizing areas with variation or poor performance

• Analyzing root causes and implementing system changes

• Documenting measurable improvement activities

• Engaging clinical and administrative leaders in performance oversight

For example, if the “Hospice Visits When Pain Is Present” measure reveals inconsistent assessments, the QAPI team should investigate workflows, education gaps, and documentation practices, and then implement corrective strategies.

Common Compliance Pitfalls and Risk Areas

Hospice agencies often struggle with consistent HQRP compliance due to underlying operational issues. Some frequent risk areas include:

Inadequate Documentation Practices
Incomplete clinical records, inconsistent pain assessments, or failure to capture HIS data elements accurately can compromise measure submission.

Ineffective Data Collection Workflows
Lack of standardized processes for HIS data capture or survey administration increases the risk of inaccurate reporting.

Insufficient Staff Training
Without ongoing education, clinical and administrative staff may misinterpret measure definitions or reporting requirements.

Lack of Oversight and Accountability
Quality reporting is too often siloed within one department, with limited leadership engagement or cross-discipline accountability.

Failures in Survey Administration
The CAHPS® Hospice Survey has strict protocols — deviations can result in invalid data or exclusion from reporting.

Identifying and mitigating these challenges requires intentional planning, continuous monitoring, and investment in technology and staff resources.

Best Practices for HQRP Success in 2026

To achieve excellence in hospice quality reporting and avoid compliance risks, hospice agencies should adopt best practices that align with Medicare expectations:

Establish Standardized Workflows
Create documented processes for HIS data collection, validation, and submission. Coordinate between clinical, administrative, and IT teams to ensure seamless operations.

Institute Regular Internal Audits
Conduct internal audits of HIS submissions, CAHPS® survey processes, and QAPI activities. Audit results should inform corrective action plans.

Educate Staff Continuously
Provide annual and role-specific education on HQRP measures, data definitions, and documentation standards. Reinforce the importance of timely, accurate reporting.

Engage Leadership in Quality Oversight
Quality reporting is an organizational responsibility. Leadership should review measure results, monitor trends, and support improvement initiatives.

Use Technology to Support Data Accuracy
Electronic health record (EHR) systems should be configured to support HIS data capture and pull accurate, reportable data for CMS submissions.

Monitor CMS Updates Routinely
CMS updates measure specifications, reporting protocols, and deadlines annually. Staying informed ensures preparedness and compliance.

HQRP and Survey Preparedness

Hospice agencies are subject to surveys that assess compliance with Medicare CoPs, including HQRP requirements. Surveyors evaluate documentation, data submission records, QAPI integration, and evidence of corrective action. Hospice providers should be able to demonstrate:

• That HQRP data submissions were completed on time

• How quality data informs operational improvements

• Internal reporting dashboards and oversight mechanisms

• Evidence of QAPI meetings and outcomes

Lack of documentation linking quality reporting with performance improvement may lead to citations during surveys under CoP standards.

Addressing Penalties and Corrective Actions

Penalties for noncompliance with HQRP generally include the 2 percent payment reduction for continued failure to submit data. However, CMS may also take additional actions if documentation deficiencies overlap with broader hospice CoP violations. If data issues are identified during surveys or audits, hospices should:

• Investigate root causes promptly

• Prepare a corrective action plan with measurable milestones

• Document all corrective steps taken

• Communicate internally and with external partners (e.g., surveyors, vendors)

Fast, transparent corrective action demonstrates organizational accountability and reduces the risk of repeated noncompliance.

Partnering With Experts to Ensure HQRP Compliance

Achieving consistent HQRP compliance in 2026 requires operational discipline, documentation integrity, and a culture of quality. Medicare’s regulatory environment is unforgiving of lapses in reporting or oversight. Hospice agencies that fail to meet CMS requirements risk financial penalties, survey citations, and diminished public confidence.

If your hospice agency seeks support with HQRP, documentation systems, and survey readiness, consult with HealthBridge, a leading consulting and management solutions firm specializing in Medicare compliance for hospice and home health providers. HealthBridge offers:

• Comprehensive HQRP compliance assessments

• Internal audit tools and process improvement frameworks

• Staff education programs and performance dashboards

• Policy development aligned with Medicare CoPs

• Turnkey solutions for quality reporting and QAPI optimization

HealthBridge partners with hospice agencies nationwide to ensure data quality, regulatory compliance, and sustainable quality improvement.

References:
CMS Hospice Quality Reporting Program (HQRP)

1. CMS Hospice Quality Reporting Program (HQRP)
   https://www.cms.gov/medicare/quality-initiatives-patient-assessment-instruments/hospice-quality-reporting
   

CMS Hospice Conditions of Participation

2. Hospice Conditions of Participation (CoPs)
   https://www.cms.gov/medicare/health-safety-standards/certification-compliance/hospice
   

CMS State Operations Manual (Appendix M – Hospice)

3. CMS State Operations Manual – Appendix M (Hospice)
   https://www.cms.gov/regulations-and-guidance/guidance/manuals/internet-only-manuals-ioms