Huh? That makes no sense. HOGE = Hover Out of Ground Effect. We calculate ours for no-wind out of ground effect hovering. Unless you're talking about how high a hover you're in. (i.e. a 100 foot hover vice a 50 foot hover)
You should be able to clear a 100ft obstacle with HOGE, so basically if you can get in with HOGE, you should be able to get out. If you have to stabilize in an OGE hover just to get in, you'll need more than that. In other words, an OGE hover requires more than HOGE power.
Note that I didn't speculate that this is what happened at Tahoe...I have no idea what happened at Tahoe...What happened at Tahoe????