Avoiding Paybacks in Hospice TPE Audits: A Step-by-Step Guide

Targeted Probe and Educate (TPE) audits are one of CMS’s primary tools to ensure hospices are billing accurately and documenting care in line with Medicare requirements. While TPE audits are meant to be educational, failing them can lead to financial paybacks, increased scrutiny, and even referral to other audit contractors. The good news: with proactive steps, your hospice can reduce risk and strengthen compliance before auditors come knocking.



1. Strengthen Documentation Practices Early

The number-one reason for denials in TPE audits is insufficient or unclear documentation. To avoid costly repayment demands:

• Ensure documentation consistently demonstrates eligibility for hospice (a prognosis of six months or less).
• Train staff to capture functional decline, clinical changes, and care needs in clear, measurable terms.
• Avoid vague statements such as “patient stable” — instead, provide comparative details like “patient now requires assistance with transfers, whereas three months ago was ambulatory with cane.”

2. Conduct Internal Chart Audits

Don’t wait for a TPE letter to discover gaps. Build a routine of internal chart reviews:

• Spot-check recent admissions for face-to-face encounter compliance and physician certifications.
• Review active cases for ongoing eligibility and timely updates to the plan of care.
• Involve both clinical and compliance staff so reviews reflect the full picture of patient decline.

3. Educate and Re-Educate Staff

CMS emphasizes the “Educate” portion of TPE — but you don’t have to wait for an audit to provide training.

• Offer regular education sessions on defensible documentation and common TPE denial reasons.
• Provide staff with real-world examples of strong vs. weak notes.
• Create quick-reference guides for nurses and IDG members to reinforce key compliance points.

4. Use IDG Meetings to Document Decline Clearly

Interdisciplinary Group (IDG) meetings are a powerful tool for audit readiness.

• Document comparative statements that reflect decline across nursing, social work, chaplain, and aide notes.
• Ensure the plan of care is updated with new interventions that reflect the patient’s changing needs.
• Use IDG notes to connect the dots between clinical observations and hospice eligibility.

5. Monitor Technical Compliance

Small technical errors can lead to denials — even when care is appropriate. Double-check that:

• Face-to-face encounters are completed and documented timely for patients entering a 3rd benefit period or later.
• Physician certifications of terminal illness are signed and dated correctly.
• Billing codes match the level of care documented (Routine Home Care, General Inpatient, Respite, etc.).

6. Engage in Mock TPE Reviews

One of the most effective strategies is to simulate a TPE audit:

• Select a random sample of recently billed claims.
• Have a compliance officer or outside consultant review documentation against CMS criteria.
• Identify trends and re-train staff on weak areas before CMS auditors find them.

7. Partner With Experts When Needed

If your hospice struggles with denials or repeat TPE rounds, consider working with a consulting partner who specializes in CMS audit support. External reviewers can bring an objective eye, identify risks quickly, and provide targeted training to help your staff succeed.

TPE audits don’t have to result in costly paybacks. By prioritizing defensible documentation, staff education, internal audits, and strong IDG practices, hospices can not only reduce financial risk but also improve the quality of care and compliance culture. The key is being proactive, not reactive — strengthening your processes now will pay off when auditors arrive.