Understanding the Hospice TPE Audit Process: What You Need to Know

Hospice providers across the country are facing closer scrutiny from Medicare, and one of the most common oversight tools is the Targeted Probe and Educate (TPE) audit. While the process can feel intimidating, it is designed to help hospices strengthen billing accuracy and compliance. By understanding what happens during a TPE audit, your team can prepare, respond effectively, and avoid costly repayment demands.

The TPE program was created by CMS to review providers who show patterns of potential billing risk. Instead of auditing every provider, CMS uses data analysis to target those whose claims appear to be outliers compared to their peers. The goal of a TPE audit is to verify that claims meet Medicare coverage and documentation requirements, educate providers on how to improve compliance, and reduce improper payments while still allowing providers the chance to correct issues before further action is taken.

The process begins when a hospice receives a notification letter from its Medicare Administrative Contractor (MAC). This letter explains that the hospice has been selected for TPE review and identifies the reason for selection, such as a high denial rate or unusual billing patterns. The letter also specifies how many claims will be reviewed in the first round, which is typically between 20 and 40.

Once selected, the hospice will receive an Additional Documentation Request (ADR) for each claim. Hospices generally have 45 days to submit the requested records, which must fully support eligibility, the levels of care billed, and compliance with hospice requirements. Missing, vague, or late documentation is one of the most common reasons for denials. After the documentation is submitted, the MAC reviews the claims and provides feedback. If most claims are compliant, the hospice may be released from the TPE process after the first round. If errors are found, the hospice is invited to an education session, which is designed to explain what went wrong and how to improve documentation and billing practices.

TPE audits can include up to three rounds of claim reviews. After each round, hospices receive education and have an opportunity to correct their issues. If compliance improves, the audit can end early. If errors continue after three rounds, however, the MAC may refer the hospice for further action, such as a UPIC audit, extrapolation of findings, or even referral to CMS for enforcement.

At the conclusion of the process, hospices may be released from review if they demonstrate compliance, placed into extended review if errors persist, or referred for further action if significant issues continue. The outcome depends on how effectively the hospice addresses the concerns identified during the audit.

Preparing for TPE audits begins with strengthening documentation practices. Records should clearly support terminal prognosis, levels of care, and plan of care updates. Regular internal chart audits are another effective way to catch errors before auditors do. Ongoing staff education is critical, since many denials stem from unclear or incomplete documentation. Hospices should also use their IDG meetings to capture comparative notes that document patient decline and changes to the plan of care. For organizations that continue to struggle with denials, working with an outside consultant can provide objective feedback, targeted training, and mock audits to identify risks early.



The TPE process does not have to be overwhelming. By understanding each step and preparing proactively, hospices can demonstrate compliance, reduce denials, and avoid unnecessary repayment demands. Most importantly, focusing on defensible documentation allows staff to spend less time worrying about audits and more time delivering compassionate care to patients and families.