Education: The “E” in TPE

Part of the current CMS Targeted Probe and Educate (TPE) process is the formal addition of education after the results of the probe are summarized. Education provides detail and suggestions on the agency’s actual review findings. This information allows the agency to improve charting before the next round (probe) of Additional Development Requests (ADRs) begins.

Education Focus Areas

Typically, the education process occurs via teleconference. For those agencies under a TPE probe related to therapy from National Government Services, here are some highlights of focus areas:

  1. Any prior and recent use of therapy by the patient must be clarified and documented. CMS deems patients who have received therapy service in the months prior to current home care less likely to need it now. This applies especially if therapy is for the same diagnosis as prior service.
  2. Caregiver status is very important. When completing ordered teaching tasks, especially related to the home exercise program (HEP), it is important to be clear. Specify availability, willingness to learn, identification of, and response by the caregiver. Many Electronic Medical Record (EMR) systems allow only a checkbox of “Pt/CG” to be marked for the interventions. Be sure to discern which applies: the patient or the caregiver?
  3. Prior Level of Function continues to show up. Identifying what the patient could do before the recent decline and need for home care helps establish a current need and potential for restoration.
  4. If a patient is going to daycare, clearly document the nature of that daycare in the record. In the case of state-licensed or certified daycare, it is assumed to meet the homebound exception and thus not affect a determination of homebound. When daycare is for social purposes only, leaving home to attend disqualifies the patient from Medicare home health eligibility. Know which definition applies to the patient.
  5. For recertifications, you must clearly show the reason to continue care into a subsequent episode. This usually adds many therapy visits to those already done, so it can call into question the reasonable and necessary aspect of therapy.

    Additionally, be sure to document any exacerbation of a chronic condition. The documentation must include more than a simple statement that an exacerbation has occurred: there should be examples and findings to support that conclusion.

These are a few of the highlights of an educational session with a MAC.

QIRT can help.

Many agencies need assistance with ADR responses, education, or the appeals processes surrounding a TPE review. QIRT’s Compliance Division has years of experience with these processes and an incredible track record.

Email QIRT for more details:, 855.485.QIRT.

Or contact a compliance expert directly: Joe Osentoski,

Comments are closed.

Up ↑

%d bloggers like this: