Even with an extended recovery period, home health agencies are likely to see a heavy financial toll due to partial episode payment (PEP) adjustments. Unknown to them, many agencies have been receiving extra payments for patients that transferred to other agencies or were readmitted. One agency in Massachusetts found out it will see more than $400,000 in recoupments due to PEPs. To weather the PEP storm, the National Association for Home Care & Hospice suggests HHAs follow these three steps: 1. Review a PEP sample. When CMS makes the PEP information available for all adjustments before it starts recovering the funds, agencies should review a sample of the claims for errors. If they find any, they should contact their intermediary. 2. Establish a reserve. To minimize cash flow impact, HHAs should establish a reserve for their potential PEP liability. 3. Hope for victory. If NAHC and the other trade associations are successful in convincing the Centers for Medicare & Medicaid Services to forgive some of the PEP debt, agencies' liability will be reduced. Await the final word.