If you fail three rounds of Targeted Probe & Educate review, the Centers for Medicare & Medicaid Services has threatened serious action. But the result might actually be … just more review. When CMS launched the TPE program, it explained there would be three rounds of TPE, if providers failed each round. Then HHH Medicare Administrative Contractors would refer the case to CMS for “further action.” That action could range from “100 percent prepay review, extrapolation, referral to a Recovery Auditor, or other action,” CMS indicates on its TPE webpage. But in one case at least, the “further action” was a fourth round of TPE. Referring providers to CMS because of failed TPE rounds is “uncommon,” an official at MAC National Government Services said in an Oct. 10 Jurisdiction 6 Home Health Provide Outreach and Education Advisory Group meeting. “One HHA has been referred to CMS following three rounds of TPE, and the CMS directive was to do a 4th round of TPE review for this provider,” the NGS staffer reported, according to the recently posted meeting minutes. Stats: “Since TPE was implemented in 2017, approximately 10.5 percent of all J6 HH providers have been reviewed,” the NGS official also shared.