Home Health & Hospice Week

Medical Review:

TPE Performance Is Going The Wrong Way

More HHAs wind up in ‘significant’ error category in latest results.

When Medicare launched its Targeted Probe and Educate medical review campaign last year, providers were hopeful they would get the hang of it and the extreme TPE failure rates would improve. Instead, the opposite seems to be happening.

New results from HHH Medicare Administrative Contractor CGS show that out of 152 completed probes in the quarter ended Sept. 30, only one home health agency was found “compliant” — a tiny 0.65 percent.

In comparison, last time CGS reported TPE results, which went from Oct. 1, 2017 through March 31, 2018, about 20 percent of agencies were found “compliant” and 80 percent went on to round 2 (see Eli’s HCW, Vol. XXVII, No. 20).

HHH MAC Palmetto GBA didn’t publicly report how many agencies failed TPE round 1, but did tell Eli that as of May 23, 2018, reviewers had denied about 30.7 percent of claims (see Eli’s HCW, Vol. XXVII, No. 21).

While failure rates appear to have increased dramatically for CGS agencies, “the areas of noncompliance virtually [are] the same ones, particularly face-to-face documentation,” points out National Association for Home Care & Hospice President William Dombi.

Keep in mind that the TPE failure rate likely wouldn’t hold true for the entire industry. “These agencies were targeted to be included in the reviews,” notes consultant Joe Osentoski with QIRT in Troy, Michigan.

Another big difference: The new CGS results show a higher proportion of agencies in the “significant” risk category. From July 1, 2018, to Sept. 30, 85 percent of agencies fell in the “significant” category (indicating an error rate greater than 50 percent), 14 percent in the “moderate” category (error rate 26 to 50 percent), and 1 percent in the “minor” category (error rate 0 to 25 percent).

In contrast, during the time period from Oct. 1, 2017, to Sept. 30, 2018, 79 percent of agencies reviewed fell into the significant category, 18 percent moderate, and 3 percent minor. If you removed the latest quarter data from that, presumably the difference would be even greater.

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