Targeted Probe and Educate reviews target agencies with the highest risk profile: elevated denial rates or billing patterns that stand out from the rest of the market. With CMS’s 2026 enrollment moratorium, the new CRUSH program integrity initiative, and expanded TPE and UPIC activity, oversight is intensifying — and it isn’t only agencies doing something wrong who get pulled in. Rapid growth, high live-discharge rates, and ownership changes can trigger a closer look too.
The agencies that come through cleanly aren’t scrambling when the ADR letter arrives. Here’s how to get ahead of it:
- Know your data. Pull your PEPPER report and track denial trends every quarter, not just at recert or survey.
- Fix it in IDG. Document objective clinical decline tied to the LCD at every IDG, and assign an owner to close each narrative gap before the next visit.
- Build response readiness. Know today who owns your ADR response and the submission deadline — TPE windows are tight, and missed deadlines can mean automatic denials.
- Audit quarterly. Bring in an outside chart review each quarter — like Senior Options provides — to catch drift before a MAC does.
If your last documentation audit was at your last survey, that’s a gap worth closing now.
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