TPE (Targeted Probe and Educate) Audits: A Conversation with Kay Hashagen, Senior Consultant with LW Consulting

Episode Date: November 5, 2025

In this episode of Stark Integrity, Kay Hashagen, Senior Consultant with LW Consulting, joins Bob Wade (Captain Integrity) to discuss a topic that often appears routine—but can carry significant compliance risk:

Targeted Probe and Educate (TPE) audits.

The episode highlights a key reality:

TPE audits may seem benign at first—but they can quickly escalate into serious compliance and financial risk if not handled properly.

What Are TPE Audits?

TPE (Targeted Probe and Educate) audits are conducted by Medicare Administrative Contractors (MACs) to:

• Review provider billing practices
• Identify errors or outliers
• Provide education to improve compliance

These audits typically involve:

• A review of a sample of claims
• Feedback to the provider
• Opportunities for corrective action

The takeaway:

TPE audits are intended to improve compliance—but they also signal risk.

Why TPE Audits Matter

While TPE audits are designed as an educational tool, they:

• Focus on providers identified as outliers
• Target specific billing issues
• Can lead to additional scrutiny if problems persist

The key point:

Being selected for a TPE audit means your organization is already on the radar.

Identifying Outliers

A central theme of the episode is:

Understanding whether your organization is an outlier.

Outliers may be identified based on:

• Billing patterns
• Utilization rates
• Comparison to peers
• Historical claims data

The takeaway:

If your data differs significantly from benchmarks, it may trigger a review.

The Audit Process

The TPE audit process generally follows a structured approach:

1. Initial Probe Review
   A sample of claims is reviewed.
2. Education Phase
   The organization receives feedback and guidance.
3. Follow-Up Reviews
   Additional rounds of review assess whether improvements have been made.

The key point:

TPE audits are iterative—and performance in early rounds impacts what happens next.

The Importance of Timely Response

One of the most critical elements discussed is:

Responding to TPE audits promptly and effectively.

Organizations must:

• Submit requested documentation on time
• Ensure accuracy and completeness
• Engage appropriate internal stakeholders

Because:

Delays or incomplete responses can increase risk and trigger further scrutiny.

Education as an Opportunity

Although TPE audits can be concerning, they also provide:

An opportunity to improve.

Organizations can use the process to:

• Identify gaps in documentation
• Correct billing issues
• Strengthen internal controls

The takeaway:

TPE audits are not just enforcement—they are a chance to enhance compliance.

The Risk of Escalation

If issues identified in a TPE audit are not resolved, the consequences can escalate:

• Additional audit rounds
• Expanded reviews
• Potential recoupment of payments
• Increased regulatory attention

The key point:

Failure to improve can turn a manageable audit into a larger compliance issue.

Building a Strong Response Strategy

The episode emphasizes the importance of:

Preparation and coordination.

Organizations should:

• Assemble a cross-functional team
• Involve compliance, coding, and clinical staff
• Review findings carefully
• Implement corrective actions quickly

Because:

A coordinated response improves outcomes.

The Role of Internal Monitoring

To reduce the likelihood of TPE audits—or improve performance during them—organizations should:

• Conduct internal audits
• Monitor billing patterns
• Identify and correct errors proactively

The takeaway:

The best defense is a strong internal compliance program.

Common Pitfalls

Organizations should avoid:

Ignoring Early Findings

Failing to act on initial feedback from auditors.

Poor Documentation

Submitting incomplete or unclear records.

Lack of Coordination

Operating in silos without a unified response.

Delayed Action

Waiting too long to implement corrective measures.

The key point:

Small missteps early in the process can lead to larger problems later.

Practical Steps for Organizations

To effectively manage TPE audits, organizations should:

• Develop a response protocol
• Train staff on audit requirements
• Monitor documentation quality
• Act quickly on feedback
• Track improvements across audit rounds

Because:

Preparation and responsiveness are critical to success.

Key Takeaways

• TPE audits are targeted reviews of billing practices
• They often indicate that an organization is an outlier
• The process includes review, education, and follow-up
• Timely and accurate responses are essential
• Failure to improve can lead to escalation
• TPE audits present an opportunity for improvement
• Strong internal monitoring reduces risk

Final Thoughts

This episode highlights an important truth in healthcare compliance:

Not all audits are created equal—but all audits should be taken seriously.

TPE audits may begin as:

• Focused
• Educational
• Manageable

But they can quickly become:

Complex and high-risk if not handled properly.

Ultimately:

The organizations that succeed are those that act quickly, learn from feedback, and strengthen their compliance processes.

Because in healthcare:

An audit is not just a review—it is an opportunity to improve before the stakes get higher.

Click here to listen to this Stark Integrity Podcast Episode:
https://podcasts.apple.com/us/podcast/tpe-targeted-probe-and-educate-audits-a/id1588939373?i=1000735330213&l=fr-FR