TPE Audits: Key Steps for Medicare Providers to Prepare and Succeed
If you bill Medicare for therapy services, a TPE audit is not something you can ignore, but a reality that every provider should be ready for. The Targeted Probe and Educate (TPE) program, run by the Centers for Medicare & Medicaid Services (CMS), is designed to improve accuracy, reduce claim denials, and give you one-on-one guidance to fix billing or documentation errors.
In this guide, we’ll walk through what a TPE audit is, how MACs partner with you to ensure proper claims submissions, the most common triggers for therapists, and strategies to prepare audit-proof documentation confidently.
What is a TPE Audit?
The Targeted Probe and Educate (TPE) is a specialized Medicare review that focuses on providers with heightened rates of claim errors.
If you submit claims to Medicare, TPE audits are a critical process you need to understand. CMS started using TPE audits to help ensure accuracy and compliance while also supporting providers with education and feedback.
Rather than penalizing you immediately, local Medicare Administrative Contractors (MACs) work directly with providers, often in person, to identify simple but costly mistakes, like a missing physician’s signature or incomplete therapy notes. The goal is to help you quickly correct errors, strengthen your compliance, and maintain uninterrupted Medicare participation. Learn more about MACs and the TPE process here.
For therapists and Medicare Providers, understanding how this process works is the first step in removing the anxiety around audits.
Purpose of a TPE Audit for Medicare Claims
A TPE audit is not a random review. Medicare pinpoints patterns of mistakes or areas where incorrect billing is common.
If your claims stand out due to frequent errors, incomplete documentation, or other issues, you may be selected for an audit. The intent is to address mistakes directly with you, allowing for correction and improvement rather than immediate penalties.
How TPE Audits Work (Step-by-Step)
The TPE audit process involves several steps:
Selection: Medicare uses data analysis to select providers who show higher-than-average issues in claims. This could mean billing the wrong codes or inconsistencies in your documentation.
Record Request: You will receive a letter asking for records related to a specific group of claims. Medicare reviews these to check for compliance with policy.
Education: After the first review, you may receive personalized education on any identified mistakes. MACs often conduct these sessions to explain exactly what went wrong and how to correct it.
Follow-up Reviews: If errors persist, Medicare will conduct up to two more rounds of audits, each time offering more education and support.
Throughout this process, the focus is on improvement.
Providers who resolve issues early may finish the TPE audit faster. If errors continue after three reviews, Medicare may refer the case for further action, such as a prepayment review or investigation.
Common Myths About TPE Audits
Understandably, there is a lot of confusion and stress around TPE audits for Medicare claims.
Some providers worry these are automatic penalties or that a single mistake triggers one. The reality is that TPE audits are designed to give you time and support to get things right.
With clear documentation and proper coding, most can successfully address audit findings. Here's a quick summary of what TPE audits are not:
They are not random; they are data-driven.
They are not designed to trap you, but to educate.
You are not immediately penalized for honest mistakes.
Why Compliant Medicare Documentation Matters
Your progress notes and claims must tell the full story of each session. Inaccurate billing, like mismatched codes or missing time details for therapy sessions, often triggers audits. For example, billing 90837 should clearly show at least 53 minutes of service, with time details included in your note.
When notes are incomplete or don’t line up with billing, you’re more likely to get flagged.
Need a refresher on preparing documentation to be audit-ready from the start? Review this information on how to prepare for insurance audits with Medicare-compliant documentation.
Common Triggers for TPE Audits
Billing Errors: Mismatched codes and notes, missing time elements, or outdated CPT codes.
Provider Outliers: Billing patterns that differ from your peers, such as unusually high numbers of long-session codes or sudden increases in claim volume.
Using a Medicare billing checklist helps ensure consistent, accurate submissions across your practice.
How to Prepare for a TPE Audit
Organize and review documentation: Ensure every session note includes date, time in/out, service code, patient identifiers, and medical necessity justification.
Educate staff: Make sure your team understands Medicare rules and follows the same documentation practices.
Respond quickly to TPE Audit requests: Track deadlines, keep copies of everything submitted, and double-check completeness before sending.
Best Practices to Prevent TPE Audits
Here’s how to keep your practice from getting flagged for errors from the start:
Perform routine self-audits to catch and fix documentation or billing issues early.
Stay updated on Medicare policy changes by subscribing to CMS bulletins, joining professional groups, and attending webinars.Write notes that serve your client’s care needs and meet Medicare’s standards.
Streamline your systems with the exact progress note template I used in my own practice!
A Solution-Oriented Approach
Mastering an audit-proof practice is about more than avoiding penalties from TPE audits. It’s about building a reliable, compliant practice that serves clients reliably and protects both the client and the provider.
Consistent documentation, accurate CPT code use, and proactive self-audits protect your reputation, revenue, and patient trust. And when you treat MACs as partners rather than adversaries, you transform an audit into an opportunity for professional growth.
In short: stay informed, stay organized, and stay ahead of Medicare policy changes. Your preparation today ensures you can face any TPE review with confidence tomorrow.
Don’t wait until you get that audit letter. If you want expert eyes on your documentation before a TPE audit or help creating a Medicare compliance plan, schedule a discovery call today.
Gabrielle Juliano-Villani, LCSW, helps healthcare organizations, online platforms, and mental health providers navigate Medicare & Medicaid with confidence. With over a decade of experience supporting mental health providers in navigating billing, compliance, and documentation, she now offers consulting and training to help others grow sustainable, compliant practices.