In addition to ensuring that data programs and documentation programs are performing optimally, Hayes Management suggests the following steps to anticipate what TPE requests might look like this year:
* Implement an aggressive pre-emptive auditing program to investigate and address possible risk areas.
* Review what CMS requested in 2018 in other audits and assess risk in those areas first.
* Examine historical data for any prepayment (precertification) and preclaim adjudication audits that CMS has performed.
* Review CMS explanations for denials and additional information the agency has requested.
* Look at historical data (not necessarily TPE related but also other prepayment reviews) that CMS has performed for the organization. Identify the trends and risks and insert them into the annual compliance plan.
* Focus on ensuring your coding and documentation integrity.