When they’re outdated or missing signatures, treatment plans may be fatal to claims for outpatient psychiatric services under Targeted Probe and Educate (TPE), CMS’s medical-review strategy. And if the error rate is high enough, Medicare administrative contractors (MACs), which run TPE, will hold educational calls with hospitals and other behavioral health providers and audit the claims a second time—although the calls are reportedly fruitful for preventing subsequent denials, unlike some of the interactions with the MACs during past audits.

That has been the experience of Stephen Gillis, director of compliance coding, billing and audit at Partners HealthCare in Boston. After a TPE outpatient psych audit didn’t go well for a Partners hospital, Gillis spoke in mid-April with a MAC nurse reviewer who was familiar with the denied claims.

“It was collaborative,” he says. That’s a good thing, because “to get out of the TPE process, the payment error rate will need to be at or below 15%.”

Outpatient mental health services are a target of TPE across the country. Mistakes in this area are prevalent, which is a longstanding problem that has been amplified by Medicare’s adoption of new CPT codes in 2013.