In active PPEO, every claim is subject to 100% prepayment review. A documentation gap that would have been a recoupment risk six months ago is a denial-before-payment event today. We audit the gaps before Palmetto does.
The Provisional Period of Enhanced Oversight is CMS's enrollment-control mechanism for hospice. Since December 30, 2024, every newly enrolled, reactivated, or CHOW hospice enters a mandatory PPEO period during which 100% of Medicare claims are subject to prepayment review by the MAC before payment is released.
This is not a post-payment audit with recovery risk. It is a hold-before-payment mechanism. A claim that would have been paid on Tuesday and audited twelve months later is now sitting in Palmetto's review queue. The hospice carries the receivable. The documentation has to be right before the check clears.
Through December 2025, 181 of 817 hospices reviewed under PPEO had their enrollment revoked — a 22% revocation rate. The documentation patterns driving those revocations are known: weak certification of terminal illness narratives, untimely face-to-face encounters, GIP level-of-care without supporting documentation, and Bene Sharing patterns flagged under Palmetto's active TPE edits.
The purpose of this assessment is to find those patterns before Palmetto does, produce a findings report your team can act on, and equip your organization with a mock ADR packet built to the Palmetto Hospice Coalition Q&A standard.
Every PPEO Readiness Assessment includes all five components below — no optional add-ons, no scope negotiation. The $1,499 fee covers the complete engagement from kickoff through report delivery.
Ten-chart review of certification of terminal illness documentation, CTI narrative quality, attending physician and hospice medical director signatures, and election statement completeness. Each chart scored against Palmetto's documented denial patterns.
Observation of two consecutive weekly Interdisciplinary Group meetings. Assessment of § 418.56 compliance: attendance, documentation, care-plan update process, and physician participation. Findings documented for the report.
Medical director verified across five sources: OIG LEIE, PECOS enrollment status, state medical board licensure, Care Compare lookback for prior hospice affiliations, and SAM.gov. CMS has expanded revocation triggers based on medical director affiliation patterns.
A complete mock ADR packet assembled to Palmetto Hospice Coalition Q&A specification — the format Palmetto expects when an ADR lands. Built using the same charts audited in Component 01, organized by denial driver: Bene Sharing, Long-LOS, RHC, GIP, F2F.
Institutional-voice findings report covering all four prior components. Each finding tied to a specific regulatory citation (42 CFR Part 418, CMS IOM Pub. 100-02, Palmetto LCD). Prioritized corrective action recommendations. Delivered within 21 days of kickoff.
Every component of this assessment produces a documented output. The final report is a single 9-page institutional-voice document — not a slide deck, not a checklist.
Each of the ten audited charts receives an individual findings notation — certification adequacy, CTI narrative quality, signature status, election statement completeness. Deficient charts are flagged with the specific regulatory standard not met.
Written summary of both observed IDG meetings against the § 418.56 standard. Attendance, documentation, care-plan update process, and physician participation each rated and documented.
Five-source verification result for your medical director, documented with source-by-source findings. Any revocation-adjacent affiliation pattern is flagged with recommended next steps.
A complete, ready-to-adapt ADR response template built to Palmetto spec, organized around your most likely denial drivers based on the chart audit findings. When a real ADR lands, your team has a structural framework already built.
Every finding is accompanied by a recommended corrective action, a regulatory citation, and a suggested timeline. The register is formatted for direct use in a compliance plan or board presentation.
Any hospice that obtained Medicare certification on or after December 30, 2024 enters PPEO automatically. If you are newly enrolled and have not had a documentation-specific compliance review, this assessment is the first thing that should happen.
A hospice whose Medicare billing number was reactivated after a voluntary deactivation or lapse in billing is treated as a new enrollment under PPEO rules. The same prepayment review requirement applies from the reactivation date forward.
A hospice that completed a CMS-approved Change of Ownership transaction on or after December 30, 2024 enters PPEO under the acquiring entity. Buyers who did not account for PPEO in due diligence need an immediate baseline assessment of the acquired operation's documentation posture.
Established hospices not currently in PPEO but operating in Georgia under Palmetto JM HHH — where Bene Sharing and Long-LOS TPE edits are actively generating ADRs — can use the PPEO Readiness framework as a proactive documentation audit before a TPE letter arrives.
30-minute call to confirm enrollment status, census size, current ADR exposure, and EMR system. SOW issued within 24 hours. No charge for the call.
Signed SOW and payment confirm the engagement. Chart selection criteria sent within 48 hours. IDG observation dates scheduled. 21-day clock starts.
Chart review, IDG observations, and medical director affiliation check conducted. Georgia hospices may receive on-site; remote conducted via secure screen-share for out-of-state PPEO states.
9-page findings report and mock ADR packet delivered via encrypted transfer on or before Day 21. Optional 30-minute debrief call to walk through priority findings.
Every week without a documentation assessment is another week of prepayment exposure on the same patterns. We confirm scope on the call and issue the SOW within 24 hours.