Top 3 Reasons Targeted Case Management Audits Fail

04/20/2023 By Nancy Leidelmeijer

Targeted Case Management is a federally-funded program that provides support and assistance to individuals with developmental disabilities or serious mental illness. The program is designed to address the complex needs of these individuals by providing them with access to healthcare, housing, employment, and counseling services, among others. TCM audits are conducted regularly to ensure the program operates efficiently and effectively and meets applicable regulations and guidelines.

1 - Inadequate documentation and record-keeping practices

Providers must maintain accurate and complete documentation to support the services provided to clients. Proper documentation is essential to support the medical necessity of services, ensure compliance with regulations and guidelines, facilitate effective communication between healthcare providers, support billing and payment for services, and provide a legal record of services provided. Common documentation mistakes include failure to document services adequately, leaving out identifying information about the client, not keeping records up to date and organized, using abbreviations that are not universally recognized, and changing records after the fact.

To improve record-keeping practices, providers can implement clear and consistent documentation procedures, ensure all records are complete and up to date, implement training for staff on best practices and documentation requirements, have a second person review records for accuracy, and use software to help manage records and reduce human error.

2 - Inadequate training and supervision of staff

Providers must ensure that all staff members receive adequate training on best practices and documentation requirements and are appropriately supervised. Inadequate training and supervision can result in staff members not understanding their roles and responsibilities, not following proper procedures, making errors in documentation, and not providing appropriate services to clients.

Providers can establish clear guidelines for training and supervision, provide ongoing training opportunities for staff members, and regularly evaluate staff performance.

3 - Lack of compliance with regulations and guidelines

Providers must comply with all applicable state and federal regulations and guidelines, including items related to documentation, service delivery, and billing. Non-compliance can lead to costly fines, penalties, and loss of eligibility to participate in the program. To improve compliance practices, providers can establish policies and procedures consistent with regulations and guidelines, provide ongoing training to staff on compliance requirements, and regularly review and update policies and procedures to ensure compliance.


TCM audits are an essential part of the Targeted Case Management program. Providers must ensure they have adequate documentation and record-keeping practices, provide adequate training and supervision to staff members, and comply with all applicable regulations and guidelines to avoid audit failures. By implementing best practices and maintaining compliance, providers can ensure that they are providing high-quality services to individuals with developmental disabilities or mental health conditions, promoting their well-being and independence, and reducing their reliance on other healthcare services.