Remember PEPPER? New Data Elements + Annual Reports Coming

Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare

PEPPER (Program for Evaluating Payment Patterns Electronic Report) is still very much alive and there are updates that you need to be aware of.

On March 30, 2021, the SNF PEPPER User’s Guide, Ninth Edition was posted to the PEPPER Resources website.   This is a 15-page Users Guide.  Please download it and reference it when reviewing your report.  On or about April 5, 2021, your SNF’s PEPPER report will be available for you to download and carefully review.  This is not a report you/your team can afford to ignore!

Remember that PEPPER does not identify the presence of improper payments, but it can be used as a guide for auditing and monitoring efforts. A SNF can use PEPPER to compare its claims data over time to identify areas of potential concern and to identify changes in billing practices.

The SNF PEPPER is available to the SNF’s Chief Executive Officer, Administrator, President, Quality Assurance and Performance Improvement Officer, or Compliance Officer through a secure portal on the website. Each SNF receives only its PEPPER. The PEPPER Team does not provide PEPPERs to other contractors, although the PEPPER Team does provide a Microsoft Access database (the First-Look Analysis Tool for Hospital Outlier Monitoring [FATHOM]) to MACs and Recovery Auditors. FATHOM can be used to produce a PEPPER.

Here’s the distribution schedule for all entities that receive annual PEPPER reports:

Portal access for SNFs (the above hyperlink provides access directions for all provider types):

Below is the Table of Contents of the updated Guide:

The SNF PEPPER Target Areas are now:

These PEPPER target areas were identified by CMS as being potentially at risk for improper Medicare payments. A high target area percent does not necessarily indicate the presence of improper payment or that the provider is doing anything wrong; however, under these circumstances, providers may wish to review their medical record documentation to ensure that the services their beneficiaries receive are appropriate and necessary, as well as to ensure that the documentation in the medical record supports the level of care and services for which they have received Medicare reimbursement.

The first digit of the PDPM code represents the Physical and Occupational Therapy component of the SNF services. Those codes beginning with C, D, G, H, K, L, O, or P are equivalent to the ultrahigh rehabilitation and very high rehabilitation Resource Utilization Groups, which were prone to overuse/abuse.

The following table can assist SNFs with interpreting their percentile values, which are indications of possible risk of improper Medicare payments:

Who benefits from PEPPER?

If you have never accessed your facility’s PEPPER report, this is the link to request access.  This is what you’ll see:

The entire PEPPER Resources website is a wealth of information.  Bookmark it and reference it often.  Join the email list for PEPPER updates here.