PEPPER Reports

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Skilled Nursing Facilities to Receive PEPPER CMS will make available free provider-specific comparative data reports for skilled nursing facilities (SNFs) nationwide. The Program for Evaluating Payment Patterns Electronic Report (PEPPER) provides SNF-specific data statistics for Medicare services that may be at risk for improper Medicare payments. SNFs can use the data to support internal auditing and monitoring activities. PEPPER is a free report comparing a SNF’s Medicare billing practices with other SNFs in the state, Medicare Administrative Contractor (MAC) or Fiscal Intermediary (FI) jurisdiction, and nation. CMS has contracted with TMF® Health Quality Institute to develop and distribute the reports. The report’s goal is to have skilled nursing facilities focus on areas in which they are an outlier. If you fall into the outlier areas of any aspects of this report, CMS feels you may be at a high risk for improper payments relating to up-coding AND down-coding mistakes.
The report focuses on the following areas:

  1. Therapy RUGs with High ADLs — for example, rehab+extensive services, or rehab with “C” ADL scores
  2. Non-therapy RUGs with High ADLs —nursing only RUGs, no therapy
  3. Change of Therapy Assessments — the number of  COT MDS’ your facility completes on a regular basis
  4. Ultra High Therapy RUGs — Ensure documentation supports the RUGs.
  5. Therapy RUGs — compared with nursing-only RUGs
  6. 90+ Day Episodes of Care — reviewing extended length-of-stays

You fall into the outlier categories if you are above the 80th percentile (too many) or below the 20th percentile (too few). The report gives your provider-specific information, and provides you with the specific data, to see where you fall. SNFs administered through short-term acute care hospitals received their SNF PEPPER electronically starting in late August, 2013. The SNF PEPPER file will be uploaded to the File Exchange inbox of hospital QualityNet Administrators and user accounts with the PEPPER recipient role. Free-standing SNFs and SNFs administered through long-term acute care hospitals and inpatient rehabilitation facilities received their PEPPER in hard copy format via USPS first-class mail, shipped on August 30, 2013. The envelope containing the PEPPER will be addressed generically to the Chief Executive Officer/Administrator. SNFs should be on the look-out for this envelope and ensure it is appropriately routed internally. For more information on the SNF PEPPER, including training and resources for SNFs and the SNF PEPPER User’s Guide, please visit PEPPERresources.org. Questions may be submitted through the Help Desk. CMS encourages SNFs to provide feedback on PEPPER through a feedback form so that the reports can be continually improved.

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