Breaking Compliance News Blog

2017 PEPPER Reports are here! Are you an outlier?

Posted by Margaret Scavotto, JD, CHC on 5/8/18 7:00 AM

2017 PEPPER Reports are here! Are you an outlier?

The latest PEPPER (Program for Evaluating Payment Patterns Electronic Report) reports have been released for SNF, LT, IRF, IPF, CAH and hospice providers. You can access your PEPPER online. Home health providers and partial hospitalization programs can expect their PEPPERs to arrive in July 2018.

This latest PEPPER uses statistics for October 1, 2016 through September 30, 2017, and will be available for download for approximately two years.

To download your PEPPER, the Compliance Officer, CEO, President or Administrator needs to:

  1. Visit the PEPPER Resources Portal
  2. Enter your information. You will need a Patient Control Number (form locator 03a on the UB04) or a Medical Record Number (form locator 03b) for a claim of a traditional fee-for-service (FFS) Medicare patient/beneficiary who was receiving services at this provider with a “From” or “Through” date between July 1 - 30, 2017).
  3. Download your PEPPER.

If you need help, review the Secure PEPPER Access Guide.

Why PEPPER matters

Your PEPPER report can help you compare your organization to other providers, and determine whether you have been identified as an outlier at risk for improper payments. PEPPER considers a provider to be an outlier if its Target Areas are at or above the 80th percentile, or at or below the 20th percentile, depending on the area. If your PEPPER shows you are an outlier, an internal audit should be conducted to identify any improper payments or non-compliant practices. CMS is quick to point out that variances from the national data do not necessarily mean billing irregularities have occurred. However, it would be wise to determine why the government has identified you as an outlier.

In other words, the government is mining your data and evaluating your claims—and so should you. By incorporating PEPPER data into your compliance auditing strategy, you can identify potential areas of non-compliance that could make you a government target. And of course, a "good" PEPPER should not give you false confidence about your claims – MPA recommends conducting documentation reviews to ensure claims are appropriate, even if you aren't an outlier.

Don’t wait

PEPPER comes once a year, but our attention to it should be ongoing. Don't wait for the report to be released in April. Work with your billing department to see what reports you can run internally to track the Target Areas as part of your compliance efforts. This way, there will be no surprises in April 2019.

Are you an outlier? Download  MPA's Guide to  PEPPER Reports  to find out

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Topics: PEPPER

The government is monitoring your claims data. Are you?

Posted by Margaret Scavotto, JD, CHC on 1/9/18 7:05 AM

Chemed Corporation, Vitas Hospice Services LLC, and Vitas Healthcare Corporation entered a $75 million settlement with the government to resolve false claims allegations. Vitas, the biggest for-profit provider of hospice services in the nation, allegedly “knowingly submitted or caused to be submitted false claims to Medicare for services to hospice patients who were not terminally ill” between 2002 and 2013. The DOJ also accused Vitas of awarding bonuses to employees based on the number of patients on hospice, regardless of need.

In addition, Vitas was accused of billing Medicare for continuous home care services that were not necessary, not provided, or did not meet Medicare requirements. Like with hospice services, Vitas allegedly set corporate goals for billing continuous home care services, regardless of patient need.

According to the Complaint, “Vitas regularly ignored concerns expressed by its own physicians and nurses regarding whether its hospice patients were receiving appropriate care.” Complaint, page 3. The Complaint also says the company’s own auditors knew of the problem – but changes were not made.

 

Let’s look at the data

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Topics: Billing and Claims Submission, Auditing and Monitoring, Penalties and Enforcement, PEPPER

PEPPER Report Card Arrives: How did we do?

Posted by Margaret Scavotto, JD, CHC on 8/17/16 6:30 AM

The PEPPER website released a map showing the percent of providers who have accessed their 2015 PEPPER reports (released in April 2016).

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Topics: PEPPER

2016 PEPPER Reports are here! Are you an outlier?

Posted by Margaret Scavotto, JD, CHC on 4/13/16 11:50 AM

PEPPER (Program for Evaluating Payment Patterns Electronic Report) reports for Q4FY15 have been released for SNF, LT, IRF, CAH and hospice providers, a few days ahead of schedule! You can access your PEPPER online. Home health providers can expect their PEPPERs to arrive in July.

This latest PEPPER uses statistics through September 2015, and will be available for download for approximately two years.

To download your PEPPER, the Compliance Officer, CEO, President or Administrator needs to:

  1. Visit the PEPPER Resources Portal
  2. Enter your information. You will need a Patient Control Number (form locator 03a on the UB04 claim form) *or* a Medical Record Number (form locator 03b on the UB04 claim form) for a claim of a traditional fee-for-service (FFS) Medicare patient/beneficiary who was receiving services at this provider with a “From” or “Through” date between September 1 - 30, 2015).
  3. Download your PEPPER.

If you need help, review the Secure PEPPER Access Guide.

Why PEPPER matters

Your PEPPER report can help you compare your facility to other providers, and determine whether you have been identified as an outlier at risk for improper payments. PEPPER considers a provider to be an outlier if its Target Areas are at or above the 80th percentile, or at or below the 20th percentile, depending on the area. If your PEPPER shows you are an outlier, an internal audit should be conducted to identify any improper payments or non-compliant practices. CMS is quick to point out that variances from the national data do not necessarily mean billing irregularities have occurred. However, it would be wise to know whether there is a reason why the government has identified you as an outlier.

In other words, the government is mining your data and evaluating your claims—and so should you. By incorporating PEPPER data into your compliance auditing strategy, you can identify potential areas of non-compliance that could make you a government target. And of course, a "good" PEPPER should not give you false confidence about your claims - it is a good practice to conduct documentation reviews to ensure claims are appropriate, even if you aren't an outlier.

MCS_Photo_Signature.jpg

Are you an outlier? Download  MPA's Guide to  PEPPER Reports  to find out

Read More

Topics: PEPPER

Did You Forget About PEPPER?

Posted by Margaret Scavotto, JD, CHC on 8/11/15 2:00 PM

PEPPER (Program for Evaluating Payment Patterns Electronic Report) reports were released for nursing homes and other providers in April 2015 (and are coming soon for home health in July). Last year, only half of nursing homes had accessed their reports three months after the release date.

A Missed Opportunity

That's too bad, because PEPPER is a powerful compliance tool that tells providers how the government sees them.

This report compares your SNF's Medicare Part A claims data to state, national and MAC or FI jurisdiction data. This report includes this comparative data for six Target Areas: 1) Therapy RUGs with high ADLs; 2) Nontherapy RUGs with high ADLs; 3) Change of therapy assessments; 4) Ultrahigh therapy RUGs; 5) Therapy RUGs; and 6) 90+ day episodes of care.

With PEPPER reports, the government processes providers' claims data for them and tells them if they are seen as high-risk. This report is a gift to providers and should be the first place we start when planning a compliance audit strategy.

What You Can Do

  • Get online. If you haven't already, log on to www.pepperresources.org and retrieve your report. See if your report identifies you as an outlier (if you are at or above the 80th percentile, or in some cases at or below the 20th percentile) in any target areas.
  • Audit. If your report shows you are an outlier, an internal audit should be conducted to identify any improper payments or non-compliant practices. CMS is quick to point out that variances from the national data do not necessarily mean billing irregularities have occurred. However, it would be wise to know whether there is a reason why the government has identified you as an outlier.
  • Don't wait. PEPPER comes once a year, but our attention to it should be ongoing. Don't wait for the report to be released in April. Work with your billing department to see what reports you can run so that you can track the Target Areas as part of your compliance efforts, at least quarterly. This way, there will be no surprises in April 2016, and you can address any improper payments as they arise.

Are you an outlier? Download  MPA's Guide to  PEPPER Reports  to find out

MCS_Photo_Signature

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Topics: PEPPER, Auditing and Monitoring

PEPPER 2015 Is Here! Are You An Outlier?

Posted by Margaret Scavotto, JD, CHC on 4/16/15 1:44 PM

PEPPER (Program for Evaluating Payment Patterns Electronic Report) reports for Q4FY14 have been released--a few days ahead of schedule! You can access your PEPPER online.

This latest PEPPER uses statistics through September 2014, and will be available for download for approximately two years.

To download your PEPPER, the CEO, President or Administrator of the SNF needs to:

  1. Visit the PEPPER Resources Portal
  2. Enter your information. You will need a Patient Control Number (form locator 03a on the UB04 claim form) *or* a Medical Record Number (form locator 03b on the UB04 claim form) for a claim of a traditional fee-for-service (FFS) Medicare patient/beneficiary who was receiving services at this provider between September 1 - 30, 2014 (“From” or “Through” date on the claim is between September 1 - 30, 2014).
  3. Download your PEPPER.

If you need help, review the Secure PEPPER Access Guide.

Not a SNF?

PEPPER might still be coming soon:

 And, for the first time in 2015, PEPPER will be released for home health (expected in July).

Now what?

Learn more about how to use PEPPER as part of your compliance program's auditing strategy.

Are you an outlier? Download  MPA's Guide to  PEPPER Reports  to find out

Read More

Topics: PEPPER, Auditing and Monitoring, Billing and Claims Submission

PEPPER report news for SNFs, hospice, and home health

Posted by Margaret Scavotto, JD, CHC on 2/6/15 7:00 AM

The Program for Evaluating Payment Patterns Electronic Reports (PEPPER) website just got a huge makeover. The re-vamped FAQ and Training and Resources pages can still be found at www.pepperresources.org, which can now be viewed on mobile devices.

When is PEPPER coming in 2015?

For most providers, PEPPER reports are released once a year, and that time is quickly approaching:

What about Home Health?

PEPPER is coming soon to Home Health! Don't miss the boat: sign up for e-mail updates so that you will hear when PEPPER reports are available for home health agencies.

What do I do in the meantime?

Don't wait for PEPPER data to come to you. The PEPPER website puts a lot of data at your fingertips, so that you can make it work for your compliance program. Check out the Data page, and the Training and Resources page. Once you understand the data the government is tracking with PEPPER, look at your organization's own data in the same areas and see how you measure up. Are you an outlier in any of these areas? If so, look deeper to see if you have a potential compliance problem.

Are you an outlier? Download  MPA's Guide to  PEPPER Reports  to find out

Read More

Topics: PEPPER

Throw out your PEPPER by mistake? Your second chance is here.

Posted by Margaret Scavotto, JD, CHC on 7/31/14 4:15 PM

Many providers accidentally threw out the hard copy of their PEPPER (Program for Evaluating Payment Patterns Electronic Report) that was mailed to them in 2013. Because these PEPPERs were generically addressed to Administrator or CEO, many providers believed they were junk mail and discarded them.

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Topics: PEPPER

Nursing Home pays $500,000 for therapy provided by contractor

Posted by Margaret Scavotto, JD, CHC on 7/9/14 1:08 PM

The United States Department of Justice recently entered a $500,000 settlement with an Iowa skilled nursing facility, to resolve allegations that the SNF billed the government for improper therapy provided by a third party therapy services contractor.

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Topics: Penalties and Enforcement, PEPPER, Billing and Claims Submission, medical necessity, Therapy

PEPPER Outlier Reports: Are you part of the 49%?

Posted by Margaret Scavotto, JD, CHC on 7/7/14 3:25 PM

The latest Program for Evaluating Payment Patterns Electronic Reports (PEPPER) reports for SNFs, from 4th Quarter 2013, have been available since May 5. As of June 30, only 49% of SNFs have accessed their PEPPER reports. Are you one of the 49%?

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Topics: PEPPER, Auditing and Monitoring, Billing and Claims Submission

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