CMS Program for Evaluating Payment Patterns Electronic Reports (PEPPER) reports will be released soon. PEPPER is a Medicare Part A claims data report that compares your SNF to state, national and MAC or FI jurisdiction data. PEPPER 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
6) 90+ day episodes of care.
PEPPER Reports will NOT be mailed to you
The PEPPER website says SNF PEPPER reports will be available for electronic access between May 5 and 12—and may be available as soon as late April. Hospices should be able to access their PEPPERs on or about April 25, 2014.
Unlike like last year’s PEPPERs, these reports will NOT be mailed to you. They will be available online to the SNF administrator, CEO or President. To be sure you receive notice that your PEPPER is available for access online, submit your information to TMF, the CMS contractor preparing and distributing the reports, now.
Why PEPPER matters
Your PEPPER report can help you compare your facility to other SNFs, and determine whether you have been identified as an outlier at risk for improper payments. PEPPER considers a SNF 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. See MPA’s website for more information about PEPPER data and your compliance auditing strategy.
The PEPPER website has this advice for providers seeking their PEPPER reports:
- Access to the PEPPER will be restricted to the provider’s Chief Executive Officer, President or Administrator. Corporate offices and/or facility management companies will need to obtain PEPPERs from each individual provider in their organization.
- Requestors will be required to enter their 6-digit CMS certification number (also referred to as a provider number or PTAN). This is *not* the same number as the tax identification number or national provider identification number.
- For verification purposes, requestors will be required to enter either a patient control number (found at form locator 03a on the UB04 claim form) *or* a medical record number (found at form locator 03b on the UB04 claim form) for a fee-for-service Medicare patient who received services at the provider during a specified time period (either the “From” or “Through” date on the claim is during the time period) (TMF will determine this time period closer to report distribution).