Now that the Centers for Medicare and Medicaid Services (CMS) has said it will relaunch the CMS Program for Evaluating Payment Patterns Electronic Report (PEPPER), SNFs should be in prep mode when the agency makes the forms available for Medicare facilities, including hospitals, post-acute care providers, and specialty facilities.

PEPPER is a free Excel-based tool to help review Medicare billing data to identify high-risk areas such as billing patterns that may need review or improvement, identify areas that may need closer monitoring or internal/third-party audits, and track trends, including longer lengths of stay, according to Alicia Cantinieri, managing director, clinical reimbursement and regulatory compliance, Zimmet Healthcare Services Group.

“It is meant to be a tool for facilities to proactively identify areas that make them more likely to be on CMS's audit radar,” she said.

As of today, PEPPER is available only to short-term acute care hospitals. However, other provider types, including SNFs, should begin preparing now to ensure they can access their reports once CMS announces their availability, Cantinieri said.

Birds-Eye View

Michele Stern, director of clinical education and training, R2 – Reimbursement Reimagined, said facilities provide a wide range of interdisciplinary services and accurate documentation of those services and interventions is crucial for both the continuity of care but also reimbursement for all eligible services being provided.

“While audit tools can be valuable in assisting with compliance and documentation review, it's important to consider the administrative burden they may place on the facility — especially when it involves restating what is already in the medical chart,” she said. 

Where to Go

Instructions for accessing PEPPER and obtaining an Identity & Access (I&A) Management System account are available on the PEPPER website at Home, including the PEPPER I&A Quick Reference Guide and the PEPPER Frequently Asked Questions document.

By establishing PEPPER access now and using available analytics tools, providers will be well-positioned to review their PEPPER reports as soon as CMS makes them available, Cantinieri said.

Comments or questions? Contact Patrick Connole at pconnole@parkplacelive.com.