Creator: Patrick Connole
PEPPER Review Time Is Here After CMS Release
CMS has released the FY25 Program for Evaluating Payment Patterns Electronic Report or PEPPER, for SNFs, making it the right time to review for teams.
The Centers for Medicare and Medicaid Services (CMS) has released the Fiscal Year (FY) 2025 Program for Evaluating Payment Patterns Electronic Report (PEPPER) for skilled nursing facilities after a hiatus.
Alicia Cantinieri, managing director, clinical reimbursement and regulatory compliance, Zimmet Healthcare Services Group, said the FY 2025 release analyzes Medicare Part A claims from the three most recent federal fiscal years, FY 2023 through FY 2025.
“PEPPER identifies target areas associated with improper payments and helps facilities identify potential overpayments and underpayments,” she said.
Based on the data used, most MDS assessments included are beyond the two-year deadline from the ARD to submit modifications.
“As always, facilities must report any overpayments to the MAC for correction. Facilities should review their PEPPER to identify potential outlier billing patterns, prioritize areas for internal auditing and compliance monitoring, and address potential needs for education and changes in billing patterns,” Cantinieri said.
“Keep in mind, outlier designation does not necessarily indicate an improper payment or billing error, but it does indicate the need for facility review as improper practices may also impact assessments and billing after the FY 2025 claims. The reports are available through the secure PEPPER Portal.”
CMS Target Areas
Jennifer Napier, practice director, Engage Consulting, said what is surprising in the new release of the PEPPER reports is that PDPM NTA component comparative billing data is silent and not represented.
“This was not an area on the reports historically, however, it would be a measure that would provide good insight in the future of PEPPER reports, as we continue to analyze PDPM comparative data,” she said.
The new CMS PEPPER release includes the following six Target Areas:
| Represents the HIPPS codes, TC, TD, TF, TG, TJ, TK, TN, or TO |
| Represents the HIPPS codes SC, SF, SI, or SL |
| Represents the Nursing HIPPS code representing the Nursing group: A, B, C, D, H, or L |
| Count of beneficiary episodes ending in the report period with a length of stay (LOS) of 20 days. |
| Count of beneficiary episodes ending in the report period with a length of stay (LOS) greater than or equal to 90+ days. |
| Count of readmissions within three to five calendar days (four to six consecutive days) to the same SNF for the same beneficiary occurring during a beneficiary episode ending in the report period. |
The comparative data on the PEPPER reports will give providers insight for the first three (3) targets of:
National 80th and 20th Percentile
Jurisdiction 80th and 20th percentile
State 80th and 20th percentile
Target area percent for SNF
For the remaining 3 targets (20-Day and 90+ Day episodes, and Readmissions), these reports will give insight for:
National 80th Percentile
Jurisdiction 80th percentile
State 80th percentile
Target area percent for SNF
Authorized officials (AOs), access managers (AMs), and staff end users (SEUs) can download their organization’s report from the PEPPER Portal. CMS also provides information on how one can become an SEU.
Comments or questions? Contact Patrick Connole at pconnole@parkplacelive.com.
