What SNF’s need to know about PEPPER

Have you received your provider-specific PEPPER report yet? The Program for Evaluating Payment Patterns Electronic Report (PEPPER) were mailed on August 30 to all free-standing skilled nursing facilities.  The envelopes are addressed to the Facility Administrator. 

The PEPPER report is in direct follow-up from the Office of Inspector General report issued last November discussing how we need to develop a better monitoring system to identify facilities that fall outside of the “normal” in several areas. The report specifically compares each SNF to the national and state averages from the 4th quarter from the past three years for episodes of care ending between Oct. 1, 2009, and Sept. 30, 2012.
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 — such as, rehab+extensive services, or rehab with “C” ADL scores
  2. Non-therapy RUGs with High ADLs — in other words, nursing only RUGs, no therapy
  3. Change of Therapy Assessments — measured by the volume of COT MDS' your facility completes on a regular basis
  4. Ultra High Therapy RUGs — how strong is your clinical documentation to support the utilization of these RUGs?
  5. Therapy RUGs — compared with nursing-only RUGs
  6. 90+ Day Episodes of Care — targeting extended length-of-stays 
According to CMS, if your SNF’s percent is at/above the national 80th percentile or at/below the national 20th percentile, the SNF is identified as at risk for improper Medicare payments.  It also provides details on “Suggested Interventions for High Outliers” and “Suggested Interventions for Low Outliers.” The PEPPER report is a useful tool that can guide compliance audits for areas of risk.  Audit results should be used to develop specific action plans for ensuring compliant documentation and providing education to your employees.

Additional information on the PEPPER program for SNFs can be found at PEPPER Resources
If you have additional questions about the PEPPER program or ways to incorporate your PEPPER report into your compliance program, please contact Lori McLaughlin at lmclaughlin@kdlegal.com.

 
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