The SNF fourth quarter of FY2021 Program for Evaluating Payment Patterns Electronic Report (PEPPER) is now available for download through the PEPPER Resources Portal. To obtain your SNF PEPPER, the Chief Executive Officer, President, Administrator, Compliance Officer, Quality Assurance/Performance Improvement Officer, or other authorized user within your organization (selecting a job title closest to their title) can access your PEPPER.

What is a P.E.P.P.E.R. (PEPPER)?

PEPPER is a data report that identifies a single SNF’s Medicare claims statistics for certain target areas. The statistics are obtained from the UB-04 claims submitted to the Medicare Administrative Contractors (MACs).

The PEPPER will show a particular SNFs data compared to the MAC aggregate jurisdiction, state, and national statistics. The intent of the PEPPER is to assist SNFs in identification of potential improper payments and compare their data to national, MAC jurisdiction, and state statistics. The PEPPER is not identifying that improper payments took place but rather, identifying potential risk for improper payments and should be used as a guide for auditing and monitoring practices.

The target areas were identified by The Centers for Medicare and Medicaid Services (CMS) as being potentially high risk for improper Medicare payments. The PEPPER includes reporting of reportable data for the most recent three fiscal years, October 1 through September 30. Reportable data is numerator count of eleven or more for any particular target in the time period reviewed. If the numerator count is less than eleven for any particular target area in the time period reviewed, no data will be displayed. 

New to this Edition of the PEPPER

One target area was deleted: PDPM High Utilization Codes.

Two new target areas were added: High Physical Therapy and Occupational Therapy Case Mix; High Speech Language Pathology Case Mix. Let’s take a quick look at these two new target areas in a little more detail. Please see below.

High PT and OT Case MixHigh SLP Case Mix
Reason for Target: SNFs could have issues with MDS coding of patients’ functional score.

Focus: If you fall into the 80th percentile in this target area, you will want your focus to ensure nursing and therapy documentation in the medical record supports the appropriateness of MDS coding, specifically as it relates to the ten items in Section GG, which is used for the PT and OT PDPM Component.
Reason for Target: SNFs could have issues with MDS coding of any of the five patient characteristics in the SLP PDPM component; acute neurologic condition, SLP-related comorbidity, cognitive impairment, swallowing disorder, or mechanically altered diet.

Focus: If you fall into the 80th percentile in this target area, you will want your focus to ensure the documentation in the medical record substantiates all the SLP-component patient characteristics coded on the MDS.

Functional Pathways’ Client Partners! Schedule your complimentary PEPPER analysis by visiting PEPPER Resources Portal and running your PEPPER report. Save the report in excel and then send the report as an email attachment to PDPM@fprehab.com.