SNF PEPPER IS AVAILABLE
The Q4FY14 release of the Skilled Nursing Facility (SNF) Program for Evaluating Payment Patterns Electronic Report (PEPPER), with statistics through September 2014, is now available for download through the PEPPER Resources Portal.
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**Available in July**: Home Health Agency PEPPER. Learn more>
What’s on your PEPPER?
PEPPER is a roadmap for assessing areas at risk from improper Medicare Part A billing. MAC, RAC, and ZPIC contractors are in alignment with the Office of the Inspector General (OIG) and Government Accountability Office (GAO) to help identify and prevent fraud, waste, and abuse in federal healthcare programs. PEPPER can support a hospital or facility’s compliance efforts by identifying where it is an outlier for these risk areas. This data can help identify both potential overpayments as well as potential underpayments.
How Does PEPPER Assist Leaders?
Six target areas are addressed using data from the SNF’s UB-04 claim forms. The latest report covers fiscal years 2011 – 2013 and includes individual SNF data as well as national, MAC jurisdictional, and state comparison data presented in graph and table formats.
PEPPER determines outliers based on the national 80th and 20th percentiles. A SNF’s target area is an outlier when in the top or bottom 20% of all SNF target area percents.
Although identification as an outlier is cause for concern, outlier status does not mean the SNF has improperly billed Medicare. Outlier status does mean the SNF appears statistically different from other providers in the country, and it does place the SNF at higher risk for audit activity. Because of this, the SNF must know its PEPPER data and how it is affected by resident characteristics, special services, and references.
Regardless of the level of risk, the six target areas should be incorporated into the SNF’s compliance program for auditing and monitoring, QAPI, and CQI to ensure continuous oversight. Medicare pre-billing audit processes may need to be adjusted as well.
Tips for Incorporating PEPPER
Failure to review PEPPER findings may be seen as reckless disregard of a SNF’s compliance obligations. Consider the following:
1. Review your PEPPER with your internal team.
2. Prioritize areas for review, including high risk for RAC or MAC review and opportunities for improvement.
3. Conduct internal and external audits to ensure compliance.
4. Review ongoing results at Corporate Compliance or QA meetings.
Remember, PEPPER is a roadmap to help organizations identify potentially vulnerable or improper payments.
Pathway Health has the resources to assist you and your staff in obtaining, interpreting, and using PEPPER data. Contact us to learn more!
Pathway Health’s PEPPER Resources
PEPPER Report and How To Use It (CD Recording)
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