Klusch: Providers must take ownership of their PEPPERs
Leah Klusch, RN, BSN, FACHCA
It is “totally wrong” for providers to let their PEPPERs fall into the hands of outside vendors, a leading long-term care coding and payment expert warned a national audience on Tuesday.
It is solely the provider's responsibility to know what is being billed and whether the facility is being billed properly, said Leah Klusch, executive director of Alliance Training Center. Klusch was the featured speaker for the McKnight's Super Tuesday webinar “P.E.P.P.E.R. Reports: Why not paying attention can be costly.”
PEPPER stands for “Program for Evaluating Payment Patterns Electronic Report.” The program is used to help providers assess their risk for improper Medicare payments and to guard against Medicare fraud, waste and abuse. It is available for short-term and long-term acute care PPS hospitals, inpatient psychiatric faculties, inpatient rehabilitation facilities, partial hospitalization programs, hospices and critical access hospitals. Each report summarizes Medicare data within three 12-month time periods, or three fiscal years, which begin Oct. 1 annually. The most recent report came out in May.
The “heart” of PEPPER statistics involves percent numbers and percentiles, which can be easily confused, Klusch cautioned. The data helps providers find outliers and percentiles that are abnormal so their risk levels can be assessed. A general rule of thumb, she said, is: SNFs with a percentile at/above the national 80th percentile or at/below the 20th national percentile are at risk for improper Medicare payments.
Klusch made numerous recommendations for providers, among them:
- Be aware of the PEPPER process and how to get reports
- Analyze reports internally, and in relation to demographics
- Consider auditing and monitoring in areas that you're significantly different from other facilities
- Recognize increases and decreases over time and identify the root cause(s)
- Continually review medical records
Klusch urged providers to be proactive so they will be able to avoid “pay and chase.”
“Don't let anybody tap you on the shoulder and say, ‘Oh, don't worry, we've got you covered,'” she said. “There's nobody to cover you as an individual SNF. It's your responsibility.”