Shelly Mesure, MS, OTR/L

Have you received your provider-specific PEPPER report yet? The Program for Evaluating Payment Patterns Electronic Report (PEPPER) were mailed on August 30 and have been slowly arriving at skilled nursing facilities throughout the country.

This 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. This report specifically compares your facility to the national and state averages from the 4th quarter from the past three years.

The SNF PEPPER version Q4FY12 contains statistics 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
  1. Non-therapy RUGs with High ADLs — in other words, nursing only RUGs, no therapy
  1. Change of Therapy Assessments — measured by the volume of COT MDS’ your facility completes on a regular basis
  1. Ultra High Therapy RUGs — how strong is your clinical documentation to support the utilization of these RUGs?
  1. Therapy RUGs — compared with nursing-only RUGs
  1. 90+ Day Episodes of Care — targeting extended length-of-stays 

You fall into the outlier categories if you are above the 80th percentile (too many) or below the 20th percentile (too few). The report gives your provider-specific information, and provides you with the specific data, as well as, the percentiles.

It also provides details on “Suggested Interventions for High Outliers” and “Suggested Interventions for Low Outliers.”

As a consultant, I have prepared my audits and client reports to reflect the provider-specific issues so that upon further review, my clients will have the benefit of having my third-party consultants pro-actively addressing any issues resulting from this report. If you are currently using a consultant, I strongly recommend they take the same initiative.

At this time, we’re not completely clear on the full impact of these reports, but there are so many hypotheticals floating around from healthcare reform. Staying prepared for these audits will be a facility’s best plan of action.

By having rehab including with understanding the PEPPER reports will help to improve the outcomes of any audit. Please feel free to visit or contact me directly at [email protected] for more details.


Shelly Mesure (“Measure”), MS, OTR/L, is the senior vice president of Orchestrall Rehab Solutions and owner of A Mesured Solution Inc., a rehabilitation management consultancy with clients nationwide. A former corporate and program director for major long-term care providers, she is a veteran speaker and writer on therapy and reimbursement issues.