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The Program for Evaluating Payment Patterns Electronic Report (PEPPER) gathers data on billing patterns of U.S. SNFs. So, what has changed now that data is based on an entirely different payment model?

On March 30, the SNF PEPPER Users Guide, Ninth Edition, was released, and it’s evident that SNF PEPPER target areas and supplemental reports will be changing over time to provide information related to potential vulnerabilities of the Patient Driven Payment Model, rather than the billing patterns that were vulnerable under the RUG system. 

SNFs were able to obtain their PEPPER on or about April 5, and new, PDPM-related target areas include:

• PDPM High Utilization codes — Claims where the first digit of the Health Insurance Prospective Payment System (HIPPS) code, representing the PT and OT component, is C, D, G, H, K, L, O or P. 

• 20-Day Episodes of Care 

• 90+ Day Episodes of Care 

• 3-5 Day Readmission (new in July 2020) — Readmissions to the same SNF for the same beneficiary

Are you an outlier? Relax! A high target area percent does not necessarily indicate the presence of improper payment or that the provider is doing anything wrong; however, you may want to review medical record documentation to ensure the services beneficiaries receive are appropriate and necessary, and to ensure documentation supports the care and services CMS reimbursed. 

Don’t forget to focus on appropriate diagnosis coding for I0020B and accurate assessment and reporting of Section GG items, as well as discharge planning to facilitate safe transitions, support appropriate lengths of stay, and avoid rehospitalizations. 

SNF PEPPER is available to CEOs, administrators, controllers and other executives through a secure portal at