CMS announced recently that the Program for Evaluating Payment Patterns Electronic Report, aka PEPPER, will be available on July 29, 2020 for SNF providers.

The July 2020 SNF PEPPER will include Q4FY19 legacy RUG-IV data:

• Therapy and Non-Therapy RUGs with High ADL,
• Change of Therapy,
• Ultrahigh Therapy RUGS,
• 20- and 90-day episodes of care.

New this year will be data on the facility’s “3- to 5-Day Readmissions.” This information will identify the percent of readmissions that occurred shortly after a 3-day gap of non-coverage.  The guidance provided in the PEPPER user’s guide states that numbers greater than the threshold could indicate the facility’s residents were being discharged prematurely or readmitted after the interrupted stay threshold (>3 days) in an effort to reset the variable per diem adjustment.

While we certainly feel this type of blanket statement is inaccurate, CMS has indicated that they will be reviewing therapy utilization post PDPM.  Facilities may want to use the legacy data to do a cursory analysis of their therapy utilization post PDPM and review internal processes if outliers are identified.

Facility administrators will be able to access their report on July 29th through the PEPPER electronic portal.   The website and links to the users guide can be found here.

Please reach out if you feel you need assistance interpreting your report. Our reimbursement experts can help you identify opportunities for review and improvement and provide recommendations as well as the tools & education needed to ensure it accurately reflects the quality care and services provided to your residents.

Amy Lee, RN, MSN, CRRN, QCP
President/CEO