The Hospice PEPPER is a report that summarizes a hospice agency’s Medicare claims data in areas that may be at risk for abuse or improper payment. PEPPER compares the hospice claims data statistics with aggregate statistics for other hospices in the state, MAC/FI jurisdiction and the nation. Hospice agencies with high billing patterns (or above the nation’s 80 percentile) are identified as at risk for improper Medicare payments and are encouraged to ensure that they are complying with Medicare payment policy, that services provided to beneficiaries are medically necessary and that medical record documentation supports the services that are billed.
The TMF Health Quality Institute, a CMS contractor, develooped the hospice PEPPER Report. The PEPPER Resource Guide is a good reference to learn how to understand and interpret the information.
PEPPER does not identify the presence of improper payments. Only a review of the medical record can determine whether services are medically necessary and appropriately billed. PEPPER will receive more attention this month for hospice agencies as CMS will be providing hospice reports that reflect statistics related to improper payments.
Hospice agencies that measure above the 80 percentile are considered at risk for improper Medicare payments. Hospice agencies will be able to review and evaluate their scores against other hospice agencies in the state, in their MAC jurisdiction and across the nation.
The PEPPER Report will be distributed to hospice agencies soon. The first course of action after receiving the report is to review your scores and compare them against other agencies. NDoc Hospice can generate specific reports as well to benchmark the PEPPER Report with internal reporting measures.
Thereafter, a good practice is to set up an internal monitoring process to ensure compliance.