CMS began releasing provider specific Program for Evaluating Payment Patterns Electronic Reports (PEPPER) in 2012. The data presented in each of the PEPPERs should be used by Hospice organizations as a guide for auditing and monitoring efforts. In this presentation, we will introduce the learner to what is contained in the hospice provider PEPPER reports, how to read the PEPPER and how to use the data to identify any potential risk areas, as well as identify steps in mitigating risk areas.
Provider approved by the California Board of Registered Nursing, CEP# 13791
Nurses will receive 1.25 contact hours for participating in this course.
District of Columbia Board of Nursing Approved Continuing Education program (CEBroker Provider #50-290).
Florida Board of Nursing (CEBroker Provider #50-290)
In support of improving patient care, Relias LLC is jointly accredited by the Accreditation Council for Continuing Medical Education (ACCME), the Accreditation Council for Pharmacy Education (ACPE), and the American Nurses Credentialing Center (ANCC), to provide continuing education for the healthcare team.
Georgia Board of Nursing (CEBroker Provider #50-290)
South Carolina Board of Nursing (CEBroker Provider #50-290)
West Virginia Board of Registered Nursing (CEBroker Provider #50-290)
New Mexico Board of Nursing (CEBroker Provider #50-290)
Arkansas State Board Of Nursing Approved Continuing Education program (CEBroker Provider #50-290).
Program for Evaluating Payment Patterns Electronic Report (PEPPER)
Data Analysis – PEPPER
How to Use the PEPPER
Where Does PEPPER Come From?
PEPPER Resources Portal
PEPPER Retrieval, cont’d
PEPPER Retrieval Rates (Sept. 2019)
Who Gets the PEPPER?
PEPPER Time Period
FY18 PEPPER Release (April 2019)
Data Restriction and Report
PEPPER – Definitions Page
PEPPER Target Areas
Percents & Percentiles
Think of the Chubby Baby…
Percents vs Percentiles within PEPPER
Target Area Report – RHC in an ALF
Target Area Report
Compare Report Example – Most Recent Fiscal Year (only)
Top Terminal Diagnoses (Provider)
Top Terminal Diagnosis (Jurisdictional Comparison)
Live Discharge by Type (Provider)
Live Discharge by Type (CGS Compare)
Target Areas and Interventions, cont’d
DATA…data…DATA (oh my!)
All of the Data is Connected
Utilizing PEPPER Data to Mitigate Risk
Payment-Related Scrutiny and PEPPER Correlation
Reminder: PEPPER Target Areas
PEPPER Target Areas, cont’d
Current Audit Focus Areas
Action Plan to Address Risk Areas
PEPPER and Hospice Liability
What to do NOW to Mitigate Risk
Up Your Regulatory Game!
Review and Improve Documentation Systems
Ensure a Robust and Real-time QAPI and Compliance Program
Does your Compliance Officer act more like…
Carrie Cooley is the Principal / Chief Executive Officer (CEO) of Weatherbee Resources. Carrie joined Weatherbee in 2009 as an Associate Consultant and was hired as the Consulting Coordinator in 2012. In 2014, Carrie was promoted to Director of the Consulting Division and in July 2015, she assumed the Chief Operating Officer position. Carrie was promoted to CEO in February 2018.
On July 1, 2018, Carrie and her business partner, Lynn Stange, purchased Weatherbee Resources from the company's founders, Heather Wilson, and Joy Barry. Together, Lynn and Carrie plan to continue the long-standing history of Weatherbee Resources' service to the hospice industry.
In her role as Principal / CEO, Carrie ensures Weatherbee's consulting services, products, and education are provided in a professional and cost-effective manner and are specifically tailored to meet each client's individual needs. As one of Weatherbee's owners, Carrie is responsible for ensuring Weatherbee is positioned to assist hospices with the ever-changing regulatory hospice environment. Carrie's excellent rapport with executives and staff alike ‐ coupled with her regulatory and clinical acumen, and knowledge of best practices ‐ assures excellent consulting outcomes.
Carrie's regulatory expertise and extensive consulting experience includes forensic clinical record auditing, baseline compliance audits/mock surveys, customized client education, interim management, clinical due diligence, and executive coaching. Carrie and her team frequently work directly with clients' legal counsel to address a wide range of hospice matters including the defense of clients under payment-related scrutiny by various entities; Carrie frequently serves as an expert witness. Weatherbee also works extensively with clients who are under a Corporate Integrity Agreement (CIA) with the Office of Inspector General (OIG); Carrie and her team execute the Independent Review Organization (IRO) audit activities required by the OIG.
Under Carrie's leadership, Weatherbee has assisted hundreds of clients under investigation by various Medicare contractors including: Targeted Probe and Educate (TPE), Zone Program Integrity Contractors (ZPIC), Unified Program Integrity Contractors (UPIC), Benefit Integrity Support Centers (BISC), Recovery Auditors (RA), the Department of Justice (DOJ), Assistant United States Attorneys (AUSA), and the OIG.
As a member of Weatherbee's Speaker's Bureau, Carrie teaches a broad range of hospice, regulatory, and leadership-related topics nationally and is a member of the faculty for Weatherbee's renowned Hospice Regulatory Boot Camps. Carrie also frequently speaks at state and national hospice conferences on compliance-related topics.
Carrie is a registered nurse and holds a master's degree from Samford University with a specialty in nursing leadership and healthcare finance.Disclosure: Carrie Cooley, RN, MSN has declared that no conflict of interest, Relevant Financial Relationship or Relevant Non-Financial Relationship exists.
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