Mitigating Risk: Hospice Pepper Reports

Mitigating Risk: Hospice Pepper Reports 

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.


Hours: 1.00 - 1.25


Certificates provided by accrediting body (9 Match)

California Board of Registered Nursing

1.25 HOURS

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


DC-RN -- District of Columbia Board of Nursing Approved Continuing Education program (CE Provider #50-290).

Nurses will receive 1.20 contact hours for participating in this course.

Florida Board of Nursing


Florida Board of Nursing CE Provider #: 50-290

Nurses will receive 1.00 contact hours for participating in this course.

American Nurses Credentialing Center

1.25 HOURS

Relias, LLC is accredited as a provider of continuing nursing education by the American Nurses Credentialing Center’s Commission on Accreditation.

Nurses will receive 1.25 contact hours for participating in this course.

Georgia Board of Nursing

1.25 HOURS

Georgia Board of Nursing CE Provider #: 50-290

Nurses will receive 1.25 contact hours for participating in this course.

South Carolina Board of Nursing

1.25 HOURS

This program was approved by the South Carolina Board of Nursing Approved Continuing Education Program (CE provider #50-290) CE Broker Course # 20-[Custom_Code]

West Virginia Board of Registered Nursing

1.25 HOURS

New Mexico Board of Nursing

1.25 HOURS

New Mexico Board of Nursing (CEBroker Provider # 50-290)

This course awards 1.25 contact hours upon successful completion.

Arkansas State Board of Nursing

1.25 HOURS

Course Details

Hours: 1.25
Type: Online Course
Content Expiration Date: 12/31/2022
Learning Objectives:
Explain the difference between percent and percentile.
Recall the Hospice PEPPER Target Areas.
Recognize organizational risk according to PEPPER report data and trends.
Describe strategies to mitigate risk identified by PEPPER.

Learning Objectives

Program for Evaluating Payment Patterns Electronic Report (PEPPER)

Data Analysis – PEPPER


How to Use the PEPPER

Where Does PEPPER Come From?

PEPPER Retrieval

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…

Act Now


Instructor: Carrie Cooley, RN, MSN
Carrie Cooley is the Principal / Chief Executive Officer (CEO) with 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 regulatory expertise and extensive consulting experience includes forensic clinical record auditing, baseline compliance audits/mock surveys, interim management, clinical due diligence, and executive coaching. Carrie and her team also work directly with clients' legal counsel in preparation for arbitration and other hearings; Carrie frequently serves as an expert witness. Weatherbee also works extensively with clients who are under a Corporate Integrity Agreement (CIA); Carrie and her team manage the Independent Review Organization (IRO) audit activities required by the Office of Inspector General (OIG). 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.  
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), 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.
Target Audience:
The target audience for this course is: Nurses; Physicians; in the following settings: Hospice, Palliative Care.
Relias will be transparent in disclosing if any commercial support, sponsorship or co-providership is present prior to the learner completing the course.
Course Delivery Method and Format
Asynchronous/Online Distance Learning; please see certificate details for specifics on delivery format.
Relias has a grievance policy in place to facilitate reports of dissatisfaction. Relias will make every effort to resolve each grievance in a mutually satisfactory manner. In order to report a complaint or grievance please contact Relias.
If you require special accommodations to complete this module, please contact Relias Support by completing the web form ( or by using the chat functionality.
All courses offered by Relias, LLC are developed from a foundation of diversity, inclusiveness, and a multicultural perspective. Knowledge, values and awareness related to cultural competency are infused throughout the course content.
Reference herein to any specific commercial product, process, or service by trade name, trademark, service mark, manufacturer or otherwise does not constitute or imply any endorsement, recommendation, or favoring of, or affiliation with, Relias, LLC.
All characteristics and organizations referenced in the following training are fictional. Any resemblance to any actual organizations or persons living or dead, is purely coincidental.
To earn continuing education credit for this course you must achieve a passing score of 80% on the post-test and complete the course evaluation.
If you require special accommodations to complete this module, please contact Relias Customer Support here.