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PEPPER Reports are Coming Back

CMS has announced it will relaunch the Program for Evaluating Payment Patterns Electronic Report (PEPPER) for all Medicare facility types — including post-acute care providers and skilled nursing facilities — in the coming months. For many nursing homes, PEPPER is an important internal compliance and auditing tool, and its return deserves your attention.

What Is PEPPER
PEPPER is a free CMS report that shows how your facility's Medicare billing patterns compare to state and national averages in targeted, high-risk areas. It covers therapy and nursing service utilization, patient length of stay, readmission patterns, and more. Each report is made available to the measured facility so leadership can assess their own trends and outlier data before regulators do.

PEPPER reports were last made available in April 2023, when CMS paused publication to reevaluate and enhance the metrics included. The wait has been longer than expected — providers had been told to expect the reports last fall — but CMS confirmed this week that the relaunch is coming.
The stakes are real. Under PDPM, billing and documentation are tightly linked, and small inconsistencies in ICD-10 coding, MDS accuracy, Section GG scoring, or clinical documentation can have significant downstream compliance and reimbursement implications. PEPPER can help surface those patterns early — long before they become audit findings or repayment demands.

Industry experts describe PEPPER as the government "handing providers a flashlight before walking into the room." Facilities that use it strategically can strengthen compliance, improve documentation practices, and build more defensible reimbursement processes. Those that ignore it are operating blind.
 
How to use PEPPER
PEPPER is most effective when treated as an interdisciplinary operational tool — not just a finance or compliance document. The facilities that get the most value out of it are drilling into medical records, validating MDS accuracy, auditing physician documentation, reviewing therapy utilization patterns, and confirming that the clinical story in the chart actually supports what is being billed.

Specific areas to watch under PDPM include:
  • High physical therapy, occupational therapy, or speech-language pathology case mix
  • Frequent quick readmissions to the same nursing home
  • Medicare-covered patients staying 90 days or longer
  • NTA capture and clinical documentation consistency
The return of PEPPER should be a prompt to act — especially for facilities that haven't reviewed one in years, or have never opened one at all. PEPPER essentially tells you where billing and utilization patterns could attract government scrutiny. Smart operators use that information proactively.
 
How to get access
PEPPER is available through the PEPPER Portal to authorized officials (AOs), access managers (AMs), and staff end users (SEUs).

If you are a staff end user, here's what to do:
  1. Sign in to the CMS Identity & Access (I&A) System using your existing NPPES or PECOS credentials.
  2. Request the PEPPER business function for your organization. (You can also request the Comparative Billing Report function at the same time.)
  3. Your AO or AM will need to approve your request.
  4. Once approved, log in to the portal and download your organization's report.
Don't Wait Until the Reports Are Released
The approval process takes time, so MHCA encourages members to take these steps now. Review the I&A System Quick Reference Guide and FAQs for step-by-step instructions for AOs and AMs. If you need assistance, contact the External User Services Help Desk.
 
Staff contact: mcarland[at]mehca.org
 

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