Home Health & Hospice Week

Some ways you can use these free benchmarking reports may surprise you — including for new HH CoP purposes.

Medicare’s Program for Evaluating Payment Patterns Electronic Report contractor is trying to encourage wider use of PEPPER reports among home health and hospice agencies by furnishing case studies of providers that are utilizing them. Take a look to learn how the reports can benefit you — perhaps in ways you haven’t thought of.

Case Study #1: Curbing Therapy Utilization

The owner of a newly acquired home health agency in Louisiana “reviewed the HHA’s PEPPER, discovered several areas of concern regarding compliance, and immediately began a corrective action plan,” PEPPER contractor TMF Health Quality Institute relates. The PEPPER report for Divinity Home Health Services in Thibodaux showed the agency was a high outlier for episode numbers in 2013, the year Amie Falgout and her husband purchased the agency. Then PEPPER reports for subsequent years showed how compliance efforts helped pull Divinity’s episode numbers out of the outlier range.

PEPPER data also revealed potential concerns with therapy utilization and case mix.

Divinity’s corrective action plan includes “educating all therapy staff on Medicare requirements and hiring an external auditor to perform a review of our high therapy utilization records,” Falgout says. “The findings of this audit have been used to guide staff education and to ensure that the therapists’ documentation supports the services they are providing to beneficiaries. The staff was very receptive and I give credit to the PEPPER for this, since the data is so clearly written and easily understandable.”

Advice: “Don’t be afraid of the data,” Falgout says. “Involve people who would best understand the data from different viewpoints, including your staff, compliance officer, referral sources. Keep an open mind.”

Case Study #2: A Good PEPPER Is Still A Helpful PEPPER

Bluegrass Care Navigators, a hospice provider in Kentucky, finds its PEPPER reports show good numbers in the target areas. But that doesn’t mean the hospice is then done with the report. The agency’s good showing under PEPPER frees up resources to conduct focused monitoring in other areas of performance, relates Bluegrass’VP of compliance and quality improvement Eugenia Smither.

How it’s used: Smither analyzes the report, distributes it internally to each office and reviews it with staff at each facility’s office, she reports. In addition to comparing themselves to the MAC, state and nation numbers, Bluegrass compares the PEPPER for each of their provider numbers, internally.

“We find the state comparison most helpful for us,” she says. “It reflects the regional differences in patient population better than the MAC jurisdiction comparison group.

“I also use PEPPER as a compliance tool to report findings to our board of directors,” Smither says. That’s something HHAs may want to take note of, considering the QAPI and governing board changes coming up in the new Home Health Conditions of Participation taking effect in July.

To make it easier for the board and offices to understand, Smither converts the report into “a dashboard to summarize the information,” she added.

Advice: “Read the report in its entirety, then go back to each section to study it in detail,” Smither offers. “Understand how the numerator and denominator are defined so that questions can be answered and you can explain differences in the statistics if needed. For example, recently we consolidated two provider numbers into one; as a result, for that time period, the live discharges statistics were a little higher than usual. But it was expected given the consolidation.”

Case Study #3: Compensating For A Red Flag

Heartlinks Hospice and Palliative Care in Sunnyside, Wash., expects its PEPPER data to be “better than the majority of their peers,” it says. But the agency’s PEPPER shows “that we have a statistically higher than average percent of patients in ALFs,” allows Heartlinks exec Rev. Ronald Jetter.

That doesn’t mean that that care isn’t expected or legitimate. But there’s no escaping the fact that “hospice care provided to beneficiaries residing in facilities such as ALFs, skilled nursing facilities or nursing facilities is now under scrutiny by CMS,” Jetter notes. Thanks in part to the PEPPER report’s data, “we have made medical record audits and staff training top priority for patients residing in these facilities,” he says, pointing out the hospice’s recent survey with no citations issued in agency operations.

How it’s used: Jetter shares the report with all relevant personnel, including medical records, the billing office manager and the clinical director of quality assessment/performance improvement. “We review the report and discuss it at our next QAPI meeting,” he relates. “Our QAPI team meets on a monthly basis to identify areas where care might have been less than excellent.”

“We have established a comprehensive auditing program focused on patient care and accurate documentation,” Jetter continues. PEPPER “also allows us to look at trends over time and enables comparison to our peers. Data is the way we all have to look at things from a different viewpoint.”

Advice: Network with your colleagues to see how they’re using their reports in their organizations, Jetter suggests.

Note: Find more details of each agency’s PEPPER experience via links at https://pepperresources.org/PEPPER/Success-Stories.