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CMS compliance tool comparing billing patterns to national benchmarks
The Program for Evaluating Payment Patterns Electronic Report, a CMS-issued compliance tool that compares a hospice's billing patterns — by level of care, length of stay, and diagnosis — against national and jurisdiction-level benchmarks.
The Program for Evaluating Payment Patterns Electronic Report (PEPPER) is a free CMS compliance tool that shows a hospice's Medicare billing patterns for high-risk target areas, compared against national, jurisdictional, and state percentiles. It is designed to help providers identify potential improper payments before CMS does. Hospice PEPPER reports were paused in January 2024 and relaunched in June 2026.
PEPPER is developed and distributed by the RELI Group (along with partners TMF Health Quality Institute and CGS) under contract with CMS [1]. Hospice PEPPER has been available since 2012 and is distributed annually, covering the three most recent federal fiscal years of claims data. CMS paused PEPPER reports across all provider types in January 2024 to make improvements, and hospice reports relaunched in June 2026 with updated data and revised target areas [2]. Hospice PEPPER organizes claims data into target areas that CMS has identified as at risk for improper Medicare payments. Target areas include: live discharges classified as "no longer terminally ill," live discharges due to patient revocation, live discharges with a length of stay between 61 and 179 days, long lengths of stay (episodes of 180 days or more), the absence of any general inpatient or continuous home care billing, GIP stays exceeding five consecutive days, routine home care days provided in assisted living facilities and nursing facilities, continuous home care provided in assisted living facilities, and average Part D claims per episode stratified by patient residence setting. For each target area, PEPPER displays the hospice's percentage or rate alongside its percentile rank compared to all hospices nationally, within its MAC jurisdiction, and within its state. The 80th percentile is the upper control limit: a hospice at or above the 80th percentile for a target area is considered at risk for improper payments and is flagged as an outlier. The report also includes a Compare Targets view to help prioritize which areas to audit first, top terminal diagnoses for the hospice and its jurisdiction, and a live discharges by type report. PEPPER data comes from UB-04 claims submissions and reflects only Medicare fee-for-service claims. To protect beneficiary privacy, target areas with a numerator or denominator below 11 are suppressed. Hospice PEPPER is accessed through the PEPPER Portal at pepper.cbrpepper.org using existing NPPES/PECOS credentials via the CMS Identity & Access (I&A) System. Only Authorized Officials and Access Managers with active I&A accounts can download reports; Staff End Users can also access reports after being granted the PEPPER business function.
PEPPER is the CMS-funded preview of what its own medical reviewers see. The target areas — live discharges, long lengths of stay, Part D patterns, ALF concentration — overlap substantially with what feeds the SSVI and with the metrics that triggered the April 2026 California UPIC suspensions. A hospice sitting above the 80th percentile on live discharges or long lengths of stay is looking at the same signal that Qlarant's predictive models surface. The report is free, refreshed annually with three-year trend data, and provides a standing internal audit benchmark against which billing patterns can be assessed each year. The relaunch after a two-and-a-half-year pause means the June 2026 report represents the first current comparative data many hospices have had access to since early 2024 — a gap that leaves billing pattern changes during that period untracked against national benchmarks.
PEPPER is a free CMS-funded report that shows a hospice's billing patterns for target areas at risk of improper Medicare payments, benchmarked against national, jurisdictional, and state percentiles, covering the three most recent fiscal years.
Through the PEPPER Portal at pepper.cbrpepper.org, using existing NPPES or PECOS credentials via the CMS Identity & Access System; Authorized Officials and Access Managers with active I&A accounts can download reports.
It means your hospice's rate for that target area is higher than 80% of all hospices in the comparison group, which CMS considers at risk for improper payments and flags as an outlier warranting internal review.
Hospice PEPPERs are distributed annually, each covering the three most recent federal fiscal years of Medicare claims data; after a pause from January 2024 through mid-2026, the report relaunched in June 2026.
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