The time for SNFs to become more vigilant about self-auditing is now, according to the Report on Medicare Compliance.  Skilled Nursing Facilities (SNFs) should have began receiving the first round of PEPPER at the end of August.  “PEPPER” stands for Program for Evaluating Payment Patterns Electronic Reports.  These reports, which are a free compliance monitoring tool, are already distributed to many other types of facilities including long-term hospitals, critical access hospitals, and rehab facilities.  The reports are used to identify potential overpayments and underpayments.

Husch Blackwell attorneys Brian Bewley and Barb Miltenberger weighed in on this issue.  According to Bewley, skilled nursing facilities often contract out for therapy, which complicates oversight.  But the SNFs submit the claims so they are the ones on the line.  “SNFs will have to become more vigilant to ensure documentation supports the services provided,” Miltenberger says.

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