PEPPER Is Relaunching — Get Ready Now
What home health agencies need to know and do now.
The Centers for Medicare & Medicaid Services (CMS) has announced that the Program for Evaluating Payment Patterns Electronic Report (PEPPER) is relaunching for all Medicare facility types — hospitals, post-acute care providers, and specialty facilities, including home health agencies.
PEPPER is a free tool that helps providers review Medicare billing data, spot potential issues early, and support accurate claims. We are sharing this alert now so your agency can secure portal access before your facility's PEPPER report reaches you.
What PEPPER actually is
PEPPER is not an audit. It is a facility-specific statistical report that shows how your agency's Medicare billing compares to other agencies — in your state, in your Medicare Administrative Contractor jurisdiction, and nationally.
The report is built around target areas: categories CMS has identified as vulnerable to improper payment. Each target area is expressed as a percentage, where the numerator represents potentially problematic claims and the denominator represents a larger comparison group. Your number sits on a distribution alongside everyone else's.
That comparison is the entire point. PEPPER does not tell you that you did something wrong. It tells you where you sit relative to your peers — and, by extension, where a reviewer would look first.
The takeaway: PEPPER is the same data CMS and its contractors are already looking at. The only question is whether you have seen it before they act on it.
Why this matters for home health agencies
It is important that a home health agency ensure their percentages are in alignment with state and national averages. If they are not, CMS will flag the agency for increased scrutiny, audits, and takebacks of money.
Reviewing your PEPPER data as soon as it is released — and comparing it to state and national benchmarks — is one of the most effective ways to catch outliers before they trigger a CMS audit.
How does the outlier flag actually work?
PEPPER's methodology is consistent across provider types. An agency at or above the national 80th percentile in a target area is identified as a high outlier for that area. That status does not accuse you of anything. It does something more practical and more dangerous: it puts your agency in the pool a reviewer draws from.
Two things worth understanding about that threshold:
- Being an outlier is not proof of a problem. A specialized agency, an unusual referral mix, or a genuinely sicker patient population can all place you above the 80th percentile legitimately. What matters is whether you can explain it, in writing, with clinical documentation behind it.
- Not being an outlier is not proof of safety. A comfortable percentile in every target area is good news, not immunity. Documentation quality still governs what happens in an actual review.
The agencies that handle PEPPER well are the ones that treat a high percentile as a prompt to go look at charts — not as a verdict to argue with.
The takeaway: an outlier percentage you can explain is a manageable finding. An outlier percentage nobody at your agency noticed is how takebacks start.
Take action now to ensure timely access
Authorized Officials (AOs), Access Managers (AMs), and Staff End Users (SEUs) can access PEPPER through the PEPPER Portal. Taking these steps now will help ensure your agency has timely access.
How to get access as a Staff End User (SEU):
- Sign in to the CMS Identity & Access (I&A) System using your existing National Plan and Provider Enumeration System (NPPES) or Provider Enrollment, Chain, and Ownership (PECOS) credentials.
- Request the PEPPER business function for your organization. The Comparative Billing Report (CBR) business function is also available and can be requested at the same time.
- Your AO or AM must approve your request.
- Once approved, log in to the PEPPER Portal and download your organization's report.
The bottleneck here is almost always step three. Access flows down from the Authorized Official registered in NPPES — and at a great many agencies that person left, changed roles, or is an owner who has never logged in. Confirm today that your AO and AM records are current and that someone can actually approve a request. That single check is the difference between downloading your report the week it lands and spending a month untangling credentials.
Need help getting started?
- I&A Quick Reference Guide
- I&A Frequently Asked Questions — step-by-step instructions for AOs and AMs
- PEPPER training and resources
- Technical assistance — PECOS External User Services (EUS) Help Desk
CMS has also scheduled a PEPPER webinar for September 24, 2026 at 1:00 p.m. ET, with registration available through the resources above. If the person who will pull and read your report is not already booked for it, book them.
What to do the week you download it
A PEPPER report that sits in someone's downloads folder protects nobody. When yours arrives:
- Read the target areas in order of percentile, highest first. Your attention belongs where the distribution says a reviewer's will go.
- For every high percentile, pull five charts. Not to prove yourself right — to find out whether the documentation supports the billing. If it does, write down why. If it does not, you have found the problem while it is still yours to fix.
- Compare year over year, not just against peers. A target area that moved sharply in one year tells you something changed in your intake, coding, or clinical practice. Find out what.
- Put it in front of your QAPI committee. PEPPER findings are exactly the kind of data QAPI is supposed to act on, and documenting that you reviewed them is itself evidence of a functioning program.
- Keep the report and your notes. If a reviewer does come, a dated internal analysis of your own outliers is one of the strongest things you can hand them.
The takeaway: the value of PEPPER is not in receiving it. It is in the five charts you pull the week after.
Confirm your access now
We recommend that every home health agency confirm AO/AM access is current and request SEU access now, well ahead of the relaunch reaching your facility type. Credentials take days to sort out; reports do not wait.
If your team would like help interpreting your PEPPER report once it is released, or reviewing your billing patterns against state and national averages, that work sits squarely in our survey readiness and compliance practice — alongside ADR review, post-payment review and plan-of-correction support. Talk to the Solutions for Care team and we will help you read the report the way a reviewer would.
Source: Centers for Medicare & Medicaid Services (CMS). Prepared for our clients by Solutions for Care.
