Louisiana Health Care Review
THE MEDICARE QUALITY IMPROVEMENT ORGANIZATION

Hospital Payment Monitoring Program - HPMP
Formerly known as PEPP - Payment Error Prevention Program

Program Overview
The Centers for Medicare & Medicaid Services (CMS) has established 2 programs to monitor the accuracy of the Medicare Fee-for-Service (FFS) program: The Comprehensive Error Rate Testing (CERT) program and the Hospital Payment Monitoring Program (HPMP).  HPMP monitors PPS inpatient hospital admissions only.  The CERT monitors all other claims. 

HPMP Quick Links

Resources & Links

HPMP Tools

PEPPER WebEx
Presentation Materials

Revised Quality Documentation PPT

The HPMP calculates the error rate for all individual PPS acute care hospitals nationally based upon the claims reviews conducted by quality improvement organizations (QIOs).  The QIOs are responsible for monitoring the quality of care, medical necessity of admissions, and accuracy of Diagnosis Related Group (DRG) payment related to Medicare inpatient hospital admissions.  The net improper payment amount - which is calculated by subtracting underpayments from overpayments for inpatient hospital admissions - in FY 2004 was $3.1 billion dollars of the Medicare Trust Fund (a 3.6% error rate).

Review & evaluation of coding, payment and compliance practices tends to indicate the same inadequacies: lack of information, inadequate or faulty documentation, and poor communication between physicians and others involved in the patient’s episode of care.

It is very important that hospitals understand payment monitoring will continue through LHCR’s current contract cycle, 11/01/05 - 10/31/08.


HPMP in the 8th Statement of Work

HPMP continues through LHCR’s current contract cycle, i.e., 8th Statement of Work, 11-01-05 through 10-31-08.   An additional focus of HPMP efforts this contract cycle is monitoring of Long-Term Acute Care Hospitals (LTACs) in our state.  LHCR and CMS continues to trend and analyze claims data to determine the focus of HPMP activities designed to reduce payment errors resulting from inappropriate utilization, DRG (coding), or billing errors.  LHCR may develop and implement hospital-specific or statewide improvement projects based on our analytical findings or CMS may direct LHCR to develop and implement projects.  CMS may also direct us to participate in nationwide projects. 
 

As health care regulations change, so will some of the advice provided here.  We will endeavor to revise these materials as soon as possible after these changes are disseminated.   It is important that hospitals maintain a system for receiving, disseminating, and acting on regulatory changes; this will include updating your compliance program as necessary in order to achieve your compliance goals. 
 
The Role of Hospitals in HPMP

Hospitals can directly reduce payment errors and support HPMP by developing, implementing, and maintaining effective:

  • utilization management programs and quality improvement programs

    • including effective resource utilization

    • prompt attention to opportunities for improvement and hospital

    • and medical staff education on the causes of payment errors
       

  • compliance programs, including

    • collaboration with compliance officers

    • prompt review of PEPPER reports

    • identification of inpatient utilization trends and patterns

      • incorporating this information into auditing & monitoring efforts
         

  • adherence to coding and billing regulations, including

    • maintaining a system for receiving, disseminating, and acting on regulatory changes

The role of compliance officers is crucial to reducing the incidence of improper payments, especially those that result from medically unnecessary services.  The HPMP Compliance Workbook, revised 2005, provides guidance, suggestions, and tools for hospitals seeking to develop, update, or strengthen their compliance programs and encourages hospitals to utilize resources provided by QIOs to support and enhance their efforts.
Resources & Links
Some of the following documents are .pdf files and require Adobe Acrobat Reader. To download, click here.
Link to CMS Improper Medicare Fee-for-Service Payments Report, November 2007
The full version of the FY 2007 report on Improper Medicare Fee-for-Service Payments.  The Improper Medicare Fee-for-Service Payments Report is a web-based tool that has been developed to allow users to view the Improper Medicare FFS Payments Reports online. Each May and November, the report is published to the public by CMS. This report is available in the CERT report website format.
 
Link to Appendix for CMS Improper Medicare Fee-for-Service Payments Report 11/07 The data appendices of the FY 2007 report on Improper Medicare Fee-for-Service Payments. This report is available in the CERT report website format.
Link to November 2007 CMS Improper Medicare Fee-for-Service Payments Long Report The long version of the  FY 2007 report on Improper Medicare Fee-for-Service Payments.
Link to the User's Guide for the FY 2007 report on Improper Fee-for-Service Payments This document is intended to provide users with instructions on the various features and functions of the Improper Medicare Fee-for-Service Payments Report.

Prevention of Hospital Payment Errors and Implications for Case Management

Link to A Study of Nine Hospitals with a High Proportion of Short-Term Admissions.
 
"PEPPER - How Hospitals Can Use Comparative Hospital Claims Data to Prevent Payment Errors" Link to PowerPoint presentation describing the Program for Evaluating Payment Patterns Electronic Report (PEPPER)
"Hospital-Acquired Conditions: Present-on-Admission Indicator" Link to PowerPoint presentation discussing new Medicare claims requirements.
"Hospital-Acquired Conditions: Present-on-Admission Indicator"
Companion article to above PPT
Link to MedLearn Matters Article #5499
CMS Issues Guidance on Emergency Services -
April 26, 2007
Link to a summary of guidance issued to hospitals on emergency services requirements under the agency’s Conditions of Participation (CoP), minimum standards which all hospitals must meet in order to quality for Medicare payments.
Medicare and Medicaid Programs;
Hospital Conditions of Participation: Discharge Appeal Rights -
Final Rule-November 27, 2006
Link to Federal Register listing containing this final rule which sets forth requirements for how hospitals must
notify Medicare beneficiaries who are hospital inpatients about their hospital discharge rights.
Medicare and Medicaid Programs;
Hospital Conditions of Participation
Final Rule-November 27, 2006
Link to Federal Register listing containing the Requirements for History and Physical Examinations; Authentication of Verbal
Orders; Securing Medications; and Postanesthesia Evaluations
Medicare and Medicaid Programs;
Hospital Conditions of Participation: Patients' Rights - Final Rule-December 8, 2006
Link to Federal Register listing containing new, updated Requirements for Patients' Rights
Recorded PEPPER Training Sessions & Resources Link to Training Resources provided by the Texas Medical Foundation.
OIG Final Supplemental Compliance Program Guidance for Hospitals Supplement that Updates the OIG guidance published in the PEPP Compliance Workbook, April 2000. Source: Texas Medical Foundation, Inc., HPMP QIOSC
Hospital Payment Monitoring Fact Sheet:
Physician Care Setting Orders
Provides examples of appropriate and inappropriate admission care setting orders.
Source: (Medicare Hospital Payment Monitoring Program (HPMP) Compliance Workbook, April 2000; Medicare Hospital Manual, Chapters 2 & 4)
Common Causes of Error Discusses the most common causes of payment errors identified during Sixth Scope of Work (PEPP) Project Data Collection.) Source: LHCR’s PEPP project data collection; sixth scope of work
Medicare Guidelines for Appropriate Use of the Inpatient and Outpatient Observation Care Settings Provides specific information regarding inpatient and outpatient observation care settings as defined by Medicare Guidelines. Source: Medicare Hospital Manual and the PEPP Compliance Workbook
Effective Utilization Management Strategies
 

Discusses UM process elements that may assist in ensuring adherence to Medicare guidelines and reduce the risks of payment error.

Source (PEPP Compliance Workbook, April 2000, pp. 1, 59-61, 90-91, 134-138,169, 187, 190; Federal Register, Facility CoP, Sec 482.30, pp. 384-385; Medicare Hospital Manual, Transmittal #689, June 1996; Medicare and Medicaid Guide, Commerce Clearinghouse, Inc., pp. 12710.93-12760.05, 12760.35; LHCR PEPP Regional Seminar, Spring & Summer 2000; ACEP Online, Management of Observation Units, Policy Resource and Education Paper, July 1994; Massachusetts Division of Health Care Finance and Policy Online, Preventable Hospitalization, August 2000.)

HPMP Tools
Some of the following documents are .pdf files and require Adobe Acrobat Reader. To download, click here.

Utilization Review:
Model Admission Flow Chart

A step-by-step illustration of the hospital admission process from 3 entry points with indications for issuance of a notice of noncoverage, HINN or ABN. Source: Louisiana Health Care Review, Inc.

HPMP Improvement Plan Template
Word Doc
PDF Doc
A tool for use in developing and monitoring Improvement Plans provided by LHCR for hospitals to utilize for assistance in identifying opportunities for prevention and reduction of their payment error rates. Source: Louisiana Health Care Review, Inc.

HPMP (PEPP) Compliance Workbook
Link to HPMPResources.org - Updated March 2008

ART Data Collection Tool
 

 


For more Quality Improvement
resources, visit
www.medqic.org

[Home]  [Privacy Policy]
This Web site is produced by Louisiana Health Care Review, Inc., the Quality Improvement Organization (QIO) for Louisiana, under contract 500-99-LA02 with the Centers for Medicare & Medicaid Services (CMS). The contents presented do not necessarily reflect CMS policy.

If you experience any problems with this site, please notify us by e-mail. Thank you.
Louisiana Health Care Review, Inc.
© 2002-2007
8591 United Plaza Boulevard, Suite 270
Baton Rouge, Louisiana 70809
Telephone: 225-926-6353 / Fax: 225-923-0957