Understanding the PEPPER: “My Patients are Sicker than Everyone Else’s Patients”

Understanding the PEPPER: “My Patients are Sicker than Everyone Else’s Patients”

We have all heard it, time and time again. In fact, I recall telling my hospital’s chief medical officer that my patients were sicker than others to explain why my average length of stay was longer than those of other internists on the medical staff. The difference, of course, was that for my patients, it was true, but not for the other doctors.

When I review Program for Evaluating Payment Patterns Electronic Reports (PEPPERs) with hospitals, I always point out that PEPPER data is comparative data, and not a measure of whether one is doing things right or wrong. The PEPPER includes measures of the percentage of medical and surgical inpatients whose claims included a CC or MCC (comorbid condition and complication and major comorbid condition and complication).

A hospital with a “sicker” patient mix, with service lines that care for more complex patients, or a tertiary or quaternary care center, can expect to have a more complex patient population and therefore have more patients with CCs and MCCs. They also would expect to have a higher case mix index (CMI).

CMI, though, is simply an average of the case weights for all inpatients: a number derived from the weight assigned to each Diagnosis-Related Group (DRG), which in turn is derived from the principal diagnosis and the presence or absence of just one CC or MCC on the claim. Hospital administrators like the CMI because it translates directly to revenue.

Improve documentation, get DRGs to move to higher-weighted DRG, as with moving a simple pneumonia to a complex pneumonia, or add a CC or MCC to a baseline DRG, and the payment from Medicare goes up.

But does CMI adequately stratify hospitals well enough to be able to say, “our inpatients are sicker than your inpatients, so we have more CCs and MCCs?” Of course not. The CMI does not change if the patient has one MCC or three MCCs, but clearly the patient with three MCCs is going to be sicker and need more resources.

Well, thanks to Dr. James Kennedy, a frequent contributor to ICD10monitor, we now have a much better measure of patient “sickness.” Dr. Kennedy found a database published by the Centers for Medicare & Medicaid Services (CMS) that indicates the average Hierarchical Condition Category (HCC) score of every inpatient admitted in 2021 at almost all hospitals. For any who have tried to venture into data.CMS.gov and survived, you know it can be a harrowing experience. Nonetheless, knowing that Dr. Kennedy took the excursion and found useful information provided me the confidence to try myself.

And I was rewarded with a .csv file with 3,134 lines and 45 columns. But of those 141,030 data points, I discovered the few that provided useful data. Those were column B (the hospital name), column E (the city name), column F (the state name), column J (the number of discharges), and column AS (the average HCC score of all inpatients). I promptly hid the rest of the data, providing me enough information to be of value. And of paramount importance, I followed Dr. Kennedy’s advice and saved the file as an .xlsx file (but only after first forgetting to do that and losing all my edits).

Because the HCC score includes demographic factors along with most diagnoses, whether they are a CC/MCC or not, and not just a single CC or MCC, as with CMI, this data is as close to the most accurate publicly available measure of patient acuity as we may be able to get.

From this initial effort to make the data more manageable, I was then able to sort the remaining data to find the hospitals with the highest average HCC score (a specialty hospital with 50 discharges has a score over 8), the national-average HCC score (1.986), the highest and lowest in a state, while also being nosy and looking at some prominent facilities throughout the country. I am sure people with Excel skills better than mine (representing the majority of the population) will undoubtedly find other interesting factoids.

So, what can you do with this? Aside from comparing your facility to your competitors for the fun of it, this may help you understand whether your high percentage of patients with CCs and MCCs (dare I say “to the point of being an outlier”) is justified by a sicker patient population, or perhaps whether it may be an indication that you should increase your clinical validation efforts. If you have access to length-of-stay data, this higher average HCC score may help explain why yours is longer than others, or whether your doctors really are keeping patients longer than necessary, or doing evaluations of incidental findings since it is more convenient, among other reasons.

In this era of constant cost pressure and consolidation, the addition of data such as this should be welcome – with, of course, the caveat that there are many factors that influence hospital finance beyond how sick your traditional Medicare patients are.

But more granular data certainly beats the alternative.

Programming note: Listen to Dr. Ronald Hirsch when he makes his Monday rounds on Monitor Mondays with Chuck Buck, 10 Eastern, and sponsored by R1-RCM.

Facebook
Twitter
LinkedIn

Ronald Hirsch, MD, FACP, ACPA-C, CHCQM, CHRI

Ronald Hirsch, MD, is vice president of the Regulations and Education Group at R1 Physician Advisory Services. Dr. Hirsch’s career in medicine includes many clinical leadership roles at healthcare organizations ranging from acute-care hospitals and home health agencies to long-term care facilities and group medical practices. In addition to serving as a medical director of case management and medical necessity reviewer throughout his career, Dr. Hirsch has delivered numerous peer lectures on case management best practices and is a published author on the topic. He is a member of the Advisory Board of the American College of Physician Advisors, and the National Association of Healthcare Revenue Integrity, a member of the American Case Management Association, and a Fellow of the American College of Physicians. Dr. Hirsch is a member of the RACmonitor editorial board and is regular panelist on Monitor Mondays. The opinions expressed are those of the author and do not necessarily reflect the views, policies, or opinions of R1 RCM, Inc. or R1 Physician Advisory Services (R1 PAS).

Related Stories

Can Any Physician Enter an Inpatient Order?

Can Any Physician Enter an Inpatient Order?

Let’s talk about the term “attending physician.”  The simplest definition is the physician primarily responsible for a hospitalized patient’s care.  While there may be many

Read More

Leave a Reply

Please log in to your account to comment on this article.

Featured Webcasts

I022426_SQUARE

Fracture Care Coding: Reduce Denials Through Accurate Coding, Sequencing, and Modifier Use

Expert presenters Kathy Pride, RHIT, CPC, CCS-P, CPMA, and Brandi Russell, RHIA, CCS, COC, CPMA, break down complex fracture care coding rules, walk through correct modifier application (-25, -57, 54, 55), and clarify sequencing for initial and subsequent encounters. Attendees will gain the practical knowledge needed to submit clean claims, ensure compliance, and stay one step ahead of payer audits in 2026.

February 24, 2026
Mastering Principal Diagnosis: Coding Precision, Medical Necessity, and Quality Impact

Mastering Principal Diagnosis: Coding Precision, Medical Necessity, and Quality Impact

Accurately determining the principal diagnosis is critical for compliant billing, appropriate reimbursement, and valid quality reporting — yet it remains one of the most subjective and error-prone areas in inpatient coding. In this expert-led session, Cheryl Ericson, RN, MS, CCDS, CDIP, demystifies the complexities of principal diagnosis assignment, bridging the gap between coding rules and clinical reality. Learn how to strengthen your organization’s coding accuracy, reduce denials, and ensure your documentation supports true medical necessity.

December 3, 2025

Proactive Denial Management: Data-Driven Strategies to Prevent Revenue Loss

Denials continue to delay reimbursement, increase administrative burden, and threaten financial stability across healthcare organizations. This essential webcast tackles the root causes—rising payer scrutiny, fragmented workflows, inconsistent documentation, and underused analytics—and offers proven, data-driven strategies to prevent and overturn denials. Attendees will gain practical tools to strengthen documentation and coding accuracy, engage clinicians effectively, and leverage predictive analytics and AI to identify risks before they impact revenue. Through real-world case examples and actionable guidance, this session empowers coding, CDI, and revenue cycle professionals to shift from reactive appeals to proactive denial prevention and revenue protection.

November 25, 2025
Sepsis: Bridging the Clinical Documentation and Coding Gap to Reduce Denials

Sepsis: Bridging the Clinical Documentation and Coding Gap to Reduce Denials

Sepsis remains one of the most frequently denied and contested diagnoses, creating costly revenue loss and compliance risks. In this webcast, Angela Comfort, DBA, MBA, RHIA, CDIP, CCS, CCS-P, provides practical, real-world strategies to align documentation with coding guidelines, reconcile Sepsis-2 and Sepsis-3 definitions, and apply compliant queries. You’ll learn how to identify and address documentation gaps, strengthen provider engagement, and defend diagnoses against payer scrutiny—equipping you to protect reimbursement, improve SOI/ROM capture, and reduce audit vulnerability in this high-risk area.

September 24, 2025

Trending News

Featured Webcasts

The PEPPER Returns – Risk and Opportunity at Your Fingertips

Join Ronald Hirsch, MD, FACP, CHCQM for The PEPPER Returns – Risk and Opportunity at Your Fingertips, a practical webcast that demystifies the PEPPER and shows you how to turn complex claims data into actionable insights. Dr. Hirsch will explain how to interpret key measures, identify compliance risks, uncover missed revenue opportunities, and understand new updates in the PEPPER, all to help your organization stay ahead of audits and use this powerful data proactively.

March 19, 2026

Top 10 Audit Targets for 2026-2027 for Hospitals & Physicians: Protect Your Revenue

Stay ahead of the 2026-2027 audit surge with “Top 10 Audit Targets for 2026-2027 for Hospitals & Physicians: Protect Your Revenue,” a high-impact webcast led by Michael Calahan, PA, MBA. This concise session gives hospitals and physicians clear insight into the most likely federal audit targets, such as E/M services, split/shared and critical care, observation and admissions, device credits, and Two-Midnight Rule changes, and shows how to tighten documentation, coding, and internal processes to reduce denials, recoupments, and penalties. Attendees walk away with practical best practices to protect revenue, strengthen compliance, and better prepare their teams for inevitable audits.

January 29, 2026

AI in Claims Auditing: Turning Compliance Risks into Defensible Systems

As AI reshapes healthcare compliance, the risk of biased outputs and opaque decision-making grows. This webcast, led by Frank Cohen, delivers a practical Four-Pillar Governance Framework—Transparency, Accountability, Fairness, and Explainability—to help you govern AI-driven claim auditing with confidence. Learn how to identify and mitigate bias, implement robust human oversight, and document defensible AI review processes that regulators and auditors will accept. Discover concrete remedies, from rotation protocols to uncertainty scoring, and actionable steps to evaluate vendors before contracts are signed. In a regulatory landscape that moves faster than ever, gain the tools to stay compliant, defend your processes, and reduce liability while maintaining operational effectiveness.

January 13, 2026

Trending News

Happy National Doctor’s Day! Learn how to get a complimentary webcast on ‘Decoding Social Admissions’ as a token of our heartfelt appreciation! Click here to learn more →

CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 1 with code CYBER25

CYBER WEEK IS HERE! Don’t miss your chance to get 20% off now until Dec. 2 with code CYBER24