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CMS WatchJuly 22, 2026·3 min read

PEPPER relaunch wraps in September, and staff coders can now download the report themselves

CMS is finishing the PEPPER rollout with monthly releases through September 2026, and staff end users can now download their facility's report once an authorized official approves the access. The coding-focused target areas also flag under-coding, at the 20th percentile.

PEPPERCMSauditdocumentationMedicare
Jess P., CPC

Reviewed by Jess P., CPC

Published July 22, 2026

Printed billing spreadsheet and a records folder under a magnifying glass, the kind of self-audit a PEPPER target area review starts with.
PEPPER hands a facility its own Medicare billing statistics and leaves the audit to the coding team.Image: HCC Buddy

Key Takeaways

  • The CMS MLN Connects edition dated July 23, 2026 says PEPPER is relaunching in the coming months for all Medicare facility types, including hospitals, post-acute care providers, and specialty facilities.
  • Staff end users can now download their organization's PEPPER once an authorized official or access manager approves the PEPPER business function in the CMS Identity & Access system; at the December 2025 relaunch only AOs and AMs could download it.
  • CMS is relaunching PEPPER via ongoing releases through September 2026, with home health agencies and inpatient psychiatric facilities in August and partial hospitalization programs, skilled nursing facilities, and Q2 FY2026 short-term acute care hospitals in September.
  • PEPPER sets an upper control limit at the 80th percentile for every target area and a lower control limit at the 20th percentile for coding-focused target areas, so a low outlier is an under-coding signal.
  • PEPPER does not identify the presence of payment errors, and CMS suppresses any numerator or denominator under 11.

The MLN Connects edition dated July 23, 2026 tells providers the Program for Evaluating Payment Patterns Electronic Report is relaunching "in the coming months for all Medicare facility types, including hospitals, post-acute care providers, and specialty facilities." The report itself is not new. What changed is who can pull it and when your facility type is up.

What actually changed since the December relaunch

CMS relaunched PEPPER for short-term acute care hospitals in December 2025. At that point, in CMS's own words, "only authorized officials (AOs) and access managers (AMs) with active Identity & Access Management System accounts can download their reports."

Staff end users can now download their organization's PEPPER through the portal once an AO or AM approves the PEPPER business function in the Identity & Access system. That is the practical change. The person who reads the report no longer has to route every request through the person who signs the enrollment paperwork.

The login is the same one you already use for NPPES and PECOS, and the Comparative Billing Report business function can be requested at the same time.

The release schedule runs through September 2026

CMS says it is relaunching PEPPER via ongoing releases through September 2026. The schedule it published:

MonthFacility types released
MarchShort-Term Acute Care Hospitals (Q4 FY2025)
MayCritical Access Hospitals
JuneHospice, Short-Term Acute Care Hospitals (Q1 FY2026)
JulyLong-Term Acute Care Hospitals, Inpatient Rehabilitation Facilities
AugustHome Health Agencies, Inpatient Psychiatric Facilities
SeptemberPartial Hospitalization Programs, Skilled Nursing Facilities, Short-Term Acute Care Hospitals (Q2 FY2026)

After the relaunch, short-term acute care hospitals get a PEPPER quarterly. Every other facility type on that list gets one annually. So if you are a skilled nursing facility or a partial hospitalization program, September is the only release scheduled for you in this cycle, and the access approval has to clear before then.

The coding target areas flag under-coding too

This is the part worth reading twice. PEPPER draws a control limit at the 80th percentile for every target area, so anything at or above it is a high outlier. Coding-focused target areas carry a second control limit at the 20th percentile, and anything at or below that is a low outlier.

That lower limit is the under-coding signal, and it only exists on the coding target areas. Outlier status gets evaluated in priority order: nation first, then MAC jurisdiction, then state, because the state comparison group is the smallest.

CMS describes the target areas as discharges and services vulnerable to improper payments, including diagnosis-related groups at risk for under-coding or over-coding.

What PEPPER will not do for you

PEPPER does not identify the presence of payment errors. It tells you where your statistics sit against a comparison group, and the chart review is still yours. A target area above the upper control limit is a place to look, not a finding.

The report also will not hand you a patient list. CMS suppresses any numerator or denominator under 11, so small-volume target areas can come back blank, and you have to rebuild the population yourself from the numerator definition in the user guide.

Each report covers the most recent 12 quarters available, so you can watch a target area move instead of reacting to one period. Index Analytics LLC develops and distributes PEPPER under contract with CMS.

What to do with it on the coding side

Treat the outlier list as a work queue for a self-audit, not as a scorecard. Pull the target areas where you sit outside a control limit in either direction, sample charts, and check whether the documentation in the record supports what was billed. That is the same question a contractor asks when it pulls your charts, which is what turns up in reviews like the Novitas nursing-home Part B audit and the insufficient-documentation denial patterns on the fee-for-service side.

For a risk-adjustment team, PEPPER sits on the fee-for-service side of the house and reports nothing about your Medicare Advantage HCC capture. It is still worth a look if your organization bills both, because the sampling method is the same one you already run on a chart chase. Line the supporting notes up in the evidence builder before you sign off that a sampled chart was coded correctly.

What coders should do now

  1. 1Check the PEPPER release month for your facility type and, if it is August or September, request the PEPPER business function in the CMS Identity & Access system now, since an authorized official or access manager still has to approve it before you can download anything.
  2. 2When the report lands, open the Compare Targets Report and list every target area at or above the 80th percentile nationally, then every coding-focused target area at or below the 20th, and work them in that priority order (nation, then jurisdiction, then state).
  3. 3Sample charts from your worst target area and check the documentation against what was billed rather than assuming the percentile is the finding, because PEPPER does not identify payment errors on its own.
  4. 4Rebuild the numerator population yourself from the target area definition in the PEPPER user guide, since the report will not give you a patient list and blanks out any cell under 11 cases.
  5. 5Line the supporting notes for each sampled chart up in the [evidence builder](/evidence) before you sign off that the code was supported.

Frequently Asked Questions

When does my facility type get its 2026 PEPPER?

CMS is releasing PEPPERs on a monthly schedule through September 2026. Long-term acute care hospitals and inpatient rehabilitation facilities released in July, home health agencies and inpatient psychiatric facilities release in August, and partial hospitalization programs, skilled nursing facilities, and Q2 FY2026 short-term acute care hospitals release in September.

Do I have to be an authorized official to download a PEPPER?

No. Staff end users can download their organization's PEPPER through the PEPPER Portal once an authorized official or access manager approves the PEPPER business function for them in the CMS Identity & Access system. That is a change from the December 2025 relaunch, when only authorized officials and access managers could download reports.

Does a high PEPPER percentile mean my facility has billing errors?

No. CMS states that PEPPER does not identify the presence of payment errors. A percentile at or above the 80th tells you your statistics sit above the comparison group for that target area, which makes it a candidate for auditing and monitoring rather than a finding on its own.

What does a low PEPPER outlier mean?

Coding-focused target areas carry a lower control limit at the 20th percentile. A percentile at or below it makes the facility a low outlier, which is the report's signal for potential under-coding rather than over-coding. Non-coding target areas only have the 80th-percentile upper limit.

Does PEPPER cover Medicare Advantage risk adjustment?

No. PEPPER reports facility-specific Medicare fee-for-service statistics for discharges and services vulnerable to improper payments. It does not report on Medicare Advantage HCC capture or risk adjustment data validation.

Related topics:PEPPERCMSauditdocumentationMedicare
Jess P., CPC

Jess P., CPC

Certified Professional Coder

Jess reviews HCC Buddy editorial content for accuracy against the current CMS-HCC model and the active FY ICD-10-CM tabular release.

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