Market Pulse  ·  Friday Edition  ·  September 18, 2026

PEPPER Came Back This Week After Three Years Dark — and Because It Benchmarks Nationally, It Will Flag Nearly Half of California and New York Whether or Not Anything Is Wrong

Regulatory · Reimbursement · Technology · Staffing   ·   Published by Rehinged Intelligence
Skilled nursing PEPPER reports were published again this week, restoring after a three-year dormancy the facility-level billing-outlier report that CMS and its contractors use to steer auditing attention. Separately, the CY 2027 Physician Fee Schedule proposal — whose comment period closed Monday, the day before CMS expanded its ACCESS Model to pay for monitoring in heart failure and COPD — would bar the third-party staffing arrangement that most remote patient monitoring vendors are built on.
Why it matters for vendors: Both stories create demand that is far more geographically concentrated than the headlines suggest. Applying PEPPER's own 80th-percentile outlier logic to the Medicare billing dimensions Rehinged can observe, 1,163 facilities sit above the national threshold on three or more measures — and 61.9% of them are in California and New York alone, because those states' median facility already bills above the national 80th percentile. Compliance and coding-audit vendors have a two-state quarter. Meanwhile the remote monitoring proposal cuts hardest at the 2,908 buildings that carry the heaviest chronic-disease census and the thinnest nursing staff — the ones least able to hire the monitoring clinicians CMS now wants employed in-house.
Sources: McKnight's Long-Term Care News · Skilled Nursing News · CMS.gov · CBR PEPPER (Index Analytics) · National Law Review · The American Journal of Managed Care · Rehinged Intelligence (14,690 scored facilities; CMS Medicare utilization and PDPM case-mix files, FY2022 and FY2021 respectively; provider and staffing data current)
Top Signals
Regulatory Reimbursement

SNF PEPPER Reports Return After Three Years — Restoring a Billing-Outlier Benchmark That Systematically Flags High-Cost States

McKnight's Long-Term Care News · CBR PEPPER · September 17, 2026

What happened

Skilled nursing facilities regained access to their Program for Evaluating Payment Patterns Electronic Report this week, the first SNF PEPPER release since April 2023. CMS has been relaunching the report type by type across 2026 — short-term acute care in March, critical access hospitals in May, hospice in June, long-term acute care and inpatient rehabilitation in July, home health and inpatient psychiatric in August — with skilled nursing and partial hospitalization arriving in the September wave. The report gives each facility its own Medicare fee-for-service statistics across target areas identified as vulnerable to improper payment, covering the most recent twelve quarters, and compares that facility against national, Medicare Administrative Contractor jurisdiction, and state peer groups. A facility at or above the 80th percentile on a target area is designated a high outlier; coding-focused areas also carry a 20th-percentile low-outlier flag. Index Analytics administers the program under CMS contract, and access runs through the PEPPER Portal using existing NPPES and PECOS credentials.

Why it matters

PEPPER does not assert that a payment error occurred, and CMS is careful to say so. What it does is hand nearly fifteen thousand facilities a single page telling them where they sit against their peers on billing intensity — and hand the compliance-services market a buying trigger it has not had since 2023. Expect immediate demand for coding audits, therapy documentation review, medical-record ADR readiness and revenue-cycle assessment. But the trigger is not evenly distributed, and vendors who work the whole country equally will waste the quarter. PEPPER's headline comparison is national, and the nation is not the market a California or New York operator actually competes in.

Rehinged facility intelligence 14,690 SNFs scored

Rehinged applied PEPPER's own outlier rule — the national 80th percentile — to the four Medicare billing dimensions observable in the scored facility base: service days per Medicare stay, payment per stay, payment per service day, and the share of days falling in the high-acuity non-therapy ancillary PDPM categories. Across the 12,880 facilities with complete data on all four, 1,163 facilities — 9.0% — exceed the national 80th percentile on three or more, and 305 exceed it on all four. Those 1,163 buildings account for $6.37 billion in Medicare allowed charges. They are larger than the rest of the market at 143 beds against 106, they are 91.5% for-profit, and they bill $22,080 per Medicare stay against $12,346 everywhere else. The thresholds themselves are 32.4 service days per stay, $15,502 per stay, $555 per service day, and 2.0% of days in high-acuity NTA categories.

1,163
facilities above the national 80th percentile on 3+ measures
305
above the threshold on all four
$6.37B
Medicare allowed charges in the flagged group
Medicare payment per stay — flagged facilities vs. everyone else
All other facilities
$12,346 per stay
Three or more flags
$22,080 per stay
Facilities above the national 80th percentile on 3+ measures — top 8 states
California471
New York249
New Jersey75
Texas63
Illinois47
Washington30
Indiana20
Connecticut16

The concentration is the story. California holds 471 of the 1,163 flagged facilities and New York 249 — together 61.9% of the national total, against 5.4% of the facilities in Texas and 1.0% in Florida. Put as a share of each state's own market, 47.8% of California facilities and 45.1% of New York facilities clear three or more national thresholds, against 5.9% in Texas and 1.9% in Florida. This is not evidence that half of California is billing improperly. It is arithmetic: California's median facility bills $19,436 per Medicare stay and New York's $17,200, while the national median is $12,253 and the national 80th-percentile threshold is $15,502 — so in both states the typical building already sits above the line the nation draws for outliers, on cost structures and lengths of stay those markets have carried for years. Vendors selling compliance auditing, coding review and therapy documentation should build the fourth quarter around California, New York and New Jersey, and should lead with benchmark interpretation rather than remediation — the operator opening this report does not need to be told they may be defrauding Medicare, they need to be told why a national percentile put them there and what the jurisdiction and state comparisons on the same page actually say.

Watch for: whether CMS holds SNF PEPPER to the annual cadence the relaunch schedule implies, which would make this an every-autumn buying moment rather than a one-time event. Watch also for whether Medicare Administrative Contractors and Unified Program Integrity Contractors begin drawing probe-audit targets from the restored data — the report itself is advisory, but the same claims patterns feed targeted review.
Regulatory Technology Staffing

CMS Would Bar the Outsourced Remote Monitoring Model in 2027 — the Same Week It Expanded Payment for the Outcomes That Model Produces

National Law Review · CMS Newsroom · September 17, 2026

What happened

The CY 2027 Physician Fee Schedule proposed rule would, beginning January 1, 2027, limit reimbursement for remote patient monitoring and remote therapeutic monitoring to services furnished by clinical staff who are direct employees of the billing practitioner or that practitioner's practice. CMS wrote that many practices billing these codes had delegated most or all of the monitoring function to outside vendors who supplied the devices, ran patient outreach, reviewed the data and employed the clinical staff — arrangements CMS says do not carry the oversight it expects. The proposal also confines RTM to established patients, requires a separately reportable initiating visit at the onset of monitoring, and revalues practice-expense inputs for device supply and setup downward on the view that current rates overstate what practices actually pay. The comment period closed Monday, September 14.

Why it matters

Wednesday's edition covered CMS expanding the ACCESS Model with heart failure and COPD tracks, putting federal payment behind continuous monitoring for two conditions that define much of the post-acute census. This proposal points the other way on the same quarter's calendar. CMS is willing to pay for the outcome and unwilling to accept the delivery structure that made it scalable: the device-plus-staffing bundle is precisely the model that let small practices and thinly staffed facilities participate at all. For vendors, the threat is not the payment rate, it is the org chart. A company whose revenue depends on employing the nurses who watch the dashboards would need its customers to employ them instead — and the customers with the most patients to monitor are the least equipped to do that.

Rehinged facility intelligence 14,690 SNFs scored

Rehinged crossed chronic-disease concentration against nursing capacity across the 12,072 facilities carrying both measures. 5,228 facilities sit in the top quartile nationally on heart failure or COPD prevalence — more than 54% of Medicare beneficiaries with non-ischemic heart failure, or more than 44% with COPD. Of those, 2,908 also run registered nurse staffing below the national median of 0.58 hours per resident per day. That group averages 0.40 RN hours per resident per day, 2.56 stars, and 48.9% annual nursing turnover. These are the buildings the proposed rule reaches: the monitoring demand is concentrated in them, and the staff who would have to perform the monitoring in-house are not.

5,228
facilities in the top quartile for heart failure or COPD
2,908
of those also below median RN staffing
48.9%
average nursing turnover in that group
Registered nurse hours per resident per day
National median
0.58 RN hprd
High-burden, low-staffed facilities
0.40 RN hprd
High chronic burden with below-median RN staffing — top 8 states
Texas412
California286
Florida195
Ohio186
Illinois166
Missouri144
Oklahoma122
Indiana120

Texas carries 412 of these facilities and California 286, with Florida, Ohio and Illinois each between 166 and 195 — a footprint that looks nothing like the California and New York concentration in the PEPPER analysis above, which is the practical point for anyone building one territory plan for both stories. Note also that this is a different cut of the market than Wednesday's ACCESS analysis: that one isolated facilities carrying heart failure and COPD together, while this one asks which facilities with either condition lack the nursing capacity to absorb a monitoring function. Remote monitoring vendors selling into skilled nursing should stop assuming the facility can supply the clinical labor and start modeling two structures — a licensure partnership in which an employed-clinician group bills, or a software-only posture in which the vendor sells the platform and the customer staffs it. Chains with employed medical directors and centralized clinical teams become materially more attractive than independents this quarter. Vendors with material RPM revenue in Texas, California and Florida should be reading the final rule the day it drops.

Watch for: the final CY 2027 Physician Fee Schedule rule, typically issued in early November and effective January 1. Watch specifically for whether CMS softens the direct employment requirement to permit contracted clinical staff under practitioner supervision, which is the single change that would preserve the existing vendor model, and for how far the practice-expense revaluation on device supply lands.
Quick Hits
CFG closed 24 skilled nursing transactions totaling more than $413 million across 13 states. The financings ran from late June through late August and were disclosed alongside a two-facility portfolio trade, confirming that debt capital remains available to mid-market operators even as operating margins stay compressed — and that refinancing events, which reset capital-expenditure budgets, are clustering in the back half of the year. Skilled Nursing News
American Healthcare REIT executives detailed the Trilogy operating playbook this week. The presentation emphasized revenue management, development capability and staffing strategy as the operating partner's differentiators — a useful read for vendors selling into REIT-affiliated operators, where the buying conversation increasingly runs through an operating partner rather than the landlord or the individual building. Skilled Nursing News
Paying Medicare Advantage plans more for dually eligible enrollees did not change nursing home use. New research found no meaningful shift in inpatient or nursing home utilization following increased payments for full Medicaid enrollees, undercutting the argument that richer MA capitation naturally produces post-acute investment — and reinforcing that SNF vendors should not wait on plan economics to fund facility-level purchases. The American Journal of Managed Care
340B drug payment cuts headline a separate CMS proposal to lower Medicare drug costs in 2027. The proposed reduction would shift savings toward beneficiaries, and while skilled nursing is not directly in scope, operators with hospital-affiliated referral partners should expect those partners' pharmacy economics to tighten — historically a precursor to harder negotiation on transfer agreements and shared-service arrangements. The American Journal of Managed Care
A bipartisan bill forcing faster Medicare Advantage prior authorization decisions cleared two House committees. The measure would standardize and accelerate approval timelines without a dissenting vote at committee, which would compress one of the longest-standing friction points in SNF admissions — and would reduce, though not eliminate, the value of authorization-chasing tooling sold on turnaround time alone. Reported via trade coverage, week of September 14
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