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New CMS Nursing Home Staffing Reporting

Effective Oct. 1, 2015, the Centers for Medicare and Medicaid Services (CMS) intends to begin collecting nursing home staffing data through the new Payroll-Based Journal (PBJ) reporting system. CMS set up a PBJ web page and posted a draft manual and vendor software specifications. The initial Oct. 1 start date is for those facilities seeking to participate in the data submission on a voluntary basis in anticipation of a mandatory start date of July 1, 2016.

As mandated under section 6106 of the Affordable Care Act, facilities will be required to submit direct care staffing information (including agency and contract staff) based on payroll and other auditable data. The data will be combined with census information to report on staffing levels, turnover and tenure to be incorporated into the facility’s quality rating. This will take the place of the reporting that now occurs on survey. Access to the PBJ system is at no cost to facilities.

The general specifications require the regular submission of data that includes: 1.) the category of work a certified employee performs (e.g., registered nurse, licensed practical nurse, licensed vocational nurse, certified nursing assistant, therapist or other medical personnel), and 2.) resident census data. 

The CMS PBJ website is an important resource for long term care facilities and payroll vendors to begin to use. In addition to the resources noted above, the website includes: timelines, technical specifications and contact information.

CMS also issued a notice to all long term care facilities entitled: Electronic Staffing Data Submission – Payroll Based Journal (PBJ).  For member convenience text from the CMS notice is copied below:

CMS has developed a system for facilities to submit staffing and census information. This system, the Payroll-Based Journal (PBJ), will allow staffing information to be collected on a regular and more frequent basis than currently collected. It will also be auditable to ensure accuracy. All long term care facilities will have access to this system.

Information about this system is posted at:

http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/NursingHomeQualityInits/Staffing-Data-Submission-PBJ.html

This posting provides information such as the timing of submissions, sample entry screens, and how we expect facilities to electronically submit their staffing data, whether through a payroll vendor or through manual entry. Nursing homes are encouraged to forward this link to their software developers and payroll or time and attendance vendors to evaluate the technical specifications. Furthermore, nursing homes should encourage software developers or vendors to participate in voluntary vendor registration at https://www.qtso.com/vendor/post.php. This information will be used to contact vendors with important PBJ news, updates, and conference call information.

CMS will host a PBJ software developer/vendor call on May 6, 2015 related to the PBJ Data Submission Specifications (V1.00.0). To receive information about this call, please register through the link in the preceding paragraph. This call will cover a high level overview of the PBJ Data Submission Specifications as well as submitted Q & A relating to the April 2015 data specifications release.

Questions regarding the PBJ Data Submission Specifications should be directed to NursingHomePBJTechIssues@cms.hhs.gov by May 1, 2015, in order to inform the upcoming PBJ software developer/vendor call. We will have an open Q & A session at the end of this call. Please note that CMS policies related to PBJ are not the focus of the vendor calls. These calls are for technical or software related information and questions only. PBJ policy related questions/comments should be sent to nhstaffing@cms.hhs.gov.

V1.00.0 of the PBJ Data Submission Specifications is posted at the link above. This version supports the voluntary submission of payroll that begins October 1, 2015. Registration for the voluntary submission PBJ system will begin in August, however data collection (electronic data submission and/or manual data entry) will begin October 1, 2015.  Please do not register at this time if you are not planning on participating during the voluntary submission period.

The following files contain technical information related to PBJ and are now available:

 PBJ Policy Manual DRAFT – General background and information about the submission requirements, such as sample submission screens, submission deadlines, and definitions of job categories.

 PBJ 1.0 Submission Specs V1.00.0 for the October 1, 2015 Release:

1.PBJ data specs PDF files ZIP – Full data spec report and the unduplicated edits report, as well as the Overview document.

2.PBJ data dictionary ZIP – The Access database used to maintain the items and edits, as well as generate the reports.

3.PBJ data specs CSV files ZIP – Comma-separated value (CSV) files of the items and item values.

4.PBJ data specs HTML files ZIP – Set of HTML files that can be used to navigate the items and edits in a browser.

5.       PBJ data specs XML and XSD files ZIP – Sample PBJ XML submission file and its associated XSD file for performing some of the validations in the specs.

                 Source: CMS PBJ e-Mail Notice dated April 8, 2015.

The PBJ is a critical new process in terms of potential impact on survey results, quality ratings and reimbursement. This represents a major new initiative on the part of CMS and given the scope of the project the implementation is likely to be complex. LeadingAge New York will be carefully monitoring ongoing developments and keeping members informed. The most critical factor at this time is for providers to initiate contact with payroll/software vendors to ensure interoperability with the PBJ system.

Contact: Patrick Cucinelli, pcucinelli@leadingageny.org, 518-867-8827