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PBJ Data Due by Nov. 14th

The quarterly Payroll-Based Journal (PBJ) data for the quarter covering July 1st through Sept. 30th must be finalized by Nov. 14th. Please keep in mind that the recently enacted minimum staffing level legislation relies on PBJ data (even if delay and/or legal challenge are possible). At minimum, this means that PBJ reporting is likely to be under greater scrutiny, making it important that providers report completely and correctly. The PBJ Policy Manual is here, and a Frequently Asked Questions (FAQ) document that discusses several common errors is here (note that the most recent versions of both documents are from 2018).

Because unlike the Five-Star methodology, the minimum staffing level legislation does not recognize hours reported for nurses with administrative duties, members should be aware that hours for administrative nurses that spend a part of their shift performing direct care can be divided into two job categories for the shift.

Based on member experiences and prior Centers for Medicare and Medicaid Services (CMS) comments, the following areas warrant special attention and may be audit triggers:

Meal Breaks. Meal breaks must be subtracted from PBJ-reported time regardless of whether staff worked through lunch or actually took the break. When reporting, you must deduct the time allotted for meals from each employee’s daily hours.

RN Staffing. Providers should ensure that they are meeting the requirement to have an RN on site for at least eight consecutive hours, seven days per week; that their reporting accurately reflects the hours; and that they are able to readily provide necessary documentation to back up the reporting.

Varying Roles and Universal Workers. While reporting is based on primary roles, CMS recognizes that staff may completely shift their primary role in a given day, and in those cases, facilities can change the designated job title and report hours under two titles for the employee. For facilities that use universal care workers, a reasonable methodology must be used to separate the time that the universal care worker spends performing their primary role from their time that is spent performing other activities. The PBJ FAQs provide further examples.

High, Low, and Fluctuating Hours. CMS and their contract auditors appear to focus on reporting that indicates unreasonably high or low work hours, large variations in weekday versus weekend staffing, as well as low weekend staffing.

Calendar Day Reporting. Staff hours must be reported on a calendar day basis. Providers are required to split shifts that straddle midnight into individual calendar days. For example, if an employee works a shift that starts at 11 p.m. and ends at 7 a.m., one hour would need to be reported for day one and the remaining six hours for day two. CMS indicates that they understand that employees may be paid per shift and not per calendar day and will consider this when conducting audits.

Because daily census is an important component of the PBJ staffing calculation and is derived from Minimum Data Set (MDS) submissions, providers should ensure that MDS assessments, including discharge records, are filed in a timely way. Please note that accurate and timely PBJ reporting also has implications for the facility's federal star ratings as well as state Nursing Home Quality Initiative (NHQI) score calculation.

Contact: Ken Allison, kallison@leadingageny.org, 518-867-8820