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Quarterly PBJ Deadline Nears

We remind nursing home members that Payroll-Based Journal (PBJ) data submissions covering Jan. 1st through March 31st must be finalized with the Centers for Medicare and Medicaid Services (CMS) by May 15th. PBJ submissions are used to calculate quarterly staffing ratings used in the Five-Star Quality Rating System. Only data that are successfully submitted by the deadline are used in determining ratings, and inaccurate submissions can result in a home being assigned a single star for the staffing domain.

Members should be certain that their homes are accurately reflecting in their reporting the requirement that they have a registered nurse (RN) on site for at least eight consecutive hours, seven days per week. The latest version of the PBJ policy manual (November 2018) and related resources are available for download at the bottom of the dedicated CMS PBJ webpage here. The user guide for uploading data through the CMSNet Secure Access Service is available here.

Because proposed staffing ratios legislation moving through both state legislative houses would base these ratios on PBJ data starting in 2022, it is an important time to ensure that reporting is complete and accurate.

Based on member experiences and prior 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 Frequently Asked Questions (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 1 and the remaining six hours for day 2. CMS indicates that they understand that employees may be paid per shift and not per calendar day and will consider this when conducting audits.

Training Time. Hours for staff who are attending training (either on site or off site) and are not available to perform their primary role, such as providing resident care, shall not be reported. If another staff member is called in to fill in for staff participating in training, the hours for the replacement employee shall be reported.

CMS has also indicated in the past that homes reporting low weekend staffing and those failing to meet the daily required RN staffing would be referred to the state survey agency for potential closer scrutiny. 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. The current PBJ Manual (November 2018) is available here, and an accompanying FAQ document is here. A more recent set of FAQs focused on technical aspects of reporting is available here.

Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841