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PBJ Data Due Nov. 14th

Nursing homes must finalize Payroll-Based Journal (PBJ) data covering July 1st through Sept. 30, 2023 by Nov. 14th. Only data that are successfully submitted by the deadline are accepted, and inaccurate or missing submissions can result in a home being assigned a single star for the staffing domain and increase the likelihood of an audit. Please keep in mind that PBJ data are used to monitor compliance with State staffing level requirements. Data submission times mark good opportunities for providers to verify that their PBJ reporting systems are sound, ensure that they submit a linking file in advance of any changes to employee ID numbers, and double check that discharge assessments are being filed in a timely manner to ensure that the Minimum Data Set (MDS)-based daily census that is used in computing staffing levels is not overstated. An overstated census artificially decreases staffing levels, putting a facility at risk of a lower star rating and potentially causing it to be out of compliance with staffing requirements.

With the switch to the updated MDS form on Oct. 1, 2023, a number of members have reported concerns that their MDS software was not allowing them to submit or even finalize Medicaid assessments. Because the Centers for Medicare and Medicaid Services (CMS) uses the MDS system to determine the daily census used in PBJ staffing calculations, delays in the submission of MDS assessments can distort hours of staff time per resident day figures. CMS has confirmed that they intend to pull the MDS census data immediately following the PBJ submission deadline of Aug. 14th and that no correction process is available. While we hope that MDS submission concerns have been resolved, we ask that members let us know if they are still experiencing difficulty in submitting assessments.

Additionally, a change in how CMS handles missing data when calculating staff turnover measures may now have a lasting negative impact on a facility’s Five-Star calculation if data are not submitted. While the change will not be implemented until April 2024, because turnover calculations rely on six quarters of data, one missed quarter now (or one quarter of erroneous data) can reduce a facility’s staffing rating for 18 months. Since July 2022, when CMS first added turnover measures to the staffing star rating calculation, CMS has excluded the three turnover measures from the calculation if data were missing for any of the six quarters used to calculate turnover rates. This approach meant that the missing data did not hurt a provider’s overall staffing score. Starting in April 2024, providers will receive the lowest possible score when their staffing turnover measures are calculated if data for one of the quarters are missing.

The PBJ Policy Manual, updated in June 2022, along with related resources including a set of Frequently Asked Questions (FAQs), are available for download at the bottom of the dedicated CMS PBJ webpage here. Information from CMS describing the various PBJ reports providers may access, including general and detailed MDS census reports that should be used to verify that discharged residents are not reflected in the census, is available here. Providers are urged to submit data and run and review the various reports with sufficient time to make any necessary corrections prior to the final due date. Additional information is available here.

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