Beginning July 1, 2016, skilled nursing facilities nationwide will be required to electronically report staffing data to CMS through the Payroll Based Journal (PBJ). As the date approaches, we have been fielding many important questions regarding the requirements for the new system.
It is very important you don’t wait until the last minute to begin your preparations for the PBJ. The system will require a significant amount of planning and set up time, in addition to the time required to get the information into the PBJ.
We’ve put together a list of important questions to consider as you prepare for the new requirements. We welcome any other questions you might have. Please contact your HW Healthcare Advisor with any questions.
Why did CMS develop the Payroll Based Journal?
The Patient Protection and Affordable Care Act, often referred to as the ACA or Obamacare, included a requirement for skilled nursing facilities to report staffing data electronically, rather than at the time of the facility’s annual survey. Funding for the development of the system was given to CMS in 2014 after a series of New York Times articles that were critical of the staffing component of the Five Star rating system.
How often will facilities have to submit data?
Nursing facilities will be required to submit data at least quarterly. Data for a given quarter is due within 45 days after the end of the quarter. For example, data for the quarter July 1, 2016 through September 30, 2016 will be due by November 14, 2016. Facilities are able to submit data as early and often as they wish during a reporting period. We recommend you make the submission the final step in your payroll process.
Is there a way to test the Payroll Based Journal system before July 1, 2016?
CMS opened the PBJ to voluntary enrollment on October 1, 2015. The voluntary period allows facilities to report data before July 1, 2016. Any data submitted during the voluntary period will be disregarded by CMS and will not be reported publically or used in the CMS Five Star ratings.
We highly recommend all providers register for the voluntary period simply to get a feel for the new system. Chain providers do not need to register all of their facilities, but may want to consider registering one or two facilities. We must stress again, you should not wait until the last minute to register for the PBJ. The voluntary period will be very helpful in preparing for the required reporting.
Who will be reported?
Facilities will be required to submit staffing data for their direct care employees and contractors who have interpersonal contact with residents. CMS has interpreted direct care staff to include nurses, activities, social services, the facility’s administrator, dietician and therapists, as well as other minor categories that may not apply to all facilities. All individuals will be coded to one of thirty-seven job codes.
Supporting employees such as dietary kitchen staff, housekeeping staff and maintenance staff can be reported on an optional basis.
What data will be reported?
For applicable job codes, the data will include the number of hours paid for each employee for every day worked during the reporting period, hire and termination dates, pay type (e.g., exempt, non-exempt, contract) and job code. The information for each employee will be reported individually. In-service time, paid time off, vacation and sick time cannot be included.
Facilities will also be required to submit the number of residents in the facility as of the last day of each month of the quarter (e.g., July 31, August 31 and September 30).
Do you only have to report hours from your payroll?
You’ll need to report hours for all employees, agency and contract staff that can be verified through either payroll, invoices, and/or tied back to a contract. The “Pay Type Code” to be reported is the “classification of whether the staff member is a direct employee of the facility (exempt or non-exempt), or employed under contract paid by the facility”. The CMS PBJ Policy Manual specifically states “hours for services performed that are billed to FFS Medicare or other payer should not be reported. For example, physician visits to residents, hospice staff, or private duty nurses hours should not be reported.”
What information will be reported for contract employees (e.g., therapists and agency nurses)?
Contracted individuals will be treated the same as employees. The hours paid for every day worked by a contract employee will be submitted to the PBJ. This presents some logistical issues, particularly for facilities that use a contract therapy company or have a large number of agency nurse hours. You should discuss with your contract companies how they will be able to provide you with the information you’ll need for the PBJ.
Your facility will need to be able to get the hours worked by each individual employee from the contract company. For example, if you use an agency for nursing staff and the agency sends Nurse Jane on Tuesday and Nurse Joe on Wednesday, you will have to report the time for Nurse Jane and Nurse Joe separately.
Can time spent by physicians or advance practice nurses in the nursing facility be reported?
Physician time can be included if the physician is being paid by the facility (e.g., the medical director). However, physicians who bill Medicare or another payor for their time cannot be included. For example, the time spent by a podiatrist performing visits to patients in your facility for which he/she will separately bill Medicare cannot be reported.
Likewise, time for advanced practice nurses, including nurse practitioners, can only be included if the facility is paying the professional providing the services. If the nurse practicitioner bills Medicare or another payor for his/her time, the facility cannot report those hours to the PBJ.
Certain states have managed care plans that oversee the care coordination for dual eligible Medicaid residents (e.g., MyCare Ohio). The time spent by these nurse practitioners cannot be reported as the facility is not paying the professional for his or her time.
Can volunteer hours be included in the Payroll Based Journal reporting?
No, volunteer hours cannot be reported as direct care hours. The CMS PBJ Policy Manual specifically states “do not include volunteers” in the descriptions of a number of the job codes, including nurse aides, activities staff and other social services staff.
How will CMS know the data is correct?
CMS has indicated they plan to audit a sample of the information submitted to the PBJ. The policy manual states “data reported should be auditable and able to be verified through either payroll, invoices, and/or tied back to a contract.”
How will the information be submitted?
Nursing facilities can report the data either via an electronic upload or manual input. The electronic uploads must be in an XML format that meets specific technical specifications.
Manual input will be an incredible burden on your facility’s staff. In addition to the time needed to input the time for each employee and each day, a significant amount of time will be required to gather and summarize the data, set up the employees in the system or assign employees to job codes. The additional time may require a facility to hire additional staff.
Which leads to the question…
Does your timekeeping system support the required Payroll Based Journal reporting?
Many of the timekeeping companies that have focus on the long-term care industry are working to develop tools for their clients. You should contact your timekeeping company immediately to discuss their readiness for the PBJ. Questions you should ask include whether they can provide you with data by employee, day, job code, etc., and if the data provided will be in the exact format for upload to the PBJ.
Facilities that use timekeeping systems that are not as common to the long-term care industry may need to work with them to get a tool developed. You may be charged a fee to have them develop a tool, but it will be well worth the money spent to avoid the manual input.
If your facility does its payroll and timekeeping manually, you should consider investing in an electronic timekeeping system. While this would require an initial investment, the time saved from manually summarizing and inputting the PBJ information each quarter would offset paying for the new system. It would also help in avoiding any human error involved with manually inputting the information, which will ensure you are reporting the correct data.
Does CMS have any additional resources?
The CMS PBJ website has a policy manual and many frequently asked questions that may be of help to you. It also includes the technical specifications for the electronic uploads.
How do I register?
Registration for the PBJ is through QIES system. You can visit the following websites for more information:
https://www.qtso.com/cmsnet.html