If you work in long-term care, Payroll-Based Journal reporting is no-doubt at the top of your to-do list. You’re not alone if you have yet to register with CMS, or if you’re still not sure how you will manage your PBJ data submissions. As we’ve presented on the topic over the last year, through webinars and education sessions, it’s come to our attention that many providers have questions about the ins and outs of PBJ submission. In this blog we’ll address some of the common queries we encounter.
1. Which facilities are required to submit PBJ data?
PBJ applies to skilled nursing facilities.
According to CMS, for PBJ submission, only long-term care facilities that are subject to meeting the Requirements for Participation as specified in 42 CFR Part 483, Subpart B are subject to the PBJ reporting requirements. This requirement does not apply to swing beds.
2. When is PBJ data due? How often should I submit PBJ data?
PBJ data submission is required to be done on a quarterly basis. For instance, mandatory collection for the first quarter of PBJ data begins July 1, 2016-September 30, 2016. The data from that quarter should be submitted no later than 45 days after the quarter ends, November 14, 2016.
Though CMS requires submission only quarterly, we suggest submitting data more often. Submitting data on a regular basis, such as a couple of weeks after payroll, will help you recognize discrepancies or inaccuracies in your PBJ data quickly so they can be addressed before the quarterly deadline.
3. What format should the data be in for submission?
Data can be entered manually and submitted to CMS, or you can upload a preformatted XML or CSV file. You can also do a combination of manual entry and those file types. Many providers are relying on a partner to help them with this process due to its complexity.
4. What data is required to be submitted?
There are three main categories of data that should be reported for each person in one of the 35 designated positions:
- Direct care hours worked – Per employee and contactor/agency personnel per day
- Tenure data – Hire and termination date
- Census information – Last day of each month
5. Which employees count as Direct Care?
CMS defines direct care staff as those individuals who, through interpersonal contact with residents or resident care management, provide care and services to allow residents to attain or maintain the highest practicable physical, mental, and psychosocial well-being. Direct care does not include individuals whose primary duty is maintaining the physical environment of the long term care facility (for example, housekeeping).
More specific information about counting hours for Directors of Nursing and other employees who may perform different duties throughout the day, such as Medical Directors and contract staff is available here.
6. Which hours count for PBJ submission?
Communities must submit the number of hours each staff member (including agency and contract staff) is paid to deliver services for each day worked.
- Training hours can be counted if the staff member is available to give direct care.
- Corporate employee hours can be counted if the corporate employee is performing direct care duties.
Some direct care hours should not be included such as overtime, PTO, sick leave, etc.
7. How do I classify my employees by job code titles?
CMS has provided a list of all applicable direct care staff and the codes associated with them. Start now to match your organization’s unique job codes/descriptions to the 35 CMS job code titles. You should also do this with your agency and contract workers. Determine a process for collecting the appropriate job title code at the beginning of each shift.
8. How do I count hours that are not captured in our time and attendance system?
Data reported should be auditable and able to be verified through either payroll, invoices, and/or tied back to a contract. There is an expectation of accountability for services provided. Facilities must use a reasonable methodology for calculating and reporting the number of hours spent on site conducting primary responsibilities, based on payments made for those services.
Before July 1, you’ll need to define your process for collecting hours from hourly staff, contract workers, salaried staff and corporate staff. Check with your agencies and contactors to determine if they are able to provide a CMS ready report of the hours worked, or you may want to utilize a check-in application to automate capturing those hours.
9. How do I report census data?
Census information must be provided for the last day of each month. Number of residents should be reported based on the primary payer: Medicaid, Medicare, or other (residents whose primary payer is neither Medicaid nor Medicare).
10. How do I report tenure data?
CMS requires that each employee have an employee record in the PBJ system to track hours and tenure data. There are specific items that are required for this record including:
- Unique Employee ID which is not personally identifiable (e.g., cannot be the person’s name or social security number)
- Hire Date
- Termination Date
Pay Type Code Definitions of the above terms and more detailed information can be found here.
Simplify PBJ Reporting with Technology
As the PBJ deadline approaches, you should be registered with CMS, mapping employee job codes to the CMS job code titles, and defining the process by which you will gather all applicable hours for direct care workers.
Are you planning to upload or enter PBJ data manually? Skilled nursing facilities are the ones ultimately accountable for all PBJ data in the event of an audit, so create a checklist for yourself that you can follow for each submission to make sure nothing gets missed. You may also want to consider adopting technology that can automate many PBJ related tasks and simplify the submission process. Either way, make sure you have your ducks in row for July 1, 2016.