The Centers for Medicare and Medicaid Services (CMS) has long recognized staffing as an integral part of the quality care puzzle, and last year introduced the Payroll-Based Journal (PBJ) as an improved method of gathering staffing data. One goal of PBJ reporting is to create a more standardized and frequent collection of this data. Beginning July 1, 2016, long-term care providers are required to begin documenting their direct care hours so that they can be uploaded to CMS on a quarterly basis.
One of the challenges Payroll-Based Journal reporting presents is developing systems whereby all direct care hours are recorded and can be reviewed. Also, consideration must be given to whether these systems can produce an auditable document trail. When submitting PBJ data, accuracy and completeness are vital as CMS will be conducting audits, and penalties may be levied if data is found to be incorrect. Now is the time to evaluate and analyze your community’s staffing data collection and reporting processes and see where the gaps are.
There are several areas where it will be easy to get tripped up if you are not prepared. I’ve identified five of the biggest PBJ land mines to look out for and offer suggestions for avoiding them.
1. Dealing with overnight shifts. Most of our clients have shifts that stretch over the midnight hour, for example from 11pm until 7am the next day. However, PBJ hours must be reported from midnight to midnight. So using the example above, 1 hour (11pm-12am) would be reported on the first day, and 7 hours (12am-7am) would be reported on the second day (less any meal breaks where staff are not available for direct care of residents). Take stock of any shifts that cross the midnight threshold and make sure you can split those hours to appropriately report them.
2. Reporting salaried staff hours. For hourly employees, all direct care hours should be reported. However, salaried employee’s hours are reported differently. Only salaried staff hours paid can be reported. For example, if an employee gets paid for 40 hours a week, but they work 50 hours one week, you can’t report the additional 10 hours worked. Only the 40 paid hours should be reported to CMS.
3.Collecting and reporting contractor/agency hours. You are required to report contractor and agency direct care hours for PBJ, which can be complicated. Take some time to plan how you will collect that information so it will be auditable. Some solutions that we’ve seen require contractors and agency workers to punch in on the facility time clock, or scan a badge when they come to work in your community. However, asking these workers to check-in when they come into the facility is an excellent alternative way to create an auditable document trail, and will minimize the amount of manual entry required at the time of submission. Utilizing a PBJ reporting system that has a check-in tool can further streamline that process for your community. For those workers who don’t check in, you will need to manually gather contracts, invoices and other paperwork that show the number of hours worked.
4. Tracking hours for staff that split roles. Caregivers may switch duties during the day making it difficult to track the hours spent on direct care. For instance, if an employee functioned as a Certified Nursing Assistant (CNA) for half of their shift and then as a Dietary Aide for the other half of their shift, then only the hours in the CNA function can be reported. However, if a CNA merely helped out in the dining room during the meal time then all of the hours for this worker should be reported under their main function (CNA, in this case). You will also want to define a process for counting hours of salaried personnel who provide direct care outside of their salaried function. For example, a director of nursing (DON) may fill-in for an hourly nurse that called off. Make sure the hours that the DON functions as a floor nurse are documented and paid for over and above the normal salary so you can report those hours.
5. Understanding the tech specs. On April 26, 2016 CMS released PBJ Data Submission Specifications Erratta v2.00.1, which are scheduled to go into effect on June 27, 2016. The biggest change in the revised specs is an update to the size of XML files that are allowed to be submitted however, there were 6 total items updated in the errata including changes to the data specifications. After June 27, submission must be made in accordance with the new specification or they will be rejected.
As you prepare for PBJ, working with your software vendors such as OnShift will be essential. You’ll also want to talk with your staffing agency and other contractors to ensure that they can provide the reports and information you will need to submit your PBJ data. If you haven’t already, consider adopting a PBJ reporting software to help streamline and simplify this complicated process.